Eastspring Investments (Singapore) Limited: investment adviser

Deduction of Fees The Adviser bills clients for fund management fees according to the billing frequencies agreed upon in the investment advisory agreement.

Item 5.C.

Other Fees and Expenses The Adviser only charges advisory fees to institutional clients. Other fees such as custodian fees are charged by the appointed custodian in an arrangement independent of the Adviser. See also “Item 12. Brokerage Practices”.

Item 5.D.

Prepaid Fees As noted in the response to Item 5.A, fees are normally billed on an agreed cycle with the client. Fees are generally paid in arrears.

In the course of providing any investment or ancillary services, the Adviser will take all reasonable steps to identify any conflicts of interest between one client and another. The Adviser has designed and implemented procedures to ensure that all clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among clients. The Adviser has established policies and procedures aimed at preventing any clients from being systematically favoured or disadvantaged, thus ensuring positive outcomes for all clients. Additionally, the Adviser actively monitors for conflicts through the implementation of "best execution" trading procedures and by conducting regular reviews of trade allocation and performance. For more information about other potential conflicts of interest, see Item 11 (Code of Ethics, Participation or Interest in Client Transactions and Personal Trading) and Item 12 (Brokerage Practices).

Item 8.A. - General Description – How does the Adviser formulate investment advice or manage client assets? Eastspring Singapore’s Investment Department is primarily made up of Equities, Quantitative Strategies (“QS”), Fixed Income, and Multi Asset Portfolio Solutions (“MAPS”) investment teams: -

(i)

Global Emerging Markets (“GEM”) and Regional Asia Value Equities Team and Japan Equity Team

The Adviser’s GEM and Regional Asia Value Equities team and Japan Equity team follow a valuation-based approach across all of its Equity strategies. The first part of the process is idea generation. This is a systematic starting point where the Adviser uses proprietary screens across a wide investment universe applying consistent anchors around valuation. This allows the Adviser to be equipped to rapidly identify stocks that are also valuation outliers which may become investment candidates. The next stage is the fundamental analysis of these outliers. This fundamental analysis drives the Adviser’s investment approach, and the Adviser employs a strong discipline around a single valuation framework. The Adviser insists on challenge and debate to test the assumptions and help to achieve a level of conviction in the valuation of each security. The next stage is portfolio construction. In taking active risk the Adviser considers the stock-by-stock relationships in the portfolio to ensure sufficient diversification. The Adviser establishes an explicit link between risk and return which reinforces the Adviser’s ability to take long-term positions without being forced to close positions in response to excessive volatility. The last stage is review and control. This is a team owned responsibility involving a formal peer review of all strategies, which ensures the integrity of the Adviser’s process. The Adviser combines a team culture with a valuation, research-driven investment philosophy to deliver a range of strategies:

Global Emerging Markets Japan Focused Value Japan Smaller Companies Regional Asia Value

(ii)

Asia Growth Equities Team

The Adviser’s Asia Growth Equities team focuses on companies that deliver growth at a rate that is above that of its industry and/or the underlying market. The team’s preference is for higher quality companies that are run by prudent management teams, are shareholder-conscious, and usually -due to some advantage -- enjoy a competitive moat that results in higher and more steady returns on capital. The Adviser also does not want to overpay for these companies and is mindful to buy at a reasonable price. Where possible, the team looks for idiosyncratic growth ideas that are not well known or well understood by the public equity markets. The team is disciplined about being focused on stocks that meet its growth criteria and its approach involves a disciplined, rigorous, and repeatable process to select stocks by blending fundamental company analysis with a deep knowledge of structural themes, as well as industry and market growth cycles. The Adviser combines a team-based culture with a research-driven investment philosophy and a deep knowledge of structural themes to deliver a range of strategies:

ASEAN Growth Asia Growth

(iii)

Quantitative Strategies (QS) Team

The Adviser believes that markets are not entirely efficient, owing to entrenched conscious and unconscious behaviors and incentives of market participants, and seeks to systematically exploit those behavioral and structural market inefficiencies. These inefficiencies encompass different risk premia or factors, such as Value, Momentum, Quality, Sentiment and Volatility, among others, and form the basis for building portfolios. The investment process starts with insights derived through experience and observed fundamental, structural, or behavioral effects or as identified through academic research. Before forming a part of any strategies, these observed inefficiencies must be validated by rigorous internal quantitative research and survive critical peer review and research challenge to avoid unfounded biases creeping into strategy formation.

The Adviser’s QS team’s Investment Committee provides governance of this process for all new strategies and changes to existing strategies. All QS investment strategies are managed through a systematic investment process that ensures efficient, unbiased, and repeatable portfolio outcomes. Portfolio construction and stock selection is quantitative, aimed at constructing optimal portfolios from the investable universe. In choosing investments, the starting point is as broad a universe of stocks as is practical, which is then shortlisted on the basis of investability and other desirable characteristics, depending on the strategy. Constraints such as maximum stock weight, portfolio concentration, liquidity, sector-, country- and style-relative exposures, etc. are applied in order to manage systematic and stock specific risk. Expected transaction costs are incorporated to ensure that the resulting portfolio changes are optimal on a net of costs basis. The end result is a portfolio that is efficient and consistent with the strategy’s investment and risk objectives. The Adviser delivers a range of strategies along the risk spectrum, which include the following: OUTCOME: Global and Regional Low Volatility Equities, and Global Income Equities CORE: Global, Regional and Single Country Multi Factor Equities BETA: Global, Regional and Single Country Beta and customized Beta Equities

(iv)

Fixed Income Team

The Adviser adopts a disciplined, medium-term investment approach in managing fixed income portfolios. This involves a comprehensive multifactor analysis that takes into account the fundamental, valuation and technical factors which impact the relevant fixed income market(s) at both top-down and bottom-up levels. The Adviser applies a “top-down” investment management approach in deriving its duration, credit and currency allocation strategy and decision. This is combined with a thorough “bottom-up” credit selection process, based on research and analysis. Economic and market analyses are carried out to determine the outlook for monetary policies, interest rates and credit spreads. Apart from determining the probable investment scenarios, potential market outcomes that would

adversely affect the investment strategies are also assessed. A comprehensive investment strategy is then systematically formulated. Examples of the Adviser’s Fixed Income strategies include:

Asian USD-denominated Bonds Asian Local Currency Bonds Emerging Market Bonds Singapore Bonds

(v)

Alternatives Team

The Adviser’s Alternatives team follows a thematically driven indirect investment strategy, providing clients with global exposure to top-performing private equity funds and co-investments. The team adopts a highly selective sourcing approach to identify top-performing managers and targets only those managers that align with the top-down themes identified by the team. The Alternatives investment strategy is currently offered to Singapore clients but not to the US clients.

(vi)

Multi Asset Portfolio Solutions (MAPS) Team

The Adviser’s MAPS Team serves as a top down multi asset investment team. The team manages several existing strategies that work to solve for clients’ investment challenges, including growth, income, volatility, and thematic assets. The MAPS can also manage customized mandates set against specific client objectives. The Adviser uses a proprietary data driven approach which guides asset allocation across core and satellite asset classes. This is rounded off by a disciplined and pragmatic risk management approach. The Adviser will actively manage portfolio exposure around the Strategic Asset Allocation to best position the portfolio utilizing inputs from its proprietary data driven approach, that has been developed and refined over the years within Eastspring. The Adviser will use the data driven approach to assess investment decisions at the asset allocation level. Portfolio construction is anchored on a disciplined process and position sizing is managed dynamically to seek a

balance where more volatile asset classes do not have a disproportionate impact on portfolio performance and risk levels. Risk management is embedded throughout the process from asset class selection to monitoring tracking error, volatility and Value at Risk. Please refer to Item 13 for information on the Quarterly Risk Oversight meetings pertaining to the investment teams. Item 8.B.

Material Risks for Significant Investment Strategies Material risks involved With respect to any investment strategies offered by the Adviser, the Adviser wishes to stress that investing in securities involves risk of loss that clients should be prepared to bear. Specific risks are disclosed to clients in the respective offering documentation. General risks that the client may indirectly face, though non-exhaustive, are:

General market risk - The portfolios may fall in value due to any of the key risk factors below and therefore an investor’s investment may suffer losses. The investments of the portfolios are subject to normal market fluctuations and, accordingly, it is emphasized that the price of assets in any of the portfolios and the income from them can fluctuate. The following statements are intended to inform investors of the uncertainties and risks associated with investments and transactions in transferable securities and other financial instruments. Investors should remember that the price of portfolios and any income from them may fall as well as rise and that investors may not get back the full amount invested. Past performance is not necessarily a guide to future performance and investments in the portfolios should be regarded as a medium to long-term investment. Although the Adviser makes every effort to achieve the investment objectives of the portfolios to the best of its knowledge, no guarantee can be given as to whether the investment objectives will be achieved. As a result, the Net Asset Value of the portfolios may be higher or lower, and therefore different levels of positive as well as negative income may be earned. Investors in equities will be subject to the risks associated with equity and equity-related securities and general market risks, including fluctuations in market prices, change in investment sentiment, political and economic conditions and issuer-specific factors or market information and the fact that equity and equity-

related interests are subordinate in the right of payment to other corporate securities, including debt securities. Likewise, investors in fixed income securities will be subject to the risks associated with debt securities including normal market fluctuations, credit and interest rate risk, and the additional risks associated with high yield debt securities, loan participations and derivative securities. In addition, investors should be aware of the risks associated with the active management techniques that are expected to be employed by the portfolios. An investment in a portfolio does not constitute a complete investment program. Investors may wish to complement an investment in a portfolio with other types of investments.

Market Suspension Risk - Each securities exchange or commodities contract market typically has the right to suspend or limit trading in all securities or commodities which it lists. Such a suspension would render it impossible for the portfolios, to liquidate positions and, accordingly, expose the portfolio to losses and delays in its ability to redeem investments. The government or the regulators may also implement policies that may affect the financial markets. All these may have a negative impact on the portfolios.

Foreign Exchange/ Currency Risk - As some portfolios will invest in securities which are denominated in currencies other than the referenced currencies of their portfolios, fluctuations in the exchange rates of these foreign currencies may have an impact on the income and value of such portfolios. Investors will be exposed to exchange rate risks if the Adviser does not hedge the foreign currency exposure (if any) of the portfolios. Also, in the event a currency hedging strategy executed does not meet its intended objective this could have adverse impact to the value of the relevant portfolio. The Net Asset Value of the portfolios may be affected unfavorably by adverse movements in foreign currency exchange rates between the currencies of the underlying assets and the base currency of the portfolios and the currency of the investments of portfolios held by investors, as well as by changes in exchange rate controls.

Liquidity Risk – Portfolios could face liquidity risk arising from investments in securities that have low trading volumes, imposed trading restrictions or temporary suspensions from trading. Investments in securities that have high liquidity risk may reduce return or incur substantial losses to a portfolio if the portfolio is unable

to sell these securities at opportune times or prices. Liquidity could dry up in a very short time especially during a crisis.

Credit risk – Portfolios could face the risk of negative valuation impact due to deterioration in credit quality including credit transitions and defaults/impairments in the underlying credit investments in the portfolios.

Counterparty and Settlement Risk – A portfolio will be exposed to credit risk on the counterparties with which it trades particularly in relation to fixed income securities, options, futures, contracts and other financial derivative instruments that are traded over the-counter. Such financial derivative instruments are not afforded the same protections as may apply to participants trading futures or options on organized exchanges, such as the performance guarantee of an exchange clearing house. A portfolio will be subject to the possibility of the insolvency, bankruptcy or default of a counterparty with which it trades, which could result in substantial losses to that portfolio. A portfolio will also be exposed to a credit risk on parties with whom it trades securities, and may also bear the risk of settlement default, in particular in relation to debt securities such as bonds, notes and similar debt obligations or instruments. Investors should also note that settlement mechanisms in emerging markets are generally less developed and reliable than those in more developed countries and that this therefore increases the risk of settlement default, which could result in substantial losses for a portfolio in respect of investments in emerging markets.

Emerging and Frontier Markets Risk - Investors should be aware that investment in emerging or frontier (include pre-emerging) markets may involve, due to the economic and political development process which some of these countries are undergoing, a higher degree of risk and special consideration not typically associated with investment in more developed markets which could adversely affect the value of the investments. Among other things, investment in emerging and frontier markets involves risks such as the restriction on foreign investment, currency risk, political and economic uncertainties, legal and taxation risks, foreign exchange controls, regulatory risk, counterparty risk, higher market volatility, less public information about companies and the illiquidity of the companies’ assets depending on the market conditions in certain emerging and frontier

markets and, to a lesser extent, developed markets. Moreover, companies may be subject to considerably less state supervision and less differentiated legislation. Their accounting and auditing do not always match western standards. Investments in some emerging countries are also exposed to higher risks in respect of the possession and custody of securities. Ownership of companies is for the most part determined by registration in the books of the company or its registrar (who is not, however, an agent of the depositary nor liable to the latter). Certificates evidencing the ownership of companies are frequently not held by the depositary, any of its correspondents or an efficient central depositary. As a result, and due to lack of efficient regulation by government bodies, a portfolio may lose the possession of or the registration of units in companies through fraud, serious fault or negligence. Debt instruments involve a higher custody risk and settlement risk as, in accordance with market practice, such paper is held by local institutions which are not, however, always sufficiently insured against loss, theft, destruction or insolvency while holding the assets. Investment in fixed income securities issued by emerging and frontier market sovereigns and corporations would usually carry lower credit ratings. These securities usually offer higher yields to compensate for the reduced creditworthiness or increased risk of default that these securities carry. When the Adviser makes investments in less developed markets, where accounting and other standards may be lower than seen elsewhere, its usual rigorous standards will be applied to endeavour that quality investments are purchased. The following statements are intended to illustrate the risks which in varying degrees are present in investing in emerging and frontier markets and less developed market instruments and the statements do not offer advice on the suitability of investments. o Frontier Markets Risk. ▪

Investors may be subject to the same risks as investments in emerging markets, as well as heightened or additional risks, including political instability, conflict, and corruption. Investments may be made in territories where border disputes exist, making the legal, political, and security climate uncertain, and there can be no assurances that such potential instability will ease. Transactions in such regions may

depend on accessing appropriate and reputable intermediaries. Despite a growing trend toward democratic processes, some frontier economies are in countries with a history of military conflict and corruption. If such activities were to recur, they could reverse favourable trends toward economic and market reform, privatization, and the removal of trade barriers, resulting in significant disruptions in markets. ▪

Repatriation of investment income, assets, and the proceeds of sales by foreign investors may require governmental registration and/or approval in some frontier markets. The investments could be adversely affected by delays in or a refusal to grant any required governmental registration or approval for such repatriation, or by withholding taxes imposed by frontier market countries on interest or dividends paid on financial instruments held by the Adviser, or gains from the disposition of such financial instruments and other assets.

▪

The economies of many of the frontier market countries may be in the early stages of modern development and are subject to abrupt and unexpected change. In many cases, governments retain a high degree of direct control over the economy and may take actions having sudden and widespread effects. Also, many converging, emerging, and frontier market country economies have a high dependence on a small group of markets.

o Legal Environment ▪

The interpretation and application of decrees and legislative acts can be often contradictory and uncertain particularly in respect of matters relating to taxation.

▪

Legislation could be imposed retrospectively or may be issued in the form of internal regulations not generally available to the public.

▪

Judicial independence and political neutrality cannot be guaranteed.

▪

State bodies and judges may not adhere to the requirements of the law and the relevant contract. There is no certainty that investors will be compensated in full or at all for any damage incurred.

▪

Recourse through the legal system may be lengthy and protracted.

o Currency Risk ▪

Conversion into foreign currency or transfer from some markets of proceeds received from the sale of securities cannot be guaranteed.

o Taxation ▪

Investors should note in particular that the proceeds from the sale of securities in some markets or the receipt of any dividends and other income may be or may become subject to tax, levies, duties or other fees or charges imposed by the authorities in that market, including taxation levied by withholding at source. Tax law and practice in certain countries into which the portfolios invest or may invest in the future is not clearly established. It is therefore possible that the current interpretation of the law or understanding of practice might change, or that the law might be changed with retrospective effect. As a result, the portfolios could become subject to additional taxation in such countries that is not anticipated when investments are made, valued or disposed of.

Environmental, Social and Governance (“ESG”) Integration Risk The Eastspring Investments Group Responsible Investment Policy (“RI Policy”) is applicable to all strategies that Adviser directly manages and in all markets that Adviser operates. In the case of thirdparty client mandates and funds delegated to third parties, the Adviser looks to meet client requirements with a close alignment to expectations outlined in the RI Policy.

Implementation of the RI Policy may result in the consideration of ESG factors within the investment process and the application of negative ESG screens. This may affect a portfolio’s exposure to certain sectors and/or companies that may impact the relative performance of the portfolio, depending on the relative performance of such investments. This may also affect a portfolio’s performance compared to similar portfolios that do not use such criteria. ESG integration is carried out with the view of enhancing long term risk-adjusted returns of the portfolios, but investors may differ in their views of what constitutes financially material ESG factors. In implementing the RI Policy, the Adviser is dependent upon information and data obtained through voluntary or third-party reporting that may be incomplete, inaccurate, or unavailable, which could cause the Adviser to incorrectly assess an issuer’s business practices with respect to ESG practices. Socially responsible norms differ by region, and an issuer’s ESG practices or the Adviser’s assessment of an issuer’s ESG practices may change over time.

Responsible Investment Product Risk – In addition to ESG Integration Risk, where a portfolio applies an ESG, Sustainable (or equivalent) investment strategy, such investing strategies may reduce or increase a portfolio’s exposure to certain companies, geographies or industries and the portfolio may forego or underweight certain investment opportunities, which can result in variations in the relative performance of the portfolio, depending on the relative performance of such investments. In carrying out an ESG, Sustainable (or equivalent) investment strategy, the Adviser is dependent upon information and data obtained through voluntary or third-party reporting that may be incomplete, inaccurate, or unavailable, which could cause the Adviser to incorrectly assess an issuer’s business practices with respect to ESG practices. Socially responsible norms differ by region, and an issuer’s ESG practices or the Adviser’s assessment of an issuer’s ESG practices may change over time.

Foreign Securities Risk - Portfolios that invest in securities traded principally in securities markets outside the United States are subject to additional and more varied risks, as the value of foreign securities

may change more rapidly and extremely than the value of U.S. securities. Less information may be publicly available regarding foreign issuers. Foreign securities may be subject to foreign taxes and may be more volatile than U.S. securities. Currency fluctuations and political and economic developments may adversely impact the value of foreign securities. The securities markets of many foreign countries are relatively small, with a limited number of companies representing a small number of industries. Additionally, issuers of foreign securities may not be subject to the same degree of regulation as U.S. issuers. Reporting, accounting, and auditing standards of foreign countries differ, in some cases significantly, from U.S. standards. There are generally higher commission rates on foreign portfolio transactions, transfer taxes, higher custodial costs, and the possibility that foreign taxes will be charged on dividends and interest payable on foreign securities, some or all of which may not be reclaimable. Also, adverse changes in investment or exchange control regulations (which may include suspension of the ability to transfer currency or assets from a country); political changes; or diplomatic developments could adversely affect a portfolio’s investments. In the event of nationalization, expropriation, confiscatory taxation, or other confiscation, a portfolio could lose a substantial portion of, or its entire investment in, a foreign security. Some of the foreign securities risks are also applicable to portfolios that invest a material portion of their assets in securities of foreign issuers traded in the United States. Any depositary receipts are subject to most of the risks associated with investing in foreign securities directly because the value of a depositary receipt is dependent upon the market price of the underlying foreign equity security. Depositary receipts are also subject to liquidity risk.

Interest Rate Risk - Interest rate risk is the risk that fixed income investments will decline in value because of changes in market interest rates. The level and volatility of short-term and long-term interest rates significantly affect the lending industry. When market interest rates rise, the market value of fixed-interest rate securities generally will fall, as investors demand a higher annual yield from future distributions. Rising interest rates also generally increase the costs of obtaining financing, which could cause the value of high yield fixed income investments purchased by a portfolio to decline.

Furthermore, the market price of floating rate securities, such as bank loans, has historically been based on LIBOR (or a similar benchmark rate), and accordingly may also be susceptible to decline in the event that market interest rates decline. The impact of interest rate changes on the value of floating rate investments is typically reduced by periodic interest rate resets. Variable and floating rate loans and securities generally are less sensitive to interest rate changes but may decline in value if their interest rates do not rise as much or as quickly as interest rates in general. Conversely, variable and floating rate loans and securities generally will not increase in value as much as fixed rate debt instruments if interest rates decline.

Concentration Risk - The portfolios’ investments may be concentrated in a specific geographical location. The value of the portfolios may be more volatile than that of a portfolio having a more diverse portfolio of investments. The value of the portfolios may be more susceptible to adverse economic, political, policy, foreign exchange, liquidity, tax, legal or regulatory event affecting the relevant market.

Specific risk considerations in relation to Low Volatility Securities The investment strategy adopted by certain portfolios may not work and/or may not achieve a reduced level of volatility, for example, the portfolios may not produce lower price variability as compared to the overall market under all circumstances and market conditions. In the event a reduced level of volatility is achieved by adopting the investment strategy, the portfolios may still be precluded from fully capturing the upside in rising markets. Hence, the value of the portfolios may be adversely affected. Low volatility stocks are seen as having a lower risk profile than the overall markets. However, a portfolio comprised of low volatility stocks may not produce investment exposure that has lower variability to changes in such stocks’ price levels. Investors should note that lower volatility does not necessarily mean low risk and may be subject to the risks of common stocks. Low volatility strategies employ systematic models to select investments on the basis of past statistical results. There is a risk that investments selected using these models may perform differently than expected as a result of the design of the model, inputs into the model, changes from historical trends or other factors.

Operational Risk - The portfolios depend on the Adviser to develop appropriate systems and procedures to control operational risk.

These systems and procedures may not account for every actual or potential disruption of a portfolio’s operations. A portfolio’s business is dynamic and complex. As a result, certain operational risks are intrinsic to each portfolio’s operations, especially given the volume, diversity, and complexity of transactions that each portfolio is expected to enter into. A portfolio’s business is highly dependent on the ability to process, on a daily basis, transactions across numerous and diverse markets. Consequently, the portfolios rely heavily on financial, accounting, and other data processing systems as well as electronic execution systems (and may rely on new systems and technology in the future). The ability of such systems to accommodate an increasing volume, diversity, and complexity of transactions could also constrain the ability of the Adviser to properly manage the portfolios. Systemic failures in the systems employed by the Adviser, the portfolios, brokers, and/or counterparties, exchanges, and similar clearance and settlement facilities and other parties could result in mistakes made in the confirmation or settlement of transactions, or in transactions not being properly booked, evaluated, or accounted for. These and other similar disruptions may cause the portfolios to suffer, among other things, financial loss, the disruption of businesses, liability to third parties, regulatory intervention, or reputational damage.

Risks relating to the valuation of illiquid investments - Valuation of a portfolio’s illiquid investments may involve uncertainties and judgmental determinations. If such valuations should prove to be incorrect, investors could be adversely affected. Independent pricing information may not at times be available or may be difficult to obtain with respect to certain of a portfolio’s illiquid investments. Accordingly, certain illiquid investments may be subject to varying interpretations of value and, in such cases, the value of an illiquid investment may be determined by, among other things, utilizing mark-to-market prices provided by dealers and pricing services and, if necessary, through relative value pricing. There is no guarantee that the value attributable to an illiquid investment by the Adviser will represent the value that will be realized by the relevant portfolio on the eventual disposition of such an investment.

Legal Risk – A portfolio may be subject to a number of unusual or unexpected risks, including inadequate investor protection,

contradictory legislation, incomplete, unclear, and changing laws, ignorance or breaches of regulations on the part of other market participants, lack of established or effective avenues for legal redress, lack of standard practices and confidentiality customs characteristic of developed markets, and lack of enforcement of existing regulations. Furthermore, it may be difficult to obtain and enforce a judgment in certain of the developing countries in which assets of a portfolio may be invested. There can be no assurance that this difficulty in protecting and enforcing rights will not have a material adverse effect on a portfolio and its operations.

Political and/ or Regulatory Risk - The value of the assets of the portfolios may be affected by uncertainties such as international political developments, changes in government policies, changes in taxation, restrictions on foreign investment and currency repatriation, currency fluctuations and other developments in the laws and regulations of countries in which an investment may be made. Furthermore, the legal infrastructure and accounting, auditing and reporting standards in certain countries in which an investment may be made may not provide the same degree of investor protection or information to investors as would generally apply in major securities markets. Foreign ownership restrictions in some markets may mean that corporate action entitlements in relation to any collective investment schemes or other investments the portfolios are invested into may not always be secured or may be restricted.

Cybersecurity Risk - The Adviser, and other services provides of the Adviser and the portfolios (“Affected Persons”) may be susceptible to operational and information security and related risks of cyber security incidents. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber security attacks include, but are not limited to, gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software distribution) for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyber-attacks may be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make services unavailable to intended users). Cyber security incidents affecting the Affected Persons have the ability to cause disruptions and impact business operations, potentially

resulting in financial losses, including by interference with a portfolio’s ability to calculate its NAV; impediments to trading for a portfolio; the inability of investors to transact business with a portfolio; violations of applicable privacy, data security, or other laws; regulatory fines and penalties; reputational damage; reimbursement or other compensation or remediation costs; legal fees; or additional compliance costs. Similar adverse consequences could result from cyber security incidents affecting issuers of securities in which a portfolio invests, counterparties with which a portfolio engages in transactions, governmental and other regulatory authorities, exchanges and other financial market operators, banks, brokers, dealers, insurance companies, and other financial institutions, and other parties. In addition, substantial costs may be incurred in order to prevent any cyber incidents in the future.

Commodity Pool Operator, Commodity Trading Adviser, Futures Commission Merchant Registration The Adviser has notified with the National Futures Association (“NFA”) as an exempt Commodity Pool Operator under Commodity Futures Trading Commission (“CFTC”) regulation 4.13(a)(3) for the Adviser’s Collective Investment Trust (Pool ID: P159804). The Adviser has also notified the NFA as an exempt Commodity Trading Adviser under the CFTC regulation 4.14(a)(8).

Item 10.C.

Other Material Relationships This brochure discusses only those functions performed by the Adviser on behalf of its clients and does not discuss the activities of other affiliated entities or related persons on behalf of their respective clients except to the extent such activities are conducted in connection with the investment advisory activities of the Adviser. Additional information relating to these related persons of the Adviser can be found on Section 7.A. of Schedule D to Part 1A of the Adviser’s Form ADV. The Adviser takes the definition of “material relationships” to include relationships with affiliated companies, which are connected to the Adviser via the same ultimate parent company.

Investment company or other mutual funds (including a mutual fund, closedend investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) Eastspring Singapore is the investment manager of certain funds managed by affiliates of its parent company.

Other investment adviser or financial planner The Adviser has entered into agreements with an affiliated entity in the U.S., Eastspring Investments Incorporated, for purposes of marketing and promoting the Adviser in the U.S.

Insurance company or agency The Adviser’s parent company is an international financial services group. In addition, the Adviser manages funds for its affiliated companies whose main business line is in insurance.

Conflicts of Interest The Adviser is committed to providing clients with service of the highest quality and seeks to act in the best interests of its clients. Nevertheless, there are circumstances where clients’ interests conflict with the Adviser’s interests, the interests of the Adviser’s affiliates (including affiliated clients), or the interests of other clients. Some of these conflicts of interest are inherent to the Adviser’s business and are encountered by other large financial services firms that offer similar services. The Adviser has policies and procedures that are designed to ensure that the Adviser acts in the best interests of its clients.

Participating Affiliate Arrangement The Adviser expects to utilize the investment professionals of its affiliates in certain circumstances, to manage a particular strategy or product to provide investment services to U.S. clients. In keeping with applicable regulatory guidance, should there be a need to utilise the investment professionals of its affiliates, the Adviser’s affiliates will enter into a Memorandum of Understanding with the Adviser through which the affiliate will be considered a “Participating Affiliate” of the Adviser as that term is used in relief granted by the staff of the SEC. This allows the Adviser, as a U.S. registered investment adviser, to use the resources of a non-U.S. affiliate, i.e., a Participating Affiliate, to render portfolio management, research, or trading services to U.S. clients of the Adviser. The arrangement with a Participating Affiliate will position the Adviser to offer investment management styles and strategies that it otherwise may not manage under the framework of U.S.

regulations. In such an arrangement, investment professionals of a Participating Affiliate may render substantially similar portfolio management research or trading services to their own advisory clients and the performance achieved may be better or worse than that achieved on behalf of the Adviser’s clients.

The Code prohibits personal securities transactions based on inside information or trading in securities appearing on applicable restricted lists; requires preapproval of certain personal transactions for Covered Persons. The Code requires under certain circumstances additional blackout period between execution of a trade for a client and execution of a personal transaction; and restricts or prohibits certain other transactions. The Adviser will provide a copy of the Code of Ethics to clients or prospects upon request, as appropriate.

Item 11.B.

Participation or Interest in Client Transactions The Adviser does not buy or sell securities to or from segregated accounts on a principal basis. The Adviser’s officers or directors may sit on the boards, and board committees, of publicly traded clients. The Adviser may effect “cross” transactions between segregated accounts subjected to restrictions in client mandates. In these cases, one client will purchase a security held by another client. Neither the Adviser nor any related party receives any transaction fee in connection with a “cross” transaction. The Adviser effects these transactions pursuant to internal procedures in place only when it deems the transaction to be in the best interest of both buying and selling clients and at prices that the Adviser has determined reflect fair value. The Adviser in many instances purchases and sells, pursuant to its discretionary authority, the same securities for the accounts of related and unrelated persons. In those instances, the Adviser has internal procedures in place to

allocate those securities to related and unrelated accounts on a fair and equitable basis over time. The Adviser maintains policies and procedures regarding market conduct and information barriers that establish appropriate Chinese walls and logical access controls around certain internal groups that might be in possession or aware of material non-public information. The policy is designed to block the flow and potential misuse of that information. In addition, the Adviser has adopted other policies and procedures designed to minimise potential conflicts of interest of this nature and to address such conflicts in a manner that is most equitable to all accounts. Item 11.C.

Participation or Recommendations

Interest

in

Personal

Trading

–

However, the Code imposes limits on such transactions, including generally prohibiting transactions within a blackout period when a client is trading in such securities or in circumstances where the Covered Person has access to material non-public information relating to the security or the issuer of the security. Except in limited circumstances, personal securities trading is subject to monitoring and oversight by the Adviser’s Compliance Department.

ITEM 12. BROKERAGE PRACTICES Item 12.A.

Broker-Dealer Selection The Adviser has full discretion to select brokers or dealers as well as commission rates at which the transactions for clients are affected. It is the Adviser’s policy to seek best execution at the best terms available with respect to each transaction, in light of the overall quality of services provided to it or its clients. In selecting broker-dealers, and in negotiating commissions, the Adviser considers a variety of factors, including best price and execution, the full range of brokerage services provided by the broker, as well as its capital strength and stability, and the quality of the services provided by the broker. In determining the abilities of a broker or dealer to obtain best execution for portfolio transactions, the Adviser will consider all relevant factors, including the execution capabilities required by the transactions, the ability and willingness of the broker or dealer to facilitate the portfolio transactions by participating therein for its own account; the importance to the account of speed, efficiency and confidentiality; the broker or dealer’s apparent familiarity with sources from or to whom particular securities might be purchased or sold; the reputation and perceived soundness of the broker or dealer; as well as other matters relevant to the selection of a broker or dealer for portfolio transactions for any account. The Adviser will not adhere to any rigid formula in making the selection of the applicable broker or dealer for portfolio transactions but will weigh a combination of the preceding factors. The Adviser will have no duty or obligation to seek in advance competitive bidding for the most favorable commission rate applicable to any particular portfolio transaction or to select any broker on the basis of its purported or “posted” commission rate, but will endeavour to be aware of the current level of the charges of eligible brokers and to minimise the expense incurred for effecting portfolio transactions to the extent consistent with clients’ interests. Although the Adviser will generally seek competitive commission rates, it will not necessarily pay the lowest commission or commission equivalent. Transactions may involve specialized services on the part of the broker or dealer involved and thereby entail higher commissions or their equivalents than would be the case with other transactions requiring more routine services.

When allocating trades to clients, the Adviser must ensure that over time each client is treated fairly and equitably in the execution of transactions. Therefore, trading personnel must ensure that, over time:

Clients are treated fairly as to the securities purchased or sold for their accounts;

Clients are treated fairly with respect to the priority of execution of orders;

Clients are treated fairly in the allocation of trades;

Allocation of trades is done on a timely basis; and

All accounts participating in an aggregated order receive average price and share transaction costs pro-rata.

Item 12.A.1. Research and Other Soft Dollar Benefits

The Adviser receives research services from certain broker-dealers, including research prepared by such broker-dealers, such as transaction cost analysis and analytical product research, as well as from third party sources. In connection with certain broker arrangements, the Adviser’s clients could pay, or be deemed to have paid, a higher commission over execution cost in exchange for these research services. The Adviser has negotiated commission rates with broker-dealers in each market, which are applied uniformly across the Adviser’s client portfolios.

While the Adviser’s US clients do not participate in the Adviser’s formal soft dollar arrangements, the Adviser has non-US clients that participate in formal soft dollar arrangements. From time to time, as part of trade execution, the Adviser will, on behalf of all clients, use brokers with whom the Adviser has such soft dollar arrangements. The Adviser does not retain any Cash / Commission rebates received for transactions executed on behalf of clients for its own account.

I The central dealing team executes with a variety of empanelled brokers, who are each under obligation to provide best execution. The brokers selected by the central dealing team varies according to the requirements of each and every order and these selected brokers may range from large global broking houses (which generally are a good source of liquidity for stocks from all sectors), through to mid-cap specialists, agency, and regional brokers. Some of the brokers used, not only provide effective trading but also offer quality research services. Eastspring Singapore also uses “execution only” brokers and crossing networks. Item 12.A.2. Brokerage for Client Referrals The Adviser does not take into consideration any client referrals from a broker-dealer or third party, either for itself or for a related person. Item 12.A.3. Directed Brokerage The Adviser generally has full discretion in selecting executing brokers for the initiation of security transactions. Certain clients require that all or a portion of their transactions be executed through firms they designate. Such arrangements between the client and the broker(s) are made outside of and independent of the Adviser’s agreement with the client. If clients direct the Adviser to utilize a particular broker, they can be preventing themselves from aggregation with other accounts in block trades and obtaining best price and execution by limiting the Adviser’s ability to negotiate elements of the trade.

management decisions for different accounts are made separately; or (2) determine that bunching or aggregating is not practical. The central dealing team may be able to negotiate a better price and lower commission rate on aggregated trades than on trades for accounts that are not aggregated. Where transactions for a client’s account are not aggregated with other orders, it may not benefit from the better price and lower commission rate. Because of prevailing trading activity, it may not be possible to receive the same price or execution on the entire volume of securities purchased or sold. When aggregation occurs, the various prices may, in the Adviser’s discretion, be averaged and accounts will be charged or credited with the average price. The effect of such aggregation may operate on some occasions to an account’s disadvantage. With respect to securities purchased in an initial public or secondary offering, it is recognized that due to the limited availability of new issues, often it is not possible to achieve a complete allocation for all new issue-eligible accounts on every trade. The Adviser’s policies provide that its portfolio manager and/ or dealer should ensure that no trade allocation unfairly advantages or disadvantages one or more clients or investment strategies over another and that over time such segregated accounts are all traded fairly. As portfolio managers place trades for each mutual fund or separately managed account individually at any time of the day, the central dealing team knows the demand from each individual fund or account prior to execution. As such, pre-allocation of trades is not always applicable. Further, orders received by the central dealing team, before the trading cut off time, are executed through the different trading venues. Any new orders of the same security generated before the cut-off time would be aggregated with the existing working orders with the same characteristics. For such aggregated orders, strict pro-rata allocation will be applied for partial allocations. All trades must be sent via the order management system, prior to execution as this ensures both pre-compliance checks and a full audit trail.

ITEM 13. REVIEW OF ACCOUNTS Item 13.A.

General Description Risk review and control is an important step in the investment process which assists in determining a level of risk consistent with investment mandates and objectives. The Adviser’s portfolio managers responsible for each particular style of management regularly monitor the accounts under their supervision and formally review each account within their style of management as frequently as deemed appropriate for such account (which may be daily, monthly, or quarterly as applicable). Specifically, they review client investment objectives, asset diversification, account performance and market activity. Client profiles are reviewed periodically and may be re-examined upon client request or in the event of a change in prevailing market conditions. The Adviser’s senior investment officers meet periodically with portfolio managers to review, among other things, investment selections and opportunities, market developments and asset allocations. Each investment team is responsible for reviewing and supervising the accounts managed with a particular style, which varies depending on the stipulated investment objectives and restrictions. Quarterly review meetings are held between the Adviser’s Portfolio and Investment Risk oversight functions and portfolio managers to review investment discipline and risk-taking with a data-informed approach focusing on the decision-making reasoning process. Quarterly review meetings are attended by the Chief Investment Officer, Head of Portfolio Research and Analytics, Head of Investment Risk, Heads of the investment teams, Investment Risk Management team or any of their assigned delegate (s). Quarterly review promotes consistency, accountability, and constructive debate, enabling intentional follow‑through and timely course correction. While revisiting past decisions provides oversight, discussions remain explicitly future‑focused and intended to function as ongoing checkpoints rather than isolated quarterly events. The Investment Risk Management team as part of quarterly review, also seeks to analyse portfolio investment performance and if any key risk indicator falls outside the review thresholds, an independent risk review will be carried out by the Investment Risk Management (IRM) team together with Portfolio Manager and his supervisor. Any exception or prevailing risk-taking concerns will get escalated to the Investment Performance Committee (IPC), which is the

executive level forum within the Adviser’s governance framework, for resolution or remediation actions.

Item 13.B.

Factors Triggering a Review Please view the response to Item 13.A.

Proxy Voting Policies – Authority to Vote Companies should have as their objective the maximization of shareholder wealth, thereby contributing to the economy. Shareholders, as providers of equity capital, are the ultimate owners of companies. To the extent not otherwise restricted by the client or investment guidelines, the Adviser seeks to add value for its clients by pursuing an active investment policy through portfolio management decisions, through voting on resolutions at general meetings, and by maintaining a continuing dialogue with the management of the portfolio company. Meetings with portfolio companies will therefore occur on a regular basis. This enables the Adviser to monitor company development over time and assess progress against objectives.

Voting Policy The Adviser follows a principles-based approach. All votes it exercises are considered in the context of the principles as set out in its Responsible Investment policy. As a general policy the Adviser is supportive of the management of the companies in which it invests. However, when companies consistently fail to achieve the Adviser’s reasonable expectations it will actively promote changes. These changes might range from the formulation of a new strategy to the appointment of new management or non-executive directors. An active and informed voting policy is an integral part of its investment philosophy. Voting should never be divorced from the underlying investment activity. By exercising its votes, the Adviser seeks both to add value and to protect its interests as shareholders. The Adviser considers the issues, meet the management if necessary and vote accordingly. It would always seek to discuss any contentious resolutions or retention of a single house view before casting its votes in order to ensure that its objectives are understood and its votes will be cast in the best interests of its investors/clients. To aid the process of making proxy voting decisions the Adviser uses a proxy advisor. The Adviser reviews, from time to time, the policies and guidelines

of the proxy advisor to understand the nature of their recommendations and test their compatibility with the Adviser’s requirements. However, specific policies and advice from the proxy advisor are not applied mechanically. The Adviser always applies its judgment and decides how to vote each resolution on its merits in the context of principles of the Adviser’s proxy policy. Clients may obtain a copy of the Adviser’s proxy voting policies and procedure upon request.

Conflict of Interests From time to time, proxy voting proposals may raise conflicts between the interests of the Adviser’s clients and the interests of the Adviser and its employees. The Adviser takes certain steps designed to ensure, and demonstrates that those steps resulted in, a decision to vote the proxies that were based on the clients' best interest and were not the product of the conflict. Issues raising possible conflicts of interest are referred to Chief Compliance Officer of the Adviser for resolution and, if necessary, escalated accordingly as appropriate.