Hermes Investment Management Limited: investment adviser

At times, under certain circumstances, information barriers may be constructed between or among one or more Federated Advisory Companies, or with EOS, in connection with the sharing of material non-public information related to a security (“MNPI”) or to prevent a person from gaining knowledge that gives rise to a conflict of interest. For example, a portfolio manager may be isolated from learning information about a strategic transaction that Federated Hermes is considering.

Type of Services The Federated Advisory Companies collectively provide advisory services to a variety of separately managed accounts or wrap fee accounts (Managed Accounts), institutional, or high net worth individual, separate accounts (Separate Accounts), registered investment companies, including exchange-traded funds (ETFs) and mutual funds (collectively, Investment Companies), investment companies that are registered under the Investment Company Act of 1940 (Investment Company Act) that offer shares that are not registered under the 1933 Act (as defined below) (Private Investment Companies) and other pooled investment vehicles (Pooled Investment Vehicles).FHI also owns other companies, both in the United States and in certain other countries, such as broker/dealers, investment advisers, management companies, commodity pool operators, and trust companies. HIML primarily provides investment management services to institutional clients, including pensions, Investment companies, charitable organizations, profit-sharing accounts and pooled investment vehicles which are not registered for public sale in the United States (“private funds”). Private funds may be registered for public sale in other jurisdictions such as Cayman Islands, Ireland or the United Kingdom. Currently, interests in the Cayman Island domiciled private funds are made available to US investors that are accredited investors and/or qualified purchasers as those terms are defined under the federal securities laws, or as otherwise permitted under applicable law. Private funds domiciled in Ireland or the United Kingdom are not registered for sale to US investors.

Segregated Accounts Services HIML provides continuous and regular investment supervisory or management services (Investment Supervisory Services) pursuant to which we have discretionary authority over a client’s assets and provide ongoing supervisory or management services with respect to the client’s assets in a range of equities, fixed income, multi-asset and private markets strategies. Such discretionary authority generally does not require prior client consultation. Investments are managed in accordance with an investment management agreement with the Client that describes the Client’s

investment objectives, strategies, restrictions and guidelines. Private funds are managed only in accordance with their own characteristics and are not tailored to any specific private fund investor (each an “Investor”).

Model Portfolio Management Services HIML also furnishes investment advice and recommendations through the provision of model portfolios for some of its investment strategies and provides periodic updates to the model portfolios (“Model Portfolio Management Services”). HIML typically provides these services to investment advisory firms or other managers (“Overlay Managers”), either directly or through turn-key asset management providers that operate platforms or programs in which Overlay Managers participate. These Overlay Managers utilize HIML’s model portfolios and periodic updates, either alone or together with other model portfolios provided by the Overlay Managers or other investment advisers, to manage the assets of the Overlay Manager’s clients. HIML generally does not have investment discretion or trading responsibilities in such arrangements, nor does HIML have an advisory relationship with the Overlay Manager’s clients, and does not manage model portfolios on the basis of the financial situation or investment objectives of individual clients that participate in these programs.

Managed Accounts Services In addition, HIML participates as an investment manager or portfolio manager in certain separately managed account or wrap fee programs (Managed Accounts or Managed Account Programs), through which it provides advisory services to pension plans, charitable organizations, and certain small institutional investors. Managed Account Programs generally are investment programs under which a client is charged a single specified fee for investment advisory services (which could include portfolio management or advice concerning the selection of other investment advisers), execution of client transactions by the program’s sponsor, and custodial services. However, with respect to certain Managed Account Programs, the single Managed Account fee does not cover the cost of execution of client transactions. We receive a portion of the fees paid by the Managed Account client for our services. In Managed Account Programs, clients (with or without the assistance of the sponsors (“Sponsors”) of the Managed Account Program) select or appoint HIML to manage designated client assets in accordance with one or more of our investment strategies. The Sponsors of the Managed Account Programs typically are broker/dealers, financial institutions or other investment advisory firms which sponsor, operate and administer the Managed Account Programs. When providing investment services to Managed Accounts, we typically act as a subadviser to the Sponsors of the Managed Account Programs. The Sponsors typically enter into investment management agreements with clients, and we do not have direct investment management agreements with clients that participate in Managed Account Programs. In all cases, the Sponsors typically provide portfolio manager selection, performance monitoring and evaluation, custody, brokerage and other administrative services (or a combination of these services) to clients. We exclusively provide advisory services to Managed Account Program clients. There are certain

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differences between how we manage Managed Accounts and how we manage other client accounts. For example, when participating in Managed Account Programs, the Sponsor is typically responsible for determining the suitability of the Managed Account Program, including HIML and our investment strategy, for the client. We are usually only responsible for managing client assets in accordance with the designated investment strategy. In certain Managed Account Programs, Sponsors and Platform Providers can limit the information that is available to us about the client, the client’s other investments or risk tolerance, and other information that would be relevant to determining whether the investment strategy or certain specific investments would be suitable for the client. Likewise, we could be restricted by Sponsors and Platform Providers from communicating directly with clients; all communications, including communications with respect to

Hermes Investment Management Limited

Asset Under Management

the clients’ investment objectives, financial condition and reasonable investment restrictions, must usually be directed through the Sponsor or Platform Provider.

As of December 31, 2025, HIML had $24.4 billion in assets managed on a discretionary basis, and $313.2 million in assets managed on a non-discretionary basis.

Direct Lending: A headline management fee of 75bps A performance fee of 10% over a hurdle of SONIA +461.93bps European Direct Lending: A headline management fee of 75bps A performance fee of 10% over a hurdle of Euribor +350bps European Direct Lending II: A headline management fee of 75bps A performance fee of 10% over a hurdle of Euribor +350bps European Direct Lending III: A headline management fee of 75bps A performance fee of 10% over a hurdle of Euribor +350bps European Real Estate Debt: A headline management fee of 60bps Note: fees are subject to negotiation and subject to change. Please refer to “Conflicts of Interest Relating to PerformanceBased Fees” in Item 6 of this brochure for further information regarding actual or potential conflicts of interest that may arise in connection with performance-based fees. Fees are typically charged quarterly in arrears and there are different calculation methodologies as follows: Using the average of the daily NAVs over the period, Using the average of the month end values within the period,

Using the market value of assets on the last trading day of each calendar quarter. In any partial calendar quarter, fees are pro- rated based on the number of days in which the account is open during the quarter. For purposes of calculating HIML’s management fees, the market value of assets in a Segregated Account shall consist of the market value of securities and other investments held in the account and will not be reduced by any margin or other indebtedness of clients with respect to such securities or other investments. Assets of Segregated Accounts that have a business relationship to each other may, at the discretion of HIML, be aggregated for purposes of calculating the management fee applicable to each Segregated Account. In certain circumstances, Segregated Account fees and minimums may be negotiable. To the extent that fees are negotiable, some clients may pay more or less than other clients for the same management services, depending, for example, on account inception date,

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applicable investment mandates or restrictions, total assets under management by HIML or number of related Segregated Accounts. The Equity and Fixed Income Allocation policies ensure that all clients are treated fairly regardless of the fees charged. See Item 12 below, for HIML’s trading policies. Fees are adjusted and/or calculated on a pro rata basis where: (i) the effective date is on a date other than the first Business Day of a calendar quarter; (ii) the effective date of termination of the Agreement is on a date other than the last Business Day of a calendar quarter; and/or (iii) where the applicable percentage changes on a date other than the first Business Day of a calendar quarter. HIML’s fees are typically adjusted to reflect deposits or withdrawals during a quarter, by pro-rating the fees (on number of days) within the quarter to before and after the deposits or withdrawal.

Hermes Investment Management Limited

Clients’ Segregated Account agreements may be terminated in accordance with agreed terms. Typically, a refund of prepaid fees is not applicable as fees are charged in arrears. However, any unearned, pre-paid fees, should they arise, will be refunded. If you have any questions regarding a refund, you may contact your client service representative. In circumstances where HIML has appointed any of its affiliates as a sub-advisor, they will be compensated by receiving a portion of the fees as per the sub-advisory agreement. In addition to management fees payable to HIML, transaction costs will be incurred along with other costs such as custodian fees, brokerage fees, wire transfer and taxes charged by service providers such as custodian, brokers and others.

Model Portfolio Management Fees The fees HIML charges and receives for providing Model Portfolio Management Services generally are asset-based fees that are paid quarterly by, or through, an Overlay Manager, and generally equal a percentage of the total assets (or a portion of the assets) invested by the Overlay Manager in the Overlay Manager’s investment strategy derived from HIML’s model portfolio. For Model Portfolio Management Services, any “breakpoints” at which the percentage charged is reduced generally are measured based on the aggregate AUM managed by the Overlay Manager using our model portfolio(s) (rather than the AUM of any specific Overlay Manager client account). Our fees typically can be negotiated only between the Overlay Manager and us. A client of the Overlay Manager typically pays an advisory fee to the Overlay Manager for the Overlay Manager’s discretionary management. In such cases, the client does not pay a separate fee to us for the Model Portfolio Management Services we provide to the Overlay Manager. HIML receives from the Overlay Manager a portion of the fees paid by the Overlay Manager’s client for its services. HIML is not generally informed of the specific fee arrangements negotiated between each Overlay Manager and the Overlay Manager’s clients. HIML’s fee for Model Portfolio Management Services could either be payable by the Overlay Managers in arrears at or after the end of each quarter for services rendered during the quarter (in which case they are not refundable) or payable in advance of the quarter in which such services are to be rendered. If paid in advance, the Overlay Manager would receive a pro-rated refund in the event that we are terminated. The Overlay Manager also can pro rate fees if a certain amount of assets are contributed to or withdrawn from a client’s account during an applicable period. In any case, any refunding would take place as and when provided in the Overlay Manager’s agreement with us. Clients of an Overlay Manager (or, as applicable, Sponsor or Platform Provider) should refer to their agreements with, and related documentation from, the Overlay Manager (or, as applicable, Sponsor or Platform Provider) for the specific terms and conditions applicable in connection with the refunding of fees charged by the Overlay Manager (or, as applicable, Sponsor or Platform Provider).

Managed Accounts Fees As discussed in Item 4 of this brochure, Managed Account clients typically pay a single fee or fees (a “wrapped fee”) which cover HIML’s services as well as other services provided by the Managed Account Program Sponsor or a Platform Provider. These other services typically include, for example, portfolio manager selection, performance monitoring and evaluation, custody, brokerage and/or other administrative services. The total Managed Account Program fee(s) charged under such programs can be up to 3.00%. Certain Managed Account Program Sponsors or Platform Providers can charge brokerage commission and/or fees separately or as part of the client’s overall Managed Account Program fee(s). Some Managed Account Program Sponsors or Platform Providers could also charge a minimum annual Managed Account Program fee to each client that participates in their Managed Account Program. HIML is not generally informed of the specific fee arrangements negotiated between each Managed Account Sponsor and each client participating in the Sponsor’s Managed Account Program. We receive a portion of the fees paid by the Managed Account client for our services. Our fees for Managed Accounts generally are assetbased fees that are paid quarterly by, or through, the Managed Account Program Sponsor or Platform Provider as a component of the “wrapped fee.” Our fees generally equal a percentage of the total assets in the Managed Account Program for which we provide advisory services. For Managed Accounts, any “breakpoints” at which the percentage charged is reduced generally are measured based on the aggregate AUM that we manage pursuant to a Managed Account Program (rather than on the AUM of any specific client account). In certain Managed Account Programs, our advisory fees could be limited to the Managed Account Program fees actually collected by the Managed Account Sponsor or Platform Provider. Our fees could either be payable in arrears at or after the end of each quarter (in which case they are not refundable) or payable in advance of the quarter in which such services are to be rendered. If paid in advance, our fees typically will be refunded on a pro-rated basis in the event that we are terminated from managing the client’s Managed Account or the Sponsor or Platform Provider terminates its agreement with us. The Sponsor or Platform Provider also may pro rate fees if a certain amount of assets are contributed to or withdrawn from a client’s account during an applicable period. In any case, any refunding would take place as and when provided in the Managed Account Program agreements between us and the Sponsor or Platform Provider. HIML generally will continue to charge management fees during any period that a client, Sponsor, or Platform Provider limits our discretion over the Managed Account. In certain Managed Account Programs, our fees can be billed separately from brokerage, custody and other fees. The Sponsors or Platform Providers that operate the Managed Account Program in which clients participate generally determine:

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side management of client accounts, and the actual or potential conflicts of interest that they present for HIML and our employees and supervised persons. In addition to these conflicts, other actual or Whether and when a client will receive a refund; potential conflicts of interest arise from HIML’s common economic Whether our fees are bundled or unbundled; interests with our affiliates (including the other Federated Advisory Whether brokerage fees will be commission-based; and Companies), our relationships with our affiliates and other persons or entities in the financial industry, and our, and our related persons’, self• The level and frequency of payment of advisory fees interests. We share certain directors/trustees, officers, employees and generally. supervised persons with certain other Federated Advisory Companies, and use shared services with other Federated Advisory Companies. In Reference should be made to the Sponsor’s Managed addition, another Federated Advisory Company may provide equity Account Program brochures and related Managed Account trading services. As used within this section, “we” shall refer to HIML, Program documentation, including the client’s account our employees and supervised persons, and/or our related persons, as documentation, for the specific terms and conditions appropriate. applicable in connection with the Managed Account Given these relationships, as described in further detail below: Programs in which we participate. We have an incentive to act in ways that benefit our affiliates and others in the financial industry with which we have Clients that participate in Managed Account Programs should relationships rather than in the best interests of our clients; be aware that services similar or comparable to those provided and to them as a participant in a Managed Account Program It is possible that our shared directors/trustees, officers, could be available at a higher or lower aggregate cost employees or supervised persons and affiliated service providers, and the other Federated Advisory Companies, face elsewhere separately or on an unbundled basis. The overall similar incentives. cost to a client that participates in a Managed Account Program could be higher than paying HIML’s standard advisory fee for a We generally address actual and potential conflicts of interest in Separate Account, negotiating custody fees with a custodian and one of the following ways: negotiating transaction charges with a broker/dealer payable on a Prohibition: we prohibit the conduct that gives rise to the per-transaction basis, depending upon the level of custody fees and conflict of interest (e.g., insider trading is prohibited under the number of securities transactions in the client’s account. our Code of Ethics); However, most clients that participate in Managed Account Programs would not be eligible (due to the size of the client’s Disgorgement: we give the benefit received to the client accounts) for our Separate Account management services and, (e.g., we will waive or reimburse a Segregated Account client for the client’s share of the advisory fees, if any, paid therefore, could not otherwise become our clients. Other than in to us or the other Federated Advisory Companies by connection with our obligations to seek to obtain best Investment Companies, including no-load funds, Private execution for securities transactions as provided under Investment Companies, or Pooled Investment Vehicles applicable law and the client’s Managed Account advised by us or other Advisory Companies or distributed by documentation, we do not undertake any ongoing Federated Securities Corp. (Affiliated Investment Vehicles) responsibility to assess for any client that participates in a into which we invest client assets); Managed Account Program the value of the services provided Deference: we defer to third parties to act or make by the Managed Account Program Sponsor or Platform decisions (e.g., we will review a matter with the board of Provider. trustees/directors or other governing body (the Board) of an Investment Company or a client or sub-advised client);

Whether HIML’s fees for Managed Accounts are payable in advance or in arrears;

Private Funds Fees

Fees for each private fund are described in its Private Placement Memorandum (“PPM”) or other offering documents. Private funds are charged a management fee based upon commitments and/or NAV. Private funds may also charge a performance fee in line with the relevant fund’s prospectus and/or other offering documents. In addition, there are other costs to the funds such as transaction fees, administration fees and other related expenses which are details in the relevant offering documents. Such charges are exclusive of and in addition to HIML’s management fee and HIML will only receive the management fee. Please refer to “Conflicts of Interest Relating to Performance-Based Fees” in Item 6 of this brochure for further information regarding actual or potential conflicts of interest that may arise in connection with performance-based fees.

Disclosure/Consent: we disclose the conflict of interest to our clients (e.g., we disclose the solicitation arrangement with our affiliate, Federated Securities Corp., and its employee-representatives) or;

Setting a De Minimis Threshold: we set a threshold for a benefit that is considered too small to influence conduct, and is therefore permitted (e.g., we set limits on entertainment and gifts under our Gift & Entertainment policy and permit de minimis political contributions as permitted under SEC Rule 206(4)-5 under the Advisers Act).

Hermes Investment Management Limited

arise in determining how to allocate them. HIML or other Federated We have adopted a Code of Ethics and written compliance policies and Advisory Companies could give advice or take action with respect to procedures that we believe are reasonably designed to prevent, detect investments of one or more clients that may not be given or taken with and cure violations by us and our employees and supervised persons of respect to other clients with similar investment strategies or objectives. the Advisers Act and other applicable federal securities laws. Our Accordingly, clients with similar strategies or objectives may not hold compliance policies and procedures also provide for various auditing the same securities or instruments or achieve the same performance. In and testing of our policies and procedures, which are reviewed no less addition, legal restrictions on the combined size of positions which could frequently than annually as required by SEC rules. Our policy is to be taken for all assets managed by HIML and/or some or all of the other manage client accounts and investment products consistent with Federated Advisory Companies, and the difficulty of liquidating an applicable law and with the other client accounts and investment investment for more than one client where the market cannot absorb products that we manage. The other Federated Advisory Companies the sale of the combined positions, could affect (including in an adverse have adopted the same Code of Ethics and similar written policies and manner) the prices and availability of certain securities or other procedures. (Please refer to “Code of Ethics, Participation or Interest in investments held by or considered for one or more clients. There also Client Transactions and Personal Trading” in Item 11 of this brochure are times when the same portfolio manager manages an Investment for further information regarding our Code of Ethics.) Company (i.e., mutual fund ), Managed Account and other client assets, The following is a further discussion of certain actual or potential and/or provides Model Portfolio Management Services, all with the conflicts of interest relating to (A) performance-based fees, (B) side by same investment style or strategy. This includes, for example, mutual side management and (C) other aspects of our business, and how we funds and Managed Accounts managed in the same style and/or other seek to address these conflicts of interest. institutional investment accounts (e.g., Segregated Accounts, Private Investment Companies, or Pooled Investment Vehicles) managed in the same style, or to the same model portfolio, as Managed Accounts. In Conflicts Relating to Performance-Based Fees certain cases, however, an affiliated Investment Company can invest in HIML and certain of the other Federated Advisory Companies manage another affiliated Investment Company, Private Investment Company or Pooled Investment Vehicle that pays, or that invests in yet another client accounts subject to performance-based fee arrangements, or subject to a performance-based fee in addition to another type of fee affiliated Investment Company, Private Investment Company or Pooled Investment Vehicle that pays, management fees or other fees to HIML (e.g., asset-based fees or flat fees). or other Federated Advisory Companies or their affiliates, in which case clients could bear those fees indirectly, including as part of the Actual or potential conflicts of interest arise in connection with investment return of the affiliated Investment Company, Private charging performance-based fees on certain client accounts while managing other client accounts at the same time for asset-based fees Investment Company or Pooled Investment Vehicle. Please refer to or flat fees. We have an incentive to favor any account for which we or “Conflicts of Interest Relating to Affiliated Investment Vehicles” and other Federated Advisory Companies receive performance-based fees. “Conflicts of Interest Relating to the Selection of Investment Vehicles Used for Cash Management Purposes” in Item 6 of this brochure for For example, when offering investment advisory services to eligible clients for an asset-based fee and a performance-based fee, we could further information regarding actual or potential conflicts of interest have an opportunity to receive greater fees or compensation from the that can arise in connection with investments in Affiliated Investment client accounts or investment products that we charge performance- Vehicles. based fees as opposed to the client accounts that we do not charge performance-based fees (e.g., asset-based fees). As a result, we have The following discusses certain more specific examples of actual or potential conflicts of interest relating to side by side management. an incentive to direct the best investment ideas to, or to allocate, aggregate or sequence trades in favor of, or to otherwise favor (whether in terms of better execution, brokerage commissions, Conflicts Related to Management of Different directed brokerage/trading or otherwise), a client account or Investment Strategies and Certain Pooled investment product that pays a performance-based fee. Investment Vehicles To address these actual or potential conflicts of interest, the Equity and HIML provides investment advisory services to Pooled Investment Fixed Income allocation policies prohibit the consideration of the Vehicles, including private funds. We manage client assets according to compensation or other benefits received by us or our affiliates, or by different investment objectives, policies, strategies, and any of our officers or employees, when allocating trades among limitations/restrictions. In addition to conflicts of interest relating to participating client accounts or investment products. Our Compliance performance-based fees, actual and potential conflicts of interest arise Department reviews and reaffirms these allocation policies annually. from managing client accounts with different investment approaches. For example, it is possible that the various investment approaches could have different investment strategies that, at times, might conflict with one another to the possible detriment of a client’s account. One account could seek to participate in a transaction in which another account could “Side by side management” refers to an investment adviser’s practice have made (or could seek to make) an investment. The two accounts could have conflicting interests and objectives in connection with the of managing different types of client accounts and/or investment transactions, including how they view the operations or activities of the products simultaneously. HIML and our employees and supervised portfolio or issuer, the targeted returns from the transaction, and the persons could have conflicts of interest in allocating their time and services among clients. To address these conflicts, HIML will endeavor timeframe for, and method of, executing the transaction. Client to devote such time to each client as HIML deems appropriate under accounts also can be invested in different parts of an issuer’s capital the circumstances to perform our duties and obligations to each such structure which have different preferences and rights, and thus, disparate interests (e.g., credit quality versus growth potential). Some client in accordance with applicable law and our investment accounts managed by HIML and/or the other Federated Advisory management agreement(s) with each such client. Companies could short securities which we have purchased in other Certain actual or potential conflicts of interest can arise in connection accounts. A concurrent long/short position between one account and with a portfolio manager’s management of an account’s investments another account can result in a loss to one account based on a decision and the investments of other accounts for which the portfolio manager to take a gain in the other account. Taking concurrent conflicting is responsible. To the extent that the same investment opportunities positions in certain derivative instruments also can result in a loss to one might be desirable for more than one account, possible conflicts could client and a gain for another client. Uncovered option strategies,

Other Conflicts Relating to Side-by-Side Management

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portfolio leveraging and significant positions in illiquid securities also regulating investments in Affiliated Investment Vehicles . can result in conflicts of interest for us when managing certain client assets side by side with other client accounts and investment products.

Conflicts of Interest Relating to the Selection of Investment Vehicles Used for Cash Management

To address these actual or potential conflicts of interest, records are maintained regarding the investment and allocation decisions made by When HIML is providing Investment Supervisory Services with respect to our portfolio managers, and our Compliance Department periodically Managed Accounts, Model Portfolio Management Services and certain reviews documentation of allocations in an effort to confirm other accounts, we generally do not have discretion over the selection compliance with allocation policies and procedures. The Compliance of investment.vehicles used for cash management purposes. The Department also periodically monitors against limits or other guidance selection of investment vehicles used for cash management purposes amounts imposed on short sales, derivatives usage, options strategies, will typically be made by, or by an agent appointed by, the client or the leverage and liquidity. Sponsor, Platform Provider or Overlay Manager. Outside of Managed Accounts and Model Portfolio Management Services, we can, in certain cases, be responsible for the selection of investment vehicles used for cash management purposes in a client’s portfolio, or for recommending investment vehicle options to the client, the client’s custodian, or HIML could invest client assets in Affiliated Investment Vehicles (i.e., another agent of the client, subject to the client’s investment policies, Investment Companies, Private Investment Companies or other Pooled guidelines and restrictions, and applicable law. Actual and potential conflicts of interest arise for HIML in connection with the selection of Investment Vehicles) that are advised by us or other Federated investment vehicles used for cash management purposes. Cash is Advisory Companies. These Affiliated Investment Vehicles generally typically invested in money market mutual funds or other liquid pay their investment advisers and service providers based on a investments or cash management vehicles, which could include, in percentage of their average net assets. Accordingly, we have an incentive to invest client assets in these Affiliated Investment Vehicles certain cases, Affiliated Investment Vehicles. For example, since HIML or our affiliates can receive investment in order to increase the compensation that will be paid to us, other advisory fees, other service fees, or other compensation from Affiliated Federated Advisory Companies and/or our other affiliates by these Investment Vehicles, we have an incentive to leave larger cash balances Affiliated Investment Vehicles. in client accounts because the cash balances can be invested in Affiliated Investment Vehicles. However, in connection with Managed Accounts To address these actual or potential conflicts of interest, we invest and Model Portfolio Management Services, we generally do not have client assets in Affiliated Investment Vehicles only when such discretion over the selection of or know the investment vehicles investments are consistent with a client’s investment objectives, policies, guidelines and restrictions, and applicable law. To the extent selected for cash management purposes (as noted above), including whether such cash will be invested in an Affiliated Investment Vehicle. required by applicable law, prior to recommending or making The same is true outside of Managed Accounts and our Model Portfolio investments in Affiliated Investment Vehicles, HIML or our related Management Services when a client’s custodian invests the cash. persons will:

Conflicts of Interest Relating to Affiliated Investment Vehicles

Disclose to the client (or, as applicable, the client’s Board of To address these actual or potential conflicts of interest, we could set Trustees or Directors) the nature of the affiliation; parameters around the amount of cash that remains uninvested for a Obtain the client’s authorization to invest in Affiliated particular Managed Account Program or client account, or our client Investment Vehicles; and could establish such parameters in its investment policies, guidelines Specify in the client’s authorization whether: (a) we or our related persons will charge, waive or reimburse the client for and restrictions. With respect to accounts where we have discretion over the selection of investment vehicles used for cash management advisory fees attributable to investments in Affiliated purposes, we will invest client assets in Affiliated Investment Vehicles Investment Vehicles; or (b) we or our related persons will only when such investments are consistent with a client’s investment waive or reimburse the client for the client’s share of the advisory fees, if any, paid by the Affiliated Investment Vehicle objectives, policies, guidelines and restrictions, and applicable law and we are able to waive or reimburse the client for the client’s share of to us or our related persons. the advisory fee. With respect to certain accounts (e.g., Managed Accounts) where we do not have discretion to select the investment Any client authorization will be in writing (which can include vehicles used for cash management purposes and written Board minutes) and could, to the extent permitted by law, authorization is impracticable, we address this conflict of interest authorize investments in Affiliated Investment Vehicles through disclosure(as noted above). This authorization or disclosure generally. With respect to certain accounts (e.g., Managed could apply, for example as required by applicable law, where Accounts) where written authorization is impracticable, we advisory fees would be paid twice for duplicative services rendered by address this conflict of interest through disclosure. This authorization or disclosure could apply, for example as required HIML or our affiliates. by applicable law, where advisory fees would be paid twice for duplicative services rendered by HIML or our affiliates. In certain cases when HIML is providing Investment Supervisory Services, Model Portfolio Management Services or Other Advisory Services, we can invest (or recommend investment) in an Affiliated Investment Vehicle (such as, for example, to obtain exposure to a particular asset class), and that Affiliated Investment Vehicle could in turn invest its cash in another Affiliated Investment Vehicle for cash management purposes; in that case, Clients could bear advisory and other fees paid by such Affiliated Investment Vehicles to HIML or other Federated Advisory Companies or their affiliates, either indirectly or as part of the investment return of the Affiliated Investment Vehicle, subject to a client’s investment policies, guidelines and restrictions and applicable law. We and our related persons will also comply with the conditions of any applicable law, rule or exemptive order

Conflicts of Interest Relating to Certain Cross Transactions

Hermes Investment Management Limited

Trades can be recommended between client accounts (including There will be times when the same security is being purchased or sold Proprietary Accounts) for various reasons. Such reasons can include an concurrently for multiple client accounts or portfolios. In these opportunity to reduce transaction fees or ability to fill sell and situations, except as discussed below, HIML, and the other Federated purchase orders, when the trade will not disadvantage either client. Advisory Companies, have policies in place which are reasonably (Please refer to “Principal and Cross Transactions” in Item 11 of this designed to commence trade execution as concurrently as practicable, brochure for further information regarding our cross transaction or otherwise in a fair and equitable manner, address potential conflicts practices.) Such cross transactions create actual or potential conflicts of interest and protect client interests. Various factors, however, can of interest between clients, and for HIML and other Federated Advisory result in trades for a client not being aggregated with batched trades for Companies. For example, it is possible that we could seek to effect a other clients of HIML or another Federated Advisory Company and cross trade to create a market to aid the selling account, to the clients receiving a different price, either higher or lower, for the same detriment of the purchasing account. security. For example, certain operational differences inherent in the To address these actual or potential conflicts of interest, neither HIML trade execution process result in trades for certain clients (such as nor our affiliates can receive any compensation for acting as a Managed Accounts and other accounts managed to the same model broker/dealer when we engage in cross transactions. For cross trades portfolio as Managed Accounts) being effected either before or after involving Investment Companies or Private Investment Companies, we trades for other clients. Also, for example and except as discussed follow procedures that comply with SEC Rule 17a-7 under the below, when providing discretionary advisory services to Managed Investment Company Act, and we typically follow similar procedures Account clients, purchases and sales of securities generally are for cross trades between client accounts that do not involve an processed on a rotational basis through the Managed Account Program Investment Company or a Private Investment Company, subject to Sponsor. With respect to our equity investment strategies utilized in other applicable regulatory requirements (e.g., cross trades involving a providing our non-discretionary Model Portfolio Management Services, UCITS fund). When we engage in cross transactions, we maintain we include the Overlay Managers in the trade rotation process for our records regarding each cross transaction, including the price at which discretionary Managed Accounts and we currently communicate model the transactions are effected. Given the monitoring obligations changes to the Overlay Managers during the Overlay Manager’s turn in involved, we generally do not allow client accounts that are “plan the trading rotation. In implementing our trade rotation process, HIML assets” subject to the Employee Retirement Income Securities Act of could allot a period of time, which can be adjusted periodically, for a 1974 (ERISA) to participate in cross trades. To ensure compliance with Sponsor or Overlay Manager to arrange executions for accounts before this requirement, we also maintain a list of accounts that are moving to the next Sponsor’s or Overlay Manager’s turn in the rotation prohibited from participating in cross trades. process. Trades relating to our equity investment strategies may be effected by another Federated Advisory Company. With respect to our fixed income investment strategies utilized in providing our nonOther Conflicts of Interest Relating to Certain discretionary Model Portfolio Management Services, given the Investments and Brokerage Practices operational aspects inherent in trading fixed income securities, decisions with respect to changes in fixed income model portfolios depend upon the availability of fixed income securities in the market; as a result, we communicate fixed income model changes to Overlay Managers as concurrently as practicable (outside of our trade rotation process) to commencing trading with respect to the Managed Accounts we manage on a discretionary basis. The Overlay Managers have discretion to accept or reject our recommended model portfolio changes and trades will be executed in accordance with the Overlay Manager’s policies and procedures, which could result in trades for Overlay Manager clients being effected before, after or at the same time as trades for other HIML clients. Managed Account Programs that require directed brokerage/trading (and other clients who direct brokerage/trading) can instruct that client transactions be executed through specific broker/dealers. Except as discussed below, the other Federated Advisory Companies have adopted similar policies. Taking these scenarios and factors into account, HIML and the other Federated Advisory Companies, have procedures in place which we believe are consistent with our duty to seek to obtain best execution of client trades and designed to treat clients fairly and prevent clients from being systematically favored or disadvantaged. Trades for a client that has directed use of a particular broker/dealer are typically placed at the end of aggregated trading activity. There can be no assurance that each client will receive the same price for a security, and, depending upon the circumstances, different clients could receive different prices, either higher or lower, for the same security.

Conflicts of Interest Relating to Receipt of Compensation or Benefits, Other than Advisory Fees Actual or potential conflicts of interest arise to the extent that HIML, or our affiliates (e.g., the other Federated Advisory Companies), or any of their respective employees, supervised persons or other representatives, receive compensation or benefits other than advisory fees. Additional compensation or benefits could be received by us or our affiliates, for example, for: Soliciting business for other Federated Advisory Companies;

ADV Part 2A Brochure – March 2026

Providing investment advice on behalf of another investment section for further information.) The allocation policies prohibit the consideration of the compensation or other benefits received by us or adviser; our affiliates, or by any of our officers or employees, when allocating Providing services to another investment adviser or trades among participating client accounts. This includes a prohibition investment product; Selling, marketing or distributing mutual fund or ETF shares on investment personnel from considering an intermediary’s sale of Federated Hermes mutual funds when allocating trades to or other investment products or services or acting as a broker/dealers. placement agent; Directing brokerage/trades to a particular broker/dealer; Conflicts of Interest Relating to Personal Trading Providing stewardship services, including engagement on corporate governance ,environmental, social, matters. HIML, and/or our employees, supervised persons and related persons We, or our affiliates, also could have other relationships with (e.g., the other Federated Advisory Companies), can invest in the same broker/dealers, commodity pool operators, commodity trading securities, or related securities, that we or our related persons invest in advisors, trust companies, other investment advisers and others in the on behalf of, or recommend to, clients, including at or around the same financial industry that benefit us or our affiliates. (Please refer to time, which can create conflicts of interest. These practices can create “Relationships with Broker/Dealers” in Item 10, and “Client Referrals actual or potential conflicts of interest for HIML and our employees, and Other Compensation” in Item 14 of this brochure for further supervised persons and other related persons. For example, our information.) portfolio managers could make a personal investment in a thinly-traded Additional compensation or other benefits create an incentive to security and then invest large quantities of client assets in that same recommend or favor our interests, and the interests of our affiliates, security in order to drive up the value of that security or our portfolio Affiliated Investment Vehicles (e.g., the Federated Hermes Investment managers could sell a personal investment in a security in advance of Companies), and other products or services, based on the selling clients’ positions in such security if the selling of clients’ positions compensation that will be received. For example, certain of our in such security would drive the value of the security down. directors/trustees, officers or supervised persons could be officers of To address these actual or potential conflicts of interest, internal the Federated Hermes Investment Companies, Private Investment controls, including our Code of Ethics, are designed to prevent HIML Companies, or Pooled Investment Vehicles sponsored by FHI, our from buying or selling securities contemporaneously with client ultimate parent company. Federated Securities Corp. can receive transactions in a manner likely to disadvantage the client. For example, compensation for the sale of fund shares or other services or products. although our Code of Ethics permits investment personnel to trade in If an intermediary’s (such as a broker/dealer’s) customers represent a securities, including those that could be recommended to clients, it significant number of the shareholders of, and assets in, a Federated contains safeguards designed to protect clients from abuses in this area, Hermes fund, we can have an incentive to favor that intermediary. We such as requirements to obtain prior approval for (i.e., preclearance), would have a similar incentive with respect to a solicitor or promoter and to report, particular transactions. No employee can execute a who referred clients to us or another Federated Advisory Company, or personal transaction, directly or indirectly, in any covered security and any other intermediary or service provider that otherwise provides a no preclearance will be granted, when he or she knows, or should have material source of revenue for us or our related persons. We can have known, that the covered security is being considered for purchase or an incentive to execute brokerage transactions through the Managed sale, or purchased or sold, by or for a client account. In addition, Account Program Sponsor or Platform Provider (or an affiliated portfolio managers and research analysts identified as serving a client or broker/dealer), which in turn has the power to recommend us to group of clients are prohibited from purchasing or selling any covered Managed Account Program clients. Outside of Managed Accounts, our security for which there is an open “buy” or “sell” order or any covered willingness to direct brokerage/trades to a particular broker/dealer security that has been purchased or sold by or for those client accounts when instructed to do so by clients likewise can encourage a within fifteen (15) calendar days before or after the security is broker/dealer to refer business to us or our related persons, resulting purchased or sold if the aggregate related open “buy” or “sell” orders in higher advisory, servicing or other compensation or other benefits. and/or purchases or sells of that covered security by those accounts are Whilst HIML does not generate soft dollars and pays for its own thereafter determined to have been of an amount sufficient to trigger a investment research, certain FHI Advisory Companies could receive blackout period. All such transactions will trigger a blackout period, and “soft dollar benefits” from certain broker/dealers, as disclosed to this provision supersedes any prior preclearance. Investment personnel clients. The receipt and use of brokerage and research services also who are not among the portfolio managers and research analysts creates various conflicts of interest for HIML and our related persons. identified as serving client accounts, as provided above, may not For example, we could have an incentive to select broker/dealers purchase or sell a covered security within seven (7) calendar days after based on our interest in receiving research or other products or one or more open “buy” or “sell” orders are placed and/or purchases or services, rather than on our clients’ interest in receiving most favorable sales are made for the client accounts in the same covered security in an execution. (Please refer to “Sales Compensation” in Item 5, amount sufficient to trigger a blackout period, subject to any prior “Relationships with Broker/Dealers” in Item 10 and “Research and preclearance. All other employees may not purchase or sell a covered Other Soft Dollar Benefits” in Item 12 of this brochure for further security on any day during which one or more open “buy” or “sell” information.) Given the differences in the structure of certain accounts, orders are placed and/or purchases or sales are made for the client Investment Companies, Private Investment Companies and other accounts in the same covered security in an amount sufficient to trigger Pooled Investment Vehicles, as well as the terms of applicable a blackout period, subject to any prior preclearance. The Code of Ethics investment management and other service agreements. and other compliance procedures also contain certain restrictions on To address these actual or potential conflicts of interest, we will invest insider trading and misuse of customer information. (or recommend the investment of) client assets in Affiliated Investment Vehicles only when such investments are consistent with a client’s Conflicts of Interest Relating to Voting Securities investment objectives, policies, guidelines and restrictions. Also, we Held in Client Accounts will waive or reimburse a Segregated Account client for the client’s share of the advisory fees, if any, paid to us or the other Federated Advisory Companies by an Affiliated Investment Vehicle into which we As discussed under “Voting Client Securities” in Item 17 of this brochure, invest the client’s assets as required by our policies and applicable law. HIML will accept the authority to vote securities held in client accounts. Conflicts of interest arise from time to time between the interests of (Please refer to “Conflicts of Interest Relating to the Selection of HIML, and our affiliates (e.g., the other Federated Advisory Companies), Investment Vehicles Used for Cash Management Purposes” and “Conflicts of Interest Relating to Affiliated Investment Vehicles” in this and the interests of our clients. HIML has adopted procedures to

Hermes Investment Management Limited

address situations where a matter on which a proxy is sought can Advisory Companies retain EOS to provide stewardship services, EOS present a potential conflict between the interests of the client and could benefit from the opportunity to represent the Federated Advisory those of HIML or our affiliates. (Please refer to “Voting Client Companies, with respect to these services in the aggregate, and Securities” in Item 17 of this brochure for a discussion of these conflicts consequently broaden the scope of its business. From time to time, of interest and how they are addressed.) (Please also refer to “Conflicts certain FHL Advisory Company clients could receive a discount if they of Interest Relating to EOS” in this section for further information.) also engage EOS to provide services. For example, certain FHL Advisory Company clients may engage EOS to provide services at a discount. The Conflicts of Interest Relating to Information Sharing cost of these services could increase if such a client were to terminate its arrangement with the FHL Advisory Company, or if the FHL Advisory Among Affiliates Company were to terminate its services to the client. In addition, while FHL Advisory Companies obtain proxy voting reports and Actual or potential conflicts of interest could arise to the extent that recommendations from EOS as part of its stewardship services, unless HIML, or our affiliates (e.g., the other Federated Advisory Companies requested otherwise by the client or disclosed in fund disclosure and EOS), share material non-public information (MNPI). At times, documents, the voting of proxies is subject to the FHL Advisory under certain circumstances, information barriers may be constructed Companies’ Proxy Voting Policy. (Please refer to “Voting Client between or among one or more Federated Advisory Companies, or Securities” in Item 17 of this brochure for additional information.) with EOS, in connection with the sharing of MNPI or to prevent a Federated Advisory Companies can request that some or all of their person from gaining knowledge that gives rise to a conflict of interest. holdings not be included in any EOS advocacy with an issuer, such as For example, a portfolio manager may be isolated from learning when the advocacy is not consistent with a particular mandate, information about a strategic transaction that Federated Hermes is investment policy or strategy. While there is no intent on the part of the considering. The Federated Advisory Companies, and EOS can share Federated Advisory Companies to act jointly with other EOS clients to internally-generated reports published by them and insights from influence or control the management or policies of an issuer, it is also engagement interactions prepared by EOS that do not contain MNPI or possible that certain stewardship services entered into by EOS could be information regarding non-public holdings or trading for client viewed as joint action by EOS and/or its clients, including the Federated accounts. Engagement is undertaken to seek to improve long-term riskAdvisory Companies, which could impose certain reporting and other adjusted returns of issuers or companies, and to create long-term requirements under applicable securities laws. EOS and the Federated value for clients and investors, consistent with applicable fiduciary Advisory Companies seek to mitigate this potential conflict of interest duties and fund and investor objectives. The level of engagement with through policies that provide that the Federated Advisory Companies a company can be subject to any limitations required, either explicitly generally will not direct EOS with respect to the companies with which it or implicitly, in the jurisdiction in which a company is domiciled in an engages or specific positions that inform its engagement. EOS also effort to comply with applicable law and/or to avoid legal or regulatory maintains policies and procedures related to client engagement and risk for a fund and/or investors. In addition, certain Federated Advisory voting recommendations that are intended, in part, to limit the Companies manage portfolios of private equity investments, and in reporting obligations of EOS and its clients under U.S. securities laws. connection with conducting assessments of and/or holding control positions in such issuers, could come into possession of MNPI with Other Conflicts of Interest respect to the issuers and potentially other issuers with which they have material business connections. To the extent that the Federated In addition to the above described conflicts of interest, actual or Advisory Companies elect not to maintain information barriers to potential conflicts of interest can arise in the following areas, among compartmentalize such MNPI, HIML and/or the other Federated others: Advisory Companies could be prohibited from investing in or selling positions held in such issuers. While there is integration of operations Portfolio managers’, traders’ and other supervised persons’ between the FHL Advisory Companies and the other Federated relationships with counterparties, issuers, and obligors, Advisory Companies, there could be limitations surrounding the including entertainment and gifts received from counterparties, issuers or obligors, political and charitable integrated activities. Neither entity will exercise investment discretion over accounts managed by the other, except that the FHL Advisory contributions, and positions on boards of directors/trustees; and Companies could provide subadvisory services for certain clients of other Federated Advisory Companies, and other Federated Advisory Specific compensation arrangements relating to portfolio Companies could provide subadvisory services for certain clients of the managers, traders and other supervised persons. FHL Advisory Companies. It is possible that future investment products could be mutually developed or that specific engagements could be Portfolio manager and trader relationships with counterparties must be entered into that may alter this arrangement. There may be instances disclosed to our Compliance Department and they are monitored on an where information barriers will be implemented when deemed ongoing basis. Our Code of Ethics addresses entertainment and gifts, as appropriate, such as when conflicts of interest are identified. well as when portfolio managers, traders and other supervised persons can make or solicit political or charitable contributions or serve on boards of directors/trustees. (Please refer to “Our Code of Ethics” in Item 11 of this brochure for further information.) Conflicts of Interest Relating to EOS Actual or potential conflicts of interest can arise to the extent that the Regarding specific compensation arrangements for portfolio managers, Federated Advisory Companies engage EOS to provide some or all of its traders and other supervised persons, compensation arrangements stewardship and engagement services in connection with Investment generally can contain a fixed salary component and a variable incentive Supervisory Services provided by the Federated Advisory Companies. . amount determined primarily on the performance of investment Engagement is undertaken to seek to improve long-term risk-adjusted accounts, strategies and/or funds/products (accounts), which can be paid in cash or a combination of cash and restricted stock of FHI. In returns of issuers or companies, and to create long-term value for certain cases, certain portfolio managers, traders or other supervised clients and investors, consistent with applicable fiduciary duties and fund and investor objectives. The level of engagement with a company persons can be eligible for certain annual payments based on can be subject to any limitations required, either explicitly or implicitly, revenue. Compensation arrangements can create actual and potential conflicts of interest, including, among others, with respect to the in the jurisdiction in which a company is domiciled in an effort to comply with applicable law and/or to avoid legal or regulatory risk for a amount of time allocated to the accounts for which a portfolio manager, fund and/or investors. For example, to the extent that the Federated trader or other supervised person is responsible and the allocation of

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investment opportunities among accounts managed by HIML and the other Federated Advisory Companies. Other potential conflicts relating to compensation can include, for example, conflicts created by calculations within specific investment professional compensation arrangements. Under certain compensation arrangements, the treatment of the accounts (or other activities) for which a portfolio manager, trader or other supervised person is responsible can vary (and can be adjusted periodically). This includes, for example, the weighting that is given to the performance of each account (or other activity) for which a portfolio manager, trader or other supervised person is responsible when compensation is calculated; the weighting assigned to the performance of an account (or other activity) can be greater than, equal to and/or lesser than the weighting assigned to the performance of other accounts (or other activities), and can be adjusted periodically. The conflicts that can result from these compensation considerations generally are addressed by the written compliance policies and procedures and the Code of Ethics implemented by the Federated Advisory Companies and through the structuring of compensation arrangements.

Instead, as discussed in Item 4 above, Managed Account clients will enter into an investment management and/or other agreements with the Sponsor or Platform Provider for the Managed Account Program. Minimum investment can vary depending on the investment strategy, but generally HIML requires a minimum investment of $50 Million to open a Segregated Account and all mandates must meet a minimum revenue requirement of$200,000. HIML’s target account size for Managed Account

Program accounts is $100,000 for Equity Accounts and $250,000 for Taxable Fixed Income Accounts. Certain asset classes can require larger account minimums to seek proper diversification. The minimum account sizes for Managed Account Programs also can differ based on the requirements of the program Sponsors, Platform Providers or Overlay Managers.

Equity HIML equity strategies encompass a variety of investment objectives and styles including value, growth & blend across different geographical regions such as emerging markets, Asia, US & global equities and different market capitalization. The Investment teams use several methods for asset selection which include fundamental analysis, quantitative analysis & qualitative analysis or combinations of all. The teams will use either a bottom-up or a top-down approach or both in their investment process, to identify and buy quality stocks that are attractively priced. The teams will also integrate ESG along with other factors including business model, financials, cash flow and growth prospects into their investment processes. ESG integration is delivered through HIML proprietary ESG tools. The Investment teams also have access and collaborate with EOS at Federated Hermes Limited (“EOS”) staff who provide stewardship services in respect of the portfolios. As discussed under “Conflicts of Interest Relating to Information Sharing Among Affiliates” in Item 6, information barriers have been implemented to prevent the exchange of material non-public information among the Federated Advisory Companies, and EOS.

Top-down analysis is applied to assess the general credit market and sector condition which determines the overall appetite for credit risk across the portfolios, how the team wants to allocate that risk and depending on the nature of the strategy, whether to employ any defensive or hedging strategies. The core consideration for the research process is the analysis of the issuer’s ability to fulfil its financial obligations and ESG related risks. Experienced portfolio managers/analysts operate on a sector responsibility basis which includes both investment grade and sub-investment grade issuer coverage, and information sharing with HIML’s equity teams. The Investment teams also have access and collaborate with EOS staff who provide stewardship services in respect of the portfolios.

Real Estate HIML Real Estate team provides client-focused property investment solutions through segregated and pooled structures that invest in real estate and real estate debt. The investment process adopts a top-down portfolio risk management and bottom-up property selection to capitalize on mismatch between price and value by targeting assets that are highly competitive within their local marketplaces and which have sustainable income streams. The team seeks to maximize performance on a risk-adjusted basis.

Direct Lending The teams will use a variety of sources in the screening and selection process including proprietary screening tools, thirdparty research materials, meetings with company management and industry & sector analyses. Risk management and monitoring is embedded in the selection and ongoing portfolio monitoring processes using different risk measures and proprietary systems as well as an investment risk oversight role performed by the Investment Risk team.

Fixed Income HIML Credit’s investment philosophy is focused on capital stability and consistency of returns rather than a series of highs and lows. By investing on a global basis, the team seeks to capture valuation anomalies across various geographic jurisdictions and to capture valuation anomalies that exist within the debt capital structure of companies and across all available debt instruments. HIML Credit team uses an active, research-intensive investment process to seek superior risk-adjusted returns through top-down and bottom up analysis. The portfolio construction process includes market risk, default risk, rating migration risk and proprietary rating.

The Direct Lending team aims to provide attractive risk adjusted returns to investors, yielding a stable income stream and preserving investors’ capital by taking a conservative approach to the asset class. The team invests in seniorsecured loans to a diverse range of UK and European midmarket businesses. The team undertakes bottom-up fundamental credit analysis of each potential investment, including undertaking management presentations, analyzing financial and commercial due diligence on borrowers and assessing the legal structure, ownership and loan terms. Following execution, the performance of each borrower is monitored and evaluated: the borrowers report on the company’s performance, usually monthly, and every quarter the company is subject to maintenance covenant tests.

Real Estate Debt The Real Estate Debt strategy aims to provide attractive risk adjusted returns to investors by investing in a diversified portfolio of senior, whole and mezzanine loans secured on real estate, including, but not limited to, office, retail and logistic assets located in Europe. The team will apply a bottom-up fundamental credit analysis in constructing the portfolio of Investments. ESG considerations will also form part of the portfolio construction and risk management, the team will seek to invest in loans secured by real estate that meets its requisite ESG criteria and, as appropriate, will actively engage with sponsors behind each borrower. The team will also carry out post investment monitoring focusing on the underlying performance of borrowers and their assets against

ADV Part 2A Brochure – March 2026

expectations as well as analyzing any ESG risks or issues that may arise during the life of the loan and updating the Investment’s ESG score.

Equity specific risks

In addition to the aforementioned strategies, HIML may, at any time, offer additional strategies which will broadly be similar in their methods of analysis and investment to those described here.

Style-specific risk – This is the risk of loss associated with a particular investment style, for example, growth stocks tend to be more volatile whereas value stocks tend to be more stable.

Risks

Equity security risk – This is the risk that the equity security’s value declines due to changes in its price due to declines in the company’s prospects or its industry or sector.

Company size risk – This is the risk of loss associated with the size of the company invested in, for example, small and medium companies tend to be more volatile and less liquid than larger ones.

As with all investments, the strategies outlined above are exposed to many risks and the value of investments and income from them may go down as well as up, and investors may not get back the original amount invested. Performance targets cannot be guaranteed, and past performance is not a reliable indicator of future result.

Fixed Income/Direct Lending/Real Estate Debt specific risks

Market risk – This is the risk of experiencing losses due to factors affecting the overall performance of the financial markets,

Default risk – This is the risk of loss from the issuer of a security not being able to make payment of interest or principal.

Liquidity risk – This is the risk that an investment held cannot be traded quickly enough to prevent or minimize loss.

Interest rate risk – This is the risk that a change in interest rate has an adverse effect on the values of the assets held.

Credit risk – This is the risk of loss resulting from a borrower’s failure to repay a loan.

General risks

Currency risk – This is the risk that return on investments in foreign securities are lower due to fluctuations in foreign exchange rates.

Country risk – This is the risk of experiencing losses or lower returns due to political, social & economic developments in the country or adverse government actions such as nationalization. This can arise when investing in foreign countries particularly less developed ones.

Regulatory/Legal risk –This is the risk that changes in laws and regulations such as restrictions on assets or activities will negatively impact the value or marketability of an investment.

Operational risk – This is the risk of loss resulting from failures in internal procedures, people and systems.

Cybersecurity risk – This is the risk of disruptions causing the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs associated with Cybersecurity failures or breaches of HIML or its service providers or the issuers of securities in which HIML’s has invested.

Counterparty risk – This is the risk of loss from the failure or inability of a counterparty to a transaction to meet its contractual obligations.

Leverage risk – This is the risk of incurring greater losses and increased volatility due to the use of leveraged financial instruments such as derivatives.

ESG risk – An environmental, social, or governance event, or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Real Estate/Real Estate Debt specific risks

Real estate valuation risk – Real estate valuations require a degree of subjective analysis of the fair market value of the underlying assets therefore, there are no guarantees that the value of the investments held will be accurate on a given date nor that the sale of any property will be at a price equivalent to its last estimated value.

This is not an exhaustive list and risks applicable to a strategy or Client’s account will depend on the investment objective, style, guidelines and type of securities held. These will be described in more details in any presentations, prospectuses and marketing materials provided and discussions held with clients.

As discussed under in Item 4 of this brochure, HIML is an affiliate through common ownership with Federated Securities Corp., a dually-registered investment adviser, municipal securities dealer and broker/dealer. Federated Securities Corp., 1001 Liberty Avenue, Pittsburgh, PA 15222, acts as distributor of the registered Investment Company and Private Investment Company clients of affiliated advisers (i.e., the other Federated Advisory Companies) and as placement agent for Pooled Investment Vehicle clients of other Advisory Companies. (Please refer to Item 6 of this brochure for additional information regarding Federated Securities Corp.’s other activities and related arrangements.) The following management persons of HIML are registered representatives of Federated Securities Corp.: Jane Lambesis is listed on the Part 1 of HIML, as someone having indirect control of the management or policies.

Rich Novak listed as a Director of HIML

HIML also has certain related persons who are general partners, members or trustees of certain family limited partnerships, limited liability companies or trusts or similar family entities. From time to time, these family entities can invest in companies (such as broker/dealer) that participate in the financial services industry. (Please refer to “Performance-Based Fees and Side by Side Management” in Item 6 of this brochure for a discussion of conflicts of interest that arise as a result of these relationships.)

Relationship with other advisers As per its ownership structure outlined in item 4, HIML is affiliated through common ownership with the following SECregistered investment advisers:

Hermes GPE LLP (“HGPE”)

Hermes GPE (USA) INC (“HGPE USA”)

Federated Advisory Services Company

Federated Hermes (UK) LLP

Federated Investment Management Company

Federated Investment Counselling

ADV Part 2A Brochure – March 2026

Federated Equity Management Company of Pennsylvania

Federated Global Investment Management Corp

Federated MDTA LLC

Federated Securities Corp.

Hermes Fund Managers Ireland Limited (“HFMIL”) (an Exempt Reporting Advisers)

HIML along with HGPE & Federated Hermes (UK) LLP are also authorized and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom. Additionally, HIML is also affiliated with the following foreign advisers:

HGPE Singapore Pte Limited which is licensed with the Monetary Authority of Singapore (“MAS”).

HFMIL which is authorized and regulated by the Central Bank of Ireland (“CBI”).

Federated Investors Australia Services Ltd which is authorized and regulated by the Australian Securities and Investments Commission.

Federated Hermes Japan Ltd which is authorized and regulated by the Japan Financial Services Agency.

HIML provides portfolio management services to HFMIL’s range of funds and has Service Level Agreements (SLAs) with and shares some directors and other employees with FHL Advisory Companies. All FHL Advisory Companies have common compliance policies and procedures. Additionally, HIML can provide sub-advisory services for certain clients of the FHI Advisory Companies, and the FHI Advisory Companies can provide sub-advisory services for certain clients of the FHL Advisory Companies including HIML. Please refer to “Conflicts of Interest Relating to Affiliated Investment Vehicles” and “Conflicts of Interest Relating to the Selection of Investment Vehicles Used for Cash Management Purposes” in Item 6 of this brochure for further information regarding actual or potential conflicts of interest that can arise in connection with investments in affiliated investment vehicles.

Other relationship HIML is also affiliated with EOS, an unregulated company that provides stewardship services to HIML and other thirdparty clients. From time to time, certain HIML clients may engage EOS to provide services at a discounted rate. The cost of such EOS services could increase if the clients were to terminate their arrangement with HIML, or HIML were to terminate its services to the clients. HIML has controls in place to address the conflicts of interest arising from the relationships discussed above such as information and operational barriers between itself and its affiliates.

As such, it is HIML’s expressed policy, as reflected in the Code, that no employee shall prefer his or her own interest to that of a Client or make personal investment decisions based on investment decisions made on behalf of Clients. All employees must acknowledge the terms of the Code annually, or as amended. Subject to satisfying applicable requirements set forth in the Code, and applicable laws, employees can trade for their own accounts in securities which are recommended to and/or purchased for clients. Item 6 of this brochure, “Performance-Based Fees and Side by Side Management”, contains a detailed discussion of HIML’s Code of Ethics and how it addresses conflicts related to HIML’s participation or interest in client transactions and personal trading. (Please refer to “Conflicts of Interest Relating to Personal Trading” in Item 6 of this brochure for further information regarding our Code of Ethics.)

Hermes Investment Management Limited

Under the Code of Ethics, certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of clients. The Code requires preclearance by Compliance of all non- exempt personal account transactions so that such transactions are consistent with policies and procedures set forth in the Code. Furthermore, personal trading by employees is monitored by Compliance to reasonably detect and prevent conflicts of interest between the personal interests of such employees and the interests of clients. To permit such monitoring, all employees are required to provide quarterly securities holding reports to Compliance relating to all securities held in, or transacted on behalf of, their personal accounts.

Conflicts of interest Examples of Conflicts of Interest that have been identified are as follows:

There could be a conflict where a member of staff or a related person deals in securities on his/her personal account that the firm buys or sells for clients. To mitigate this, HIML requires staff members to pre-clear transactions in their personal account and implement a monitoring test designed to detect front-running.

There could be a conflict where either member of staff are offered lavish hospitality by prospects to secure deals or are offering similarly extravagant hospitality to prospects. To mitigate this, HIML has in place a Gifts & Entertainment policy and procedure designed to manage the risk by requiring disclosure and preclearance of gifts and hospitalities sent and received by staff. There could be a conflict between a member of staff’s interests and HIML or its clients’ interests arising from that employee outside activities. HIML has put in place an Outside Business Interests policy and procedure which require disclosure and pre-clearance before employees can take up any Outside Business Activity. There could be a conflict where a HIML fund or segregated account invests in another affiliate fund. This could occur where cash held in one HIML fund/segregated account is swept into another affiliate Money Market Fund, as part of cash management where the investment restrictions allow and both funds have an annual management charge. This is mitigated as no management fee will be charged for the investment made by the HIML fund/ segregated account. Please refer to “Conflicts of Interest Relating to Affiliated Investment Vehicles” and “Conflicts of Interest Relating to the Selection of Investment Vehicles Used for Cash Management Purposes” in Item 6 of this brochure for further information regarding actual or potential conflicts of interest that could arise in connection with investments in affiliated investment vehicles. There could be a conflict to the extent that HIML or its affiliates (e.g., the FHL Advisory Companies, the other Federated Advisory Companies and EOS) share material non-public information (MNPI) in relation to a security or transaction. At times, under certain circumstances, information barriers may be constructed between or among one or more Federated Advisory Companies, or with EOS, in connection with the sharing of MNPI or to prevent a person from gaining knowledge that gives rise to a conflict of interest. For example, a portfolio manager may be isolated from learning

information about a strategic transaction that Federated Hermes is considering. A copy of the Conflicts of Interest policy is available on our website. An existing or prospective Client can obtain a copy of the Code of Business Conduct and Ethics upon request.

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Item 12 – Brokerage Practices Broker-Dealers Selection Criteria Depending on the terms of the Client’s agreement with HIML, HIML is generally given authority to make the following determinations without obtaining Client consent before effecting transactions:

Which securities are to be bought and sold;

The total amount of the securities to be bought or sold;

The broker or dealer through whom securities are to be bought or sold and;

The commission rates or prices at which securities transactions for client accounts are effected.

HIML uses the Central Dealing Desk model to ensure a separation of duties. Portfolio managers are responsible for the investment decision to trade which is then routed to the Central Dealing Desk for execution. The Central Dealing Desk is made up of a team of experienced dealers with a wide knowledge of the markets and instruments the firm deals in. It is their job to focus on achieving the best possible execution of trades on behalf of clients. Orders transmitted to the Central Dealing Desk are passed on to third parties to execute in the relevant financial markets. For equity investment teams the Central Dealing Desk operates a hybrid dealing model using both internal dealing desks and an outsourced external dealing desk operated by CF Global Trading UK Limited (‘CF Global’). CF Global execute orders for trades in the APAC and MEA regions in alignment with our Policy. Hermes Investment Management Limited and other Federated Advisory Companies are the entities trading on behalf of clients for jurisdictions and instruments not traded by CF Global. This hybrid model provides local market coverage for markets which operate outside of standard UK business hours. we have oversight over and monitors the quality of execution of all orders placed by CF Global. The Counterparty Credit Risk Summary Policy sets out the framework to monitor and manage counterparty credit risk. Separate processes exist to identify and approve Trading Counterparties prior to utilization. The distinction between a Broker/Dealer (“B/D”) and a Trading Counterparty lies in the types of transactions being executed and the level of credit exposure to that entity that exists. Equally, an assessment of the counterparty’s risk profile is undertaken commensurate to the level of trading risk. B/D related transactions are done on a delivery vs. payment basis (DVP), in which the risk of not receiving either monetary value or securities is low. This would also include margined forward settling U.S. Agency and Non-Agency MBS transactions. The risk to an Executing Broker, where the roles of an Executing Broker and Clearing Broker are bifurcated, would also be viewed similarly. Transactions executed with a Trading Counterparty (Non-DVP), for example margin, free delivery, or unmargined extended settlements; or acting as a Clearing Broker can include additional risks, such as a higher risk of not receiving either monetary value or securities.

While the standard B/D approval process is robust, the Trading Counterparty approval process establishes a higher standard, as

many of the transaction types identified can expose the funds/ segregated accounts directly to the Trading Counterparty. The process used to determine a “minimal credit risk” for unsecured credits within Federated Hermes money market fund franchise is the same process and standard used in approving and monitoring Trading Counterpart. The process of taking on new counterparties will normally be initiated by trading or Investment Management to the applicable Desk head or Global Investment Operations (GIO). The requests will be in writing and include a justification on best execution for an asset class or specific security and any additional relevant information about the B/D. Additional applicable criteria may be included (e.g. Regulatory requirements etc.), however not at the expense of obtaining best execution.

Global Trade Services Team reviews the full legal name of the broker as it is known to its underlying regulatory body; the name of its regulator and its regulatory identifier (FINRA, FCA, SEC, etc.); the Broker’s Legal Entity Identifier (LEI), the last three years’ worth of audited financial statements and, if applicable, the last two - three years’ worth of Focus Report and depending on the domicile of the B/D entity, either the current W9 or W8 tax form.

Compliance conducts an internal review including highlighting significant or non-standard results for additional review. Compliance focuses on confirming that the proposed B/D does not present risks from an AML perspective and/or a reputational risk perspective. This review may include, but is not limited to checking for economic sanctions, evaluating key individuals, seeking identity information for the company, and considering any negative news about the B/D. Compliance maintains applicable processes, policies, and procedures based on the requirements of the regulator governing the entities seeking to engage with the B/D.

The Global Liquidity Group conducts a review of the B/D’s financial statements, as well as additional research to evaluate the B/Ds ability to function as a going concern to execute and timely settle DVP trades. Baseline criteria for the evaluation will include current and recent trends in net income, capital, capital market activity and any additional information relating to operational functions that may impact the ability of the B/D to timely settle trades.

If the B/D is not approved, the requesting Trader and relevant other parties will be notified. If the B/D is approved, the approval will be sent to Legal for completion of any required contracts / agreements, and subsequently, instructions will be issued to set up the entity within the broker database.

Trading Counterparty Approval (Non-DVP transactions) If a Trader identifies a Trading Counterparty that he/she would like to utilize, it is first determined if the Trading Counterparty is already on the Approved Repo Counterparty list (a list of all approved Trading

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Counterparties maintained by the Taxable Money Market Credit Analysts). If approved, the Trader may use the Trading Counterparty without additional review. If the Trading Counterparty is not already on the Approved Repo Counterparty list, the Trader will discuss the name with an assigned investment analyst who will review the credit of the Trading Counterparty which will be documented in a credit report.

Trading Counterparties (Non-DVP transactions) not on the Approved Repo Counterparty List. There may be times where there is a need to execute a specific transaction with a Trading Counterparty that is not included on the Approved Repo Counterparty list for purposes of obtaining best execution and minimizing opportunity cost. In these instances, exceptions will be vetted, including how counterparty risk and/or risk of delayed or failed settlement is mitigated, by the Global Liquidity Group and the Head of Global Trading, and reviewed at the Counterparty Risk Committee. The Counterparty analysis will include a determination that the Counterparty represents minimal credit risk for the transaction based on the mitigating factors discussed.

An assessment of the counterparty’s risk profile is undertaken commensurate to the level of trading risk. Compliance undertake KYC and AML checks and sanctions screen counterparties on a daily ongoing basis. The Guidelines Monitoring team code and monitor counterparty guidelines. The Legal department arranges the completion of the relevant legal documentation as necessary and Operations facilitate the setup of counterparty risk management controls such as collateral and margin. Following completion of all required reviews and signoffs, the Risk team will recommend rejection or approval of the counterparty. A list of approved counterparties is maintained by the Risk team. Where a DVP (Delivery-versus-Payment) or ETD (Exchange Traded Derivative) broker is required for a singular transaction and no permanent relationship is envisaged, a one-off counterparty approval can be granted. A simplified assessment process will be followed

Best Execution In seeking best execution of Client transactions, the Dealing Desk considers a number of factors, including price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of an order. When assessing the best result the weights given to each trading factor are dynamic and may depend upon several variables such as: The characteristics of the client, the objectives, investment policy and risks specific to the portfolio, the characteristics of the client order, the characteristics of the financial instruments that are the subject of that order and the characteristics of the execution venues to which that order can be directed. Our execution policy is available on our website.

Commission Rates or Equivalents The Dealing Desk will monitor the expenses incurred for effecting portfolio transactions to the extent consistent with clients’ interests and objectives. Although the Central Dealing Desk generally seeks competitive commission rates, it will not necessarily pay the lowest commission or commission equivalent. Commission rates paid for equities can vary depending on the asset class, market (by country), investment style, and type of transaction. Commissions on exchange traded derivatives are paid to the clearing broker on trade date. They are split into a clearing commission that the clearing broker keeps and an execution commission that the clearing broker pays to the execution

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broker on receipt of a monthly invoice. Each contract has a different rate that is agreed by the Central Dealing Desk on a transaction-by-transaction basis. HIML monitors the effectiveness of execution arrangement on a regular basis. As part of the monitoring third party transaction cost analysis is used to monitor the effectiveness of the Central Dealing Desk against the market. As noted above, another Federated Advisory Company can provide us with equity trading services

Research or other “Soft Dollar” benefits To comply with more stringent European Standards, HIML pays for all investment research and does not use soft dollars from dealing commission to pay for research.

Brokerage for Client Referrals HIML does not receive client referrals from broker-dealers.

Directed Brokerage Accounts Where a client designates a broker-dealer, or broker-dealers, HIML and the Central Dealing Desk may not be in a position where they can negotiate commission rates or spreads or obtain volume discounts and best price may not be achieved. Trades for a client that has designated a broker or dealer may be placed at the end of batched trading activity for a particular security. Accordingly, directed transactions could be subject to price movements, particularly in volatile markets, that could result in the client receiving a price that is less favorable than the price obtained for the batched order. Under these circumstances, the direction by a client of a broker or dealer to execute transactions could result in higher commissions, greater spreads, or less favorable net prices than might be the case if Central Dealing Desk could negotiate commission rates or spreads freely, or select brokers or dealers based on best execution. These potential results are particularly relevant if directed accounts are trading after large block trades, involve illiquid securities or occur in volatile markets. The Central Dealing Desk may execute trades in over-thecounter securities with market makers on a net basis in those securities. Unless, and even if, the designated broker is a market maker in such securities which the Central Dealing Desk may purchase or sell on behalf of these accounts, HIML may be unable to obtain best execution on such transactions.

Trade Aggregation Segregated Account: We can aggregate or “bunch” orders being placed for execution at the same time for the accounts of two or more clients where we believe such aggregation is appropriate and in the best interest of clients. This practice can enable HIML and the Central Dealing Desk to seek more favorable executions and net prices for the combined order. All orders placed for execution on an aggregated basis are subject to the Equity and Fixed Income allocation policies and Procedures (the “Procedures”). The Procedures are designed to ensure that no client or account will be favored over another. The Procedures are summarized as follows:

All client orders are executed promptly and fairly by Dealing Desk, whose sole responsibility is to obtain best execution. The Dealing Desk does not give unfair preference to any particular client or any group of clients. The overall goal of these requirements is to treat each account fairly, with no inappropriate biases, while retaining tradable position sizes in each account. The portfolio manager must determine that the purchase or sale of the particular security order is appropriate for the client and consistent with the client’s investment objectives and with any investment guidelines or restrictions applicable to the client’s account. In determining to include a Client account in a bunched order, the Central Dealing Desk considers the nature and size of the expected bunched order, and other factors appropriate under the circumstances. Orders will only be aggregated together if the order parameters match and there are no client restrictions on aggregating orders. The Central Dealing Desk must reasonably believe that the bunched order is consistent with the overall duty to seek best execution and can benefit each client participating in the aggregated order. Generally, each client that participates in a bunched order shares in commissions or other transaction costs on a pro rata basis. When a bunched order is partially filled, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial trade allocation process and that does not consistently advantage or disadvantage particular clients or groups of client accounts. However, adjustments to the allocation can be made to avoid de minimis allocations to Client accounts or to avoid deviations from pre-determined holding limits established for any account. Model Portfolio: HIML generally will communicate model changes to Overlay Managers as concurrently as practicable to commencing trading with respect to clients managed on a discretionary basis, or otherwise in a fair and equitable manner designed to address potential conflicts of interest and protect client interests. Overlay Managers have discretion to accept or reject HIML’s recommended model portfolio changes and will execute trades in accordance with the Overlay Manager’s policies and procedures, which may result in trades for Overlay Manager clients being effected before, after or at the same time as trades for other HIML clients. Managed Account: Certain Managed Account Programs do not expressly direct the use of a particular broker/dealer but are structured in such a way (in terms of fees and other factors) that transactions are typically executed through the Program Sponsor or other broker/dealers affiliated with the programs, consistent with the duty to seek best execution. In certain circumstances, HIML and other Federated Advisory Companies will execute transactions with other broker/dealers in pursuit of best execution or, to the extent necessary, to obtain the desired security.

ADV Part 2A Brochure – March 2026

As discussed in more detail in Item 5 of this brochure, clients participating in Managed Account Programs generally pay a single fee or fees to cover investment management, custody and brokerage commissions for transactions effected through the Sponsor or other broker/dealer identified with the specific Managed Account Program. Brokerage commissions in Managed Account Programs are generally determined by the designated broker/dealer and included in the Managed Account Program fee. Transactions executed through other broker/dealers would typically result in additional charges to the client account. Thus, in a traditional Managed Account Program, given the wrapped fee, we generally are not in a position to negotiate commission rates with the broker/ dealers or to aggregate trades with other client accounts for execution purposes (except that we could aggregate trades for accounts within each separate Managed Account Program). However, to the extent permitted by the Managed Account Program and consistent with the policies discussed under the heading “Selection Criteria for Broker/Dealers” in

Thus, to the extent permitted by the Managed Account Program and consistent with the policies discussed under the heading “Selection Criteria for Broker/Dealers” in this section, HIML typically would execute transactions with other broker/dealers in pursuit of best execution, which transactions can be aggregated with trades for other client accounts, and which would result in additional charges to such account. Similar to Segregated Accounts, Managed Account clients (either directly or through the Managed Account Program Sponsor or Platform Provider) can also expressly limit HIML’s discretionary authority, including directing us to use a particular broker/dealer to execute portfolio transactions. In such a case, we may not be in a position to negotiate commission rates or spreads or obtain volume discounts, and such transactions may not be aggregated with orders for the same securities of other accounts managed by HIML.

Trading Error HIML has adopted written policies and procedures that it believes are reasonably designed to identify and resolve errors made in the trade execution and management process (“Trade Errors”). HIML will evaluate any exception made in the process of managing or placing an order for, or executing a security transaction on behalf of, a client account over which HIML has investment discretion to determine if it is a Trade Error. Regarding Model Portfolio Management Services, HIML also evaluates any exception made in the

process of providing a model recommendation to an Overlay Manager in a program to determine if it is a model delivery error (collectively, as applicable, with Trade Errors, “Errors”). Consistent with HIML’s policies and procedures, and obligations under applicable law, HIML strives to identify and resolve Errors promptly, document such Errors, take reasonable steps to seek to prevent the reoccurrence of such Errors and treat clients fairly in resolving such Errors. Where a single Error results in multiple transactions in a client account, gains and losses on these transactions may be netted in evaluating the net impact of such an Error.

Client Reporting The nature and frequency of reports to clients varies and will usually be determined by the specific requirements of each client. All our client reports are typically written and delivered electronically via email with some reports delivered via client portals or to distributor platforms (applies to our EU products only). HIML can provide monthly or quarterly performance or other reports to Separate Account clients as set forth in the investment management agreement with the clients. Separate Account clients will also receive account statements and other reports from the custodians for their accounts.

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As part of HIML’s Model Portfolio Management Services, HIML provides Overlay Managers with model portfolios and updates thereto, and other reports as set forth in its agreement with the Overlay Manager. Overlay Managers could incorporate such reports into the reports the Overlay Managers provide to their clients. HIML can also provide quarterly performance or other reports to Managed Account Program Sponsors or Platform Providers as required by the Managed Account Program Sponsors or Platform Providers. The reporting requirements are usually stated in our agreement with the Managed Account Program Sponsor or Platform Provider. Managed Account Program Sponsors and Platform Providers can reasonably modify, duplicate or incorporate such reports into the reports that they provide to Managed Account Program participants.

What Is Innovation Limited (third-party)

Federated Securities Corp (affiliate)

The cost of the referral fees is borne entirely by HIML not its clients. Some of HIML’s clients can retain consulting firms to assist them in selecting investment managers. Some consulting firms provide services to both those who hire investment managers and to investment management firms. HIML can pay to attend conferences sponsored by consulting firms and/or purchase services from consulting firms where it believes those services will be useful in operating our investment management business. HIML’s clients and prospective clients should be aware that consulting firms might have business relationships with investment management firms that they recommend to their clients. Please refer to “Conflicts of Interest Relating to Receipt of

Compensation or Benefits, Other Than Advisory Fees” in Item 6 of this brochure for a further discussion of these conflicts of interest and how they are addressed.

HIML’s authority to trade securities can also be limited by tax, laws or regulation that require diversification of investments and favor the holding of investments once made. Before accepting discretionary authority, HIML will discuss with the client, its investment strategy for the client to decide if it meets with their investment objective. Client’s investment guidelines and restrictions must be provided to HIML in writing and are usually part of the IMA signed by the Client and HIML.