Pictet Asset Management SA: investment adviser

Pictet AM Ltd is a United Kingdom based investment adviser regulated by the Financial Conduct Authority (“FCA”) and has been providing discretionary or advisory investment management services on a global scale to a wide range of international institutional clients since 1980. Pictet AM Singapore is a Singapore based investment adviser regulated by the Monetary Authority of Singapore (“MAS”) and has been providing discretionary or advisory investment management services to a wide range of international institutional clients since 2005. Pictet AM USA is a U.S. based investment adviser, registered with the SEC and has been providing discretionary or advisory investment management services to institutional clients since 2021. In addition, Pictet AM USA conducts business development, solicitation and U.S. based relationship management activities on behalf of the other SEC Pictet AM Firms, with respect to institutional investors in the United States. These institutional investors include, among others, public and corporate retirement plans, government funds, foundations, endowments and the Pictet AM US Active ETFs. Pictet AM USA markets the other SEC Pictet AM Firms’ segregated portfolio management strategies and foreign funds offered on a private placement basis. When a prospective U.S. investor expresses interest in another SEC Pictet AM Firm’s strategy, Pictet AM USA refers the prospect to the relevant SEC Pictet AM Firm. The relevant SEC Pictet AM Firm conducts due diligence, contract negotiation and all onboarding steps in relation to the prospect. Once the prospect becomes a client of the relevant SEC Pictet AM Firm, Pictet AM USA receives read only access to the client’s account information through a technological solution authorised by the relevant affiliate. This supports its business development oversight and U.S. based relationship management responsibilities. It also receives client account documents to support these responsibilities. Pictet AM USA does not have a local trading desk. It also does not handle onboarding or contracting for affiliate clients.

B.

Types of Advisory Services

The SEC Pictet AM Firms provide both non-discretionary and discretionary investment management services to institutional clients. These services include:

Assistance in determining appropriate risk and return objectives for each client. Defining the appropriate asset mix which is most likely to achieve those objectives. Selection or advice on specific markets, currencies and securities from those categories. Assuming discretionary responsibility for all aspects of day-to-day management and investment of the client’s account(s).

Pictet AM SA and Pictet AM Ltd manage a wide range of equity, fixed income and multi asset strategies including Total Return. Pictet AM Singapore manages a wide range of fixed income and equity total return strategies. Pictet AM USA manages the Emerging Markets Fixed Income strategy.

C.

Tailoring of Services and Client Restrictions

Each SEC Pictet AM Firm tailors services to institutional client needs. Clients define investment restrictions with their SEC Pictet AM Firm (as adviser) which in turn implements those restrictions throughout the mandate. Further information on account reviews and reporting appears in Item 13.

D.

Wrap Fee Programs

Investment management services for wrap fee programmes are generally the same as those offered to non-wrap clients. However, wrap accounts may face practical constraints, most often due to their smaller asset size, which can lead to slightly different returns. These differences typically stem from investment and administrative restrictions, as well as the wrap fees charged by the sponsor. Pictet AM SA

Provides model portfolios to an investment advisory group (“the sponsor”).

Performs no trade execution for wrap clients.

Receives a portion of the sponsor’s wrap fee.

Pictet AM Ltd

Acts as portfolio manager within an unaffiliated sponsor’s wrap program.

Performs trade execution for wrap clients.

Receives a portion of the sponsor’s wrap fee as management fee.

Neither Pictet AM USA nor Pictet AM Singapore participates in wrap fee programs.

E.

Client Assets Under Management (As of 31 December 2025)

The below figures are in USD and rounded to the nearest 100,000. Pictet AM SA

Discretionary: 330,703,333,875

Non-discretionary: 353,940

Pictet AM Ltd

Discretionary: 24,402,700,000

Non-discretionary: 0

Pictet AM USA

Discretionary: 382,000,000

Non-discretionary: 0

Pictet AM Singapore

Discretionary: 3,547,900,000

Non-discretionary: 380,400,000

Differences between Pictet Asset Management system valuations and custodian valuations can result in differences in advisory fees.

C. Other Fees and Client-Incurred Expenses The SEC Pictet AM Firms’ advisory fees exclude all transaction-related and third-party expenses. Clients typically pay the following third-party expenses:

brokerage commissions; transaction fees; custodian charges; fund-level management fees (third-party funds and exchange-traded funds); other fund-related fees, including but not limited to servicing fees and other ancillary charges; transfer taxes; wire and electronic transfer costs; taxes and commissions related to securities transactions; and any other fees charged by third parties.

Where client assets are invested in third-party funds, those funds charge fees as described in their prospectuses. The SEC Pictet AM Firms consider these expenses when selecting funds.

Fees Related to Investment in In-House Funds In some instances, the SEC Pictet AM Firms invest client assets in Pictet AM in-house funds, subject to client investment guidelines and eligibility criteria, which also charge management fees. In addition to the advisory fee paid to the relevant SEC Pictet AM Firm, the funds in which clients participate bear “service fees” for administration and shareholder servicing, which are paid from fund assets to an affiliated management company. These fees are separate from, and in addition to, the advisory fees described above and reduce overall investment returns. For the SEC Pictet AM Firms, if an in-house fund already charges a management fee, the relevant SEC Pictet AM Firm excludes the value of the client’s investment in that fund when calculating its management fee unless otherwise agreed in writing. Where no management fee exists at the fund level, the SEC Pictet AM Firms calculates its management fee based on the total assets under management. For the US ETFs where the relevant SEC Pictet AM Firm is appointed as sub-adviser, the relevant SEC Pictet AM Firm receives management fees as disclosed in the respective ETF prospectus.

D. Termination of Advisory Agreements Each advisory agreement permits either party to terminate the agreement on written notice on a mutually acceptable period of notice, which is usually not more than 30 days.

E. Compensation for Sale of Securities or Other Investment Products The SEC Pictet AM Firms each receive the following additional compensation:

Referral compensation from Pictet AM entities that enter into agreements with clients introduced by the relevant SEC Pictet AM Firm. There are no additional fees charged to the client to remunerate the relevant SEC Pictet AM Firm.

Remuneration for distribution of Pictet AM non-US regulated funds whereby: ‒ Pictet AM SA receives such remuneration from Pictet AM Europe and Pictet AM Hong Kong, which receive the management fee directly from the funds. ‒ Pictet AM Ltd receives such remuneration from Pictet AM Europe, Pictet AM Hong Kong and Pictet AM SA, which receive the management fee directly from the funds. ‒ Pictet AM US receives such remuneration from Pictet AM Europe, Pictet AM SA, which receive the management fee directly from the funds. ‒ Pictet AM Singapore receives such remuneration from Pictet AM Europe, Pictet AM SA, Pictet AM Hong Kong, which receive the management fee directly from the funds.

Delegated investment management compensation from Pictet AM Europe or Pictet AM SA where they have partially or totally delegated to another SEC Pictet AM Firm investment management of one or more non-US regulated funds. In this context, the relevant SEC Pictet AM Firm receives a part of the management fee received directly from the fund by Pictet AM Europe or Pictet AM SA.

The SEC Pictet AM Firms market advisory services through internal Sales or Business Development teams and, in some cases, through similar functions in other Pictet Group entities. Personnel in these areas receive salary, revenue-linked and qualitative bonuses, and in some instances profit share. The SEC Pictet AM Firms apply remuneration controls to ensure referral-related compensation does not incentivise behaviour inconsistent with fiduciary or regulatory obligations, including scoring mechanisms that reduce bonuses for poor compliance.

Conflicts Arising from Fee Differentials Fee levels differ among clients because fees are negotiated individually. Higher-fee accounts create an incentive to prioritise such accounts when trading or allocating investment opportunities. The SEC Pictet AM Firms address such conflicts through:

fair and consistent allocation of investment opportunities between different client accounts in the same strategy, subject to client restrictions, instructions and cash-flows; pre-allocation of all orders; pro-rata allocation based on client order size, taking into account market lot sizes and avoiding uneconomic allocations; and continuous compliance monitoring to verify consistent treatment across comparable accounts.

This incentive can influence the timing or selection of securities transactions or allocation of limited opportunities. Performance‑fee arrangements can encourage selection of investments that carry higher risk because these investments can generate higher returns and therefore higher performance fees. For the Pictet total return funds that are managed, the performance‑fee structure is not negotiated at arm’s length. The conflicts associated with performance‑based fees are addressed through our side‑by‑side management processes described below.

B. Side‑By‑Side Management The SEC Pictet AM Firms manage multiple accounts that follow substantially similar investment strategies. This structure creates conflicts of interest. These conflicts arise from the possibility of preferential treatment among accounts, differences in fee structures, differences in performance‑related compensation to portfolio managers and differences in timing and size of transactions. Conflicts also arise when investment opportunities have limited availability, including initial public offerings. Fund managers who receive higher performance‑related compensation from managing certain strategies, such as total‑return funds, can have incentives that influence investment decisions. Accounts paying higher fees can also create incentives for preferential treatment. These conflicts are addressed using the following measures:

Investment opportunities are allocated on a pro‑rata basis, taking into account market conventions such as standard lot sizes and avoidance of uneconomic allocations.

Regular compliance monitoring is conducted to ensure that investment opportunities are allocated fairly across similar accounts and that investment risks remain consistent.

New products launched or seeded by affiliates of the SEC Pictet AM Firms can initially be owned predominantly by those affiliates or their clients. These accounts are monitored carefully to mitigate preferential treatment.

Discretionary authority is exercised in a manner consistent with client objectives, which can result in different timing and nature of actions taken across accounts.

Information access across investment teams is controlled through information barriers.

Investment results differ across accounts because of factors including cash availability, timing of account openings, client contributions or withdrawals and client‑specific restrictions. Some clients cannot participate in certain investments or can participate only partially or at different times, including where minimum IPO or fixed‑income investment thresholds would produce uneconomic allocations. The SEC Pictet AM Firms ensure that investment decisions focus on their respective fiduciary duties and not on their financial interests. Across comparable strategies and circumstances, the SEC Pictet AM Firms provide fair and equitable access to investment opportunities.

In addition, the SEC Pictet AM Firms’ policies deal with information barriers among investment teams, ensuring that our investment teams can access only those accounts necessary for them to carry out their roles and responsibilities.

pension and profit‑sharing plans charitable organisations insurance companies registered mutual funds private investment funds sovereign wealth funds regulated and unregulated funds U.S. pooled investment vehicles such as LLCs and Collective Investment Trusts other U.S. and international institutions

Pictet Asset Management Ltd Pictet AM Ltd primarily provides portfolio management services to the following types of institutional clients:

pension and profit‑sharing plans registered mutual funds private investment funds sovereign wealth funds regulated and unregulated funds other U.S. and international institutional clients

Pictet Asset Management (USA) Corp. Pictet AM USA primarily provides portfolio management services to the following types of institutional clients:

pension and profit‑sharing plans registered mutual funds unregulated funds

Pictet Asset Management Singapore Pte. Ltd. Pictet AM Singapore primarily provides discretionary investment management services to the following types of institutional clients:

corporate pension and profit‑sharing plans registered mutual funds private investment funds sovereign wealth funds regulated and unregulated funds other international institutions

The SEC Pictet AM Firms have established minimum account requirements for certain client accounts, which can vary based on the investment vehicle (separate account or fund), investment strategy and asset class. For

separately managed accounts, the SEC Pictet AM Firms generally require a minimum of US$ 50 million; however, in its discretion and in special circumstances, the SEC Pictet AM Firms can accept accounts of lesser amounts. Minimums applicable to pooled vehicles (including non-U.S. regulated funds) are set forth in the applicable governing or offering documents. Minimums are subject to waiver in the SEC Pictet AM Firms’ discretion and may be waived from time to time. To open or maintain a separate account, clients are required to sign an investment management agreement with the SEC Pictet AM Firms that stipulate the terms under which the SEC Pictet AM Firms are authorized to act on behalf of the client to manage the assets listed in the agreement. In certain instances, the SEC Pictet AM Firms may also manage assets for clients of its affiliates and will receive from the affiliate a portion of the fee or other compensation paid by the end client for such services. Under these circumstances, the client enters into an investment management agreement with the affiliate and, in turn, the affiliate delegates authority to the SEC Pictet AM Firms. For example, Pictet Asset Management (Europe) SA may delegate investment management of non-U.S. regulated funds to the SEC Pictet AM Firms and the SEC Pictet AM Firms receive a portion of the management fee paid by the fund. For wrap programs in which the SEC Pictet AM Firms either serve as portfolio manager or acts solely as a model portfolio provider, account size requirements for the underlying sponsor accounts are established by the program sponsor and can differ from the SEC Pictet AM Firms’ separate account minimum. In these programs when acting solely as a model portfolio provider, the SEC Pictet AM Firms do not implement trades for sponsor- managed accounts.

Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. Clients and investors should understand that they could lose some or all of their investment and should be prepared to bear the risk of such losses. Clients and investors should read carefully all applicable informational materials and offering or governing documents for further information on the various risks associated with investing before retaining a SEC Pictet AM Firm to manage an account or investing in any product or vehicle it manages or advises.

A. Methods of Analysis and Investment Strategies The SEC Pictet AM Firms rely on multiple sources of information to support their investment analysis. These sources include external research providers and internally generated primary research. Information reviewed includes the financial press, meetings with company management, research received from analysts at other financial institutions (including brokers), independent research providers, conference materials, corporate rating services, timing services, annual reports, prospectuses, filings with the SEC and other regulators, company press releases and system generated information supplied through tools, such as Bloomberg Financial. Investing in securities and other financial instruments involves risk of loss of part or all of the amount invested and clients should be prepared to bear such losses. The SEC Pictet AM Firms use long only and total return investment strategies to manage client assets. These strategies apply fundamental analysis, quantitative inputs where relevant, macroeconomic assessments, sector and issuer research and security level evaluation depending on the strategy and client mandate. Different strategies may emphasise different analytical techniques and instruments so the nature and magnitude of the risks described in the “Risk of Loss and Material Risks” sub-sections will vary by strategy and client mandate. The SEC Pictet AM Firms use derivative instruments including but not limited to futures, options, swaps and forward foreign exchange contracts. Derivatives are used for investment purposes, for efficient management such as the prompt implementation of large cash flows and for hedging intended to protect client portfolios from adverse market events. Derivatives used include both exchange-traded and over-the-counter instruments. As derivatives can embed economic leverage and create additional counterparty, liquidity and operational risks, clients should read the “Derivatives, Leverage and Collateral Risks” section together with any strategy-specific disclosures in the relevant offering or governing documents. Where applicable and consistent with the fiduciary duty to act in the best interests of clients and the adherence to the Principles for Responsible Investment (PRI), the SEC Pictet AM Firms integrate material environmental, social and governance (“ESG”) criteria in their investment processes and ownership practices with a view to enhancing returns and mitigating risks over the medium to long term. ESG considerations are also applied within risk management and reporting tools to maintain high standards of transparency and accountability. As the treatment of ESG factors may differ between strategies and products so not all portfolios will be exposed to ESGrelated risks and opportunities to the same extent, clients should refer to the “ESG and Sustainability-Related Risks” disclosures and the specific documentation for the strategies in which they invest. Investment strategies are defined according to the following categories: Non-ESG Integrated, ESG Integrated, ESG Focused and Positive Impact. These categories help indicate the degree to which ESG considerations form a central component of the investment objective or process and, therefore, which ESG-related risk disclosures are most relevant for a given strategy.

Exclusions apply to actively managed funds, certificates, baskets and discretionary mandates. Exclusions do not apply to passive strategies that replicate market indices or to open-ended funds managed by third party managers. Pictet AM’s exclusions framework constitutes a minimum standard for strategies in scope and such strategies can apply more stringent exclusion criteria. Where relevant, Pictet AM retains full discretion over the implementation of exclusion criteria and can grant exemptions on a case-by-case basis in instances where issuers are on a credible pathway to improve on ESG issues that triggered the exclusion. Pictet AM relies on third party service providers, non-profit organizations and governments when determining, from an ESG perspective, which investments to exclude from the selection of securities to purchase. This process is based on the categorization by such providers of the types of companies, industries and countries that are excluded from the permissible investment universe. There is no assurance that the exclusion list determined by Pictet AM or a third-party service is complete or that all relevant securities have been restricted. The exclusion list is subject to change at any time without notice. As a result, the application of exclusions and related risks may differ across strategies and over time. Therefore, clients should review the product-level disclosures that apply to their specific investments. The following section provides a description of the investment strategies managed by the SEC Pictet AM entities. A discussion of the risks associated with these strategies appears at the end of this item.

Equities Long Only AI & Automation The investment strategy of “AI & Automation” is to invest at least 80% of its net assets (plus borrowings for investment purposes) in global equity securities of AI and automation companies and focuses on companies that have a distinct link to artificial intelligence and/or automation as measured by the proportion of the company (e.g., sales, earnings before Interest, taxes, depreciation and amortisation (“EBITDA”), enterprise value, capital expenditure (“CapEx”) or other relevant metrics) that contributes to and benefits from the value chain in artificial intelligence, robotics, cybersecurity, semiconductors and software; this includes companies that produce the essential hardware and services, as well as those providing technologies that enable robots to sense, process, communicate and act; companies that redefine, optimize and automate enterprise workflows; companies that change the way we interact with each other and consume and those that develop robotics and automation solutions aimed at consumer and service applications for everyday life. The investment strategy is expected to have significant exposure to securities of issuers in the information technology, industrials, communication services and consumer discretionary sectors. Further, AI & Automation is expected to, in the aggregate, invest more than 25% of its assets in securities of companies in the industries comprising the information technology sector.

AI Enhanced International Equity The investment strategy of “AI Enhanced International Equity” is enhanced by the use of artificial intelligence, as described below. Under normal market conditions, the investment strategy is to invest at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities of International companies which are those listed within the MSCI EAFE Index (the “Index”). The investment strategy seeks to outperform the Index using an enhanced index strategy with a low tracking error to invest across the international equity market using an artificial intelligence model to identify stocks. Artificial intelligence refers, in this case, to the application of computer systems or models to perform tasks that typically require human intelligence. The artificial intelligence model uses hundreds of features engineered from a broad range of data such as fundamentals, analyst sentiment, prices and market activity, short interest and calendar effects to make relative forecasts of the stocks of the Index. These are regularly updated and combined in a proprietary optimizer with risk and control estimates and constraints on position sizing. The portfolio managers of AI Enhanced International Equity review the output of the optimizer, which drives both buy/sell recommendations during implementation of the desired portfolio. These buy/sell recommendations are then reviewed and approved by the portfolio managers before purchases and sales are executed. AI Enhanced US Equity

The investment strategy of “AI Enhanced US Equity” is to invest at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities of U.S. companies. A “US Company” for this purpose are those that are listed within the S&P 500 Index (the “Index”). The investment strategy seeks to outperform (net of fees) the Index using an enhanced index strategy with a low tracking error to invest across the U.S. equity market using an artificial intelligence model to identify stocks. Artificial intelligence refers, in this case, to the application of computer systems or models to perform tasks that typically require human intelligence. The artificial intelligence model uses hundreds of features engineered from a broad range of data such as fundamentals, analyst sentiment, prices and market activity, short interest and calendar effects to make relative forecasts of the stocks of the Index. These are regularly updated and combined in a proprietary optimizer with risk and control estimates and constraints on position sizing. The portfolio managers of the Pictet AI Enhanced US Equity ETF review the output of the optimizer, which drives both buy/sell recommendations during implementation of the desired portfolio. These buy/sell recommendations are then reviewed and approved by the portfolio managers before purchases and sales are executed.

Cleaner Planet The investment strategy of “Cleaner Planet” is to invest at least 80% of its net assets (plus borrowings for investment purposes) in securities of “Cleaner Planet” companies. Cleaner Planet companies are global companies that contribute and benefit from the structural change towards a more sustainable economy including companies that have a distinct environmental and/or social impact objective, measured by the proportion of the company (e.g. sales, EBITDA, enterprise value, CapEx or other relevant metrics) that contributes positively to activities such as energy efficiency, renewable energy, pollution control, water supply & technology, sustainable buildings, waste management & recycling, sustainable agriculture & forestry, circular economy, dematerialized economy or enabling technologies and infrastructure that support the aforementioned activities. The investment strategy is also expected to have significant exposure to securities of issuers in the information technology, industrials and utilities sectors. Further, Cleaner Planet is expected to, in the aggregate, invest more than 25% of its assets in securities of companies in the industries comprising the information technology sector.

Emerging Markets Rising Economies The Emerging Markets Rising Economies strategy invests in equities within emerging markets and frontier countries where there is active working population growth. The strategy is actively managed and is implemented through an exchange traded fund structure. The investment process combines both a quantitative and fundamental approach to select companies for inclusion within the portfolio. The quantitative element focuses on companies with cheap relative valuations which are exhibiting positive change, and the fundamental analysis undertaken emphasises dividend as a strand of overall value and similarly involves looking for companies that are seeing an improvement in fundamentals. Investing in this strategy involves risk of loss. Principal risks are described under Risk of Loss and Material Risks.

Family The Family strategy is an active, large cap, global equity portfolio that invests in family and founder-owned, publicly listed companies. The strategy seeks to outperform global equity markets through a full business cycle. We believe that owner-managed businesses are managed differently, allocating capital with a long-term vision that can create sustainable competitive advantages. The Family universe is dynamic and renewed annually. Our Family portfolio is built by selecting the best opportunities within the investment universe based on fundamental analysis complemented by top down risk control. To help select the best long-term investments and mitigate risk, ESG is integrated into every step of the active investment process, with a focus on the governance factors that influence the performance of family-owned businesses.

Global Utilities The Global Utility strategies primarily invest in public utility businesses globally. The team adopts a bottom-up analytical framework focussing on attractive and sustainable returns in order to select the best companies. Because of the asset-heavy nature of the businesses and the fact that they are often regulated, we expect total returns to be balanced between dividends and share price appreciation.

Global Emerging Market Equities We are active, bottom-up investors focussed on fundamental analysis. The strategy's philosophy is based upon two pillars: 1) a view of cash returns and cash generation, 2) a focus on valuation. This philosophy helps to identify market mispricing primarily across two areas, namely where the market underestimates: • structural compounders – companies that can sustain their above average/above market returns, cash

generation and growth rates. • cyclical turnarounds – either where the company is experiencing temporarily depressed returns which the

market incorrectly extrapolates into the future or the company’s cash flows are at a cycle peak, which should not be extrapolated into the future. We will only invest in these companies at attractive valuations. We believe a portfolio made up of companies like this should be able to outperform across market cycles. We integrate material ESG factors into our investment research, portfolio construction, portfolio review and active ownership processes. ESG research and integration help shape our engagement and voting activities. Any information we gather from these feeds back into investment analysis and hence can have an impact on subsequent investment decisions, resulting in an approach that we believe enhances our ability to generate long-term risk adjusted investment returns.

Global Environmental Opportunities (“GEO”) The framework underpinning our approach to environmental equities focuses on identifying companies with a low environmental footprint that help address global environmental challenges through their products and services along the environmental value chain. These environmental solutions are required to support the transition to a lower‑carbon economy, a more circular economic model and a more dematerialized or digitalized economy, as well as to drive more sustainable practices in agriculture and forestry, improve the monitoring and prevention of pollution and protect scarce resources, such as water. We believe that the providers of these environmental solutions are poised to deliver secular growth that is both superior to, and less volatile than, the broader market. The environmental investment universe is dynamic and is maintained through primary research, comprehensive environmental lifecycle analysis and insights from a dedicated advisory board of renowned environmental experts. Our thematic portfolio is built by selecting the most compelling opportunities within our investment universe based on fundamental analysis, while remaining unconstrained by region, sector or company size.

Global Thematic Opportunities (“GTO”) The strategy invests mainly in companies that may benefit from global long-term themes resulting from secular changes in economic, social and environmental factors, such as demographics, lifestyle or regulations. We believe that equity markets tend to under-price the persistence of secular growth. In our framework, we look for stocks with value drivers (sales growth and margins) linked to megatrends, where our research leads us to believe that margins and sales growth will not fade. The resulting unnecessary risk premium is our source of value creation relative to a passive investment in the global equity market. The strategy invests mainly in companies that are related to thematic activities such as products and services supporting the energy transition, circular economy, energy efficiency, water quality and supply, sustainable forestry and agriculture, sustainable cities, nutrition, human health and therapeutics, personal self-fulfilment,

security, luxury products, digital disruption or other relevant economic activities. Our investment team believes that a focused, unconstrained thematic investing approach to owning companies whose value drivers are underpinned by secular growth can outperform the global equity market. The underlying thematic investment universes are dynamic and maintained through primary research and through input from our dedicated advisory boards composed of academic and industry specialists. Thematic single theme portfolios are built upon these universes. Our global thematic portfolio selects the best opportunities from these underlying thematic portfolios based on fundamental analysis, while remaining unconstrained with regards to regions, sectors or sizes.

Indexed Equity mandates Our indexation methodology aims to build a portfolio that closely replicates the benchmark, meaning a fully replicated portfolio, with the same number of stocks and weights as the benchmark. Full replication enables us to replicate the performance of the benchmark as accurately as possible whilst minimising the tracking error and systematic relative risks (meaning that the portfolio’s relative performance should become immunised to external shocks). In cases where full replication is not possible, we deploy a proprietary strategy called “quasi full-replication”. This method avoids very small positions where transaction costs will be disproportionately high and any illiquid positions within the benchmark. We also apply our quasi-full replication in case of exclusions requested by clients or ESG requirements.

Japanese Equities The Pictet Japanese Equity strategies are actively managed portfolios built from the bottom-up. The strategies are style agnostic, focused on valuation rather than a particular style. This tends to result in portfolios that are blend or core in nature. The strategies seek to outperform their relevant benchmarks through a full business cycle, providing suitable risk-adjusted returns. The benchmark does not drive the weight or positioning of the portfolios – if the team does not find a stock attractive, they will not hold it. Every step of the Japanese Equities team’s investment process is informed by their philosophy. The team, which has extensive experience investing across cycles and is very stable, seeks companies for which the market underappreciates the level of growth, the balance sheet quality, the profitability and, ultimately, the cashflow generation ability over the long term. Sector exposures are by-products of stock selection and are not specifically targeted. Equally, factor exposure is residual of the stock selection process. While it is routinely monitored it does not drive stock selection.

Positive Change Positive Change is an unconstrained, large-cap, global equity strategy with improving impact at its core – assessed by improving alignment to the United Nations Sustainable Development Goals ("SDG"). The strategy seeks to outperform the global equity market through a full business cycle. Based on an active, bottom-up approach, informed by the output of Pictet’s AI-based SDG Alignment Indicator and backed by fundamental research, the strategy looks to capture the market mispricing of the superior returns and structural growth of companies with leading alignment and the re-rating potential as companies with lower alignment improve. We seek to invest the portfolio in companies that generate attractive returns and cash flow, enjoy high barriers to entry and trade at attractive valuations.

Quest - Sustainable Investment Equities mandates We manage a range of equity products in developed markets. We invest in companies that are fundamentally solid, reliably profitable and robust and reasonably priced and whose ESG characteristics are considered to be above average. We believe that companies with stable profitability and healthy balance sheets, whose shares trade at attractive valuations, should fare better in periods of market turbulence, enabling them to deliver superior

returns over the long run. ESG scoring is also applied to all the companies in the investment universe, ensuring that we invest in companies with sound ESG practices. We exploit the scalability and rigour of a quantitative investment approach, further enhanced by fundamental oversight.

Thematic Equities The framework that underpins our approach to thematic equities is based on long-term structural changes in society, the environment and economics, such as demographic development, commercialization, technological advancement and sustainability. We call these long-term structural changes ‘megatrends’. We believe that the basis for successfully identifying investment themes is the identification of pockets of economic activities that are supported by multiple megatrends. Such economic activities are more likely to experience secular growth that is both superior and less volatile than the market average. Thematic investment universes are dynamic and maintained through primary research, as well as input from dedicated advisory boards composed of theme specialists and proprietary tools. Our thematic portfolios are constructed by selecting the best opportunities within their respective investment universes based on fundamental analyses, while remaining unconstrained with regard to regions, sectors or sizes.

Timber The Timber strategy seeks to achieve a positive environmental and/or social impact by investing in companies that contribute to solving global environmental challenges through sustainable forest management and woodbased materials. Sustainable management of forestland and the wood fibre value chain play a vital role in the sequestration of atmospheric carbon (CO2). Sustainably managed forests also have the potential to be reservoirs of biodiversity and help to safeguard soil and water resources. Wood fibre is the raw material for a growing variety of bio-based materials that can substitute plastics and other non- biodegradable materials and are essential in a circular economy model. The strategy primarily invests in companies that are related to harvesting, planting and management of timberlands and/or in the processing, production and distribution of wood and wood fibre-based materials, products and related services along the entire forest value chain and other relevant economic activities. In the longer term, we believe that such economic activities are more likely to experience growth that is both superior and less volatile than the market average. The investment universe is dynamic and maintained through primary and secondary research, environmental full lifecycle analysis as well as through input from a dedicated advisory board composed of forestry and timber theme specialists. Our thematic portfolio is then built on selecting the best opportunities within the respective investment universe based on fundamental analyses, while remaining unconstrained with regards to regions, sectors or sizes.

Swiss Equities Our philosophy is based on a core approach of looking at how companies are valued compared to their intrinsic value – either in terms of assets or the present value of future cash flows. We believe companies are either misunderstood or mispriced and only through strong fundamental research can opportunities be identified. These portfolios tend to exhibit modest tilts towards both growth and value.

Total Return Equities Total Return Merger Arbitrage The manager pursues a merger arbitrage strategy investing in announced Merger and Acquisition (M&A) transactions predominantly in Europe and in the US. The manager assesses transactions with an opportunistic approach to select the transactions that offer the best risk / reward profile by doing an in-depth analysis of each transaction combined with a bottom-up fundamental assessment of the companies involved. The strategy seeks to achieve returns that are uncorrelated with the broader market.

Multi-strategy Alphanatics (“Alphanatics”) A multi-strategy market neutral approach that seeks to generate positive absolute returns with limited volatility through investments in various segments managed by selected Pictet AM investment teams. The segments pursue various strategies across different asset classes (mainly equities and fixed income) and regions to extract alpha (being the returns above and beyond what the broader market delivers). Residual market risk and duration risk are hedged to ensure market neutrality.

The Global Emerging Markets Equity Long/Short (GEM L/S) The Global Emerging Markets Equity Long/Short (GEM L/S) strategy aims to deliver consistent steady returns with low correlation to wider equity markets. The strategy uses a bottom-up fundamental approach to investing complemented with a top-down understanding of the regions and countries we invest in. While equity focused the strategy will have the ability to invest across the capital structure in order to achieve the optimal risk/reward. The portfolio will be made up of core alpha long and short positions complemented with catalyst driven and opportunistic trades.

Total Return Asian Special Situations ("TR Asia") The strategy follows an event driven approach with a focus on opportunities in Asian equities. It aims to deliver consistent and uncorrelated returns throughout the market cycle by exploiting any special situation in corporate life. The strategy has little directionality and is uncorrelated to broader markets. The opportunities which the strategy seeks to exploit can be grouped into defined catalysts, announced Mergers and Acquisitions and preevent situations.

Total Return Equities - Atlas (“Atlas”) Atlas is a global long/short equity strategy combining intensive bottom-up fundamental research with detailed top-down analysis. The objective is to achieve long-term capital appreciation with a degree of downside protection.

Total Return Energy Evolution The manager pursues an Energy sector focused, market neutral strategy that seeks to generate positive absolute returns with limited volatility. The strategy targets Energy related opportunities in Europe and North America, identifying common themes and exploiting dislocations across sectors and regions whilst maintaining disciplined risk management.

Total Return Global Consumer The Total Return Global Consumer equities strategy follows a market neutral approach to investing and covers a broad range of consumer, technology, media and telecommunications sectors globally. The strategy seeks to provide long-term capital appreciation by investing primarily in liquid and large caps in developed markets. The investment team uses a bottom-up approach targeting strong equity alpha and a low correlation to the stock market. The strong emphasis on deep fundamental analysis aims to generate high conviction positions with nonconsensual insight and idiosyncratic returns.

Fixed Income Long Only Absolute Return Fixed Income

The Macro & Multi-Sector team ("MMS"), formerly named Global Bonds team, manages our absolute return fixed income strategies using the same investment principles and value-based investment process as the Pictet Global Bonds fund, managed by the same team. Our MMS team has a long-term investment horizon and aims to deliver positive absolute returns while controlling downside risks by investing globally across all fixed income sectors in both developed and emerging markets, not constrained by a market benchmark. Our Fund Managers invest in a diversified range of fixed income strategies based on long-term valuations independent of a central forecast scenario. The team aims to build robust portfolios based on strategy diversification and balanced risk budgeting. The team aims for stable returns within a strict, risk-managed analytical framework. Our multi-stage investment process aims to build a well-diversified portfolio, balanced across our long-term investment trends, across our alpha sources of interest rates, spreads and currencies and across risk scenarios. Duration, sector, rating, issuer domicile and currency are carefully analysed using a multi-dimensional risk matrix. The Fund Managers are mindful of risk replication and hidden correlations in order to control portfolio risk and avoid drawdowns.

CHF Bonds The CHF Bonds team manages CHF bonds using both an active and passive approach. In the active approach our objective is to generate steady positive excess return over a cycle, while targeting capital protection by limiting drawdowns. Based on extensive fundamental research, our active positioning reflects our anticipation of macro trends, systemic risk and credit events with a medium-term time horizon. Although strategically positioned, we exit a position early in case of a deterioration of underlying fundamental factors. In the passive approach, our objective is to replicate the performance of a reference index with a similar level of risk. An index is composed of different sectors, countries, maturities and ratings. We aim to replicate these characteristics by selecting a limited number of positions, using a ‘stratified sampling’ methodology.

Climate Government Bonds The Climate Government Bond strategy applies a sustainable strategy of allocating capital to sovereign bonds of countries with falling carbon emission trends, in view of supporting the long-term global warming objectives of the Paris Agreement (as adopted under the United Nations Framework Convention on Climate Change seeking to limit global warming), by mainly investing in bonds and other debt securities. The strategy aims to achieve similar return characteristics to the FTSE WGBI with much lower emissions. Our investment approach aims to generate good risk-adjusted returns by managing an active macro-overlay over a science-based, carbon emissionsfocused sovereign bond allocation. The strategy allocates capital to countries by screening for improving trends in reduction of CO2 emissions and carbon efficiency across the nations that signed the Paris Agreement in both developed and emerging markets. We look at country climate-related policies as a forward-looking component of the overall assessment and consult a board of external experts to deepen our understanding of climate policies. Our two-pillar investment process starts first with the country carbon allocation and is followed by the active portfolio management over that core allocation using a risk-focused and value-based investment process. The aim of this process is to have a strategic allocation over the core carbon allocation that balances the overall portfolio from a risk-on/risk-off perspective as well as across the three alpha sources of interest rates, spreads and foreign exchange (“FX”).

Developed Markets Credit We aim to deliver steady capital growth over a period defined for each product by investing in corporate bonds and other fixed and floating rate securities. The investment team has extensive experience investing across cycles with a view to delivering diversification and macro risk management in a variety of market regimes. Through sector diversification as well as duration and macro hedge management, we aim to reduce risk and volatility. We consider market conditions and business cycles and seek to identify the most attractive investment opportunities from across the universe of corporate bonds. Our disciplined investment process blends top-down evaluation of the global environment with bottom-up sector and individual issuer analysis. This process allows us to better identify and deal with any inefficiency within the asset class. The investment managers sit within the Developed Markets Credit (DMC) team and are supported by the DMC Credit Research team consisting of nine fundamental credit analysts specialised by sector and two systematic research analysts.

Emerging Market Corporate Bonds (“EMC”) We believe that achieving a target performance across all market conditions requires an active and in-house research-driven approach using diversified sources of performance drivers with thorough risk management and integration of sustainability factors. For EM corporates specifically, our philosophy and process are based around liquidity, diversification and capital preservation. We believe that security selection wins in the long run; as bond investors, we are ultimately concerned with receiving coupon and final payment at maturity. Thus, we believe in extracting the majority of our alpha through thorough bottom-up company analysis and our engagement with the companies we invest in, with the help of a well-resourced and experienced corporate analyst team with local knowledge and focus. We expect about 75% of alpha to come from security selection. Country fundamentals are another relevant driver of EM corporate performance, especially in the short-to medium-term, and significant developments, such as sovereign rating changes or (geo)political events, can be impactful. We follow a pairing matrix across EMFI sub asset classes, where a sovereign investment manager, a corporate analyst and a corporate investment manager are assigned to each country in the universe. The corporate analyst and investment manager can thus draw on the work and expertise of the sovereign investment manager, especially the fundamental country assessment. This is taken as in input in our own assessments informed by the view from the corporate analysis. We typically expect that 10% of alpha comes from country and sector allocation. USD EM corporate bond prices are expressed in spread over US Treasuries and thus the US and even global cycle matter. We have dedicated strategy resources in the team to support us in analysing US and global macro developments and position in duration and overall beta. Duration is less relevant for the short duration fund than for the regular maturity strategy, but credit exposure is expected to contribute a small percentage to relative performance, say around 10-15%. Including relevant ESG factors has got to be a critical part of the fundamental issuer analysis, in our view, especially to avoid underperformers. Looking at Governance is and has always been a key part of the credit analysis. There are many family businesses in our universe and exhaustive analysis of owner reputation and track record is an important part of analysts’ work to avoid adverse outcomes. Environmental and social factors can have a significant impact on a companies’ ability to repay, too, for instance in the case of controversies or significant future CapEx needs. Relevant ESG factors are integrated in our fundamental company analysis. Our process is bottom up driven. We identify cheap risk adjusted credits with neutral to positive macro story while maintaining a highly liquid and diversified portfolio. We start with the benchmark, the CEMBI Broad Diversified as our universe, use valuation monitors to identify the cheapest names to dive deeper into with fundamental research. The analyst assigns rankings to each bond in their focus list and fund managers will pick the strongest analyst convictions for portfolio construction. We can also invest in off benchmark sovereign and quasi sovereign credits as well as new issues that haven’t been included in the index yet. After the fundamental research done on a credit, a name has to pass two further tests for us to be able to invest in the portfolio: 1.Alignment with our global and country view; 2.Add/maintain the liquidity and diversification of the portfolio. Once a credit is deemed cheap relative to its risk, fundamentally sound, has neutral/positive macro backdrop, is liquid and adds to portfolio diversification, we invest in the name. The decision to invest is made collaboratively with consensus reached through pairing between the investment managers and the analysts responsible for the issuer in question with one of the Co-Head of Emerging Markets Corporate as the lead for the funds having the ultimate say. At times, we employ credit default swaps, (“CDS”), futures and FX derivatives. The use of derivatives is primarily used for hedging purposes rather than active risk taking.

We also monitor the portfolio at least quarterly (at higher frequency if there are significant market events) to ensure that we hold the cheapest risk-adjusted names in the investable universe. The quarterly frequency is important to align with the frequency of reporting. However, the portfolio managers are assessing valuations of positions daily.

Emerging Market Fixed Income The Emerging Markets Fixed Income strategy invests primarily in U.S. dollar denominated debt securities issued or guaranteed by sovereign, quasi-sovereign and corporate issuers located in emerging market countries. The strategy may also invest in euro denominated debt securities where the currency exposure is hedged into U.S. dollars. The investment decisions combine bottom-up credit selection with country and global macroeconomic analysis. The strategy may use derivatives for efficient portfolio management or hedging. Any benchmark referenced is used solely for performance comparison or risk monitoring purposes and does not constrain portfolio construction unless expressly stated in the applicable governing documentation. Investing in this strategy involves risk of loss. Principal risks are described under Risk of Loss and Material Risks.

Emerging Market Sovereign We believe that successful investing in EM Fixed Income requires an active and research-driven approach using diversified sources of performance drivers and integration of sustainability factors. • Independent and in-depth fundamental research of EM sovereign and corporate issuers undertaken by an

experienced and diverse group of EM investment specialists • Consideration and application of global macroeconomic and policy analysis in the construction of EM fixed

income portfolios • Regional and local expertise is enhanced by a dedicated trading capability to provide additional in-depth and

targeted technical knowledge and insights • Sustainability research, partnership and engagement to enhance a strong risk-management mindset and

investment idea generation while supporting longer-term sustainable outcomes for emerging markets. As an active manager we aim to achieve a target alpha across all market conditions with a focus on diversification and risk management. We avoid having too much concentrated risk in a small number of oversized active trades. While we can significantly deviate from the benchmark as a diversified collection of active trades, we seek to have the right diversification through careful risk calibration of positions. We look to outperform in both up and down-market environments by taking active views relative to the benchmark within a tight risk budget and a focus on diversification. This is achieved via expression of our views in over-or underweights versus benchmark allocations in cash bonds and FX positions, duration and beta views and, in blended strategies, dynamic asset allocation between local and hard currency, as well as within hard currency between sovereign and corporate positions. We use additional tools, such as country CDS, in order to protect the portfolio in volatile market conditions.

Fixed Income Money Market The objective of our Money Market team is to offer a high degree of capital preservation and liquidity to investors as well as to optimise the funds' performance given the major risks they manage which include credit, liquidity and duration and given the prevailing money market rates. Our investment process is closely integrated with the Credit Research Team, as we believe that credit is the main driver of performance and risk. On the other hand, we pay strong attention to the fund liquidity, both at the asset level and at the portfolio structure level. With their money market products, the Money Market team aims to offer investors high liquidity and appropriate returns on cash through active management within a structured risk framework.

Global Bonds Our main strategy is managed by the Macro & Multi-Sector team ("MMS"), formerly named the Global Bonds team, include Global Bonds, European Bonds and US Bonds. Our MMS team has a long-term investment horizon, focusing on the range of expected returns in each asset class. Our Fund Managers invest in a diversified range of fixed income strategies based on long-term valuations independent of a central forecast scenario. The team aims to build robust portfolios based on strategy diversification and risk budgeting per strategy. The team aims for stable returns within a strict, risk-managed analytical framework. Our multi-stage investment process aims to build a well-diversified portfolio, balanced across our long-term investment trends, across our alpha sources of interest rates, spreads and currencies and across risk scenarios. Duration, sector, rating, issuer domicile and currency are carefully analysed using a multi-dimensional risk matrix. The fund managers are mindful of risk replication and hidden correlations in order to control portfolio risk and avoid drawdowns.

Global Sustainable Credit We aim to deliver steady capital growth by investing in corporate bonds in different currency and other fixed and floating rate securities. The investment team has extensive experience investing across cycles with a view to delivering diversification and macro risk management in a variety of regimes. The investment process aims to achieve a positive environmental and social impact by only investing in companies supporting the energy transition, circular economy, energy efficiency, water quality and supply, healthcare and social integration, as well as in ESG Labelled Bonds and in companies with a low environmental footprint with consideration of, but not limited to, carbon intensity. The strategy integrates ESG factors based on proprietary and third-party research to evaluate investment risks and opportunities. By favouring relatively stronger balance sheets and avoiding poorly rated ESG issuers, we aim to reduce risk and volatility. Our investment process is closely integrated with the Credit Research Team, as we believe that credit is an important driver of performance and risk.

Total Return Fixed Income Absolute Return Emerging Markets The AR EM Strategy adopts a global approach to emerging markets opportunities. An unconstrained high conviction emerging and niche market strategy; it focuses on diversified bottom-up Alpha sources designed to perform in all market environments. The strategy aims to mitigate the volatility of the Beta by: • Investing on a long and short basis in a wide range of emerging and niche market sovereign bonds, rates and

FX • Using decorrelated assets within emerging and frontier markets • Positioning for the repricing of overvalued assets, event driven opportunities, seasonality and pure relative

value • Following a strict stop loss and liquidity diversification policy

The strategy takes no structural bias to directionality and has a strong focus on downside protection.

Distressed & Special Situations (“D&SS”) D&SS operates an absolute return long/short credit-focused strategy, seeking to generate attractive returns through the cycle with low correlation to traditional asset classes. The investment manager employs a long/short approach to investing in financially stressed and distressed companies, predominantly in Europe, while maintaining the ability to source ideas globally. Deep fundamental research underpins the investment process, encompassing both long and short positions, capital structure trades and, where appropriate, recovery rates. Liquidity and jurisdiction are considered when constructing a balanced portfolio from a bottom-up standpoint across a diversified range of issuers. However, the investment manager typically implements selective,

concentrated high-conviction positions where opportunities arise. The strategy targets the more liquid end of the distressed investing spectrum, focusing primarily on larger capital structures. More specifically, the investment manager takes a flexible approach to expressing trade theses on both the long and short sides through: • Bonds • Loans • Credit derivatives • Equities (listed) and post-reorganization

Emerging Markets Total Return (“EM TR”) We believe that successful investing in EM Fixed Income requires an active, research-driven approach that uses diversified sources of performance drivers and integrates sustainability factors. • Conducting independent and in-depth fundamental research of EM sovereign and corporate issuers,

undertaken by an experienced and diverse group of EM investment specialists. • Incorporating global macroeconomic and policy analysis in the construction of EM fixed income portfolios. • Enhancing regional and local expertise with a dedicated trading capability to provide additional in-depth and

targeted technical knowledge and insights. • Engaging in sustainability research, partnership and engagement to foster a strong risk-management mindset

and investment idea generation while supporting longer-term sustainable outcomes for emerging markets. As an active manager, we aim to achieve a target alpha across all market conditions with a focus on diversification and risk management. We avoid having too much concentrated risk in a small number of oversized active trades. We seek the right diversification through careful risk calibration of positions. This is achieved by expressing our views via cash bonds and FX positions. We use additional tools, such as country CDS, to protect the portfolio in volatile market conditions.

Private Debt – European Direct Lending Pictet European Direct Lending is a pan-European private debt strategy focused on delivering superior riskadjusted returns from a portfolio of first-lien senior secured loans, underpinned by Pictet’s ESG principles and a robust risk management framework. The strategy leverages a differentiated, origination-led approach, partnering selectively with mature, niche market leaders across Europe’s lower mid-market, notably within Healthcare, Education, Business Services and Software/Tech.

Multi Asset International Multi Asset & Strategy (“IMAS”) We use a long only, top-down approach with strong risk controls to build a diversified portfolio of assets. The portfolio is not managed to a specific benchmark and has the flexibility to allocate to different asset classes, including emerging market equities and bonds, based on the qualitative assessment of the investment team. Dynamic asset allocation is at the heart of our investment process and enables us to adapt to the rapidly changing markets of today. We have the flexibility to invest directly in the underlying securities, in an in-house fund or in a fund managed by a third-party manager.

Multi Asset Solutions We closely work with clients to enhance their portfolio return / risk profiles using funds, custom strategies, Tactical Asset Allocation defined by Pictet AM Multi Asset investment committee and different types of hedging

strategies in order to reduce some of their portfolio risks (forex, equity, duration, volatility). We are involved in all aspects of portfolio engineering and risk monitoring.

Multi Asset Switzerland We manage multi-asset mandates according to the guidelines and objectives of each client. The Multi-Asset team is responsible for defining the optimal Tactical Asset Allocation (“TAA”) based on our own macroeconomic research. Our macro analysis is based on four pillars: economic cycle, liquidity analysis, valuation and sentiment indicators. The outcome is active management of our TAA. In terms of products, we generally use a fund solution employing an active selection process, choosing both active and passive products. Both TAA and thematic selection processes are applied to portfolios using a modular approach. Furthermore, the team manages multiasset funds with an absolute return target for both Swiss and Japanese investors. To achieve this, the team has established a dedicated investment team focused on managing these strategies, utilizing the same macro analysis framework as well as our active fund selection process.

B. Risk of Loss and Material Risks

General Risk Statement Each investment strategy managed by the SEC Pictet AM Firms is subject to material risks. This section summarises the main categories of risk that can affect client accounts. It does not identify every possible risk for every investment strategy or client and it is not possible to identify all risks in advance. Investing in securities and other financial instruments exposes clients to the risk of loss of part or all of the amount invested. Clients must be prepared to bear the risk of such losses. For investments in funds, detailed risk disclosures appear in the relevant prospectus or offering documents, which investors must read alongside this Brochure.

1.

General Investment & Market Risks

Investment Risk All investment strategies expose portfolios to fluctuations in financial markets, shifts in investor sentiment and unexpected changes in issuer fundamentals. Asset prices reprice quickly when markets reassess growth, inflation, profitability, credit conditions or systemic stability. The design, assumptions and execution of an investment strategy influence outcomes and any divergence between expected and realised conditions generates loss. Market movements reprice asset classes simultaneously or non-linearly and correlations between assets shift under stress. Investors experience periods of sustained drawdowns, mark-to-market losses and prolonged underperformance relative to benchmarks or peers. Economic Risk Macroeconomic forces (including interest-rate cycles, inflation trends, wage pressures, productivity changes, fiscal balances, monetary-policy regimes, credit availability, sovereign risk and structural economic reform) reshape the operating environment for issuers and asset classes. Economic shocks propagate rapidly through supply chains, financial conditions, corporate earnings and funding markets. Asset values adjust sharply when economic expectations change direction or magnitude (e.g., hard landings, stagflation, policy missteps, external imbalances or rapid tightening of financial conditions). Market Disruption, Geopolitical and Terrorism Risk Unexpected shocks (including war, armed conflict, terrorism, state-sponsored cyber operations, sovereign disputes, sanctions, trade interventions or geopolitical realignments) distort price formation and impair market functionality. These events restrict access to markets, disrupt liquidity, increase volatility, suspend trading, impair settlement systems and materially affect issuers’ financial strength.

Russian Invasion of Ukraine: The invasion and associated sanctions, capital-control measures, asset freezes, index exclusions and operational restrictions alter market access, eliminate liquidity in affected instruments, reduce recoverability of assets and cause abrupt valuation impairments across related geographies and sectors. Environmental Risks & Natural Disasters Severe weather events, climate-driven physical impacts, natural disasters, environmental contamination and resource depletion damage infrastructure, disrupt operations, increase operating and capital costs and impair asset values. These events create physical loss, operational downtime, legal liabilities and supply-chain disruption. Market functioning experiences extreme stress when environmental events affect financial centres, energy systems, transportation infrastructure or data centres. Public Health Risks Widespread illness, epidemics and pandemics interrupt global supply chains, labour markets, transportation networks, business operations and consumer activity. Government responses (including quarantines, travel restrictions, mandated closures and public-health interventions) affect valuations, reduce issuer revenues, increase costs and impair liquidity. Financial markets experience sharp repricing, widening spreads, trading interruptions and operational instability.

Inflation and Deflation Risk Inflation reduces real returns, compresses margins, raises input costs and increases interest rates and discount rates applied to valuations. Sharp increases in inflation generate policy tightening, reduced credit availability, earnings pressure and market volatility. Deflation depresses revenues, weakens nominal growth, increases real debt burdens and heightens default risk. Both inflation and deflation regimes generate sudden shifts in valuation levels across asset classes and disrupt asset allocation relationships. Recession Risk Economic contractions increase credit stress, default rates, unemployment and earnings declines. Corporate revenues and cash flows contract, impairing valuation and raising refinancing risk. Historically stable correlations between asset classes break down during recessions, limiting diversification benefits and generating large swings in portfolio volatility and liquidity. Political, Legal, Taxation & Regulatory Developments Risk Governments and regulators implement policy changes (including tax reforms, ownership restrictions, foreign-exchange controls, capital-movement restrictions, nationalisations, sanctions, industry reforms and changes to financial-market rules) that immediately affect issuers and investors. Sudden policy shifts alter market access, profitability, valuations and the legal enforceability of rights. Foreign-exchange adjustments, tariff realignments and cross-border capital restrictions affect repatriation of investment proceeds and pricing of international assets. Sanctions & Export Control Risk (Including Secondary Sanctions) Sanctions and export-control regimes evolve quickly and can be imposed by the United States, the European Union, the United Kingdom and other authorities. New or expanded restrictions, including secondary sanctions applicable to non-U.S. persons, can render certain issuers, sectors, countries or transactions prohibited, blocked or practically untradeable with little or no notice. Resulting impacts can include trading halts, settlement failures, forced divestment or write-downs, frozen assets or the inability to receive dividends, interest or principal. Market infrastructure or service providers can adopt conservative interpretations of sanctions that further limit trading or custody, particularly in emerging markets. Screening and compliance procedures can reduce but cannot eliminate the risk of loss, delay or additional cost. Energy Security & Commodity Supply Shock Risk Geopolitical conflicts, embargoes, cartel decisions, infrastructure disruptions and shipping-route constraints can cause sharp and prolonged volatility in energy and commodity markets. Such shocks can influence issuers directly through input costs or revenue variability and indirectly through inflation, interest rate adjustments, currency

movements or changes in consumer demand. Elevated commodity volatility can also widen bid-ask spreads, increase margin requirements and reduce liquidity in related instruments. Even portfolios without direct commodity exposure can be affected through supply chain dependencies or macroeconomic effects. Hedging instruments can be imperfect, unavailable or ineffective in offsetting losses during stressed conditions. Elections & Policy Transition Risk Elections, referendums and leadership changes can lead to significant adjustments in fiscal, industrial, trade, antitrust, labour, national security and climate policies. Shifts in policy direction can alter tax burdens, subsidy frameworks, regulatory enforcement, market-access rules or capital-flow restrictions. Markets can react abruptly to campaign proposals, opinion polls or early policy announcements, creating uncertainty around valuations, financing conditions and cash flows. These developments can lead to increased volatility, reduced liquidity or impaired effectiveness of hedging strategies. The timing, substance and market impact of political outcomes cannot be predicted with certainty.

2.

Portfolio Composition and Exposure Risks

Concentration Risk Portfolios with exposure to specific issuers, industries, sectors, geographies, investment styles or thematic exposures experience amplified sensitivity to any adverse event affecting that concentration. Concentrated exposures intensify credit deterioration, operational disruption, regulatory intervention, political instability, technological change and other adverse factors. Concentration increases volatility, reduces liquidity and limits diversification benefits. Counterparty Risk Exposure to derivative dealers, prime brokers, custodians, clearing houses, settlement agents, banks, securities-lending agents and other intermediaries generates financial loss when these entities fail, default or experience operational or liquidity distress. These failures affect cash transfers, collateral return, asset servicing, settlement or the ability to unwind positions. Loss severity increases when exposures are uncollateralised or when collateral values deteriorate rapidly. Settlement Risk Settlement processes in global markets experience delays, mismatches, errors, operational backlogs, data failures, registrar issues or manual-processing bottlenecks. In less developed markets, settlement systems lack robustness, increasing exposure to failed transactions, erroneous transfers or inability to confirm beneficial ownership. Settlement failures restrict trading capacity, distort pricing and increase liquidity and operational risk. Trading Venues Risk Exchanges and trading venues halt trading, delist instruments, shorten trading hours, restrict order types, impose circuit breakers or suspend market access. Structural changes (such as venue consolidation, outages, cyber incidents or infrastructure breakdowns) impair execution and price formation. Instruments that lose exchange listings experience abrupt liquidity loss and forced-sale risk. Failure of Brokers, Clearing Houses, Counterparties & Exchanges Risk Intermediaries responsible for execution, clearing, custody and settlement experience solvency events, operational failures or regulatory intervention. Such failures freeze assets, interrupt cash movements, eliminate access to trading, impede corporate-action processing and create direct financial loss. Clearing-house stress or default cascades across participants and imposes sudden liquidity or margin obligations on market participants. Improper Market Actors Risk Fraud, manipulation, misrepresentation, insider trading, abusive trading practices and inaccurate disclosures by issuers or intermediaries distort securities prices and impair investor outcomes. Market abuses (whether in on-exchange trading, OTC instruments or private markets) result in artificial price movements, valuation errors, permanent capital loss and compromised investment decisions. Market Abuse Risk Securities experience price instability when market participants engage in spoofing, layering, wash trades, dissemination of false information, pump-and-dump activity, coordinated misinformation or other misconduct. These activities distort liquidity, impair fair valuation and destabilise portfolio exposures. Operation of Markets Risk Exchanges, trading systems, clearing networks, index providers and market infrastructure operators adjust rules, methodologies, constituents or operational parameters. Market closures, outages, index rebalances, contract expiries and technical failures disrupt trading strategies, generate execution delays or produce unanticipated valuation effects. Currency Exchange Risk Foreign-currency exposure alters returns independently of underlying asset performance. Exchange-rate changes derive from monetary-policy divergence, inflation differentials, geopolitical tensions, fiscal stress, capital-flow restrictions and unexpected policy intervention. FX volatility amplifies when liquidity thins, capital controls intensify or cross-border flows accelerate.

Liquidity Risk Liquidity conditions deteriorate when market stress increases, market-makers withdraw, risk capital contracts or selling pressure accelerates. Securities become difficult to trade without material price impact. Bid-ask spreads widen, transaction sizes shrink and execution delays increase. Illiquidity disrupts portfolio rebalancing, hedging and redemption management. Illiquidity Risk Illiquid securities (including private instruments, restricted securities, bespoke financings, complex structures and securities with limited secondary markets) require extended holding periods and cannot be realised at prevailing valuations. These exposures limit portfolio flexibility, complicate risk management and intensify valuation uncertainty. Valuation Risk Valuation processes depend on quoted prices, broker quotes, model-driven estimates, third-party data, observable inputs and subjective judgments. Data errors, stale pricing, modelling assumptions, inconsistent methodologies or limited market activity generate inaccurate valuations. Incorrect valuation influences portfolio reporting, performance measurement, risk analytics and investor decision-making. Volatility Risk Periods of pronounced volatility arise from economic shocks, policy changes, market structure issues or concentrated flows. Sharp revaluations occur when volatility and liquidity stress reinforce one another. Frequent Trading & High Turnover Risk Strategies executing high trading volume incur elevated transaction costs, spreads, commissions and operational expenses. High turnover increases tax friction, reduces net performance, accelerates realised losses or gains and increases operational burden. Trading-related slippage and market-impact costs compound over time. Authorised Participant and Market Maker Concentration Risk (ETF Usage) Exposure obtained through exchange-traded funds depends in part on the activity of a limited number of authorised participants and market makers that support liquidity, price formation and the creation and redemption of ETF shares. Reduced activity, withdrawal or capacity constraints among these firms, particularly during market stress, can widen bid-ask spreads, increase premiums or discounts to net asset value and disrupt creation or redemption processes. These conditions may affect execution quality, increase trading costs or alter tracking behaviour relative to the underlying exposures. The number and behaviour of authorised participants and market makers are not controlled by the investment manager.

3.

Strategy-Specific and Thematic Risks

Management Risk Investment strategies depend on portfolio managers, analysts, risk teams and governance structures. Decisions on security selection, position sizing, risk limits, execution and timing directly determine outcomes. When judgments, processes or oversight deviate from design or fail to respond to changing conditions, portfolios experience weaker performance, higher volatility or larger losses than anticipated. Changes in personnel, team structure, culture or incentives alter investment behaviour and the consistency of outcomes over time. Model Risk Some strategies use quantitative, fundamental, ESG or hybrid models to support idea generation, risk measurement, asset allocation or trade execution. Models embed assumptions about relationships between variables, statistical properties of markets, data quality and future behaviour. Errors in design, calibration, coding, implementation or use of inputs produce incorrect rankings, position sizes, hedges or risk assessments. Models that rely on historical relationships fail when market regimes change or when other market participants adopt similar approaches, leading to crowded trades and correlated losses.

Expert Network Risk

Certain research processes use external experts, industry specialists, consultants or networks to supplement internal analysis. These parties are expected to respect confidentiality duties and insider-dealing rules. If an expert discloses material non-public information or if internal controls fail to prevent such use, portfolios face trading restrictions, regulatory investigation, reputational harm and financial loss. Even without inside information issues, experts provide subjective views that introduce bias, selective disclosure or incorrect judgments into the investment process. Investments in Undervalued Assets Risk Strategies that target securities judged to trade below intrinsic value accept the risk that the identified “undervaluation” persists or reflects permanent impairment rather than opportunity. Issuers with depressed valuations often operate in challenged industries, face structural headwinds, governance weaknesses or balance-sheet stress. The expected catalyst for value realisation (such as restructuring, strategic action, regulatory resolution or market re-rating) fails to materialise, arrives later than expected or produces less benefit than anticipated. As a result, undervalued-focused strategies experience extended underperformance and higher drawdowns relative to more broadly diversified approaches. Thematic Investment Risk Thematic strategies concentrate on specific long-term themes, such as technology disruption, demographic change, climate transition, healthcare innovation or other structural trends. Security selection depends on proprietary frameworks for mapping issuers to themes and for assessing the strength, timing and scope of those themes. Performance deteriorates when:

the theme proves weaker, slower or shorter-lived than expected;

the economic benefit of the theme accrues to different companies or industries than anticipated;

companies labelled as “thematic” deliver weak fundamentals, poor capital allocation or governance failures; or

valuation premia for thematic exposures compress sharply.

Thematic portfolios often exclude securities that do not fit the theme, even when those securities offer attractive risk-return characteristics. This constraint reduces diversification, increases concentration and results in forgone opportunities in non-thematic areas. Passive Management Risk Passive and index-tracking strategies aim to replicate the composition and performance of a reference index. Portfolios remain closely aligned with index weights regardless of market conditions, issuer-specific developments or valuation levels. These strategies do not reposition defensively during stressed markets and do not pursue off-index opportunities. Tracking differences arise from transaction costs, index changes, corporate actions, cash flows, sampling techniques and operational factors. The result is performance that diverges from the index and that underperforms active strategies that respond dynamically to opportunities or risks. IPO / New Issues Risk Strategies that participate in initial public offerings or new issues face additional risks. Newly listed securities lack an extended trading history, coherent analyst coverage and full transparency regarding business quality, governance or financial reporting patterns. Prices in the aftermarket often exhibit sharp swings as the investor base forms and as insiders or early backers gain the ability to sell. Allocation in hot deals is frequently smaller than requested, which disrupts sizing and portfolio construction. Certain new issues also embed complex structures, dual-class voting or unusual shareholder protections that affect long-term value. Short Selling Risk Short selling exposes portfolios to the risk that security prices increase rather than decline. Losses on a short position expand as the price rises and do not have a natural upper bound. Lenders of the borrowed securities recall shares, tighten lending terms or increase borrowing costs, forcing the strategy to close positions at unfavourable prices. Regulatory actions such as short-sale bans, reporting obligations or settlement constraints further restrict flexibility. In stressed conditions, short squeezes, low borrow availability or crowded positioning produce rapid and severe mark-to-market losses.

Commodity Exposure Risk Exposure to commodities or commodity-linked instruments introduces sensitivity to supply-demand imbalances, geopolitical developments, weather, storage and transport constraints, production decisions, regulatory changes and technological shifts. Commodity markets experience pronounced volatility and structural phenomena such as backwardation or contango that influence roll returns and total performance. Indices, swaps or structured commodity products sometimes diverge from spot-price behaviour because of rebalancing rules, contract selection or collateral yields. Corporate Event Risk Corporate actions (including mergers, acquisitions, spin-offs, restructurings, recapitalisations, rights issues, share buybacks or special dividends) alter capital structure, earnings profiles and risk characteristics. Event-driven strategies that seek to benefit from corporate events depend on accurate assessment of transaction terms, regulatory approvals, financing and stakeholder behaviour. Breakdowns in deals, adverse changes to terms, unexpected competing bids or regulatory blocks generate losses. For non-event strategies, unanticipated corporate actions disturb portfolio construction, change factor exposures or introduce new risks that differ from the original investment case.

4.

Security-Specific Risks: Equity and Equity-Like Instruments

Equity Securities Risk Equity securities represent ownership interests in an issuer and rank junior to debt and other senior instruments in a liquidation. Equity values respond directly to changes in earnings, cash flows, balance-sheet strength, competitive dynamics, innovation success, regulatory developments, management quality, sentiment and macroeconomic conditions. Equity markets exhibit higher volatility than many fixed-income markets, with sharp drawdowns in stress episodes. Share prices reprice immediately in response to new information or shifts in expectations and losses crystallise when issuers underperform, dilute shareholders, assume excessive leverage or enter structural decline. Capitalisation Risk Issuer size creates different risk profiles.

Small-capitalisation issuers typically operate with narrower product ranges, smaller customer bases, less diversified revenue streams, lower market share and weaker access to capital markets. Their share prices exhibit higher volatility, wider spreads and more pronounced reactions to company-specific news.

Mid-capitalisation issuers sit between small and large companies in terms of liquidity, resilience and market access, but still experience greater sensitivity to competition, execution errors and macroeconomic stress than the largest issuers.

By contrast, large-capitalisation issuers often display more diversified businesses but still face structural, regulatory or disruptive risks. Concentrated exposure to any capitalisation bucket alters liquidity characteristics, volatility patterns and sensitivity to economic cycles. Depositary Receipts Risk American Depositary Receipts (ADRs), Global Depositary Receipts (GDRs), European Depositary Receipts (EDRs) and similar instruments represent interests in underlying non-local shares. Their value tracks the underlying security but also depends on the terms of the depositary arrangement, custody structures, local market practices and any fees or charges imposed by the depositary or underlying issuer. Delistings, unwinds of depositary programmes, changes in conversion terms, capital-control measures or local-market restrictions disrupt trading and settlement. In such cases investors experience forced conversion into local shares, cash-out at unfavourable terms or prolonged holding of instruments with impaired liquidity and uncertain legal treatment. Trading in depositary receipts regularly exhibits different liquidity profiles and spreads than trading in the underlying local shares. Index and Tracking Error Risk (Equity Context)

Equity portfolios that track or reference equity indices exhibit tracking error—the difference between portfolio performance and index performance. Tracking error arises from sampling techniques, optimisation choices, corporate actions, index rebalances, security substitutions, cash drag, transaction costs, tax effects and operational decisions. Errors in the index itself (such as misclassifications, delays in reflecting material events or methodology changes) feed through directly to portfolio exposures. When indices concentrate on specific sectors, styles or capitalisation buckets, index-tracking portfolios inherit these concentrations and experience similar drawdowns when those segments underperform.

5.

Fixed Income and Credit Risks

Credit Risk Fixed income instruments expose portfolios to loss when issuers fail to meet contractual interest or principal obligations. Credit deterioration, weakened financial profiles, declining cash flows, covenant breaches, structural subordination, deteriorating collateral coverage and sector-specific downturns impair issuer solvency and repayment capacity. Three components of credit risk are relevant:

Default Risk: Issuers fail to pay interest or principal, generating a full or partial loss of capital.

Credit Spread Risk: The market reprices an issuer as less creditworthy, widening spreads and reducing the value of outstanding instruments.

Downgrade Risk: Rating agencies lower an issuer’s credit rating, triggering forced selling, liquidity stress and valuation declines.

Interest Rate Risk Interest rate risk reflects the sensitivity of fixed income securities to changes in prevailing interest rates. Rising policy rates, inflation expectations or yield curves reduce the present value of fixed coupon payments. Longer-maturity and lower-coupon securities exhibit sharper price declines when rates rise. Unexpected interest-rate movements also disturb hedging strategies and cross-asset correlations. Duration Risk Duration expresses the magnitude of a bond’s price response to rate movements. Instruments with longer duration experience larger price changes for each unit of interest-rate movement. Portfolios with elevated duration experience amplified volatility and larger mark-to-market losses when yields shift abruptly due to economic releases, central-bank decisions or liquidity conditions. Reinvestment Risk Cash flows from coupons, maturities and principal repayments require reinvestment into new interest-bearing securities. When market yields decline, reinvestment into lower-yielding instruments reduces long-term returns and compresses income. Reinvestment risk is especially relevant to amortising structures, callable bonds and strategies depending on steady income generation. Equivalent effects arise for Sukuk, where reinvestment of returned capital occurs at profit-rate levels below those originally assumed. Extension Risk Extension risk occurs when borrowers slow repayment of principal (particularly relevant for mortgage-related, asset-backed and floating-rate structures) resulting in a lengthening of expected maturity. When interest rates rise, borrowers avoid refinancing, extending the life of higher-yielding securities unexpectedly. This exposes investors to prolonged interest-rate sensitivity and magnifies valuation declines.

Call (Early Redemption) Risk Issuers redeem callable debt before stated maturity when refinancing conditions allow cheaper funding. During falling-rate environments, issuers exercise call options on higher-yielding debt, forcing reinvestment at lower

prevailing yields and reducing portfolio income. Frequent calls destabilise cash-flow projections and disrupt portfolio construction. Sovereign & Quasi-Sovereign Debt Securities Risk Sovereign and quasi-sovereign exposures depend on the fiscal stability, policy credibility, governance quality, institutional capacity and external-financing conditions of the issuing government. Governments impose payment delays, restructure debt, alter repayment terms or repudiate obligations based on political priorities, foreign-currency reserves, economic downturns or policy shifts. Unlike corporate issuers, sovereign creditors lack access to standard bankruptcy mechanisms, increasing loss severity when a sovereign defaults or restructures. Non-Investment Grade Investment Risk (High-Yield Risk) Non-investment-grade instruments carry materially higher credit, liquidity, volatility and recovery risks. High-yield issuers often exhibit leveraged balance sheets, limited financial flexibility, shallow capital-market access and heightened sensitivity to cyclical downturns. Pricing gaps and liquidity air-pockets occur frequently around earnings announcements, rating actions and market stress periods. Valuation uncertainty increases when trading volumes thin or when issuer disclosure quality is lower than that of investment-grade issuers. Convertible Bonds Risk Convertible bonds blend characteristics of debt and equity. The embedded conversion feature alters sensitivity to credit, volatility, interest-rate movements and issuer-specific equity performance. When issuer equity underperforms, convertibles behave similarly to subordinated bonds but with lower coupons and weaker downside protection. When equity rallies but conversion conditions are unfavourable, holders do not participate fully in the upside. Structural features (such as reset provisions, soft calls, mandatory conversions and dilution adjustments) create additional complexity and valuation dispersion. Sukuk Investment Risk Sukuk represent beneficial ownership in underlying Sharia-compliant assets or contractual payment arrangements. Performance depends on asset quality, enforceability of contractual rights and the issuer’s financial capacity. No collateral is pledged in many structures and recoveries depend on asset performance or obligor credit strength. Secondary markets for Sukuk frequently exhibit limited liquidity, reducing exit opportunities and impairing valuation reliability. Cross-jurisdictional legal interpretations introduce complexity in default scenarios. Contingent Convertible (“CoCo”) Instruments Risk CoCos absorb losses when a trigger event occurs—such as capital-ratio deterioration or regulatory determination. Instruments convert to equity or are permanently written down, eliminating principal and income. CoCos sit low in capital structures, exhibit high price volatility and respond sharply to issuer-specific news, regulatory action and sentiment shifts. Because conversion or write-down terms are fixed contractually rather than negotiated, recoveries in stress conditions are unpredictable and often severe. LIBOR Discontinuance & Benchmark Transition Risk The discontinuance of the London interbank offered rate (“LIBOR”) and other interbank reference rates replaces long-established benchmarks with alternative reference rates such as the secured overnight financing rate (“SOFR”) or Sterling overnight index average (“SONIA”). Differences in liquidity, term structure, market adoption and operational frameworks create pricing mismatches between legacy and new instruments. Instruments referencing fallback provisions exhibit valuation jumps or step-changes when fallback mechanisms activate. Benchmark reform also generates operational, documentation, systems and model-calibration risk and requires careful management of mismatched exposures across instruments.

6.

Private Credit, Distressed Debt and Special Situations Risks

Illiquidity and Transfer Restrictions Risk (Private Credit & Distressed Instruments) Private credit and distressed debt instruments frequently lack active secondary markets and trading occurs (when possible) only through negotiated, bilateral transactions. Transferability often requires advance consent from

issuers, agents or general partners and legal governing documents impose strict limits on sales, assignments and participations. These restrictions prevent timely exit, compel holding periods that exceed underwriting assumptions and generate losses when deterioration accelerates and no viable buyer exists. Investors also experience delays or denials when requesting approvals for transfers, creating trapped capital and heightened valuation uncertainty. Loans to Private Companies Risk Direct lending and loan acquisitions to private companies introduce heightened credit, liquidity, governance and information-quality risk. Many private borrowers operate with concentrated business models, less diversified revenue streams, limited operating history and higher vulnerability to macroeconomic pressure. Their financial reporting is less frequent, less detailed and less standardised than public issuers. Managerial transitions, founder dependency, operational setbacks or tightening credit conditions impair borrower performance and repayment capacity. Smaller borrowers also exhibit weaker access to capital markets, higher refinancing risk and reduced resilience during economic downturns. These characteristics elevate the probability of covenant breaches, restructuring or default. Distressed & Financially Impaired Issuers Risk Distressed debt strategies invest in issuers experiencing severe financial, operational or legal stress (including those that are non-performing, in restructuring, in default or expected to default). Recoveries depend on complex negotiation processes, legal judgments, creditor hierarchy, jurisdictional insolvency regimes, liquidity of collateral assets and actions by controlling stakeholders. Disputes among creditor classes, litigation, cross-border bankruptcy inconsistencies and contested valuations prolong recovery timelines and reduce final outcomes. Distressed instruments also exhibit extreme price volatility, limited transparency and frequent periods with no observable market pricing. Investors experience prolonged lock-up periods and uncertain return timing. Default Resolution, Court & Insolvency Process Risk Restructuring and insolvency processes are complex, adversarial and unpredictable. Outcomes depend on court decisions, creditor-committee dynamics, valuations of impaired assets, regulatory interventions and debtor– creditor negotiations. Jurisdictional differences influence recoverability, including whether seniority, collateral, guarantees and voting rights are respected. Court rulings delay or prevent enforcement, prioritise claims differently from expectations or impose unfavourable restructuring terms. Recoveries are reduced when administrative costs, professional fees and operational erosion consume enterprise value. Documentation, Covenant & Structural Subordination Risk Private credit and distressed transactions rely on bespoke loan documentation. Weak or permissive covenant packages (including covenant-lite structures, wide baskets, builder baskets, EBITDA adjustments or absent maintenance covenants) reduce creditor protection and accelerate credit deterioration before remedial action is possible. Structural subordination occurs when exposure is held at a holding-company level or at an entity behind other funded debt, reducing expected recovery. Intercreditor agreements, hidden liens, transfer restrictions or opaque capital structures materially affect priority of claims and enforcement rights. Revolving Credit Facilities Risk Facilities allowing borrowers to draw and repay freely introduce unique liquidity and capital-commitment risks. Investors funding such facilities must reserve capital for potential future drawings, reducing deployable capital and creating cash-management strain. Borrowers draw unexpectedly large amounts during periods of financial stress, converting undrawn commitments into funded exposures at the worst point in the credit cycle. If borrowers do not draw to the full commitment, portfolios hold unproductive capital or experience lower than expected returns due to unused-commitment fees. Event-Driven, Special Situations & Opportunistic Credit Risk

Event-driven and special-situations strategies rely on specific catalysts—such as refinancing events, recapitalisations, asset sales, litigation outcomes, regulatory changes, operational turnarounds or liability-management exercises. Catalysts fail to materialise, occur later than expected or produce outcomes that diverge from the underwriting thesis. Special-situations instruments also exhibit elevated downside asymmetry, limited liquidity and valuation complexity due to their reliance on non-standard contracts, bespoke negotiations and issuer-specific events. Complexity & Non-Standard Instrument Risk Private debt instruments often contain bespoke payment waterfalls, contingent interest mechanisms, performance kickers, equity-linked components, warrants or profit-participation features. Complex or opaque instrument structures introduce modelling challenges and valuation dispersion. Loss severity increases when structures incorporate payment-in-kind toggles, covenant holidays, collateral pledges with uncertain enforceability or cross-default provisions that trigger unexpectedly. Valuation & Pricing Uncertainty (Private Credit & Distressed Assets) Because private credit and distressed instruments trade infrequently and often lack observable market prices, valuations depend on internal models, third-party marks, lender quotes and subjective judgement. Inputs (including forecast cash flows, comparable transactions, recovery assumptions, discount rates and collateral valuations) exhibit wide uncertainty. During periods of market stress, broker quotes become stale or unavailable, resulting in increased dispersion of valuations and heightened risk of material mispricing. Fraud & Financial Irregularities in Private Issuers Investments in private companies involve elevated risk of fraud, misappropriation, accounting irregularities or other misconduct due to limited public disclosure, varying audit standards and less developed regulatory oversight. Information may be incomplete, inaccurate, delayed or intentionally misleading. Such issues can result in over-valuation, unexpected write-downs, covenant breaches, liquidity shortages or a total loss of value. Recovery may be limited by weak collateral, complex legal structures or protracted enforcement processes. Due diligence and monitoring reduce but cannot eliminate the risk of undetected fraud or financial irregularities. Legal, Structural & Jurisdictional Enforcement Risk Legal documentation, creditor rights and enforcement outcomes differ significantly across jurisdictions. Some jurisdictions weaken creditors’ rights, delay enforcement, permit debtor-friendly restructuring mechanisms or impose capital-control restrictions. Cross-border restructurings introduce conflict-of-law issues, recognition limits on foreign judgments and asymmetric treatment of different creditor classes. Enforcement in emerging markets involves elevated legal uncertainty, political influence and limited transparency in court processes.

7.

Derivatives, Leverages and Collateral Risks

Derivative Instruments Risk Portfolios that use derivatives such as forwards, futures, options, swaps, warrants, total-return swaps, structured notes and similar instruments are exposed to a distinct set of risks in addition to the risks of the underlying assets. Derivatives frequently embed economic leverage, which amplifies both gains and losses. A relatively small movement in the price, rate, index, spread or other underlying reference produces a disproportionately large impact on the value of the derivative position. In adverse conditions, this leads to rapid and substantial capital loss and forces portfolios to liquidate positions at unfavourable prices to meet margin or collateral calls. Derivatives markets exhibit periods of illiquidity, pricing gaps and wide bid-ask spreads, especially during stress episodes. Quoted prices in such conditions do not always reflect executable levels and exit opportunities become scarce. Valuation of complex or bespoke derivatives requires models, assumptions and input data that introduce additional model-risk and valuation-risk elements.

Derivatives also expose portfolios to documentation, legal and operational risk. Contractual terms in International Swaps and Derivatives Association (“ISDA”) and related agreements govern close-out, termination events, collateral, netting and dispute resolution. Ambiguities or adverse provisions in these documents, together with trade-capture errors, confirmation mismatches, collateral disputes and settlement failures, directly affect realised outcomes. Leverage Risk (Including Embedded Leverage in Derivatives and Financings) Leverage arises when portfolios obtain exposure that exceeds their capital base through derivatives, borrowing, repos, reverse repos or other financing structures. Leverage magnifies sensitivity to market movements, increases volatility and accelerates losses when markets move against positions. When leverage is present, adverse price movements quickly erode equity and lead to:

margin calls from clearing houses or counterparties,

forced deleveraging under pressure,

liquidation of positions into thin liquidity, and

breach of financing covenants or regulatory constraints.

Financing counterparties adjust haircuts, eligibility criteria and financing terms during periods of market stress, which compresses available leverage precisely when portfolios face adverse market moves. Collateral Risk Collateral arrangements are designed to mitigate counterparty default risk, but they introduce their own risk profile. Key exposures include:

Valuation Risk on Collateral: Collateral values fluctuate with market conditions. Declines in collateral value between margin calls or during settlement gaps create unsecured exposures.

Quality and Liquidity of Collateral: Certain forms of collateral, particularly lower-quality securities or complex instruments, are difficult to liquidate without material price impact. In a default scenario, liquidation proceeds fall short of the amount owed.

Operational and Legal Risk: Inadequate documentation, imperfect perfection of security interests or weaknesses in collateral management processes delay or prevent realisation of collateral.

Reinvestment Risk on Cash Collateral: When cash collateral is reinvested, the reinvestment portfolio can suffer losses or fail to earn returns sufficient to cover the obligation to return cash to the counterparty.

Hedging Risk Hedging strategies use derivatives or related instruments to offset identified risks in a portfolio, including market, currency, interest-rate, spread or volatility exposures. Effective hedging requires stable relationships between the hedged exposure and the hedging instrument. In practice:

Correlations between instruments change, especially in stressed markets.

Basis risk arises when the hedge references a different but related index, curve, maturity or instrument.

Liquidity conditions differ between the underlying exposure and the hedge, preventing timely adjustment or close-out.

As a result, hedges under- or over-compensate losses or generate losses even when the underlying exposure performs as expected. Hedging transactions also introduce incremental costs, operational complexity and counterparty risk and they often reduce, rather than increase, flexibility in managing positions during fast-moving markets. Credit Default Swap (CDS) Risk

Credit default swaps transfer credit risk between protection buyers and sellers. A portfolio that buys protection assumes the risk that the protection seller fails to perform when a credit event occurs; a portfolio that sells protection assumes exposure to the full loss associated with a credit event on the reference entity or index. Key CDS risks include:

Counterparty Risk: The protection seller fails to pay after a credit event or the protection buyer fails to meet premium obligations.

Liquidity Risk: CDS markets experience periods of thin trading and wide bid-ask spreads, especially for single-name contracts and stressed entities, which locks in positions and raises exit costs.

Pricing and Model Risk: CDS pricing depends on recovery assumptions, curve construction and market-implied default probabilities. Misestimation of these inputs or reliance on stale quotes produces mispricing.

Legal and Settlement Risk: The definition of a “credit event,” the determination process by ISDA determinations committees and settlement mechanics (cash vs. physical, auction results) introduce uncertainty about timing and magnitude of payments.

Repurchase & Reverse Repurchase Agreement Risk Repurchase agreements (“repos”) and reverse repurchase agreements are forms of secured financing. In a repo, the portfolio sells securities against cash and agrees to repurchase them later, whereas, in a reverse repo, the portfolio provides cash in exchange for securities as collateral. Risks include:

Counterparty Default: If the counterparty in a reverse repo defaults, the portfolio holds collateral whose market value falls short of the exposure, particularly after a sharp market move.

Collateral Value Risk: In a repo, if the value of sold securities increases relative to the cash received and the counterparty defaults, the portfolio suffers loss because it must replace those securities at higher prices.

Liquidity and Roll-Over Risk: Reliance on short-dated repos to fund longer-dated or less liquid assets exposes the portfolio to funding roll-over risk if counterparties withdraw or re-price funding during stress.

Legal and Operational Risk: Imperfect title transfer, documentation weaknesses or operational failures impair the ability to enforce collateral rights or to re-use collateral.

Structured Finance Securities Risk Structured finance exposures include asset-backed securities (“ABS”), mortgage-backed securities (“MBS”), collateralised loan obligations (“CLOs”), collateralised debt obligations (“CDOs”), credit-linked notes and similar tranched instruments. Investors in such instruments face:

Complexity Risk: Performance depends on multiple layers of structure: collateral pool quality, tranche subordination, credit-enhancement features, trigger mechanisms and servicing quality. Understanding risk requires detailed analysis of documentation and deal behaviour.

Correlation and Concentration Risk: Losses in the underlying pool often cluster in extreme scenarios; correlations rise under stress, quickly eroding the protection of mezzanine or equity tranches.

Model and Data Risk: Valuations rely on default and prepayment assumptions, recovery rates and correlation models. Deviations between actual outcomes and modelled scenarios result in significant mispricing.

Liquidity Risk: Secondary markets for many structured products tighten or freeze during periods of credit stress, leading to wide bid-ask spreads, limited dealer balance-sheet capacity and forced-sale discounts.

Servicer and Operational Risk: Performance depends on the behaviour and capabilities of servicers, trustees and administrators. Servicing failures, misalignment of incentives or operational problems reduce recoveries and impair cash-flow timing.

8.

Collective Investment Vehicles and Real Assets Risks

Collective Investment Schemes Risk Portfolios that invest in other collective investment schemes, including UCITS, mutual funds, ETFs, closed-ended funds, limited partnerships and other pooled vehicles, inherit the full risk profile of those underlying schemes in addition to the risks of the top-level portfolio. The success of such an allocation depends on the underlying scheme:

achieving its stated investment objective and strategy,

operating with robust liquidity and risk-management frameworks, and

executing its processes effectively in all market conditions.

When an underlying scheme performs poorly, experiences liquidity stress, faces operational difficulties, suspends redemptions or liquidates, investors in the top-level portfolio experience valuation losses, delayed redemptions or forced re-allocations. Investors also bear their proportionate share of the fees and expenses of the underlying schemes, including management, performance, administration and custody charges. This fee layering reduces net returns compared with direct investment in securities. Where collective investment schemes are advised or sponsored by related entities, conflicts of interest exist because internal products generate revenues for the group. These conflicts relate to product selection, retention of underperforming schemes and allocation of capacity in capacity-constrained strategies. Large subscriptions into or redemptions from an underlying scheme create flow risk: portfolio managers of the scheme adjust positions rapidly to accommodate flows, altering risk exposures and transaction costs for all investors. In stressed conditions, such flows accelerate market impact, deepen drawdowns and weaken liquidity in underlying holdings. Fund-of-Funds and Master–Feeder Structure Risk Fund-of-funds and master–feeder structures introduce additional structural and governance risk. In a master– feeder arrangement, feeder investors depend on the investment, liquidity, fee and governance decisions taken at the master level. Events at the master fund (such as changes in investment policy, use of leverage, gating, suspensions, borrowing or restructuring) transmit directly to the feeder, without control by the feeder’s investors. Differences in legal, regulatory, tax or accounting regimes between master and feeder entities also influence returns, liquidity and tax outcomes for investors. Fund-of-funds structures concentrate risk in the selection, monitoring and replacement of underlying managers and funds. Limited transparency into underlying portfolios, especially in hedge funds and private funds, increases due-diligence and oversight risk. Real Estate & Real Asset Fund Risk Real estate and real asset strategies (whether implemented directly or via listed and unlisted vehicles) expose investors to risks linked to property markets, infrastructure assets and other real-asset classes. These risks include:

cyclical fluctuations in property values, rents, occupancies and user demand;

leverage and refinancing risk within real estate or infrastructure holding structures;

construction, development and project-completion risk;

asset-specific risks such as tenant defaults, lease renegotiations and asset obsolescence;

regulatory, planning, environmental and zoning constraints; and

valuation risk for illiquid assets that rely on appraisals and infrequent transactions.

Real asset funds often rely on external appraisers and models to estimate fair value. Infrequent transactions, limited comparable sales and subjective assumptions generate valuation dispersion and lagged recognition of market stress. Liquidity frequently depends on secondary markets for fund interests, periodic redemption windows or manager-controlled liquidity tools. In adverse conditions, redemption gates, deferrals, side pockets or suspensions restrict investor access to capital and crystallise losses when forced sales occur into weak markets. Real Estate Investment Trust (REIT) Risk REITs and similar listed real-estate vehicles exhibit the same fundamental risks as direct property holdings, together with equity-market volatility and market-structure effects. REIT performance depends on:

the value and income profile of underlying properties and mortgages;

tenant quality, occupancy levels, lease terms and re-letting risk;

financing structures, interest rate sensitivity, debt maturities and covenant packages; and

management quality, capital-allocation discipline and governance.

REIT share prices respond rapidly to interest-rate changes, expectations for property markets and equity-market sentiment. REITs often exhibit higher volatility and lower liquidity than large-capitalisation equities. Concentrated exposure to specific REIT segments—such as retail, office, logistics, residential or specialised sectors—intensifies sensitivity to structural changes in those markets. Commodity Exposure via Collective Vehicles Risk Commodity exposure obtained through funds, commodity-linked notes, exchange-traded products or structured vehicles embeds both the underlying commodity risk and structural risks of the vehicle itself. These structures depend on counterparties, collateral, roll methodologies, index rules and legal terms. Tracking differences between the vehicle and spot or front-month futures prices arise from roll yields, financing costs, fees and liquidity effects. In stressed markets, secondary trading in commodity vehicles becomes thin, spreads widen and large flows distort pricing relative to underlying commodity markets. Structural changes, such as index rebalancings, contract-selection changes or issuance suspensions ,alter risk and return characteristics for existing holders.

9.

Emerging Markets and China Programme Risks

General Emerging Markets Risks Investments in emerging markets involve higher risk than investments in developed markets. Social, political, legal and economic systems in many emerging countries are less stable, less transparent and less predictable. Regulatory frameworks are less mature, investor protections are weaker and enforcement of laws and contracts is less consistent. Corporate governance standards in emerging markets are often weaker than in developed markets. Board oversight, shareholder-rights protections, disclosure practices, related-party transaction controls and minority-investor safeguards are less robust. The risk of fraud, accounting irregularities, misappropriation of assets or management self-dealing is higher and audit processes are less effective at detecting such issues. Allegations and discoveries of fraud, misreporting or governance failures trigger extreme price movements, trading suspensions or delistings and result in permanent capital loss. Emerging market trading venues frequently exhibit higher volatility and lower liquidity than developed market exchanges. Bid-ask spreads are wider, daily trading volumes are thinner and the market depth required to execute institutional-size trades at stable prices is weaker. Market manipulation, insider trading and other forms of market abuse occur more frequently and sanctions or enforcement actions are less effective at deterring such behaviour. Due to these characteristics, emerging market securities are generally suitable only for investors who accept higher risk, longer investment horizons and larger drawdowns than those typical of developed markets. Political & Economic Risks in Emerging Markets

Emerging markets experience higher political and macroeconomic instability than developed markets. Political regime changes, abrupt shifts in economic policy, social unrest, corruption, policy reversals and weak or contested institutions create abrupt market moves and structural breaks in pricing relationships. Governments in emerging markets impose foreign-exchange controls, capital-movement restrictions, price controls, subsidies, nationalisations, expropriations and sudden tax or regulatory changes. These actions alter the value of existing investments, restrict the ability to trade or dispose of assets and impair the legal position of foreign investors. Exchange-rate levels and cross-rates experience sharp and unexpected adjustments, which produce large FX translation effects and disturb cross-border capital flows. Armed conflict, civil unrest, terrorism or cross-border tensions in or near emerging markets disrupt trade, investment and capital markets and generate sharp valuation declines in affected issuers and countries. Capital Repatriation Restrictions Risk Some emerging markets impose restrictions on the timing, amount or method of repatriating capital, income or sale proceeds. Governments or regulators require prior approvals, impose holding periods, set conversion windows or limit foreign-exchange access. When repatriation restrictions exist, portfolios experience delays in receiving cash flows, face uncertainty about the conversion rate and timing of transfers and hold blocked balances denominated in local currencies. These restrictions distort liquidity management, disrupt rebalancing decisions and create mismatches between realised investment returns and cash available to investors. Weaker Accounting Standards & Disclosure Risk In many emerging markets, accounting, auditing and financial-reporting standards are weaker or less consistently applied than in the U.S. or other developed markets. Auditors have fewer resources, less independence and less effective regulatory oversight. Financial statements from emerging market issuers exhibit less detail, lower frequency and less comparability across companies. Off-balance-sheet exposures, related-party transactions, contingent liabilities and risk factors are disclosed less clearly. Investors and asset managers operate with incomplete or delayed information, which increases the risk of mis-pricing, mis-allocation of capital and underestimation of downside risk. Risk of Investing in the People’s Republic of China (PRC) Investments in the PRC are subject to specific regulatory and policy risks. PRC authorities control market access, foreign-ownership levels, capital movements and trading mechanisms. They introduce trading quotas, sectoral restrictions, foreign-investment caps and specific requirements for foreign institutions. Authorities in the PRC also retain broad powers to intervene in markets and in corporate structures. They implement sudden regulatory reforms, enforce new licensing requirements, restructure sectors or take actions that affect foreign ownership, listing status or the ability of foreign investors to hold or trade certain securities. Nationalisation, expropriation, forced restructurings or changes in control frameworks for strategic industries create significant loss and legal uncertainty for foreign investors. Legal and regulatory systems in the PRC function differently from those in developed markets and judicial independence and enforcement standards differ from Western norms. Contractual rights, shareholder protections and access to legal remedies operate under these conditions and reflect local political and policy priorities.

China RMB Investment Channels: R-QFII, Stock Connect, Bond Connect & CIBM Risk Access to Chinese onshore equity and bond markets for foreign investors often relies on specific policy programmes and regulatory channels, including RMB Qualified Foreign Institutional Investor (“R-QFII”) quotas, Stock Connect, Bond Connect and access to the China Interbank Bond Market (“CIBM”). These channels introduce programme-specific risks, including:

Quota and Access Risk: Eligibility criteria, investment quotas and participation rules are set and adjusted by PRC regulators. Changes to programme terms, suspensions or revocations of access directly affect the ability to trade, increase or unwind positions.

Ownership and Custody Risk: Legal ownership structures for foreign investors under these programmes differ from conventional custody arrangements in other markets. Beneficial ownership, nominee arrangements and recognition of foreign investor interests depend on local legal interpretations and operational practices.

Trading, Settlement & Operational Risk: Trading days, settlement cycles, holiday calendars and local market conventions differ from those in investors’ home markets. Operational mismatches, cutoff times, trading limits, price-limit rules and suspension mechanisms interrupt execution and create settlement risk.

Regulatory & Policy Change Risk: Authorities adjust rules, introduce new conditions or implement policy changes with limited consultation and short notice. Such actions influence liquidity, pricing, eligibility of securities and continuation of existing investment strategies.

Currency & Conversion Risk: Investments conducted through RMB channels involve conversion between RMB and investors’ base currencies. FX controls, intraday liquidity patterns and local banking rules influence conversion timing, available rates and the ability to repatriate proceeds.

10. Operations, Technology and Data Risks Information Technology (“IT”) Risk Investment and risk-management processes depend on complex IT infrastructure: trading platforms, order-management and execution systems, risk engines, pricing tools, data warehouses, network architecture and end-user applications. System outages, software defects, failed releases, network congestion, regression issues and capacity constraints interrupt order routing, trading, reconciliation, valuation, risk reporting, compliance monitoring and client reporting. Incomplete or delayed data flows distort risk measures, performance reports and portfolio information used for decision-making. Complex organisations frequently operate decentralised or end-user computing tools (for example spreadsheets with macros, databases, dashboards and other tools built outside central IT governance). Weak documentation, version control, access management or testing on such tools introduces hidden operational risk, errors in calculations and inconsistent data across teams. When IT functions are shared across legal entities or business lines, coordination or communication failures around system changes, decommissioning, vendor migrations or security controls disrupt critical services and create unintended consequences for portfolios. Cloud Risk Use of cloud platforms for infrastructure, software, data storage, analytics and application hosting introduces dependencies on external providers and on regulatory compliance around data location, security, privacy and outsourcing. Cloud misconfigurations, service outages, latency spikes or provider-driven changes to functionality or pricing disrupt operations and data access. Data residency rules and regulatory expectations around cloud oversight impose strict requirements on architecture, vendor management, backup and recovery and monitoring. Weak governance and oversight of cloud solutions increase exposure to operational disruptions, data loss, delayed recoveries and non-compliance. Critical systems hosted in the cloud (such as portfolio-management platforms, risk engines or data-integration pipelines) create concentrated operational risk in the event of a major incident at a cloud provider. Data Sources Risk

Investment processes depend on large volumes of data from internal and external sources: market data, prices, ratings, fundamentals, ESG metrics, alternative data, index compositions, macroeconomic series and reference data. Errors, gaps, stale values, survivorship bias, incorrect mappings, delayed feeds or inconsistent conventions result in incorrect valuations, mis-stated risk measures, flawed screens, erroneous exclusions or inclusions and inaccurate performance or exposure reports. When decision-making relies on data sets supplied by third-party vendors, internal controls must detect vendor errors; otherwise, those errors propagate directly into trade decisions and risk assessments. Data-integration complexity across front-office, risk, operations, compliance and reporting applications creates reconciliation challenges. Inconsistent identifiers, incomplete history or divergent hierarchies across systems generate breaks between views, increase manual intervention and elevate operational risk. Cybersecurity Risk Cybersecurity Risk is a measure of the extent to which an entity is threatened by a potential circumstance or event and typically is a function of:

the adverse impact or magnitude of harm, that would arise if the circumstance or event occurs; and

the likelihood of occurrence.

With the increased use of technologies such as the cloud, artificial intelligence and the dependence on computer systems to perform necessary business functions, the SEC Pictet AM Firms may be prone to operational and informational security risks resulting from breaches in cybersecurity (“cyber-attacks”). A cyber-attack refers to both intentional and unintentional events that may cause us or the invested company to lose proprietary information, suffer data corruption or lose operational capacity. Cyber-attacks include, but are not limited to, infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks or devices that are used to service our operations through “hacking” or other means for the purpose of misappropriating assets or sensitive information, corrupting data or causing operational disruption. Cyber-attacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on the SEC Pictet AM Firms or invested company’s websites (i.e. efforts to make network services unavailable to intended users). In addition, authorised persons could inadvertently or intentionally release confidential or proprietary information stored on the SEC Pictet AM Firms or invested company’s systems. The same cyber security risks as identified above also apply to a company in which the SEC Pictet AM Firms have invested on behalf of their clients. Cybersecurity failures or breaches by the SEC Pictet AM Firms, affiliates, service providers or firms in which the SEC Pictet AM Firms invest may cause disruptions and impact business operations, potentially resulting in financial losses to the SEC Pictet AM Firms or the invested company, impediments to trading, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs and/or additional compliance costs. In addition, substantial costs can be incurred in attempting to prevent cyber incidents. Data Localisation & Cybersecurity Law Risk Some jurisdictions impose data localisation, cybersecurity and cross-border data-transfer requirements that restrict the collection, storage, analysis or sharing of information relevant to research, trading, operations or client service. Certain data may need to remain onshore or be processed by locally certified providers. Regulatory changes or enforcement actions may occur with limited notice and may restrict due-diligence activity, limit vendor selection, increase operational cost or delay processes. Authorities may also suspend transfers or initiate investigations, disrupting operational workflows. Compliance measures can mitigate but cannot eliminate these risks. Artificial Intelligence (“AI”) Models & Data Risk AI and machine-learning models appear in investment processes, risk management, research analytics, client reporting tools and operational workflows. These models rely on large and often complex data sets, non-linear algorithms and optimisation objectives that are difficult to interpret. Key AI-specific risks include:

Data Risk: Training and input data contain errors, biases, missing values or unrepresentative samples. This distorts model outputs, embeds structural bias and produces unreliable predictions.

Model Risk: AI models generate outputs that deviate from design due to mis-specification, overfitting, unstable relationships or regime changes. Predictive features lose relevance when market structures, regulations or competitor behaviour change.

Transparency and Explainability Risk: Complex AI architectures (for example deep learning) are difficult to interpret. Limited understanding of how inputs drive outputs impairs challenge, validation and oversight of AI-driven decisions.

Regulatory Risk: Evolving legal frameworks on AI, data privacy and algorithmic decision-making impose constraints on data use, model design, documentation, testing and human oversight. Non-compliance results in fines, enforcement action and mandated model changes.

Fraud and Enhanced Cyber Risk: Adversaries use AI to craft sophisticated phishing, identity theft, deepfakes or automated attacks against systems, clients and portfolio companies, raising the effectiveness and scale of malicious activity.

Content and Confidential Information Leakage Risk: Use of AI tools may expose proprietary strategies, confidential information or personal data if sensitive material is entered into systems that store or learn from prompts. Outputs may also reproduce protected content, creating intellectual‑property or confidentiality concerns. Controls reduce but cannot fully prevent data leakage or related disputes.

If AI outputs drive investment or risk decisions without robust oversight, portfolios experience unexpected exposures, unbalanced risk profiles or systematic biases that are difficult to detect in real time. Electronic Trading Risk Electronic trading platforms, direct market access, smart-order routers, algorithms and connectivity links are integral to execution. System failures, connectivity interruptions, latency spikes, mis-configured algorithms, throttling limits and exchange outages disrupt order submission, routing and confirmation. Errors in algorithm logic or parameter settings generate unintended orders, incorrect sizes or aggressive pricing that results in large trading losses and market impact. Discrepancies between simulated and live-market behaviour create slippage relative to expectations. In fragmented markets, routing or aggregation logic that under-performs in certain conditions results in inferior execution prices compared with other venues or manual trading. Social Media and Digital Communication Risk The firm, portfolio companies and other market participants operate in an environment where information spreads through social media and digital channels at high speed and with limited verification. Rumours, leaks, commentary and campaigns influence sentiment and pricing, especially for securities with high retail participation or thematic focus. For the firm itself, inappropriate or unauthorised use of social media or digital channels by employees generates regulatory, reputational and conduct risk, including non-compliance with marketing, promotion, endorsement and recordkeeping requirements. Weak governance over digital communication tools increases exposure to mis-statements, selective disclosure and brand damage.

Technological Developments and Obsolescence Risk Rapid technological change alters market structure, trading practices, data availability and the competitive landscape for issuers and for asset managers. Investment processes that fail to adapt to new technology, data sources, execution tools or risk-management methods lose competitive edge, operate less efficiently or rely on outdated assumptions. At the issuer level, technology disruption, digital competition and shifting business models eliminate incumbent advantages, compress margins and render assets obsolete faster than historic patterns.

For portfolios exposed to technology-intensive sectors or to issuers heavily dependent on specific platforms or intellectual property, these shifts translate directly into earnings risk, valuation compression and increased volatility. Technology Sector and Intellectual Property (“IP”) Risk (Technology Companies) Investments in technology companies concentrate risk in industries characterised by high competition, rapid product cycles and heavy reliance on innovation and intangible assets. Technology issuers depend on patents, copyrights, trade secrets, software, data sets and proprietary algorithms. Litigation over intellectual property, adverse judgements, injunctions or invalidations of key IP rights destroy competitive advantage and earnings potential. High research and development intensity and continuous innovation requirements elevate execution risk and failures in product development, adoption or integration result in rapid value destruction. Technology-sector valuations frequently embed ambitious growth and profitability expectations. Disappointments relative to these expectations result in rapid multiple compression and large price drawdowns. Where the firm operates technology-rich processes in certain jurisdictions with weaker IP protection or state intervention in digital industries, there is additional risk of theft, forced technology transfer or inadequate legal recourse. Third-Party and Fourth-Party Concentration Risk (Critical Outsourcing) Investment and operational processes depend on a range of external service providers, including cloud and data-centre operators, order and execution management systems, index and pricing vendors and market-data providers. Concentration among a small number of providers and reliance on their subcontractors increase vulnerability to outages, cyber events, licensing disputes or financial distress affecting those firms. Substitution may be difficult due to contractual, technical or timing constraints. Systemic or industry-wide incidents may impair trading, valuation, reconciliations or reporting and may contribute to delays, errors or losses. Oversight and contingency frameworks reduce but cannot remove these risks. Change Management and Model Drift Risk Updates to investment models, code, data pipelines, system configurations or trading infrastructure can introduce defects or unintended changes if not properly designed, tested and deployed. Data patterns and market conditions may also evolve over time, causing model drift and reducing predictive accuracy or altering risk characteristics. Weaknesses in change-management or model-governance processes can lead to errors, outages, control failures or adverse performance. Governance measures can reduce but cannot eliminate these risks given the complexity of systems and dynamic market environments. Timing of Implementation Risk Execution of investment decisions, model changes, system upgrades and strategic shifts in portfolios always occurs within specific market and operational windows. Differences across time zones, trading hours, settlement cycles and internal approval processes introduce timing risk: orders enter the market after prices move, liquidity conditions change between decision and execution or model updates go live during volatile periods rather than in controlled windows. Implementation of new systems, tools, benchmarks, products or risk frameworks generates transitional risk when old and new processes coexist. During transition, data inconsistencies, duplicated logic, temporary manual workarounds and partial adoption create elevated operational and error risk. Dependence on Key Personnel Risk Investment performance, portfolio management continuity, risk oversight and client servicing rely on individuals with specialised knowledge, judgement and experience. Departure, illness, incapacity, disengagement, internal mobility or reduced effectiveness of portfolio managers, analysts, traders, risk officers, technologists, compliance personnel or senior management introduces immediate process‑execution risk. Knowledge gaps, disrupted workflows, loss of institutional memory and reduced depth of challenge persist during transitions.

Replacement hiring requires integration time and new personnel introduce differences in judgement, execution style and risk tolerance. During these transition periods, processes perform inconsistently, error rates rise and investment outcomes diverge from expectations Force Majeure and Large-Scale Operational Disruption Risk Severe events such as natural disasters, pandemics, public-health emergencies, war, terrorism, infrastructure failures, systemic cyber incidents and large-scale power or telecommunications outages disrupt physical premises, data centres, personnel availability and critical third-party service providers. These events interrupt trading, valuation, reconciliation, reporting and oversight functions. Business-continuity arrangements reduce, but do not eliminate, performance degradation, delays and operational bottlenecks. Prolonged or severe force-majeure events create broken data chains, impaired liquidity, delayed settlement and valuation uncertainty and materially alter the risk profile of affected portfolios.

11. Sustainability and ESG-Related Risks Sustainability Risk (Overall ESG Risk) Sustainability risk arises when ESG events or conditions materially affect the value, liquidity, performance, operational profile, reputation, funding position or long-term viability of an issuer or asset. Sustainability risk manifests through physical events, transition dynamics, regulatory changes, social developments, governance failures or combinations of these factors. These risks affect revenues, operating costs, capex requirements, liabilities and ultimately valuations. ESG risks interact with all other financial risks and alter expected risk-return characteristics across asset classes. Transition Risk Transition risk arises when issuers face financial and operational impacts from the global shift to a low-carbon or more sustainable economic model. Key drivers include carbon-pricing regimes, regulatory reforms, emissions-reduction requirements, energy-efficiency mandates, changes in subsidies, changes in consumer preferences, technological disruption, litigation and competitive repositioning. Issuers exposed to carbon-intensive sectors, resource-intensive processes or outdated technologies experience higher compliance costs, stranded-asset risk, reduced demand for their products and significant capital-expenditure requirements to meet new standards. Transition risk also arises from rapid policy intervention, regulatory tightening or sudden withdrawal of state support. Physical Climate Risk Physical climate risk arises from both acute and chronic environmental conditions. Acute risks include storms, floods, wildfires, droughts and other extreme weather events. Chronic risks include rising sea levels, shifting climate patterns, heat-stress impacts, biodiversity loss and long-term resource degradation. These conditions impair asset values, disrupt operations and supply chains, damage infrastructure, reduce productivity, increase insurance costs, decrease asset-useful life and generate material financial losses. Physical risk also reduces availability of natural resources essential to certain business models.

Environmental Risk Environmental risk arises when issuers face impacts from environmental degradation, pollution, contamination, waste generation, hazardous materials, water scarcity, biodiversity loss, habitat destruction or other ecological pressures. Operational disruptions, remediation obligations, regulatory sanctions, liability claims, resource-access constraints and increased compliance requirements all impair issuer performance and valuations. Environmental performance directly affects capital costs, customer relationships and licence-to-operate conditions for affected issuers.

Social Risk Social risks arise from factors related to labour practices, workforce safety, human rights, supply-chain conditions, diversity and inclusion, community impact, customer welfare, data privacy and social licence to operate. Issuers with weak labour standards, unsafe conditions or exposure to forced labour or other human-rights risks face operational shutdowns, litigation, lost contracts, fines, reputational damage and higher operating costs. Social risks also arise from public-health developments, demographic changes, inequality and changes in consumer or regulatory expectations. Governance Risk Governance risk arises when issuers exhibit inadequate governance structures, ineffective or conflicted boards, poor controls, weak oversight, poor audit quality, aggressive accounting practices, corruption, bribery exposure or failures of ethical conduct. Governance weaknesses drive financial mis-statements, operational failures, insider conflicts, regulatory sanctions, litigation and loss of investor confidence. Governance failures amplify the impact of all other ESG risks and undermine execution of strategy and capital allocation. ESG Definition, Data and Methodology Risk Definitions of ESG, sustainability and responsible-investment criteria differ significantly across market participants, data providers, regulators and issuers. No universal standard exists across jurisdictions or data vendors. ESG data is inconsistent, incomplete, unaudited and subject to methodological divergence. Third-party ESG scores, classifications, ratings and assessments differ materially, often producing conflicting outputs for the same issuer. ESG models depend on subjective assumptions, qualitative inputs, inconsistent disclosure, backward-looking information and estimation approaches. This creates:

classification risk (incorrect inclusion or exclusion of securities),

assessment risk (incorrect evaluations of issuer ESG characteristics),

timing risk (lag between events and ESG-data updates), and

comparability risk (inability to compare across issuers or geographies).

These characteristics influence portfolio construction, screening decisions, risk assessments and reporting. ESG Investment Return Risk Portfolios that implement ESG or sustainability strategies accept the risk that ESG alignment does not improve, preserve or optimise returns relative to strategies without ESG constraints. ESG strategies often exclude sectors, issuers or opportunities based on screening criteria or thematic definitions. These exclusions reduce diversification, alter factor exposures, reduce opportunity sets and generate differences in sector, style or geographic exposures relative to unconstrained strategies. ESG investing also results in performance divergences when market conditions favour securities or sectors that fail ESG screens. Thematic or impact-oriented ESG strategies rely on specific developmental, regulatory or industry shifts; when these shifts underperform expectations, such strategies experience weaker performance. ESG Public Sector Subsidy / Funding Risk Some environmental and social projects, renewable-energy investments, climate-transition assets and impact-oriented instruments depend on government subsidies, tax incentives, grants or sector-specific state support. If authorities withdraw, reduce or redesign subsidy programmes, funding flows or policy support structures, project economics deteriorate and expected returns fall.

Changes in political priorities or fiscal pressure lead directly to financial loss for investors exposed to assets dependent on transition-policy support. Sustainability-Linked Policy, Regulatory & Disclosure Risk Global sustainability regulation continues to evolve rapidly. Portfolios and issuers are subject to diverse regimes, including:

EU Sustainable Finance Disclosure Regulation (SFDR),

UK SDR,

US SEC ESG-related disclosure expectations,

local stewardship codes,

sustainability taxonomy frameworks, and

climate-reporting obligations.

Divergent regimes create compliance complexity, reporting burdens and operational risk. Changes to classification rules, definitions, reporting thresholds or regulatory scrutiny alter costs, required disclosures, constraints and strategy positioning. Inaccurate or incomplete ESG disclosures expose investment managers to regulatory review, enforcement, litigation, reputational risk and forced reclassification of strategies. Interaction of ESG Risks with Broader Financial Risks ESG risks amplify traditional market, credit, operational, legal and liquidity risks. Transition policies alter demand, margins and creditworthiness. Physical risks disrupt operations, impair assets and increase financing costs. Social and governance failures trigger credit stress, litigation, operational failures and reputational damage. As ESG and financial risks interact, ESG risk is integrated into investment, issuer due-diligence, monitoring, valuation and risk-management processes.

12. Legal, Regulatory and Tax Risks Legal and Regulatory Risk Investment, risk-management and distribution activities all sit within legal and regulatory frameworks at local, regional and international levels. Laws, regulations, case law, supervisory guidance, exchange rules and self-regulatory standards change over time and often without long transition periods. These changes alter what strategies are permissible, how they operate, what disclosures are required and the cost and complexity of compliance. Uncertainty in the interpretation or application of laws, regulations, contracts and constitutional documents gives rise to legal and regulatory risk. Differences in interpretation between regulators, courts, auditors, tax authorities and market participants result in unexpected obligations, restrictions or liabilities. Complex products, cross-border structures, novel market practices and evolving technologies (including derivatives, AI and digital tools) sit under particular legal and regulatory scrutiny. Supervisory authorities conduct thematic reviews, inspections and enforcement actions. Findings result in remedial programmes, redress exercises, restrictions on certain activities, increased capital or liquidity requirements, changes to product terms and higher compliance and reporting costs. Global reforms such as post-crisis derivatives regulation, benchmark reform, bank-capital rules and cross-border marketing regimes already reshaped and continue to reshape, the product and strategy set. Where portfolios invest in regulated sectors (for example financial services, utilities, telecoms, healthcare, defence or technology), sector-specific rules, licensing regimes, conduct obligations and political sensitivities generate additional regulatory event risk at issuer level. Regulatory intervention in these sectors leads to abrupt earnings and valuation adjustments. Litigation, Disputes and Enforcement Risk

The firm, its affiliates, its funds and client accounts are exposed to litigation, arbitration, regulatory investigations and other dispute processes. Sources include:

investor or client complaints and claims;

counterparty and trading disputes;

portfolio-company, issuer or borrower claims;

employment, data-protection and IP-related matters; and

actions brought or supported by regulators or other authorities.

Legal proceedings generate legal costs, settlement payments, adverse judgments, management distraction, disclosure obligations and reputational consequences. Outcomes depend on court decisions, factual findings, expert evidence and evolving legal doctrines. Even where outcomes are favourable, defence and management-time costs are significant. At portfolio level, litigation and regulatory action involving issuers, borrowers, sponsors or intermediaries affect valuations, recovery prospects and timing of cash flows, particularly in credit, real-asset, private-market and distressed strategies. Outsourcing / Third-Party Oversight Compliance Risk Material functions may be outsourced to external service providers or sub-advisers, subject to oversight obligations under applicable law. Failures by these providers to perform in line with contractual, regulatory or policy requirements can cause operational disruption, regulatory breaches, financial loss or reputational harm. Cross-border arrangements may add complexity due to differing legal regimes and data-handling requirements. Monitoring, due diligence and contractual controls help manage but cannot eliminate the possibility of service provider failures. ERISA Plan Asset and Pay-to-Play (Political Contributions) Risk Accounts subject to ERISA or similar laws may be affected by rules governing plan-asset status, fiduciary duties and prohibited transactions. Misclassification or non-compliance may result in penalties, excise taxes or required transaction unwinds. Separately, political contribution rules may restrict the ability to receive compensation from certain government entities for a period of time following contributions by covered associates. These restrictions apply regardless of intent and may affect account eligibility or compensation. Monitoring and controls reduce but do not eliminate compliance risk. Cross-Border Personal Data Transfer Risk Transfers of personal data across borders are subject to evolving legal requirements and enforcement expectations. Mechanisms such as standard contractual clauses, adequacy decisions or localisation mandates may be required and authorities may suspend transfers or impose remedial measures. Restrictions or investigations may disrupt vendor arrangements, delay operational processes, increase costs or necessitate changes to systems. Non-compliance may result in fines or regulatory orders. Safeguards can mitigate but cannot remove all risks associated with cross-border data transfers.

Cross-Border and Extraterritorial Regulation Risk Many strategies invest globally and serve clients in multiple jurisdictions. Cross-border activities bring portfolios and the firm within scope of overlapping and sometimes conflicting regulatory regimes, including those with extraterritorial effect (for example US, EU or UK rules applied to non-local activities). Key elements include:

marketing and private-placement rules for funds and mandates;

cross-border derivatives, trading and clearing requirements;

sanctions and export-control regimes;

data-protection and outsourcing rules; and

local substance and governance requirements for certain vehicles.

Compliance in this environment requires multiple sets of registrations, notifications, local representatives, reporting obligations, documentation standards and product adaptations. Failure to comply results in fines, investor remediation, loss of passporting or marketing rights or forced restructuring of products and operations. At the portfolio level, issuers operating across many jurisdictions face similar overlapping constraints. Regulatory changes or enforcement in any one material jurisdiction alter profitability, capital structures, investment plans and strategic options. Contractual and Documentation Risk Investment activity depends on a network of contracts: fund offering documents and partnership agreements, investment-management agreements, ISDA and Credit Support Annex (“CSA”) documents, brokerage and custody agreements, financing documents, security and collateral arrangements, shareholder agreements, subscription and side-letter terms. Ambiguous drafting, gaps, inconsistent definitions, mis-aligned commercial expectations or weak enforcement provisions all create risk. In stress or dispute scenarios, counterparties rely on contractual language to allocate losses, margin, collateral, rights of termination, step-in and control. Outcomes differ materially from expectations when contracts are interpreted differently by courts, when documentation fails to reflect commercial intent or when certain protections are missing or unenforceable under local law. For private-market transactions, credit agreements, shareholder agreements and inter-creditor deeds define rights in restructurings, defaults and exits. Covenant-lite loans, permissive baskets, complex EBITDA adjustments and weak security regimes reduce creditor protection and impair recovery outcomes. Tax Risk Tax rules affect investors, funds, mandates, portfolio companies and investment structures. Tax regimes evolve in response to policy priorities, fiscal pressures and international initiatives (including base erosion and profit shifting, global minimum tax and transparency frameworks). Changes in tax rates, deductibility rules, loss-relief rules, withholding regimes, value added tax/sales-tax treatment and investor-level rules alter net returns and after-tax performance. Key components of tax risk include:

Regime and Rule-Change Risk: Legislatures and tax authorities introduce or reinterpret rules at short notice, often with retroactive effect or limited grandfathering. These actions change the tax profile of existing investments, structures and instruments and influence the location and design of new products.

Withholding, Reclaim and Relief-at-Source Risk: Cross-border investments are subject to withholding taxes on dividends, interest and other income. Relief depends on treaty networks, documentation, local processing rules and administrative capacity. Failures in documentation, monitoring or reclaim processes result in over-withholding that is not recovered, directly reducing returns.

Fund, Mandate and Investor-Level Structuring Risk: The tax treatment of a fund or mandate depends on its legal form, jurisdiction, investor base, asset mix and elections. Errors or mis-alignment between structure and investor needs result in tax leakage, loss of exempt status or unintended taxable events at fund or investor level. For tax-advantaged investors, failure to maintain required characteristics (such as diversification, income-distribution or holding-period conditions) creates additional liabilities.

Operational and Reporting Risk: Complex global operations require accurate tax classification of instruments, transactions and counterparties and timely reporting under multiple regimes (including Foreign Account Tax Compliance Act (“FATCA”), Common Reporting Standard (“CRS”), Mandatory Disclosure Regime in the EU (“DAC6”) and local equivalents). Weaknesses in data, systems, process design or oversight result in incorrect tax reporting, penalties, interest charges and remediation programmes.

Portfolio-Company and Transaction-Level Tax Risk:For private equity, private credit and real-asset strategies, portfolio-company tax positions influence exit proceeds and cash-flow projections. Aggressive

historic tax structures, unresolved enquiries, inadequate provisioning and changes in local interpretation of incentives or reliefs all affect valuation, recoveries and distribution profiles. Interaction of Legal, Regulatory and Tax Risks with Investment Performance Legal, regulatory and tax environments form part of the economic context for all investment strategies. Regulatory reforms alter permissible activities, costs and constraints; legal rulings reshape contractual expectations; tax changes reposition net returns and capital-flow incentives. These elements interact with market and credit risks:

by changing issuer profitability and capital structures;

by influencing trading behaviour and liquidity;

by altering which products and strategies remain viable; and

by driving costs and complexity in compliance, reporting and product design.

Portfolios that ignore these dimensions at the structuring, due-diligence and monitoring stages face unanticipated performance erosion, disrupted strategies and increased operational burden.

C. Material Risks of Securities Primarily Recommended The SEC Pictet AM Firms do not recommend primarily a single type of security across all client accounts and strategies. Portfolios may invest in a range of instruments, including equity and equity-like securities, fixed income and credit instruments, structured finance securities, derivatives, collective investment vehicles, real assets and commodity-linked instruments, depending on the strategy and client mandate. The material risks associated with these instruments are described in the “Risk of Loss and Material Risks” section above, including where particular securities or structures involve significant or unusual risks. Not all strategies use all types of securities described in that section and the relevance and severity of a given risk will vary according to the specific instruments held, the way a strategy is implemented and the client’s circumstances.

B. Futures / Commodities Registration CFTC Registration Status None of the SEC Pictet AM Firms is registered with the CFTC as a Futures Commission Merchant, Commodity Pool Operator or Commodity Trading Advisor or as an associated person of any of these categories. NFA Exemptions Each of the below SEC Pictet AM Firms is recorded with the National Futures Association in the following exempt categories:

Pictet AM SA: Exempt Commodity Pool Operator and Exempt Commodity Trading Advisor.

Pictet AM Ltd: Exempt Commodity Pool Operator and Exempt Commodity Trading Advisor.

Pictet AM Singapore: Exempt Commodity Pool Operator and Exempt Commodity Trading Advisor.

C. Material Relationships or Arrangements with Related Persons Below is the description of any relationship or arrangement that is material to the SEC Pictet AM Firms’ advisory business or to their clients and that the SEC Pictet AM Firms have with any related affiliates listed below. Where such relationship or arrangement creates a material conflict of interest with clients, the nature of the conflict and the related controls are set out either in:

For the Investment Company / Other Pooled Investment Vehicles within their description in point 2 below. For all the other relationships and arrangements, at the end of this item.

1.

Broker-Dealer Affiliates

Banque Pictet & Cie SA (“Banque Pictet SA”) Banque Pictet SA is a Switzerland based licensed bank and broker-dealer with FINMA and is a related person of each of the SEC Pictet AM Firms. Activities include:

Asset management and custodial services.

Broker-dealer services for non-U.S. client accounts on a limited basis when instructed by the SEC Pictet AM Firms (clients may request not to use Banque Pictet SA).

Referrals or delegations of clients to the SEC Pictet AM Firms.

Provision of general research information and certain administrative, support and IT services to the SEC Pictet AM Firms.

Joint ESG engagement with Pictet Wealth Management for a limited number of companies (holdings shared only between relevant ESG teams).

Bank Pictet & Cie (Europe) AG (“BPAG”) BPAG is a Germany based BAFIN-licensed bank and is a related person of the SEC Pictet AM Firms. BPAG acts as custodian for Luxembourg UCITS funds managed by the SEC Pictet AM Firms and as a broker for the SEC Pictet AM Firms.

2.

Investment Company / Other Pooled Investment Vehicles

U.S. ETFs advised by Pictet AM SA, Pictet AM Ltd and Pictet AM USA(“U.S. ETFs”) Pictet AM SA, Pictet AM Ltd and Pictet AM USA are investment advisers to the U.S. ETFs which are registered investment companies. The U.S. ETFs are the only in-house funds offered to U.S. investors where the relevant SEC Pictet AM Firm, acts as manager. The relevant SEC Pictet AM Firm receives a management fee from each U.S. ETFs. This relationship creates a material conflict with clients whereby there are side-by-side management conflicts between the U.S. ETFs and other relevant SEC Pictet AM Firm clients (such as allocation of investment ideas and trades). The controls in place to address this conflict are:

The side-by-side management controls described in Item 6.

The application of the same due diligence, fairness and conflict management standards to the U.S. ETFs as to other clients.

Luxembourg mutual funds where Pictet Asset Management (Europe) SA (“Pictet AM Europe”) is the Management Company Pictet AM Europe is the Management Company of Pictet AM Luxembourg mutual funds, which are not marketed or targeted to U.S. clients (except to U.S. based intermediaries and wealth managers for distribution to offshore clients). Pictet AM Europe delegates investment management of several Pictet Group Luxembourg mutual funds to the SEC Pictet AM Firms. This relationship creates a material conflict with clients whereby there are incentives to favour these funds when allocating opportunities. The controls in place to address this conflict are:

Delegation arrangements are subject to regulatory and internal oversight.

The side-by-side management controls described in Item 6.

The application of the same due diligence, fairness and conflict management standards to the Pictet Group Luxembourg mutual funds as to other clients.

Swiss mutual funds where Pictet AM SA is the Management Company Pictet AM SA is the Management Company of Pictet AM Swiss mutual funds, which are neither marketed nor targeted to U.S. clients. Pictet AM SA delegates investment management of several Swiss funds to Pictet AM Ltd. This relationship creates a material conflict with clients whereby there are incentives to favour these funds when allocating opportunities. The controls in place to address this conflict are:

Delegation arrangements are subject to regulatory and internal oversight.

The side-by-side management controls described in Item 6.

The application of the same due diligence, fairness and conflict management standards to the Pictet Group Luxembourg mutual funds as to other clients.

3.

Other Investment Adviser affiliates

Pictet Alternative Advisors SA (“PAA SA”) Pictet Alternative Advisors (“PAA”) is the dedicated alternative investment advisory division of the Pictet Group. PAA SA is an authorised asset manager under FINMA in Switzerland and an exempt reporting adviser with the SEC. PAA SA is an affiliate of the SEC Pictet AM Firms. PAA SA undertakes the following activities:

Permitting SEC Pictet AM Firms to promote certain PAA SA-managed private funds on a private offering basis to accredited investors as defined in Rule 501(a) of Regulation D promulgated under the Securities Act. Structuring and oversight of alternative investment vehicles. Operation of a Thematic Expert Board for certain thematic private equity co-investment and multi-strategy funds which are not offered to US investors and on which selected Pictet AM SA’s Thematic Strategies team serve.

Pictet Alternative Advisors (UK) Ltd (“PAA UK”) PAA UK is United Kingdom based and authorised and regulated by the FCA and is registered as an exempt reporting adviser with the SEC. PAA UK is an affiliate of the SEC Pictet AM Firms. PAA UK undertakes the following activity:

Permitting SEC Pictet AM Firms to promote certain PAA UK-managed private funds on a private offering basis to accredited investors as defined in Rule 501(a) of Regulation D promulgated under the Securities Act.

Pictet North America Advisors SA (“PNAA”) PNAA is Swiss based and regulated by FINMA and registered as an investment adviser with the SEC. PNAA is an affiliate of Pictet AM SA, Pictet AM Ltd and Pictet AM USA. PNAA undertakes the following activities:

Receipt and use of generic thematic portfolio models from Pictet AM SA in the discretionary management of segregated accounts for U.S. clients. Leverages the U.S. ETFs managed by Pictet AM SA, Pictet AM Ltd and Pictet AM USA that PNAA can place in the discretionary portfolio management of its clients or propose to clients with advisory mandate.

Pictet AM Ltd Pictet AM Ltd is a United Kingdom based investment adviser authorised and regulated by the FCA and is registered as an investment adviser with the SEC. Pictet AM Ltd is an affiliate of the other SEC Pictet AM Firms. Pictet AM Ltd undertakes the following activities:

Management of a broad range of equity, fixed income and multi-asset strategies, including total return strategies for institutional clients and pooled vehicles. Delegation of all or part of client accounts to and from other Pictet AM entities. Non-U.S. client referrals to and from the Pictet Group to access specific strategies. U.S. client referrals from Pictet AM USA. Promotion of certain PAA private funds on a private placement basis. Joint business development (including with Pictet AM USA in the U.S.). Provision of centralised trading desk services for non-Asian markets. Offering of U.S. ETFs for discretionary and advisory mandates. Sharing of internally produced investment research. Receipt of investment advisory services for Japanese Equities.

Pictet AM SA Pictet AM SA is a Swiss based investment adviser regulated by FINMA and is registered as an investment adviser with the SEC. Pictet AM SA is an affiliate of the other SEC Pictet AM Firms. Pictet AM SA undertakes the following activities:

Management of a broad range of equity, fixed income and multi asset strategies, including total return strategies for institutional clients and pooled vehicles. Shared management of certain equity, fixed income and multi asset strategies with other Pictet AM entities. Non-U.S. client referrals to and from the Pictet Group to access specific strategies. U.S. client referrals from Pictet AM USA. Promotion of certain PAA private funds on a private placement basis. Delegation of portfolio management to and from other Pictet AM entities. Provision of trading desk services for non-Asian total return equity and fixed income strategies. Provision of model portfolios for use by PNAA. Offering of U.S. ETFs for discretionary and advisory mandates. Sharing of internally produced investment research.

Pictet AM Singapore Pictet AM Singapore is a Singapore based investment adviser regulated by MAS and is registered as an investment adviser with the SEC. Pictet AM Singapore is an affiliate of the other SEC Pictet AM Firms. Pictet AM Singapore undertakes the following activities:

Management of emerging markets fixed income and equity total return strategies for institutional clients and pooled vehicles. Operation of an Asia-focused trading desk executing or placing orders in Asian fixed income markets. Referrals of clients to PAA entities for access to alternative strategies. Promotion of certain PAA private funds on a private placement basis. Provision of investment advisory services within Pictet AM’s Emerging Market Fixed Income platform. Receipt of delegated portfolio management from other Pictet AM entities. Use of Pictet AM Ltd and Pictet AM SA trading desks for non-Asian securities. Sharing of internally produced investment research.

Pictet Asset Management (Hong Kong) Ltd (“Pictet AM Hong Kong”) Pictet AM Hong Kong is Hong Kong based and regulated by the Securities & Futures Commission. Pictet AM Hong Kong is an affiliate of the SEC Pictet AM Firms. Pictet AM Hong Kong undertakes the following activities:

Provision of investment advisory and portfolio management services in Asian and emerging market equity and fixed income strategies for non-U.S. institutional clients and pooled vehicles. Management of Hong Kong-domiciled funds and offshore hedge funds not offered to U.S. investors. Receipt and provision of delegated portfolio management for hedge fund and long-only strategies within Pictet AM. Operation of an Asia equity trading desk placing orders for Pictet AM entities. Sharing of internally produced investment research.

Pictet Asset Management (Japan) Ltd (“Pictet AM Japan”) Pictet AM Japan is a Japan based and regulated by Financial Services Agency. Pictet AM Japan is an affiliate of the SEC Pictet AM Firms.

Pictet AM Japan undertakes the following activities:

Management and distribution of Japanese domestic funds for local investors. Provision of an Asia equity trading desk placing orders in Japanese and certain regional equity instruments for other Pictet AM entities. Provision of investment advisory services for Japanese Equities to Pictet AM Ltd. Sharing of internally produced investment research. Receipt and referral of clients for strategies managed by Pictet AM SA and Pictet AM Ltd.

Pictet AM Europe Pictet AM Europe is Luxembourg based and regulated by the Commission de Surveillance du Secteur Financier (“CSSF”) and exempt registered adviser with the SEC. Pictet AM Europe is an affiliate of the SEC Pictet AM Firms. Pictet AM Europe undertakes the following activities:

Acting as management company for Pictet AM Luxembourg mutual funds (including oversight of governance, risk management and distribution arrangements). Delegation of investment management of several funds to SEC Pictet AM Firms and other Pictet AM entities. Provision of private assets and hedge fund solutions aimed at U.S.-based intermediaries and institutional investors.

Pictet AM USA Pictet AM USA is a U.S. based investment advisor and registered with the SEC Pictet AM USA is an affiliate of the other SEC Pictet AM Firms. Pictet AM USA undertakes the following activities:

4.

Business development and marketing of Pictet AM strategies to U.S. institutional and intermediary clients. Client servicing and relationship management for U.S. clients primarily managed by Pictet AM SA. Provision of investment advisory services within the Emerging Market Fixed Income platform. Referrals of potential investors to PAA entities for alternative strategies. Offering of U.S. ETFs for discretionary and advisory mandates. Promotion of certain PAA private funds on a private offering basis to eligible U.S. investors.

Futures Commission Merchant (“FCM”) / Commodity Pool Operator (“CPO”) / Commodity Trading Adviser (“CTA”)

There are no SEC Pictet AM Firm affiliates that act as an FCM, CPO or CTA beyond the exempt status of Pictet AM SA, Pictet AM Ltd and Pictet AM Singapore, as disclosed above.

5.

Banking or Thrift Institution

Banking relationships are disclosed under Banque Pictet SA and BPAG above. No additional banking or thrift institution relationships are identified in relation to the SEC Pictet AM Firms.

6.

to 11. Other related persons

No material relationships or arrangements with accountants, lawyers, insurance companies, pension consultants, real estate brokers or sponsors/syndicators of limited partnerships.

D. Recommendation or Selection of Other Investment Advisers Unaffiliated Investment Advisers The SEC Pictet AM Firms do not recommend or select unaffiliated investment advisers for their U.S. clients. Delegation and sub-advisory relationships exist only within the Pictet AM Group as described above. Compensation for Internal Referrals Pictet AM USA receives a fee from the other SEC Pictet AM Firms for mandates that it solicits. Pictet AM SA, Pictet AM Ltd and Pictet AM Singapore do not pay or receive referral compensation for U.S. client referrals other than the fee paid to Pictet AM USA for such mandate.

Material conflicts of interest with the above identified affiliates of the SEC Pictet AM Firms and how they are addressed The material conflicts, arising from our business relationships with above affiliated entities, are set out below, together with details of how they are managed.

The execution of orders by affiliated brokers The SEC Pictet AM Firms may use the broker-dealer services of Pictet Group brokers on a limited basis for nonUS client accounts. This relationship creates a material conflict with clients whereby there is an economic incentive to route trades and custody to the affiliated bank/broker. The controls in place to address this conflict are:

The use of Pictet Group brokers is limited and clients have the right to instruct that the relevant Pictet Group broker is not used. The Pictet AM best execution policy applies to any transactions meaning Pictet Group brokers charge commissions and spreads at arm’s-length levels. Pictet AM monitors trade-execution quality and commission levels in relation to Pictet Group brokers.

The appointment of affiliated custodians There is no material conflict between affiliated custodians and the SEC Pictet AM Firms because the client appoints the custodian.

The use of Pictet AM Group affiliates to place orders for securities The SEC Pictet AM Firms can direct client orders to other Pictet AM trading desks for order placing. This relationship creates material conflicts with clients whereby there are incentives to favour:

One SEC Pictet AM Firm’s managed accounts over another’s managed accounts when allocating opportunities Pictet AM trading desks for order placing in order to increase Pictet AM revenues.

The controls in place to address these conflicts are:

The side-by-side management controls described in Item 6.

Where one of the SEC Pictet AM Firms directs client orders to other Pictet AM trading desks for order placing, these trades must be executed in accordance with the Pictet AM best execution policy.

There is regular monitoring of adherence to the Pictet AM best execution policy for the ordered executed by Pictet AM trading desks.

All Pictet AM entities act solely as agent and do not charge any commission or mark-up additional to that charged by the executing broker.

The Pictet AM Group trading desks execute orders or place orders for execution only for its advisory clients.

The potential sharing or leakage of sensitive information relating to clients, their investments and their trading activities to affiliates. All Pictet AM companies have robust “Information Barriers” in place to mitigate and reduce potential conflicts arising from the risk of disclosing confidential information to another Pictet Group entity or its staff:

With the Pictet Group, the following controls are in place: o

Physical access controls restricting access to Pictet AM premises only to Pictet AM staff.

o

Restricting investment department systems’ access to sensitive investment management and trading information to the relevant investment teams only.

o

The use by Pictet AM of separate systems for portfolio management, trading and investment accounting from the rest of the Pictet Group, with strict controls in place to prevent any access by nonPictet AM staff to Pictet AM systems.

o

There are no shared employees between Pictet AM and the rest of the Pictet Group who carry out activities of portfolio management, operations or trading for Pictet AM and other parts of the Pictet Group.

Amongst the Pictet AM entities, controls are in place restricting investment department systems’ access to sensitive investment management and trading information to the relevant investment teams only.

Referrals of clients to / from other Pictet Group entities Clients may be referred to / from the SEC Pictet AM Firms by other Pictet Group entities. This relationship creates a material conflict with clients whereby there is an incentive to increase Pictet AM revenues. The controls in place to address this conflict are:

The SEC Pictet AM Firms do not make or receive any payments for U.S. client referrals, except that Pictet AM USA receives a fee from the other SEC Pictet AM Firms for any U.S. mandates that Pictet AM U.S. has solicited on their behalf.

Other mitigation controls within Pictet AM In addition to the mitigation controls listed above, the following mitigation controls also apply within Pictet AM: • Compliance activities of the Pictet AM group are supervised by the Pictet AM Global Chief Compliance Officer

to ensure that relevant policies (including the Pictet AM Code of Ethics and Core Compliance Charter) are applied to the Pictet AM entities providing key services to the SEC Pictet AM Firms. • These policies set the required high professional standards of behaviour that all Pictet AM staff are expected to

follow in the conduct of their personal and professional affairs in compliance with the SEC rules and those of the other regulators to whom the Pictet AM entities are subject. • There is also a risk-based compliance monitoring programme in place that is reasonably designed to ensure

that the activities carried out by related entities to the SEC Pictet AM Firms are performed in compliance with all relevant rules and regulations including those of the U.S.

Recommendation or Selection of Other Investment Advisers The SEC Pictet AM Firms do not recommend or select unaffiliated investment advisers for their U.S. clients. Delegation and sub-advisory relationships exist only within the Pictet AM Group as described above.

Compensation for internal referrals

Pictet AM USA receives a fee from the other SEC Pictet AM Firms for mandates that it solicits.

Pictet AM SA, Pictet AM Ltd and Pictet AM Singapore do not pay or receive referral compensation for U.S. client referrals other than the fee paid to Pictet AM USA for such mandates.

Officers, directors and employees within SEC Pictet AM Firms are permitted, subject to the Code and applicable law, to trade for their own accounts in securities that the SEC Pictet AM Firms recommend to and/or purchases for clients. These situations create potential conflicts of interest because employees could have the opportunity or incentive to benefit from knowledge of client orders, to trade ahead of client transactions or otherwise to obtain more favourable terms than clients. The Code is designed to mitigate these conflicts and to ensure that such personal activity does not interfere with making or implementing decisions in the best interests of clients. Clients and prospective clients can obtain a copy of the Code by contacting Robert Henderson, Global Pictet AM Chief Compliance Officer, at +44 207 847 5000 or pam_core_compliance@pictet.com.

B. Personal Securities Transactions Employee personal trading is subject to preclearance for most transactions and restrictions on trading in close proximity to client trading activity. Personal trading is monitored on a daily basis by the Pictet AM Business Ethics team to manage potential conflicts between the SEC Pictet AM Firms, their staff and clients. Without appropriate controls, personal trading in the same or related securities as clients could result in front running, trading ahead of clients or unequal treatment between employee and client accounts. The preclearance requirements, trading window restrictions, reporting obligations and daily monitoring are designed to mitigate these conflicts and to help ensure that client interests are placed ahead of officers, directors and employees’ personal interests. In addition, employees must report all brokerage and trading accounts to the Pictet AM Business Ethics team upon joining and must provide:

an annual report of holdings; and

a quarterly report of trading activity.

C. Insider Trading Policy and Information Barriers The SEC Pictet AM Firms maintain policies, procedures and controls to prevent misuse of material non-public information. These include: • physical access controls; • system entitlements that restrict access to sensitive investment management and trading information to the

relevant teams; • separate portfolio management, trading and investment accounting systems within SEC Pictet AM Firms; and

• the absence of shared employees performing portfolio management, operations or trading across SEC Pictet

AM Firms and other Pictet Group entities. Trading in securities issued by clients or their affiliates is subject to monitoring to help ensure consistency with procedures for the management of inside information. Additional details in relation to the management of conflicts related to information barriers are set out in Item 10.

D. Participation in Client Transactions SEC Pictet AM Firms do not undertake proprietary investment and other Pictet Group entities do not conduct proprietary investment on behalf of any SEC Pictet AM Firms. Certain Pictet Group entities outside SEC Pictet AM Firms can trade for their own accounts in securities that SEC Pictet AM Firms can buy or sell for clients. These arrangements create potential conflicts of interest, including incentives to favour securities or investment vehicles in which SEC Pictet AM Firms or their affiliates have an interest or to allocate investment opportunities unevenly between proprietary and client accounts. SEC Pictet AM Firms’ information barriers are designed to prevent access by those entities to SEC Pictet AM Firm clients’ orders, transactions or positions. The SEC Pictet AM Firms are permitted to recommend or purchase, for client accounts, securities or investment products in which the SEC Pictet AM Firms, their affiliates or other related persons have a financial interest (for example, as investment manager, general partner or co-investor) but only if authorised by the client. These arrangements present conflicts of interest, including an incentive to favour affiliated products or positions over comparable third party alternatives. The SEC Pictet AM Firms address these conflicts through client authorisation requirements, product approval and due diligence processes, information barrier arrangements, allocation and best execution policies and ongoing compliance monitoring. Where permitted by applicable regulation and when in the best interests of both clients, the SEC Pictet AM Firms can facilitate the crossing of securities between client accounts via external brokers at an independently determined market price, usually at lower-than-normal broker commissions. The SEC Pictet AM Firms receive no fees for such cross transactions. ERISA plan clients and U.S. registered investment companies under the Investment Company Act of 1940 cannot participate in cross trades.

In addition to this counterparty risk assessment, when selecting or recommending broker-dealers for client transactions, the SEC Pictet AM Firms consider a range of execution-related factors including but not limited to the broker’s:

commission rates and spreads

execution price and overall cost of the transaction

ability to handle the size, type and complexity of the order

speed and likelihood of execution and settlement

responsiveness and quality of order handling

provision of research and other services (where permitted by law and regulation)

The SEC Pictet AM Firms seek to obtain over time and on a consistent basis the best overall result for clients which is not necessarily the lowest possible commission rate for each individual transaction. In assessing the reasonableness of a broker’s compensation (such as commissions or spreads), the SEC Pictet AM Firms consider the totality of the services and execution quality provided to client accounts. Use of Affiliated Brokers The SEC Pictet AM Firms use affiliated brokers on a limited basis. Affiliates are not paid more than standard commission rates or standard spreads for securities executed net of commission. Clients can instruct an SEC Pictet AM Firm not to use affiliates to execute orders for their accounts. Where affiliated brokers are part of the Pictet Group, the SEC Pictet AM Firms have an economic interest in their success. This creates a conflict of interest as the SEC Pictet AM Firms have an incentive to route client orders to affiliated brokers rather than to unaffiliated brokers that might otherwise be available. The SEC Pictet AM Firms seek to manage this conflict through their best execution processes and oversight, including monitoring execution quality and pricing for affiliated brokers against comparable unaffiliated brokers and permitting clients to opt out of the use of affiliated brokers. Best Execution The SEC Pictet AM Firms follow their Best Execution Policy to ensure that client trades achieve the best possible result on a consistent basis. The effectiveness of the policy and execution arrangements are reviewed, including assessment of whether execution venues continue to produce the best results for clients. The policy is reviewed at least annually and upon material changes. Oversight is performed by the Pictet AM Trade Execution Committees for Equities and Fixed Income and monitored by traders and Compliance.

1.

Research and Other Soft Dollar Benefits a.

Use of client commissions for research and who pays for research

All research used for the benefit of multi-asset and fixed income strategies managed by the SEC Pictet AM Firms is paid for from the relevant SEC Pictet AM Firm’s own profit and loss account. For equity strategies, the SEC Pictet AM Firms consume research received from a variety of external sources including brokers and third-party independent research providers (“external research”). In accordance with applicable laws and its fiduciary obligations, the SEC Pictet AM Firms can use a percentage of client dealing commissions to pay for external equity research where it assists in the investment decision-making process of its investment managers. b. Benefit to the firm and conflict of interest When the SEC Pictet AM Firms use client brokerage commissions to obtain research or other eligible services, the SEC Pictet AM Firms receive a benefit because they do not have to produce or pay for this research or these services from their own resources. This creates a conflict of interest because the SEC Pictet AM Firms have an incentive to select or recommend brokers based in part on the research or other services they provide rather than solely on clients’ interest in receiving the most favourable execution of their transactions. c.

Paying-up (higher commissions or spreads)

The SEC Pictet AM Firms’ equity trades are unbundled. Where permitted by law and the client, research commission is collected alongside the cost of execution via Commission Sharing Agreement (“CSA”) or Research Payment Account (“RPA”) brokers and trades with non-CSA/ non-RPA brokers are on execution-only rates. In all cases, the provision of external research will be dependent on the ability of the SEC Pictet AM Firms to fulfil their best execution obligations to clients as well as their obligations under section 28(e) of the Securities and Exchange Act of 1934 (“Section 28(e)”) and internal criteria. In certain circumstances, the SEC Pictet AM Firms can cause clients to pay commissions or spreads that are higher than those that might otherwise be available from other brokers in recognition of the value of research or other eligible services provided consistent with Section 28(e) and applicable law. d. Which accounts benefit and allocation of research and soft dollar benefits Soft dollar benefits funded by client dealing commissions are generally used to support the investment decision making of the relevant equity investment teams and not all client accounts that generate research commissions will necessarily benefit to the same extent from the research obtained. The SEC Pictet AM Firms do not seek to allocate soft dollar benefits strictly in proportion to the commissions generated by each individual client account. This creates a potential conflict of interest that the SEC Pictet AM Firms seek to manage through their governance, budgeting and oversight processes including the Pictet AM Research Committee. e.

Types of products and services obtained

Examples of the research services that the SEC Pictet AM Firms use are: • Macroeconomic forecasting • Market analysis and forecasting • Sector analysis • Stock analysis • Quantitative research • Thematic research

f.

Governance, budgeting and procedures for research and other soft dollar use

External research is obtained from brokers and independent research providers and can be funded by client commissions on condition that the material or services provided they are “eligible research” meaning such research: • concerns one or several financial instruments or other assets;

• concerns the issuers or potential issuers of financial instruments; or • is closely related to a specific industry or market such that it informs views on financial instruments, assets or

issuers within that sector, and which explicitly or implicitly recommends or suggests an investment strategy and provides a substantiated opinion as to the present or future value or price of such instruments or assets or otherwise contains analysis and original insights and reach conclusions based on new or existing information that could be used to inform an investment strategy and be relevant and capable of adding value to the SEC Pictet AM Firm’s decisions on behalf of clients. Research is bought for the benefit of clients of the SEC Pictet AM Firms by the managers and analysts responsible for a defined set of products and portfolios. A budget is calculated for each team using the Pictet AM approach and parameters as described within the Pictet AM Research Policy. This budget is calculated by the desk head, reviewed by the Chief Investment Officer and finally ratified by the Pictet AM Research Committee. This budget is reviewed on a quarterly basis by the Pictet AM Research Committee. Where an RPA is used, the relevant SEC Pictet AM Firm uses a segregated research account controlled by the relevant firm or an approved affiliate to pay for external research. RPA-funded research must be used exclusively to support client portfolio investment decisions. In some cases, an external RPA administrator oversees the collection, budgeting and quality review of RPA-funded research. The relevant SEC Pictet AM Firm enters into CSAs to fund external research using a portion of client dealing commissions on the following conditions:

The service (which can include research and advisory services, economic and political analysis or software incidental to such goods and services) assists the team in meeting mandated investment objectives.

The goods and services do not include market data, travel, accommodation, entertainment, general administrative goods or services, general office equipment or premises, membership fees, employee salaries or direct money payments.

The service has been reviewed for quality by the recipient.

CSA brokers provide execution-only rates for all transactions outside of the research-funding component. The SEC Pictet AM Firms will ensure that the use of client dealing commissions for the purchase of research has been conducted in accordance with the relevant principles and regulations and in accordance with our policies and procedures. 2.

Brokerage for Client Referrals a.

Whether brokerage is used to obtain client referrals and related conflict

The SEC Pictet AM Firms do not receive client referrals from brokers. Accordingly, the SEC Pictet AM Firms do not select or recommend brokers based on any arrangements to receive client referrals from such brokers. b. Procedures regarding brokerage for referrals Not applicable 3.

Directed Brokerage a.

Practice and policy on directed brokerage and conflicts / costs

If a client instructs an SEC Pictet AM Firm to use a specific broker, the client’s instructions are followed. Directed brokerage restricts our ability to:

negotiate commission rates;

select brokers able to execute difficult trades efficiently;

aggregate orders to achieve lower costs;

obtain optimal execution prices for directed accounts; and

use brokers vetted by the Counterparty Risk Committee.

As a result, directing brokerage can result in higher overall transaction costs or less favourable execution outcomes than might otherwise be achieved. b. Clients permitted to direct brokerage and potential impact Clients can choose to direct the SEC Pictet AM Firms to a specified broker. However, doing so can limit the SEC Pictet AM Firms’ ability to achieve most favourable execution of their transactions and can result in higher commissions or less favourable prices compared to accounts where the SEC Pictet AM Firms are free to select brokers.

B. Aggregation and Allocation of Client Transactions a.

Aggregation practices and condition

Transactions for multiple clients are generally aggregated to provide fair and efficient execution. Aggregated orders execute at an average price, with costs allocated pro-rata subject to market conventions and to avoid uneconomic allocations. Some clients can trade after aggregated orders if aggregation is not feasible, which can affect execution prices. Client orders are not aggregated with orders of other Pictet Group entities or employees. Compliance monitors trade allocations. b. Trade Reallocations Trades are only reallocated to correct errors in initial order entry or allocation. Procedures and Compliance monitoring is maintained to ensure reallocations are fair and consistent with fiduciary duties. c.

Errors and Breaches

Account errors, trade errors and other operational mistakes can occasionally occur in connection with the management of client accounts by the SEC Pictet AM Firms. The SEC Pictet AM Firms have established policies and procedures to address the identification and correction of such errors, which generally require that errors caused by the SEC Pictet AM Firms and affecting a client’s account be resolved promptly and fairly. The SEC Pictet AM Firms are committed to ensuring that clients do not experience financial loss as a result of errors for which the SEC Pictet AM Firms are responsible. Errors can arise from a variety of situations including portfolio management (such as inadvertent violation of investment restrictions), trading, processing or other functions (for example, miscommunication of information, incorrect number of shares, wrong price, wrong account or placing a buy order instead of a sell order and vice versa). The intent of these policies and procedures is to restore a client account to the appropriate financial position as determined in good faith by the SEC Pictet AM Firms based on what is reasonable in light of all relevant facts and circumstances surrounding the error. Consistent with the applicable standard of care, the SEC Pictet AM Firms’ policies, procedures and client agreements generally do not require perfect implementation of investment management decisions, trading, processing or other functions. Therefore, not all mistakes will be considered compensable to the client. Imperfections (including but not limited to the implementation of investment decisions, quantitative strategies, financial modelling, trade execution, cash movements, portfolio rebalancing, processing instructions or facilitation of securities settlement as well as imperfections in processing corporate actions or generating reports) would not constitute compensable errors depending on the materiality and other relevant facts and circumstances.

the Chief Investment Risk & Data Officer;

the Head of the investment team under review and senior portfolio managers;

the Head of the Investment Risk Department; and

the Risk Manager or deputy for the relevant investment team.

The Chief Risk Officer can attend these meetings on an ad hoc basis, particularly for significant strategies.

B. Other-Than-Periodic Reviews In addition to periodic reviews, additional reviews are performed whenever this is appropriate or required. Triggering events include client requests, compliance or guideline monitoring results, industry developments, market events, regulatory or statutory changes and any issues identified within a client account. These matters are directed to the investment professionals and business management responsible for the relevant areas.

C. Client Reports The standard reporting package for segregated clients includes monthly and/or quarterly reports with valuation information, a performance summary, performance attribution and manager commentary describing portfolio activity, performance drivers, market developments and outlook. Valuations are broken down by asset type, currency, geography and sector. Please note valuations are generated by Pictet AM’s investment accounting and portfolio management systems. Therefore, as custodians and the Pictet AM systems use different accounting methods, reporting dates and valuation methodologies, there is a risk that differences in valuations can occur. Alternative reporting formats are also provided when clients have specific reporting requirements. After formal reviews, supplementary information is prepared when appropriate.

Pictet AM SA, Pictet AM Ltd and Pictet AM Singapore can receive institutional client referrals from Pictet AM US. The receiving SEC Pictet AM Firm remunerates Pictet AM US for the referral. No additional cost is charged to the client in connection with this arrangement. The relevant SEC Pictet AM Firm can also pay compensation to external introducers or Pictet Group entities for referred clients. This compensation is typically a percentage of the annual management fee paid by the referred client. These costs are fully borne by the relevant SEC Pictet AM Firm and do not increase the fees charged to clients. The SEC Pictet AM Firms do not receive compensation for referring clients to non-Pictet AM entities, except for distribution fees associated with investor referrals into non-US mutual funds and Pictet AM USA for the U.S. ETFs. A conflict of interest may arise because referral arrangements could create an incentive for the SEC Pictet AM Firms to favour referred clients or to promote products or strategies that generate referral‑related payments. This conflict is mitigated by the fact that the clients concerned are institutional investors that set their own investment objectives, strategies and restrictions and retain full discretion over portfolio construction as set out in the investment management agreement. Discretionary authority is exercised only within client‑defined mandates, and sales or referral personnel are organisationally separate from portfolio management. The SEC Pictet AM Firms maintain a Code of Ethics, compliance oversight of referral arrangements and remuneration controls designed to prevent preferential treatment, and clients receive clear disclosures enabling them to assess any potential conflicts.

B. Other Compensation (including Third-Party Economic Benefits) A group of senior managers of the SEC Pictet AM Firms can receive additional remuneration via the Pictet AM Long Term Incentive Plan, based on profitability metrics and subject to a three year deferral. Pictet AM SA, Pictet AM Ltd and Pictet AM Singapore receive economic benefits from third parties in the form of external research, which is funded through client dealing commissions or Commission Sharing Agreements (please refer to Item 12). These arrangements involve a defined set of eligibility criteria and oversight mechanisms including quality review, compliance with Section 28(e) of the Securities Exchange Act of 1934 and monitoring by the Pictet AM Research Committee. Research benefits are used solely to support investment decision-making in the best interests of clients. SEC Pictet AM Firms engage a third-party media and communications firm to support media appearances and promotional activities, including placements on financial news platforms such as Bloomberg TV and NYSE TV. The media firm may also coordinate advertising initiatives and may collaborate with other external service providers in connection with these activities. The SEC Pictet AM Firms do not pay this media firm directly. Instead, the costs are paid by an affiliate within the Pictet Group that is not a registered investment adviser. As a result, the SEC Pictet AM Firms receive an economic benefit in the form of increased marketing exposure and brand visibility. These costs are not charged to advisory clients, are not included in advisory fees and are not reported as client expenses. This arrangement creates a conflict of interest because the SEC Pictet AM Firms have an incentive to participate in media and promotional activities that enhance their public profile. Media appearances, interviews and related content are designed for general informational and marketing purposes and are not intended as personalised

investment advice. Because the affiliate, rather than the SEC Pictet AM Firms, pays for these services, the SEC Pictet AM Firms receive marketing benefits without bearing the associated costs, which may incentivise continuation or expansion of the arrangement. The conflict of interest is addressed through the following measures:

Media and advertising content is reviewed to ensure compliance with applicable securities laws and advertising rules.

Investment advice is based solely on each client’s objectives, restrictions, risk tolerance and financial circumstances, and is not influenced by media or marketing activity.

Neither the SEC Pictet AM Firms nor their personnel receive compensation tied to referrals, asset gathering or investment recommendations arising from media arrangements.

The SEC Pictet AM Firms clearly distinguish marketing and informational content from personalised investment advice.

These documents describe the nature and extent of the SEC Pictet AM Firm’s discretionary powers and the types of investments that may be made. Where required, the client also grants the relevant SEC Pictet AM Firm trading authority to place orders or a power of attorney with the client’s custodian to permit the relevant SEC Pictet AM Firm to implement investment decisions directly in the client’s account.

Client Investment Guidelines and Restrictions Each client is responsible for establishing its investment objectives, risk tolerance, benchmark (if any) and any investment guidelines and restrictions that will govern the management of its account. Institutional clients typically determine their investment constraints in consultation with the relevant SEC Pictet AM Firm. These guidelines and restrictions must be provided in writing (usually in the investment management agreement, investment policy statement or similar document) before the SEC Pictet AM Firm begins managing the account. The SEC Pictet AM Firms are required to manage client accounts in accordance with these investment guidelines and restrictions. Examples of such limitations can include constraints on specific issuers or sectors, concentrations, geographic or currency exposures, use of derivatives or leverage or ESG-related exclusions. If a client modifies its guidelines or restrictions after the mandate has begun, the changes must be agreed in writing and will apply on a forward-looking basis.

Consistent Management of Similar Accounts The SEC Pictet AM Firms seek to manage client accounts that pursue the same investment strategy in a consistent manner. In practice, this means that accounts invested in the same product or strategy are generally managed using the same investment process and model portfolio, subject to client-specific guidelines, restrictions, tax considerations and legal or regulatory constraints. As clients can impose different investment restrictions or have different objectives or operational requirements, accounts invested in the same strategy may not hold identical positions or weightings and their performance may differ over time. The SEC Pictet AM Firms will not implement an investment decision for a particular account if doing so would be inconsistent with that account’s written investment guidelines or restrictions.

Legal and Regulatory Limits on Discretion In addition to client-imposed guidelines and restrictions, the SEC Pictet AM Firms’ discretionary authority is subject to applicable laws, regulations and tax rules in the jurisdictions in which they and the relevant portfolios operate. For both regulated and unregulated funds, as well as for segregated mandates where applicable, these requirements may include, among other things, portfolio diversification standards, investment concentration limits, borrowing or leverage limits, restrictions on investments in affiliated entities and other regulatory constraints on portfolio composition and investment practices.

The SEC Pictet AM Firms monitor compliance with these regulatory limits as part of their overall compliance and investment-risk frameworks and adjust portfolio management as necessary to remain within applicable legal and regulatory requirements, while continuing to manage accounts in line with clients’ stated objectives and guidelines.

Agreements with Clients About Voting Authority In accordance with SEC guidance on proxy voting responsibilities, a client and the relevant SEC Pictet AM Firm, as investment advisor, can agree to limit the exercise of voting authority. These agreements can specify that:

the SEC Pictet AM Firm will not exercise voting authority if doing so imposes costs on the client (for example, restricting securities lending);

the SEC Pictet AM Firm will vote only on selected proposal types defined by client preference (for example, contested elections for directors);

the SEC Pictet AM Firm will not vote on matters where the cost of voting is high or the expected benefit is low; and

votes will not be cast where voting is not reasonably expected to affect the value of the client’s investment.

Furthermore, in considering whether the proxy voting policy and procedures are reasonably designed to ensure compliance with SEC Rule 206(4)-6 and to fulfil fiduciary duties to multiple clients, the SEC Pictet AM Firms also consider whether a uniform voting approach serves the best interests of each individual client.

Circumstances Where the SEC Pictet AM Firms Do Not Vote The SEC Pictet AM Firms are not required to vote every proxy. The SEC Pictet AM Firms refrain from voting when pre-agreed limitations apply or when abstaining better serves the client’s interests including situations where costs exceed benefits. Additional circumstances include:

absence of an executed Power of Attorney;

incomplete voting recommendations;

newly established accounts not yet fully set up; or

legal or operational restrictions on voting certain securities (e.g., embargoed holdings).

Use of Third-Party Proxy Advisors The SEC Pictet AM Firms use the services of third-party proxy-voting service providers whose expertise and global coverage support informed and consistent voting across all relevant company meetings worldwide.

Scope of Voting Activities The SEC Pictet AM Firms apply the following principles to determine the scope of proxy-voting activities:

For actively managed funds, the SEC Pictet AM Firms aim to vote on 100 percent of equity holdings.

For passive strategies, the SEC Pictet AM Firms aim to vote on companies representing 80 percent of the relevant benchmark weight, subject to upward or downward adjustments depending on strategy characteristics (such as portfolio size, geography or market capitalization).

For segregated accounts, including mandates and third-party (i.e. sub-advisory) mutual funds managed by Pictet AM, clients delegating voting authority can apply the SEC Pictet AM Firms’ proxy voting policy or adopt their own.

Conflicts of Interest Conflicts of interest related to proxy voting are identified within the SEC Pictet AM Firms’ policies, procedures and systems. The SEC Pictet AM Firms may face a conflict of interest if voting rights are exercised in a way that is influenced by client relationships, employee affiliations or personal investments rather than acting in clients’ best interests. Such conflicts are mitigated by requiring personnel to disclose and seek prior approval for outside business interests and investment professionals are prohibited from holding securities in funds they manage, with annual attestations required. In addition, there are communication barriers in place to prevent information sharing in relation to proxy voting. These controls undergo regular review to support effective oversight.

Availability of Proxy-Voting Records The SEC Pictet AM Firms publish complete proxy voting records on their website as part of their responsible investment policy. Clients may request portfolio-level proxy voting information for open-ended funds and segregated accounts. Clients may also obtain a copy of the SEC Pictet AM Firms’ proxy voting policies and procedures upon request.

B. Clients Retaining Voting Authority When a client elects not to delegate proxy voting authority to the relevant SEC Pictet AM Firm, the client (or the client’s designated representative) retains exclusive responsibility for voting. In such cases, proxies and voting materials are sent directly to the client by custodians or transfer agents. The SEC Pictet AM Firms do not provide voting recommendations to such clients and do not share intended votes for any accounts where they hold proxy voting authority.