Santander Asset Management SA Sgiic: investment adviser

C. Client assets as of December 31, 2025. SAM manages a total of $159,860,026,382 of client assets, totaling $135,408,694,440 on a discretionary basis and $24,451,331,942 of client assets on a non-discretionary basis.

Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable.

SAM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and

taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to SAM’s fee, and SAM shall not receive any portion of these commissions, fees, and costs.

Item 12 further describes the factors that SAM considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).

Performance-based fee arrangements may create an incentive for SAM to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. SAM has procedures designed and implemented to ensure that all clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among clients.

Debt structure; Solvency, Liquidity and Vulnerability indicators

Country Allocation

Within authorized portfolio limits

Liability management: Buybacks, Debt Swap

Liquidity considerations

Repos

Instrument Selection

Fund Portfolio Implementation

Risk Management Market Risk

In order to measure and control market risk, we utilize:

 Aladdin, application developed by BlackRock to calculate parametric and

historical VaR.Internal developments to stress testings

Credit Risk

In order to measure and control credit risk, we analyze:

 Internal developments to measure and control mutual fund exposure by

issuer, rating and/or industry group  Internal developments to measure and control global exposure by issuer

Liquidity Risk

In order to measure and control liquidity risk, we analyze:

 Internal developments to calculate Mutual Fund’s effective liquidity.  Internal developments to calculate Fund of Funds’ availability ratio,

according to all the facts that take part in the process of effective settlement of the holdings.

The risk analysis we carry out covers different sources of suspense for each fund verifying fulfilments for the established parameters in the management term. To summarize, we can highlight the following points of control, which are made

periodically (daily, weekly and monthly) by the Risk and Pricing Control Department. 1.1. Control of investment policies

An in-house tool application has been developed that allows configuring on a daily basis the investment policies in addition to portfolio information provided by the managers and control the compliance of policies defined for investment funds: type of assets, markets, currencies, minimum ratings, etc. In addition, Aladdin also has a control module.

The Risk and Compliance department of SAM is, furthermore, the mediator for the Depositary (the Depositary is the entity where the assets of the investment funds are deposited and kept in custody. The Depositary carries out, among other functions, the surveillance and supervision of these investment funds.) in the event of any breaches detected and is in charge of its monitoring and implementing measures to normalize their situation. Asset Management Control (define) is, furthermore, the mediator for the Depositary (define) in the event of any breaches detected and is in charge of its monitoring and implementing measures to normalize their situation. 1.2. Control of exposure levels

The policies can be expressed in terms of strategic exposure thresholds. These exposure thresholds represent, therefore, a structure of minimum / maximum exposure levels in variable and fixed income and, in the case of the latter, it also establishes limits by modified duration.

The Risk and Compliance department of SAM performs a daily control of exposure levels and the information is integrated with the rest of operational controls performed in order to obtain a complete vision, by the fund and manager, of the level of compliance with legal, operational and risk thresholds. 1.3 Value at Risk

The exposure of IIC (Collective Investment Schemes, in this specific case regulated Investment Funds) is monitored to market risk in accordance with methodologies for calculating the risk value. This is, the estimated maximum loss of a portfolio for a given time horizon and a certain trust level using determined periodicities and methodologies based on the nature of funds, the type of instruments and assets in which they are invested as well as their management philosophy.

1.4. Back-testing

Back-testings are used as a mechanism for verifying the validity of VaR estimates performed, a back-testing analysis is performed periodically, which compares if the number of exceptions performed in a year - i.e.: number of days in a year in which losses performed exceed the estimated VaR – complies with the trust level used in the VaR calculation. Possible deviations are monitored and recorded each time the VaR of portfolios is calculated and Internal Audit certifies the reasonability of results at least once a year. 1.5. Stress Testing

On the other hand, scenarios based on actual past market crisis situations are established and subjected to the current portfolios and fluctuations suffered by these assets or other similar characteristics. The goal is to quantify the sensitivity of current portfolios to events of the same calibre.

The mentioned controls are performed periodically (daily, weekly and monthly) by the Risks and Valuation Control Department. There are internal control procedures that describe in detail how to proceed for specific problems that may arise.

Evaluation of performance of the portfolio:

Every week the control department compares the returns (net and gross of fees) of each subfund with the returns obtained by the corresponding benchmark assigned to each subfund and the competition. The calculation also includes risk measures like beta, tracking error etc. On a monthly basis the PM’s get performance attribution data for their main funds. Inside the control area, of SAM Group there is a specific department for performance measurement (Performance and Portfolio Analysis). In this case, the tool used is FACSET, and the performance measurement is based on net and gross return, which indicates whether the return is calculated after deducting all applicable fees and expenses or not. On a weekly frequency, the gross and net of fees return of each portfolio is compared to that of its benchmark, for different time periods (1month, YTD, 1year, etc.). Some performance ratios (such as Sharpe, Treynor, Information) are also calculated to

provide more detail on risk-adjusted performance.

With the same frequency, an analysis against competitors is performed based on net and gross of fees return, to obtain the quartile and percentile of the portfolio, in order to make an analysis against it main competitors denominated analysis over peer group. The performance analysis is sent weekly to the Portfolio managers and the Board of Directors. Those figures are discussed in the Directors Committee meetings when scheduled.

Risk of Loss. Investing in securities involves a risk of loss, including the potential loss of one’s entire investment. In addition, clients face certain risks that arise from SAM’s investment strategies. There may be other risks applicable to SAM’s investment strategies, the markets and/or instruments in which SAM invests on behalf of its clients. Each prospective client should also consult its own legal, investment, tax, and other advisers in determining the risks of engaging SAM to manage and/or advise on all or a portion of its investment portfolio, and whether such an engagement is appropriate for it. Cybersecurity Risk. Our information and technology systems and those of key service providers may be vulnerable to potential damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by their respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. A failure of any such system or a security breach or cyberattack could significantly disrupt our operations. Service providers are subject to the same cybersecurity risks as we are. If a service provider fails to adopt, implement or adhere to adequate cybersecurity measures, or in the event of a breach of its networks, information may be lost, damaged or corrupted or improperly accessed, used or disclosed. Any system failure, security breach or cyberattack on us, or any of our service providers, could cause us or the funds or managed vehicles to suffer, among other things, financial loss, business disruption, including trading capabilities and the ability to transmit payments, increased operating costs, liability to third parties, regulatory intervention and reputational damage. In addition, there are increased risks relating to our and our service providers’ reliance on computer programs and systems when personnel are required to work remotely for extended periods of time, such as in connection with pandemics, natural disasters or other similar events, including an increased risk of cyber-attacks and unauthorized access to computer systems. Force Majeure Events. Some force majeure events such as pandemics, natural

disasters, wars, and similar events may adversely affect our ability and the ability of our service providers (including our counterparties and vendors) to perform our and their obligations, particularly if our or their employees become ill or are otherwise unable to work as a result. Certain force majeure events could have a broader negative impact on the world economy and international business activity generally. Any of the foregoing could adversely affect the performance of an investment strategy, could negatively impact our business and could have a material adverse effect on our ability to manage client assets. SAM and its clients may be adversely affected by unfavorable economic, market, geopolitical, social and trade conditions, including inflation, changes in interest rate policy, armed conflicts, sanctions, tariffs, trade disputes, supply chain disruptions and social unrest. These events may increase volatility, widen credit spreads, reduce liquidity, impair valuations and adversely affect the operating performance of issuers and counterparties which could negatively affect client investments and returns

SAM maintains business continuity and operational resilience controls based on Santander Group guidelines and procedures designed to support the continuity of critical activities, incident response and recovery planning, and the management of operational and third-party risks. Such controls may mitigate, but cannot eliminate, the impact of these events.

AI and Machine Learning risks. SAM may also be exposed to risks arising from the use of artificial intelligence and machine learning technologies by SAM and by third parties. These risks include inaccurate outputs, data misuse, confidentiality breaches, cybersecurity incidents, insufficient transparency and inappropriate reliance on automated tools. SAM is subject to Santander Group policies and governance frameworks for artificial intelligence designed to align with the applicable European regulatory framework, including controls relating to risk assessment and data treatment.

SAM anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which SAM has management authority to effect and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which SAM, its affiliates and/or clients, directly or indirectly, have a position of interest. SAM’s employees and persons associated with SAM are required to follow SAM’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of SAM and its affiliates may trade for their own accounts in securities, which are recommended to and/or purchased for SAM’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of SAM will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of SAM’s clients. In addition, the Code requires pre-clearance of many transactions and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between SAM and its clients. It is SAM’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. SAM will also not cross trades between client accounts. SAM’s clients or prospective clients can obtain the firm's Code of Ethics. SAM adheres to the Code of Ethics of Banco Santander, which is available on its website.