Arga Investment Management, LP: investment adviser

The principal direct owners of ARGA are:  A. Rama Krishna, CFA  2009 Krishna Family Trust Types of Advisory Services We offer discretionary investment management services to:

A number of private investment funds or pooled investment vehicles (“Commingled Funds”), each a series of the ARGA Funds Trust, a Delaware statutory trust. Investors in the Commingled Funds comprise high-net-worth individuals and institutional investors including, but not limited to, trusts, foundations, corporations, endowments, and corporate and public pensions and family offices. Interests in the Commingled Funds are not registered under the Securities Act of 1933, as amended, and the Commingled Funds are not registered under the Investment Company Act of 1940, as amended. Accordingly, interests in the Commingled Funds are offered exclusively in private transactions within the United States by means of a private placement memorandum to investors satisfying the applicable eligibility and suitability requirements. Detailed terms applicable to investors in the Commingled Funds are described in the Declaration of Trust of the ARGA Funds Trust and in each Commingled Fund’s offering memorandum.

Investment companies (“Mutual Funds”) registered with the SEC under the Investment Company Act of 1940 and located in the United States. These include the ARGA Emerging Markets Value Fund, ARGA International Value Fund and ARGA Value Fund, each a series of The Advisors’ Inner Circle Fund III.

Collective Investment Trusts (“CIT Funds”) available to US tax qualified pension and profit-sharing plans, governmental plans, retirement income accounts and other tax qualified investors. The CIT Funds are each a separate fund of the ARGA Investment Management Collective Investment Trust, established pursuant to a Declaration of Trust

dated November 7, 2022, as amended from time to time, and organized under the laws of the Commonwealth of Pennsylvania.

Open-ended investment companies with variable capital that are qualified as UCITS (Undertakings for Collective Investment in Transferable Securities) (“UCITS Funds”). The UCITS Funds are established as sub-funds of Skyline Umbrella Fund ICAV, an umbrella-type Irish collective asset management vehicle with segregated liability between its sub-funds. The UCITS Funds are governed by the laws of Ireland and are open to non-U.S. investors. Detailed terms applicable to investors in the UCITS Funds are described in the Skyline Umbrella Fund ICAV Prospectus and the applicable UCITS Fund Supplement.

An Australian fund structured as a regulated unit trust (“Australia Unit Trust”), registered with the Australian Securities and Investment Commission and subject to the Corporations Act requirements for managed investment schemes. Equity Trustees Limited, a subsidiary of EQT Holdings Limited, serves as the Responsible Entity for the Australia Unit Trust.

Internal, single investor funds (“Proprietary Funds”), generally 100% funded by the assets of our Chief Investment Officer, A. Rama Krishna and affiliated trusts, or the assets of our Nonexecutive Chairman, Peter Carman. Interests in our Proprietary Funds are not offered to outside investors and there is no private placement or offering memorandum available for these funds. We expect to manage additional such funds in the future. Our Proprietary Funds are managed along with other accounts, and trade orders for our Proprietary Funds may be aggregated with trade orders for other accounts for purposes of trade execution. We have therefore implemented strict fairness policies with respect to trading practices and allocation procedures to avoid any incentive to favor any one account over another, consistent with our fiduciary obligation to allocate investment opportunities fairly.

The Commingled Funds, Mutual Funds, CIT Funds, UCITS Funds, Australia Unit Trust and Proprietary Funds are sometimes collectively referred to in this brochure as “the ARGA Funds.” We also offer discretionary management services to a number of separate managed accounts comprising pension plans, state or municipal government entities, foreign registered investment companies, family offices, corporate entities and other investment advisers and sub-advisory services to three investment companies registered under the Investment Company Act of 1940 (collectively “Separate Accounts”). The three sub-advisory investment companies include:

The Vanguard International Value Fund. ARGA manages a portion of the fund;

The PACE® Select Advisors Trust with respect to the PACE® International Emerging Markets Equity Investments portfolio. ARGA manages a portion of the portfolio; and

The PACE® Select Advisors Trust with respect to the PACE® Small/Medium Co Value Equity Investments portfolio. ARGA manages a portion of the portfolio.

All accounts to which we provide investment advisory services, including the ARGA Funds, are sometimes collectively referred to in this brochure as “the Accounts or Clients.” Our investment objective is to generate long-term returns by investing primarily in equity and equity-linked securities of issuers that are trading at a discount to their perceived intrinsic value. We offer investment advisory services on equity and equity-linked securities, including exchange-listed securities, over-the-counter traded securities, foreign securities and participatory notes. Our investment advisory services are limited to these types of investments. Some of the strategies we offer include: 1. Global Equity Strategy This strategy invests primarily in equity and equity-linked securities of companies located in any part of the world, including the United States, that are trading at a discount to their perceived intrinsic value. These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 2. International Equity Strategy This strategy invests primarily in equity and equity-linked securities of companies located in any part of the world that are trading at a discount to their perceived intrinsic value and are either (i) domiciled outside the United States, or (ii) domiciled in the United States, but a significant portion of their revenues, earnings, assets, costs or employees are outside the United States. These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 3. Emerging Markets Equity Strategy This strategy invests primarily in equity and equity-linked securities of companies that are trading at a discount to their perceived intrinsic value and that are either (i) located in emerging markets, or (ii) located in developed markets but a significant portion of their revenues, earnings, assets, costs or employees are from or in emerging markets. These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 4. Global Sector-Neutral Strategy This strategy invests primarily in a sector-neutral portfolio of equity and equity-linked securities of companies located in any part of the world, including the United States, that are trading at a discount to their perceived intrinsic value. These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 5. International Sector-Neutral Strategy This strategy invests primarily in a sector-neutral portfolio of equity and equity-linked securities of companies located in any part of the world that are trading at a discount to their perceived

intrinsic value and are either (i) domiciled outside the United States, or (ii) domiciled in the United States, but a significant portion of their revenues, earnings, assets, costs or employees are outside the United States. These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 6. Global Concentrated Equity Strategy This strategy invests primarily in a highly concentrated portfolio of equity and equity-linked securities of companies located in any part of the world, including the United States, that are trading at a discount to their perceived intrinsic value. These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 7. International Small-Cap Equity Strategy This strategy invests primarily in equity and equity-linked securities of smaller capitalization companies located in developed markets around the world that are trading at a discount to their perceived intrinsic value and are either (i) domiciled outside the United States, or (ii) domiciled in the United States, but a significant portion of their revenues, earnings, assets, costs or employees are outside the United States. These securities may be traded on exchanges or recognized markets or over the counter in developed markets. 8. EAFE Equity Strategy This strategy invests primarily in equity and equity-linked securities of companies located in developed market countries around the world that are trading at a discount to their perceived intrinsic value and are either (i) domiciled outside the United States and Canada, or (ii) domiciled in the United States and Canada, but a significant portion of their revenues, earnings, assets, or employees are outside the United States and Canada. These securities may be traded on exchanges or recognized markets or over the counter in developed markets. 9. European Equity Strategy This strategy invests primarily in equity and equity-linked securities of companies that are trading at a discount to their perceived intrinsic value and (i) are in European developed or emerging markets or (ii) have significant exposure to Europe. These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 10. Global Small Cap Equity Strategy This strategy invests primarily in equity and equity-linked securities of smaller capitalization companies located in developed markets, including the United States, that are trading at a discount to their perceived intrinsic value. These securities may be traded on exchanges or recognized markets or over the counter in developed markets. 11. US Small Cap Equity Strategy This strategy invests primarily in equity and equity-linked securities of smaller capitalization companies that are trading at a discount to their perceived intrinsic value and are either (i)

located in the United States or (ii) have a significant portion of revenues, assets, earnings or employees in the United States. These securities may be traded on exchanges or recognized markets or over the counter. 12. US Equity Strategy This strategy invests primarily in equity and equity-linked securities of (i) companies listed on US stock exchanges or (ii) companies not listed on US stock exchanges but a significant portion of their revenues, earnings, assets or employees are from or in the US, that are trading at a discount to their perceived intrinsic value. These securities may be traded on exchanges or recognized markets, in both developed and emerging markets. 13. China A Onshore Equity Strategy This strategy invests in A shares of Chinese companies listed on the Shanghai and Shenzhen stock exchanges that are trading at a discount to their perceived intrinsic value. 14. Asia Ex Japan Equity Strategy This strategy invests primarily in equity and equity-linked securities of companies that are trading at a discount to their perceived intrinsic value and are either (i) located in Asia (excluding Japan) or (ii) located outside Asia but a significant portion of their revenues, earnings, assets or employees are from or in Asia (excluding Japan). These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 15. Emerging Markets Ex China Equity Strategy This strategy invests primarily in equity and equity-linked securities of companies that are trading at a discount to their perceived intrinsic value and are either (i) located in emerging markets (excluding China) or (ii) located outside emerging markets but a significant portion of their revenues, earnings, assets or employees are from or in emerging markets (excluding China). These securities may be traded on exchanges or recognized markets or over the counter. 16. Emerging Markets Select Equity Strategy This strategy invests primarily in equity and equity-linked securities of large capitalization companies that are trading at a discount to their perceived intrinsic value and that are either (i) located in emerging markets, or (ii) located outside emerging markets but a significant portion of their revenues, earnings, assets, or employees are from or in emerging markets. These securities may be traded on exchanges or recognized markets or over the counter, in both developed and emerging markets. 17. US SMID Cap Equity Strategy This strategy invests primarily in equity and equity-linked securities of smaller and midcapitalization companies that are trading at a discount to their perceived intrinsic value and are either (i) located in the United States or (ii) have a significant portion of revenues, assets,

earnings or employees in the United States. These securities may be traded on exchanges or recognized markets or over the counter. Diversified Value Strategies. We launched global and international diversified value strategies, for clients seeking to benefit from ARGA’s rigorous research process and value orientation, but with a more benchmark-aware approach. These strategies seek to maximize long-term returns for a given tracking error budget relative to the relevant benchmarks. Investment Restrictions Our investment strategies are described in greater detail in the offering documents of the relevant ARGA Fund, where available. In general, we do not tailor a strategy to the needs of individual fund investors or Separate Account clients. However, in certain circumstances, for Separate Accounts we may agree on reasonable client-imposed guidelines and restrictions. These guidelines and restrictions are reviewed prior to investing a portfolio to ensure there are no issues with managing the portfolio according to our investment strategy. Assets under Management As of December 31, 2025 we managed approximately $ 24,571,096,652 of client assets on a discretionary basis.

Performance-based Fee. We may enter into performance-based compensation arrangements with certain clients. Clients who are subject to performance fees will be qualified clients within the meaning of Rule 205-3 under the Investment Advisers Act of 1940. Under this fee arrangement, the client pays a base management fee and a performance-based fee. The performance-based fee is generally 15% (as described in applicable fund offering documents or applicable advisory agreements with Separate Account clients) of net returns over the hurdle rate of a specified benchmark relevant to the applicable period. The performance-based fee may be subject to a loss carry forward or high-water mark provision that generally requires that any losses suffered by an

account (adjusted to reflect withdrawals/redemptions) be offset by subsequent net returns before a performance-based fee is payable by the account. These performance-based compensation arrangements may result in a total annual fee that is higher than our standard annual asset-based management fee. The fees described above are our typical fee rates. However, ARGA has the right to negotiate fees and enter into agreements with one or more of its clients at these negotiated fees. Fees may vary depending on individual portfolio considerations, investment size, timing of opening and other circumstances of the mandate/relationship. Fees for the Separate Accounts are negotiated with each such Separate Account client. Details of how the fees are calculated for the Commingled, UCITS Funds and Australia Unit Trust can be found in the offering documents of the applicable fund, which are provided to potential investors prior to investing in a fund. In the case of performance-based fees (if applicable), fees are paid from each applicable investor’s capital account. With respect to the ARGA CIT Funds, each fund pays a Trustee Fee. The Trustee Fee is an “all in fee” which covers (i) the normal operating fees and expenses of the fund; (ii) compensation to the Trustee for the fiduciary services provided by the Trustee; and (iii) compensation to ARGA for the investment advisory and administrative services. The CIT Funds are not subject to performance fees. Details of how the fees are calculated for Separate Accounts are included in the investment advisory agreement for each such client. Our fees from the Separate Accounts are either paid directly from the client account or from outside the assets of the client account, per each such client’s instructions. ARGA also serves either as the advisor or sub-advisor to six investment companies registered under the Investment Company Act of 1940. Under the advisory and sub-advisory contracts approved by the trustees and/or directors of each of these funds, ARGA manages the investment and reinvestment of assets of these funds, continuously reviews, supervises, and administers an investment program for these funds and determines in its discretion the securities to be purchased or sold and the portion of such assets to be held uninvested. In exchange for these services:

With respect to the ARGA Mutual Funds, ARGA receives a fixed investment advisory fee payable on a monthly basis. The ARGA Mutual Funds are not subject to performance fees.

With respect to our sub-advisory services for investment company clients who are registered under the Investment Company Act of 1940, the fees are calculated as follows: o The Vanguard International Value Fund (ARGA manages a portion of the fund): ARGA receives an investment advisory fee consisting of a base fee plus a performance adjustment. The fees are paid on a quarterly basis.

o The PACE® Select Advisors Trust with respect to the PACE® International Emerging Markets Equity Investments portfolio and the PACE Small/Medium Co Value Equity Investments portfolio (ARGA manages a portion of the portfolios). In exchange for these services, ARGA receives a fixed investment advisory fee, paid on a monthly basis. Expenses In addition to management fees, Accounts may pay other fees and expenses in connection with ARGA’s investment management services. Generally, Accounts are responsible for such other fees and expenses, as governed by the applicable offering document or investment advisory contract. The other fees and expenses for the ARGA Funds (excluding the CIT Funds) may include, but are not limited to:

Accounting and auditing fees (including audit fees, tax return preparation costs relating to the Funds’ accounts and administration fees); Legal fees and expenses; Trustee/Custodian fees; Where applicable, the cost of preparation and distribution of reports and statements to fund investors by the custodians; All trading expenses and transaction costs (including brokerage commissions and expenses clearing and settlement charges, interest on loans and debit balances, margin interest, broker service fees and other clearing and custodial expenses); and The management fee and, if applicable, performance-based fee.

ARGA may choose to bear some or all of the operating expenses as well as organizational expenses, as described in the ARGA Fund’s offering documents. With respect to the CIT Funds, each fund pays a Trustee Fee. The Trustee Fee is an “all in fee” which covers (i) the normal operating fees and expenses of the fund; (ii) compensation to the Trustee for the fiduciary services provided by the Trustee; and (iii) compensation to ARGA for the investment advisory and administrative services. Separate Accounts are generally responsible for all custodial fees, brokerage commissions, clearing fees, interest and withholding or transfer taxes incurred in connection with trading for the accounts; our management fee, and, if applicable, a performance-based fee. If considered appropriate, we may invest a portion of an Account’s assets in one or more money market funds, mutual funds or exchange-traded funds. When any such investments are made, the Account will pay, in addition to the compensation payable to us, their proportionate share of any management fees charged by the manager of such money market funds, mutual funds or exchange-traded funds.

ARGA does not require clients to prepay fees in advance. Clients may, however, choose to do so if agreed in the relevant advisory contract. When a client closes their account, management fees are prorated as of the termination date. The client receives a refund of the portion of any prepaid management fee that is not earned. Brokerage and other transaction costs that are borne by the Accounts are described further in Item 12 (Brokerage Practices) of this brochure. Neither ARGA nor its officers or employees receive compensation for the sale of securities or other investment products to its clients. The only form of compensation received from advisory services is the fees charged for providing investment advisory services, as described above.

We have a fiduciary duty not to favor the account of one client over that of another, without regard to the types and amounts of fees paid by those accounts. In light of the conflicts of interest described above, we have allocation policies and procedures in place to designed to ensure that all Accounts are treated fairly. Generally, allocations are made among Accounts with a similar strategy on a pro rata basis, based on the size of the Account. Explanations for variations from this approach are required to be documented and are subject to periodic review by our compliance staff to ensure that all Accounts are being treated fairly.

separate accounts and sub-advisory services to investment companies registered with the SEC under the Investment Company Act of 1940 (“collectively, “Separate Accounts”). Investors in the ARGA Funds, excluding the CITs Funds, generally include high net worth individuals and institutional investors including, but not limited to, trusts, foundations, corporations, endowments, corporate and public pensions and family offices. Our CIT Funds are available to US tax qualified investors, which include pension and profit-sharing plans, governmental plans, retirement income accounts and others. We offer separate account services typically to investment companies, pension plans, state or municipal government entities, foreign registered investment companies, corporate entities, public fund managers, pension trusts, family offices and other investment advisers. Our Commingled Funds have a minimum initial investment amount of $1,000,000. Additional investments are in increments of $1,000,000. Our UCITS Funds have a minimum initial investment amount of $100,000. Our Australia Unit Trust has a minimum investment of AUD 25,000. The minimum additional investment is AUD 1,000. Our Mutual Funds each have a minimum initial investment of $250,000 for the institutional share class. The investor shares class of the Mutual Funds are currently not available for purchase. There is no minimum investment amount for our CIT Funds. The minimum investment for a Separate Account is $10,000,000. These minimums and/or increments may be reduced or waived by ARGA at its sole discretion.

Comprehensive fundamental company research then focuses on operational expertise, financial stability, and sustainability factors, with stress tests performed to determine potential downside risk. The end result seeks a portfolio of businesses with a substantial discount to intrinsic value,

with expected holding periods of generally 3-5 years. Holdings are continually evaluated based on their discount to intrinsic value; position sizes are influenced by the discount and perceived risk, and sales generally tend to occur when discounts narrow relative to the relevant universe or when changing fundamentals alter the investment thesis. ARGA believes sustainability considerations can create risks and opportunities for the companies in which we invest. Sustainability factors are treated similarly to any other fundamental factor affecting businesses. Sustainability risks and opportunities that affect costs, earnings, product composition, market share, etc., and that lead to a significant impact on longterm earnings and valuations are deemed material. Material sustainability factors are evaluated along with all fundamental factors that are used as inputs to company Dividend Discount Models (DDM). Sustainability factors are flagged during the research process using ARGA’s sustainability scoring framework. The framework flags key areas of sustainability risk and the opportunity for deeper research. Used early in our process, it scores companies on 14 environmental, social and governance factors which aggregate a much larger compilation of metrics. For those companies where sustainability impacts are deemed material and quantifiable, we aim to reflect these in company DDM inputs. A company’s DDM valuation upside/downside, in turn, informs the stock selection and portfolio sizing decision. ARGA engages with company management primarily to enhance our DDM inputs. ARGA is not an activist investor. We seek to understand risks ahead of investing, then incorporate risks in our valuation models. We engage with companies on data transparency and address missing data issues. If needed, we may engage further via proxy voting and communication with board members. ARGA is a UN PRI signatory. Artificial Intelligence (“AI”) ARGA may utilize AI tools in the ordinary course of its business operations. AI tools are used solely for administrative, operational, and research support functions, such as gathering and organizing data, improving efficiency in certain processes, and serving as a supplemental source of information. AI tools are not used to make investment decisions, formulate investment advice, generate recommendations, execute trades, or determine portfolio allocations. All AI-generated output is subject to review, validation, and verification before it is relied upon in any capacity. All investment decisions, including security selection, portfolio construction, and trade execution, are made by the firm's investment professionals exercising independent judgment. No AI tool or algorithm has discretionary authority over client assets. ARGA has adopted written policies and procedures governing the use of AI, addressing acceptable uses, required human oversight, protection of confidential and client information, and restrictions on the use of AI in client-facing communications. Employees receive periodic

training on appropriate AI use. ARGA conducts due diligence on third-party AI vendors, including review of data security practices and contractual provisions to prevent the use of client or proprietary information for model training or unrelated processing. ARGA periodically reviews its AI policies and practices to ensure consistency with its fiduciary obligations and applicable regulatory requirements. Risks Associated with our Investment Strategies Overall Investment Risk. All securities investments risk the loss of capital. The nature of the securities purchased and sold for an account and of the investment techniques and strategies we employ may increase this risk. There can be no assurance that an account will not incur losses. Many unforeseeable events, including, but not limited to, actions by various government agencies, such as the Federal Reserve Board, and domestic and international economic and political developments, may cause sharp market fluctuations which could adversely affect the accounts. Each strategy’s investments generally consist of securities we identify using our methodology. Since the strategy involves identifying securities which are generally undervalued by the marketplace, success of the strategy necessarily depends upon the market eventually recognizing such value in the price of the security. This may not necessarily occur. Portfolio positions may undergo significant short-term declines and experience considerable price volatility. An investment in a fund or in an account using one of our strategies should not be regarded as a complete investment program and should be considered only by investors who are prepared to experience possible short-term volatility and fluctuations in value, in the interest of seeking potential long-term capital appreciation. Equity Risks. ARGA’s strategies expect to invest primarily in equity and equity-linked securities (including participatory notes). The value of these securities generally will vary with the performance of the issuer and movements in the equity markets. Risks of “Value” or Valuation-based Investing. ARGA invests in businesses it believes are undervalued based on long-term earnings power and dividend-paying capability. These types of investments may present risks in addition to the general risk of investing in equity and equitylinked securities. These stocks are subject to the risk of forecast errors in fundamental factors affecting their valuation. Investors could suffer losses if our assessment of market conditions or a company’s value or prospects for exceeding earnings expectations is inaccurate. Also, strict adherence to “value” or valuation-based investing may result in significant underperformance relative to market indices or other investment styles that are “growth” or “momentum” oriented or those that adopt a flexible approach. This generally happens when the market favors “growth” or “momentum” investing over valuation-based investing. While we believe our industry models add significant value to our research process, risks include having a framework which does not adequately capture all variables that reflect a particular company’s unique circumstances, leading to a potentially erroneous conclusion about its competitive positioning, valuation, etc.

Our investment process depends on high quality inputs into our valuation (DDM) models. Analysts must have in depth understanding of a company, its products, industry and cycle, competition, margins, reinvestment needs, risk factors and accounting issues in order to provide these inputs. There can be no guarantee that these inputs prove accurate over time. Portfolio Construction. Portfolio construction inputs from risk models and optimizer (in case of diversified strategies) provide insights based on historical relationships and/or theoretical assumptions. Output is not guaranteed, and actual performance may vary materially. The optimization process can be sensitive to input errors, potentially resulting in underestimated risks. These tools are intended for informational purposes only within the portfolio construction process and do not protect against loss. General Economic and Market Conditions. The success of ARGA’s investment activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of the investments), and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of securities prices and the liquidity of ARGA’s investments. Volatility or illiquidity could adversely impact portfolios returns. The investment strategies may maintain substantial trading positions that can be adversely affected by the level of volatility and liquidity in the financial markets. We note that the LIBOR transition to SOFR did not impact ARGA’s investment activities. Non-U.S. Investments. ARGA expects to invest in financial instruments of non-U.S. corporations and governments. Investing in the financial instruments of companies (and, from time to time, governments) outside of the United States involves certain considerations not usually associated with investing in financial instruments of U.S. companies or the U.S. government. These include political and economic considerations, such as greater risks of expropriation, nationalization, confiscatory taxation, limitations on the removal of assets and general social, political and economic instability; the relatively small size of the securities markets in such countries and the low volume of trading, resulting in potential lack of liquidity and in price volatility; the evolving and unsophisticated laws and regulations applicable to the securities and financial services industries of certain countries; fluctuations in the rate of exchange between currencies and costs associated with currency conversion; and certain government policies that may restrict investment opportunities. In addition, accounting and financial reporting standards that prevail outside of the U.S. often are not as high as U.S. standards and, consequently, less information is typically available concerning companies located outside the U.S. than for those located in the U.S. As a result, ARGA may be unable to structure its investments to achieve the intended results to mitigate all risks associated with such markets. It may also be difficult to enforce ARGA’s rights in such markets. For example, financial instruments traded on non-U.S. exchanges and the non-U.S. persons that trade these instruments are not subject to the jurisdiction of the SEC or the securities laws and regulations of

the United States. Accordingly, the protections accorded to ARGA’s investments under such laws and regulations are unavailable for transactions on foreign exchanges and with foreign counterparties. Emerging Markets. Investments in emerging market securities carry greater risks than investments in securities of issuers based in developed countries. These include the risks of less publicly available information, more volatile markets, less strict securities market regulation, less favorable tax provisions, and a greater likelihood of severe inflation, unstable currency, war and/or expropriation of personal property. In addition, investment opportunities in certain emerging markets may be restricted by legal limits on foreign investment in local securities. Emerging markets generally are not as efficient as those in developed countries. In some cases, a market for a security may not exist locally, and transactions will need to be made on a neighboring exchange. Volume and liquidity levels in emerging markets are lower than in developed countries. When seeking to sell emerging market securities, little or no market may exist for such securities. In addition, issuers based in emerging markets are not generally subject to uniform accounting and financial reporting standards, practices and requirements comparable to those applicable to issuers based in developed countries, thereby potentially increasing the risk of fraud or other deceptive practices. Furthermore, the quality and reliability of official data published by the governments or securities exchanges in emerging markets may not accurately reflect the actual circumstances being reported. The issuers of some emerging market securities, such as banks and other financial institutions, may be subject to less stringent regulations than would be the case for issuers in developed countries and, therefore, potentially carry greater risks. Custodial expenses for a portfolio of emerging markets securities generally are higher than for a portfolio of securities of issuers based in developed countries. Frontier Markets Risks. Frontier markets are inherently riskier than developed and advanced emerging markets, given the earlier stage of their economic and capital market development. Given the more limited investment flows, frontier markets do tend to be less liquid than their developed and emerging market peers. Frontier markets carry higher governance risk, political instability, capital control risk and foreign exchange risk. Sustainability Risks. ARGA may purchase and hold securities that present sustainability risks. Evaluation of sustainability factors is often subjective and ARGA may not identify or evaluate every relevant factor for every investment. As a result, ARGA’s sustainability evaluation may differ from evaluations made by other investment advisers and may not reflect the beliefs or values of any particular investor. While ARGA may engage with companies on sustainability factors and related concerns as deemed appropriate, such engagement may not always yield positive outcomes and we make no representation that any change or improvement in a company’s sustainability or related issues is or was a direct result of our engagement.

Sustainability risks include but are not limited to:

Effects of climate change on company operations;

Water accessibility and usage;

Environmental impact on surrounding habitat of company operations;

Employee health, safety and labor practices, etc.;

Community impact of company; and

Corporate governance practices.

Evaluation of sustainability risks and opportunities and implementation of applicable sustainability-related investment restrictions rely on the availability of timely, complete and accurate sustainability data reported by issuers and/or third-party research providers. Sustainability data is often based on estimates or assumptions. To the extent relevant data is unavailable or inaccurate, ARGA’s ability to evaluate sustainability risks and opportunities and successfully implement applicable sustainability-related investment restrictions may be limited or compromised. ARGA evaluates sustainability factors that lead to potential risks or opportunities, in the same way as other financial factors. As a result, the integration of any such factor, including sustainability, may lead portfolios to perform differently from those that do not integrate these factors. Depository Receipts. ARGA may invest in non-U.S. companies through the purchase of depository receipts, which are negotiable certificates that represent a security, usually in the form of equity that is issued by a foreign publicly listed company. Depository receipts are generally used to reduce administration and duty costs that would otherwise be levied on each transaction. However, depository receipts do not eliminate foreign exchange risk for ARGA’s investment in the non-U.S. company, and ARGA’s portfolios will not be the direct owner of the security or securities represented by the depository receipts. Participatory Notes. ARGA may invest in non-U.S. companies through the use of participatory notes. Investing in participatory notes involves the same risks as a direct investment in the shares of the companies the notes seek to replicate. However, due to transaction costs and other expenses, the performance results of participatory notes will not replicate exactly the performance of the issuer or markets the notes seek to replicate. Additionally, participatory notes are subject to counterparty risk meaning the risk that the issuer of the participatory notes may default on its obligation under the note. Participatory notes may be considered illiquid investments. Currency Exchange Exposure. ARGA may invest a portion of its assets in the securities of nonU.S. issuers and other instruments denominated in non-U.S. currencies, the prices of which are determined with reference to currencies other than the U.S. dollar. ARGA, however, values its

securities and other assets in U.S. dollars. ARGA may or may not seek to hedge its non-U.S. currency exposure by entering into currency hedging transactions, such as treasury locks, forward contracts and cross-currency swaps. There can be no guarantee that instruments suitable for hedging currency or market shifts will be available at the time when ARGA wishes to use them, or that hedging techniques employed by ARGA will be effective. Furthermore, certain currency market risks may not be fully hedged or hedged at all. To the extent unhedged, the value of ARGA’s positions in non-U.S. investments will fluctuate with U.S. dollar exchange rates as well as the price changes of the investments in the various local markets and currencies. In such cases, an increase in the value of the U.S. dollar compared to the other currencies in which ARGA makes its investments will reduce the effect of any increases and magnify the effect of any decreases in the prices of ARGA’s investments in their local markets and may result in a loss to the portfolios. Conversely, a decrease in the value of the U.S. dollar will have the opposite effect on ARGA’s non-U.S. dollar investments. Furthermore, ARGA may incur costs in connection with conversions between various currencies. Non-U.S. currency exchange dealers realize a profit based on the difference between the prices at which they are buying and selling various currencies. Thus, a dealer normally will offer to sell currency to ARGA’s portfolios at one rate, while offering a lesser rate of exchange should ARGA desire immediately to resell that currency to the dealer. ARGA conducts its currency exchange transactions on a spot (i.e., cash) basis at the spot rate prevailing in the currency exchange market. Most of ARGA’s currency exchange transactions occur at the time securities are purchased and are executed through the custodian acting for the portfolios. Concentration of Investments. ARGA expects that at times certain portfolios may be somewhat concentrated. Although concentration may increase the possibility of achieving significant investment returns, concentration of investments in a limited number of issuers, industries or sectors is generally regarded as increasing both relative investment risk and potential portfolio volatility. In addition to issuer, industry or market risk by reason of concentration, ARGA’s investments may be exposed to potentially significant losses by reason of adverse developments affecting one or more of such limited number of portfolio companies. A loss in any such position could materially reduce ARGA’s performance or asset base, to the extent not offset by other gains. Limited Capitalization Companies. ARGA may invest a significant portion of a portfolio’s assets in company securities with limited market capitalizations, where applicable. While these companies may often provide significant potential for appreciation, these securities may also involve higher risks than investments in securities of large companies. The prices of small capitalization and even medium capitalization securities are often more volatile than prices of large capitalization securities. The risk of bankruptcy or insolvency of many smaller capitalized companies (with the attendant losses to investors) is higher than for larger, “blue-chip”

companies. In addition, due to thin trading in some small capitalization securities, an investment in those securities may be illiquid. Execution of Orders and Portfolio Turnover. ARGA’s trading strategy depends on its ability to establish and maintain an overall market position in a combination of securities and other investments selected by the firm. ARGA’s trading orders may not be executed in a timely and efficient manner due to various circumstances, including, without limitation, systems failures or human error attributable to the portfolios, its brokers, agents or other service providers. In such events, ARGA might only be able to acquire some, but not all, of the components of such position, or if the overall position were to need adjustment, ARGA might not be able to make such adjustment. As a result, ARGA would not be able to achieve the market position selected by the firm and might incur a loss in liquidating its position. ARGA does not have any limits on portfolio turnover, and portfolio securities may be sold without regard to the time they have been held when, in ARGA’s opinion, investment considerations warrant such action. A high rate of portfolio turnover involves correspondingly greater expenses than a lower rate and may result in taxable costs for investors depending on the tax provisions applicable to such investors. Liquidity Risk. Illiquidity in certain markets and securities could make it difficult for ARGA to liquidate positions on favorable terms, thereby resulting in losses. Competition; Availability of Investments. Certain markets in which ARGA may invest are extremely competitive for attractive investment opportunities and, as a result, there may be reduced expected investment returns. There can be no assurance that ARGA will be able to identify or successfully pursue attractive investment opportunities in such environments. Among other factors, competition for suitable investments from other pooled investment vehicles and other investors may reduce the availability of investment opportunities. There has been significant growth in the number of firms organized to make such investments, which may result in increased competition to ARGA in obtaining suitable investments. Reliance on Information Provided. ARGA may elect to invest in securities on the basis of information and data filed by the issuers of such securities with the SEC or made directly available to the firm by the issuers of the securities and other instruments or through sources other than the issuers. Although ARGA evaluates all such information and data and seeks independent corroboration when it considers it appropriate and when it is reasonably available, ARGA is not in a position to confirm the completeness, genuineness or accuracy of such information and data. Foreign Taxation Risk. With respect to investments in the securities of non-U.S. companies, different tax regimes in foreign jurisdictions may subject investors to withholding or other taxation that would not be imposed in other markets. The amount and nature of taxes may be highly uncertain.

Pandemic Risks. A local, regional, national or international outbreak of a contagious disease, including, but not limited to, COVID-19, Middle East Respiratory Syndrome, Severe Acute Respiratory Syndrome, H1N1 influenza virus, avian flu or any other similar illness, or a fear of any of the foregoing, could adversely impact our Accounts by causing significant disruptions in local and global economies, thereby adversely impacting the value of the Accounts’ investments. It is unknown whether and how the values of the Accounts’ investments may be affected if such an epidemic persists for an extended period of time. Russia Exposure. At the end of December 31, 2021, ARGA’s exposure to Russia was limited to three securities held in certain Accounts. Given the political uncertainty, we exited our position in two of the securities in the first quarter of 2022 and substantially reduced our position in the third security. We were not able to exit the position entirely due to Russia’s suspension of trading by foreign investors in its equity market. As such, ARGA valued the security to zero and the security continues to remain valued at zero. Any past successes with our investment methodology cannot assure future results. There can be no assurance that the investments or investment techniques we employ for the accounts will achieve the accounts’ investment objectives or that the accounts will be profitable. The foregoing risk factors are not a complete enumeration or explanation of the risks involved in investing with ARGA. The risks inherent to the strategies employed by ARGA, including but not limited to those listed above, are described in further detail in each fund’s offering documents. With respect to our Mutual Funds, such risks are described in further detail in The Advisors’ Inner Circle Fund III Prospectus for such Mutual Funds. With respect to the CIT Funds, such risks are described in further detail in the Declaration of Trust of the ARGA Investment Management Collective Investment Trust.

Additionally, we have established a Code of Conduct setting forth appropriate standards of behavior and business conduct to which all employees are expected to adhere during the course of their employment with, and when conducting business on behalf of, ARGA. As a fiduciary, we owe our clients the highest duty of loyalty and we rely on each of our employees to avoid conduct that is or may be inconsistent with this duty. Our Code of Ethics is based on the following principles: (i) the interests of our clients come before our interests and those of our employees; (ii) the professional activities and personal investment activities of our employees must be consistent with the Code and must avoid any actual or potential conflict between the interests of clients and those of our employees and our firm; (iii) the activities of our employees must be conducted in a way that avoids any abuse of any such person’s position of trust with, and responsibility to, our firm and to our clients; and (iv) our employees may not engage in any act, practice or course of conduct that would violate the code of ethics standards prescribed for investment advisers by the SEC. Conflicts of Interest

ARGA’s Code of Ethics, Code of Conduct and compliance policies and procedures aim to identify and prevent actual and potential conflicts of interest related to client, employee, and proprietary activities. While ARGA follows these procedures to eliminate potential conflicts of interest, there is no guarantee they will detect and prevent every situation where potential conflicts could arise. The below provides a description of the material conflicts of interest that ARGA has identified, the nature and extent of the conflict, the potential impact on and risk that the material conflict could pose to a client, and how the material conflict has been or will be addressed.

Allocation of Investment Opportunities. ARGA manages several funds, including Mutual Funds and CIT Funds as well as Proprietary Accounts not open to outside investors, on a discretionary basis, some of which may include investments belonging to one or more ARGA employees

directly and beneficially, that use the valuation-based investment strategy utilized for all Accounts. ARGA expects to manage additional such funds in the future. To avoid any incentive to favor one Account over another in the allocation of investment opportunities (particularly where there are differing performance-based fee arrangements), ARGA has implemented strict fairness policies to ensure the fair and reasonable treatment of all Accounts managed by ARGA in situations where one or more Accounts have parallel strategies, overlapping strategies or participate simultaneously in a buy or sell program involving the same security. These policies are designed to ensure that ARGA does not unfairly favor one Account over another and apply equally to all Accounts regardless of the size of their portfolios. To ensure fairness in the allocation of opportunities among Accounts, ARGA seeks to ensure that investment strategies pursued for an Account are consistent with the mandate for that Account; risk limits and parameters are adhered to; and legal, regulatory, tax and other restrictions are complied with. ARGA periodically examines trade allocations among Accounts to confirm their consistency with our fiduciary obligation to allocate investment opportunities fairly. In instances such as clients directing trades through particular brokers, ARGA may place non-simultaneous trade orders for the other Accounts, which may affect the execution price of the security to the detriment of one or the other. Recommending Related Issuers. ARGA manages several funds (including commingled funds, UCITS funds, Australia Unit Trust, CIT funds and mutual funds) (collectively, “Related Issuers” for the purposes of this section) on a discretionary basis from which we may receive monetary or non-monetary benefits but where the investment might not be suitable for a Separate Accounts. We may receive ongoing management fees from increased assets under management and/or performance fees if those assets increase in value. Our role in managing and advising our Related Issuers inevitably gives rise to potential conflicts between our interests and the interests of our Separate Accounts clients because we may potentially favor our Related Issuers over such other client accounts, a client account may have limited investment options available to them or a recommended related or connected issuer may not be suitable for a client account. We have implemented policies and procedures designed to ensure investments for each of our Accounts are suitable based on a robust process incorporating each such Account’s objectives and investment guidelines. Investment recommendations and decisions for each Account are carefully made based on each such Account’s objectives and investment guidelines. A list of ARGA’s related/connected issuers is available to clients upon request at no charge. Insider Trading. ARGA’s insider trading policy forbids employees from (i) trading, either personally or on behalf of others, on the basis of material non-public information; or (ii) communicating material non-public information to another person in violation of the law. This policy extends to the activities of our employees both within and outside their duties at the firm. We have also implemented a number of controls designed to detect and prevent insider trading.

Personal Securities Transactions. To ensure employees do not use knowledge of client transactions for personal gain, all employees identified as Access Persons, their spouses and their immediate family members living in the same household are subject to reporting and certification requirements. Specifically, Access Persons must (i) identify any and all personal investment accounts in which they may have a direct or indirect beneficial interest initially upon hire or upon becoming an Access Person and annually thereafter; and (ii) disclose, on a quarterly basis, all reportable transactions and investment activity in such investment accounts. Access Persons, their spouses or immediate household family members contemplating the purchase or sale of any security, including an interest in a private placement vehicle or initial public offering, must obtain pre-clearance from ARGA prior to such purchase or sale, whether or not such securities are purchased or sold on behalf of our clients. Personal transactions in reportable securities are subject to a 30-day holding period. Pre-clearance is not required for transactions in certain categories of securities such as money market funds, U.S. government securities and mutual funds. However, in the case of a mutual fund for which ARGA serves as sub-advisor, as per our Code of Ethics, pre-clearance is required prior to any purchase or sale of securities in such mutual fund. All Access Persons are also subject to periodic reporting and certification requirements. Outside Business Activities. Conflicts of interest may arise if one of our employees is involved in activities not directly related to ARGA’s activities. These conflicts have the potential to be most acute when an employee owes fiduciary or other legal obligations in connection with those outside activities. An employee in a “position of influence” or acting as a director, officer, partner, or adviser to another organization (a non-issuer) may also raise a conflict of interest due to competing interests of time or compensation, or the potential for undue influence over a potential client. As well, client confusion may arise as to which entity the client is dealing with. The potential impact or risk to a client is that the employee may put the interests associated with the various outside activities ahead of employee’s obligations and responsibilities to ARGA and its clients, which may result in, among other things, unsuitable investments recommended to or traded in for a client. For this reason, ARGA has established policies and procedures that govern the outside activities of our employees. These include a notification and pre-approval process to identify and address any potential conflicts, restricting any outside activity that would interfere or give the appearance of interfering with an employee’s ability to act in the best interests of, or perform work for, ARGA and our clients. We monitor the outside activities on an ongoing basis (through initial, annual and “as arising” reporting and certification requirements) to identify and address any new conflicts arising from changes to such activities. Gifts and Entertainment. The exchange of frequent and/or extravagant gifts and business- related entertainment may impair the independence and/or objectivity of the recipient, which could impact investment management decisions, trading activities or expenses incurred to the detriments of our clients. Therefore, our Code contains prohibitions, limitations, and reporting

and certification requirements regarding the provision and receipt of gifts and entertainment by ARGA employees. Campaign Contributions. To avoid the risk of biased decision-making in circumstances where ARGA or an ARGA employee makes a political contribution to an elected official or candidate for state or local office in exchange for potential advisory business, our Code imposes certain prohibitions, strict limitations and preclearance requirements on campaign contributions by ARGA and our employees. Additionally, all employees are subject to quarterly reporting and certification requirements concerning their campaign contributions. Internal Compensation Arrangements and Incentive Practices. Conflicts of interest may arise if an adviser creates internal compensation incentives for certain employees (such as sales or revenue targets) to recommend certain products or services. The potential impact or risks to a client is that an employee may be biased in recommending a product or service due to the compensation arrangement/incentive practice in place or the negative consequences of not achieving the sales/revenue targets and not give appropriate consideration to the suitability of a product or the appropriateness of a service to the client. As a matter of policy, the compensation of employees is not tied to investments made in the ARGA products or services provided. ARGA does not provide compensation or incentive arrangements (including sales or revenue targets) to registered individuals in respect of any advising activities. Any compensation or incentive arrangements to employees is discretionary, not directed at the contribution to the overall performance of a particular client and not tied to trades or recommendations to invest in a particular product or service. Trades for Accounts where ARGA or a Related Person of ARGA is a Partner, Director or Officer of an Issuer. Conflicts of interest may arise if an adviser or one of its related persons (i.e., a partner, director or officer) recommends or purchases securities of an issuer where the adviser or the related person is a partner, director or officer of that issuer. The potential impact or risk to a client is that the adviser or its related person may be incentivized to invest in the issuer due to their position at the issuer and the associated potential benefits, rather than because the investment is in the best interests of a client. This conflict overlaps with conflicts arising from outside activities, described above. ARGA has policies and procedures designed to ensure investments for its clients are suitable based on the client’s objective and guidelines and restrictions. At the current time, ARGA employees are not permitted to act as a partner/director/officer of an issuer. Restrictions on Trades with Certain Investment Portfolios. Conflicts of interests may arise if an adviser recommends or effects a trade between clients, or between a client and an adviser (or its personnel). These transactions, known as “cross trades,” present an inherent conflict of interest since the adviser is effectively negotiating for both sides of the trade (i.e., with respect to the sale of such investment between the portfolios as it manages both the selling portfolio that controls

the portfolio asset and the follow-on portfolio purchasing the investment in the portfolio asset). The adviser may be incentivized to benefit one account over the other to maximize its fees. The potential impact or risk to a client is that an adviser may recommend or effect trades that are not in the best interests of each client, may preference the interests of one adviser client over another client, or of the adviser (or its personnel) over a client, or which may increase costs to the client. As a matter of policy, ARGA does not engage in cross trades. Interested Transactions. We may, from time to time, invest in a security in which our firm or one of our related persons, directly or indirectly, has an interest. For instance, it should be expected that the assets of the firm or our related persons will be invested in securities of issuers in which one or more of the Accounts hold positions. In addition, the assets of one Account may be invested in securities of issuers in which other Account or Accounts hold positions. Given the likely frequency of such an occurrence, clients will not be provided with notification of such occurrences. This may represent a conflict of interest for us, and this conflict, and our procedures for addressing such conflict, are described in Item 6 of this brochure. As described above, all personal securities transactions by the firm’s Access Persons are subject to pre-approval before the Access Person may proceed with the transaction, except for transactions in certain categories of securities such as mutual funds (unless ARGA serves as subadvisor to such mutual funds, in which case pre-clearance is required), money market funds and U.S. government securities. We may permit an Access Person to buy or sell securities or related securities that an Account is also buying or selling, but subject to the requirement that such a transaction will not disadvantage any client Account. We may permit an Access Person to invest in the Mutual Funds that ARGA manages, but subject to the requirement that such a transaction will not disadvantage any client account and does not violate restrictions related to insider-trading. In addition, as described earlier, all Access Persons are required to submit personal trading information to the firm for compliance review. Our pre-approval procedure and the submission of Access Persons’ personal trading information assist us towards our goal of ensuring that no personal trading of any Access Person will disadvantage any client Account. Valuation. Conflicts of interest may arise if an adviser is involved in the valuation of securities held in client accounts because the adviser may be incentivized (via management, performance or account fees) to establish higher values in pricing portfolio positions. Inflating valuations may also help the adviser by overstating portfolio performance thus potentially attracting additional client investment, thereby increasing assets under management, which in turn may increase asset-linked fees. The potential impact or risk to a client regarding this conflict is that securities in a portfolio could be overvalued, which could increase management, performance and/or account fees.

ARGA has established policies and procedures governing the valuation of securities, in accordance with applicable recognized accounting standards and industry practices governing the fair valuation of investments. Valuation of investments follow an established pricing matrix. Any changes, overrides or errors to policies and procedures are escalated to the Chief Compliance Officer and ARGA’s GIPS (Valuation) Committee. Error Management (Trade or Pricing Errors). Conflicts of interest may arise in connection with the treatment of trade and pricing errors in a client account. Trade errors include trades in securities in the incorrect amount of securities intended to trade for a portfolio; a purchase (sale) of a security when it should have been sold (or purchased); the purchase or sale of a security not intended for the portfolio, and/or contrary to investment guidelines or restrictions; and incorrect allocations of trades. Pricing errors include an overstatement or understatement in the valuation of a portfolio security. The associated conflict arises because the adviser may wish to protect its own interests rather than acknowledge its error and/or engage any obligations to compensate a client portfolio for a loss or to hold onto a gain. The potential impact or risk to a client is that errors may not be appropriately resolved, resulting in incorrect client portfolio security pricing, incorrect client fees or increased costs to a client account resulting from corrective measures, all of which may negatively impact a client’s investment or return. ARGA has established policies and procedures to ensure clients are made whole where there is a trade error arising from ARGA’s actions. If an error is caused by a party other than ARGA, ARGA will seek reimbursement or monetary compensation from the other party that caused the error, as appropriate, to minimize any loss. ARGA has established policies and procedures for daily trade matching to ensure trade details are correct and have been input to our portfolio management system correctly so that trade errors are identified and rectified in a timely manner. Marketing Practices. Conflicts of interest may arise from the discretion that an adviser has over marketing materials (and representations included in those materials) provided to current and prospective clients. Given that attracting and retaining investment capital is critical to the profitability and general success of an adviser, the adviser may have an incentive to misrepresent or overstate various evaluation metrics (including but not limited to investment performance, strategy, and service offerings) in order to influence capital allocation decisions of current and prospective clients, possibly to the detriment of those clients. The potential impact or risk to a client is that a decision to establish a relationship with the adviser may be based on misleading or exaggerated information provided to the client, and not on the basis that the advancement of such a relationship should be based on the best interest of a client. In turn, this could result in unsuitable investments being made on behalf of a client. ARGA has established policies and procedures designed to ensure that our marketing materials comply with the rules and regulations governing the advertising and solicitation activities of

investment advisers. Our marketing materials undergo multiples checks internally and are reviewed and approved by ARGA’s compliance department prior to use or distribution, in an effort to ensure information is accurate, complete, not misleading and can be substantiated. Performance metrics are required to be calculated in accordance with established policies and procedures and performance criteria are disclosed in accordance with regulatory obligations. Actual or potential conflicts arising in best execution, soft dollars, and proxy voting are described below in Item 12. Brokerage Practices and Item 17. Voting Client Securities. Reporting of Violations. Our employees are required to report any apparent or potential violation of the Code to the Chief Compliance Officer. Review and Enforcement. The Chief Compliance Officer is responsible for ensuring adequate supervision over the activities of all employees who act on our behalf in order to prevent or detect violations of the Code by such employees. The foregoing is a summary of our Code. Clients and prospective clients may obtain a complete copy of the Code by addressing a request to Neda Clark, Chief Compliance Officer, 1010 Washington Blvd., 6th Floor, Stamford, CT 06901 or clark@argainvest.com.

In addition to broker oversight, the Committee also evaluates our soft dollar arrangements, discussed in more detail below under “Soft Dollars.” We do not adhere to any rigid formulas in making the selection of our executing broker-dealers but rather allocate a portion of each Account’s brokerage business to the brokers weighing a combination of criteria including the broker’s execution capability, accessibility and responsiveness, back office processing capabilities, timeliness of trade execution, reputation and financial soundness, trade accuracy and ability to maintain anonymity, in addition to the value of the research provided by the broker. The commissions an Account will pay to brokers may not necessarily represent the lowest commission rates available but will also reflect our qualitative evaluation of the research or other

brokerage related services supplied by such brokers and which benefit the Account, either alone or together with other Accounts. In each case, we will make a determination that the amount of any increased commission costs on account of such research or other services is reasonable relative to the value of services so provided. Actual brokerage commissions received by a broker-dealer may be more or less than the suggested allocations. From time to time, clients may ask ARGA for feedback or suggestions with regard to the use of certain broker-dealers and/or custodians. While ARGA is never involved in the decision-making process with the client, we may offer some information based on our experiences with certain firms and we may make introductions if requested. ARGA receives no economic benefit for any introduction it may make. Soft Dollars The research obtained through an Account’s brokerage allocations, whether or not directly useful to that Account, may be useful to us in connection with services we render to another Account or Accounts we manage. Similarly, research we obtain for commissions paid to brokers in the course of managing such other Accounts may be useful to such Accounts that generate the commissions as well as other client Accounts. Since any particular research we obtain may be useful to the Account generating the commissions as well as other client Accounts, in considering the reasonableness of brokerage commissions paid by an Account, we will not attempt to allocate the relative costs or benefits of research between the Account and the other Accounts we manage. Section 28(e) of the Securities Exchange Act of 1934, as amended, provides a "safe harbor" to investment managers who use commission dollars of their advisory accounts to obtain investment research, brokerage and other services that provide lawful and appropriate assistance to the managers in performing their investment decision making responsibilities, provided that the amount of any increased commission costs on account of such research or other services is reasonable relative to the value of the services so provided. Any such arrangement we may enter into will be confined to the products or services that qualify as eligible “research and brokerage services” within the meaning of Section 28(e) and that meet the other requirements of that Section. The research we receive under such an arrangement may be both proprietary (prepared by the relevant broker/dealer) or created or developed by third parties. ARGA has soft dollar arrangements with certain brokerage firms that execute transactions on behalf of ARGA’s clients (the “Soft Dollar Broker”). Per the soft dollar policy and arrangement, the Soft Dollar Broker pays for certain research and brokerage services (including valuation services and data, databases, analysis, and reports concerning issuers, industries, securities, markets, economic factors and trends). When we use an Account’s brokerage commissions to obtain research or other products or services, we receive a benefit because we do not have to produce or pay for the research, products or services. We may, therefore, have an incentive to select or recommend a broker29

dealer based on our interest in receiving the research or other products or services, rather than on the Account’s interest in receiving most favorable execution. We may cause an Account’s brokerage commissions to be higher than those charged by other broker-dealers in return for soft dollar benefits. In addition, certain brokerage or research services obtained with soft dollars may be used for investment decision-making purposes as well as purposes unrelated to investment decisionmaking. With respect to any such services, ARGA will make a reasonable allocation of the cost of the service between “soft” and “hard” dollars based on the extent to which the services are used for investment decision-making purposes (which may be paid for with soft dollars) versus non-investment decision-making (which are paid for with hard dollars out of ARGA’s own funds). The allocation of costs between soft and hard dollars presents an additional conflict of interest between ARGA and certain of its Accounts (i.e., those from which ARGA receives soft dollar benefits). As mentioned earlier in this section, ARGA allocates its trades based on a variety of criteria. Once the trade allocation is determined, ARGA directs client transactions to the executing brokers, which may be a Soft Dollar Broker, to execute transactions on a client’s behalf. The transactions executed with the Soft Dollar Broker may result in soft dollar benefits. In general, any and all brokerage allocations will be subject to principles of best execution and the other allocation policies described above, as well as any restrictions imposed by applicable law. Clients may direct ARGA to use a particular broker-dealer under certain circumstances, including where a client has a pre-existing relationship with the broker or participates in a commission recapture program, among other situations. ARGA still maintains a fiduciary responsibility to disclose to the client that due to the directed brokerage arrangement, the client may not benefit from ARGA’s ability to obtain lower transaction costs through bunching orders. ARGA may limit the amount of directed brokerage that a client can use. We may be unable to achieve most favorable execution of client transactions and directing brokerage may not be costeffective to clients. Aggregation of Orders When we deem the purchase or sale of securities to be in the best interest of more than one Account, we may aggregate the securities to be purchased or sold by all such accounts in order to obtain best execution or lower brokerage expenses. In particular, execution prices for identical securities purchased or sold on behalf of multiple Accounts in any one business day may be averaged. In cases where it is not economical to pro-rate trades, such as when the total number of executed shares does not make it economical to allocate the shares to all Accounts due to transaction costs per allocation, we allocate shares to the Accounts utilizing the computer-generated random by

account allocator function of our order management system. In these circumstances we may be unable to achieve most favorable execution of client transactions. All trade orders are generally allocated among Accounts of the same or similar mandate at the time of trade creation / initial order preparation. Factors affecting order creation include availability of cash, existence of client-imposed trading restrictions or prohibitions, trading holds or halts imposed by our investment team or a recognized exchange, among other things. We may bunch or aggregate like orders, but allocation is determined before any order is given to a broker.

We provide the investors in our Funds with written monthly statements, which include their account asset values and performance figures, monthly commentary and quarterly reports. We also provide investors with audited Fund financial statements on an annual basis. With respect to investors in the ARGA Mutual Funds, shareholder statements are made available to investors by the funds’ transfer agent on a monthly basis. Semi-annual Reports, Annual Reports (which include audited financials), the Prospectus and the Statement of Additional Information for each Mutual Fund are made available to investors by the funds’ administrator, SEI Investments Global Fund Services. They are also available on the ARGA website at: www.argainvest.com. With respect to the CIT Funds, shareholder statements are available on a monthly basis on the website of SEI Trust Company, the Trustee of the ARGA Investment Management Collective Trust. All CIT Fund documents are also available on the Trustee’s website. Other Accounts. We provide our Separate Accounts with written monthly reports and more detailed quarterly reports, as requested by such clients. The reports may include such details as account asset value, performance and top contributors and detractors.

The Commingled Funds are subject to an annual financial statement audit by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. The audited financial statements are prepared in accordance with generally accepted accounting standards in the USA and are distributed to each such Funds’ investors within 120 days following the Fund’s fiscal year-end. Assets of the CIT Funds and Mutual Funds are deposited with the applicable qualified custodian of such funds. Audited financial statements of the CIT Funds are available on the website of SEI Trust Company, the Trustee of the ARGA Investment Management Collective Trust, within 120 days following the CIT Funds’ fiscal year end. Audited financial statements of the Mutual Funds are distributed to investors by SEI Investments Global Fund Services, the administrator of the Mutual Funds, within 60 days of the Mutual Funds’ fiscal year end. Assets of Separate Accounts clients are deposited with a custodian selected by each such client. The qualified custodian generally provides Clients with performance reports and/or account statements, at least quarterly. ARGA sends monthly commentaries to clients, which include performance data. Clients should always carefully review the account statements they receive from the qualified custodian and compare them with the monthly commentaries received from ARGA. Clients’ custodians maintain the official accounting records of clients’ accounts.

sale of securities for a client’s account and the commission rates to be paid to a broker-dealer for an Account’s securities transactions. Investors in the ARGA Funds do not have any ability to restrict the investment of their account other than guidelines agreed to within applicable offering documents. Separate Accounts may negotiate reasonable investment restrictions, relevant to their particular circumstances, as agreed to within the applicable advisory agreement.

We have determined that Glass Lewis has (i) the capacity and competency to adequately analyze proxy issues based on current and accurate information; and (ii) robust policies and procedures which enable it to offer research in an impartial manner and in the best interest of our clients. ARGA analysts will still apply ARGA’s proxy voting guidelines described below, when voting proxies on behalf of clients through Glass Lewis. This includes rejecting the advice of Glass Lewis in circumstances where ARGA determines doing so is in the best interest of our clients. These proxy voting guidelines are clearly described in our Proxy Voting Policy and designed to promote the best interest of our clients’ portfolios. Our views and voting policies are general principles, not absolute terms, and we may consider certain voting decisions on a case-by-case basis depending on a company’s particular facts and circumstances. Routine Matters Generally, we vote proxies in favor of routine proposals, unless there is specific information indicating that approval of the proposal would adversely affect the value of the investment or would not be in the best interest of clients. Such routine matters generally include, among others: routine election of directors, appointment of independent auditors, date and place of the annual meeting, ratification of directors’ actions on routine matters, and indemnification of directors and/or officers. Generally, we vote “for” proposals that are determined to improve the management of a company, increase the rights or preferences of the voted securities, and/or increase the chance that a premium offer would be made for the company or for the voted securities. Our decision to vote in support or opposition of a proposal will be based on the specific circumstances described in the proxy statement and other available information.

Social Conscience/Moral Issues We generally vote on a moral or social issue based on the potential economic impact of the proposal. In cases where the economic impact is not clear, a vote to “abstain” may be appropriate. Financial or Corporate Governance Questions Financial and corporate governance issues take more time to consider and may be complicated by activities such as hostile takeovers and mergers. ARGA will generally vote in favor of the following types of proposals:

Election of competent, qualified directors that support the board’s independence. ARGA generally believes that two thirds of the board should be independent and that elections should be held as part of a formal and transparent process, the details of which should be fully disclosed. Mandatory retirement age for directors. Appointment of external auditors that provide qualified, competent advice, avoid conflicts of interest and uphold the transparency and integrity of financial reporting; and Reasonable incentive compensation plans for executives and directors that encourage long-term alignment, for example share ownership and/or variable performance-based components with long-term assessment horizons. Compensation plans that align executives and directors with long-term sustainability targets. Confidential voting, cumulative voting, “bundled” elections or proposals to lower barriers to shareholder action. Proposals to restore shareholder ability to remove directors with or without cause.

ARGA will generally vote against the following types of proposals:

Compensation plans that are not aligned with shareholder interests, such as short-term performance-based incentives, stock options that form a significant part of compensation, a large component of guarantees or discretionary component and target pay above industry/peers median. Board entrenchment proposals and anti-takeover measures, such as “poison pill” and “golden parachute” provisions. Related party transactions, where insufficient disclosures have been furnished for a fully informed vote. Limitations on shareholder ability to act, blank check preferred stock authorizations, eliminating cumulative voting rights, and proposals to adopt classified boards.

Sustainability Considerations ARGA will generally vote “for” proposals that increase the level of oversight and improve sustainability practices. Examples include:

Appointments of directors/board level committees charged with oversight of sustainability issues. Increased disclosure and documentation of sustainability policies. Implementation of sustainability targets that are deemed to have a positive long-term impact on company earnings.

ARGA will generally vote “against” the following types of proposals:

Policies that directly contravene industry sustainability standards and that put the company at risk of litigation. Policies that are likely to have a detrimental impact on the safety of employees. Decreased transparency and reporting.

Shareholder Proposals ARGA will consider all proposals and vote “for” proposals that promote greater accountability and enhanced governance structures. Dividend and Share Buybacks Dividend and share buyback programs will generally be assessed on a case-by-case basis in the context of the most efficient use of capital. We endeavor to engage with companies to understand in depth their rationale for such programs. Corporate Actions: Class Actions, Litigation, Bankruptcy Other than with respect to the ARGA Funds, ARGA will not have any responsibility to initiate, consider or participate in any bankruptcy, class action or other litigation against or involving any issue of securities held in, or formerly held, in a client Account or to advise or take any action on behalf of a client or former client with respect to any such actions or litigation. Client Guidelines Some clients may have their own set of proxy voting guidelines. These may conflict with the proxy guidelines discussed above or the voting guidelines of another client. If such a situation arises, we comply with client guidelines by voting the proxies based on the number of shares held by the client. Conflicts of Interest To the extent there is a perceived conflict of interest between the best interests of a client and those of the analyst or of ARGA as the investment adviser, the matter is referred to the Chief Investment Officer and the Chief Compliance Officer. These individuals will determine that a material conflict exists or may be perceived to exist and will decide whether it is appropriate to disclose the conflict to the affected client to give the client an opportunity to vote the proxy or to address the voting issue through other objective means, such as voting in a manner consistent with a pre-determined voting policy or receiving an independent third-party voting recommendation.

In the unlikely event the proxy issue is not addressed by the guidelines above and materially conflicts with the interests of ARGA or any person involved in the proxy voting process, we will nevertheless vote such proxy in the best financial interest of the client and will document the basis for such vote. Proxy advisory firms such as Glass Lewis may have significant business relationships with subjects of their research and voting recommendations. For example, a Glass Lewis board member may also sit on the board of a public company for which Glass Lewis may have published a research report or a Glass Lewis client may be a public company with an upcoming shareholder’s meeting and Glass Lewis may have published a report with voting recommendations. These and similar situations give rise to an actual or potential conflict of interest. We believe Glass Lewis has implemented adequate Conflict Management Procedures to avoid and manage (if unavoidable) conflicts of interest arising between an issuer and Glass Lewis. For example, Glass Lewis requires any employee who serves as an executive or director of a public company to disclose the conflicts and abstain from any involvement in the research, analysis or making of any vote recommendations for such company. Limitations on ARGA’s Proxy Voting Obligations ARGA may elect not to vote client proxies or may abstain from voting in certain situations:

We will not vote proxies on behalf of a client where the client has reserved the right to vote proxies itself or has delegated the right to vote to a third party. We will not vote proxies on behalf of a client after the effective termination date of the investment advisory agreement with such client. We may abstain from voting proxies in circumstances if we determine doing so would have no identifiable economic benefit to the client, such as when the security is no longer held in the client’s portfolio or when the value of the portfolio holdings is insignificant. We may abstain from voting a client’s proxy when the cost or disadvantage resulting from voting, in our judgment, outweighs the economic benefits of voting. For example, in some non-U.S. jurisdictions, the sale of securities voted may be prohibited for some period of time, usually between the record date and meeting date (“share blocking”). In general, ARGA believes that the loss of investment flexibility resulting from share blocking generally outweighs the benefit to be gained by voting. We do not offer a securities lending service. Proxies for securities on loan through securities lending programs will generally not be voted, as ARGA’s clients (not ARGA) control these securities lending decisions. We may not be able to vote proxies due to circumstances beyond our control such as a regional disaster, business continuity or cyber event involving ARGA, our proxy advisory firm or client custodians, which may prevent proxies from being voted on time, or errors not attributable to, and beyond, ARGA’s control.

Disclosures Clients may obtain a copy of ARGA’s current Proxy Voting Policy and/or the method for obtaining information concerning the voting of any proxy by contacting Neda Clark, Chief Compliance Officer at (203) 614-0819 or clark@argainvest.com. Clients may also request such information by writing to Neda Clark, Chief Compliance Officer at ARGA Investment Management, LP, 1010 Washington Blvd., 6th Floor, Stamford, CT 06901.