Nippon Life Global Investors Americas, Inc.: investment adviser

NLGIA makes investment recommendations for NAMCO; however, NLGIA is not responsible for implementing the recommended transactions. The terms of the investment management agreement, investment sub-management agreement, investment advisory agreement, investment guidelines, or other applicable documents (”Governing Documents”) determines whether NLGIA has full discretion in choosing investments. NLGIA’s advisory services consist of making recommendations and/or executing investment decisions as applicable according to each clients’ Governing Documents in real estate funds, infrastructure funds, private equity funds, private debt funds, and the equity funds and fixed income funds.

Such charges, fees, and commissions are exclusive of, and in addition to, NLGIA’s fee, and NLGIA does not receive any portion of these commissions, fees, and costs. Information regarding NLGIA’s brokerage practices is included in this brochure under the heading Brokerage Practices. In addition, when investing in other private funds, clients will incur fees and expenses charged to investors in those funds.

Performance could be negatively impacted by a number of different market risks including but not limited to:

Market conditions – the prices of common stocks and other securities may decline due to market conditions and other factors, including those directly involving the issuer.

Security selection – the identification of securities representing high-quality businesses and management teams is a difficult task, and there are no assurances that such opportunities will be successfully recognized over the long term. While such investments offer opportunities for above-average capital appreciation, they also involve a high degree of financial risk and can result in substantial losses.

Investments in Fixed Income Securities – risks associated with investing in fixed income securities (i.e., bonds) include: o The bond issuer’s inability to pay interest or repay the bond; o Changes in market interest rates cause the bond’s value to fall; o Illiquidity in the bond market may make the bond difficult or impossible to sell; o The bond issuer may repay the bond prior to maturity; or o Inflation may reduce the effective yield on the bond’s interest payments.

Bonds Call Provisions – many bonds, including agency, corporate and municipal bonds, and all mortgage-backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, clients are exposed to reinvestment rate risk – clients will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond.

Investments in Private Funds – investments in private funds tend to be illiquid and this could impair NLGIA’s ability to redeem an investment from private funds.

Fund-of-Funds (“FoFs”) Strategies Risk – investment performance of FoFs is directly related to the performance of the underlying funds. There is no assurance that the underlying funds will achieve their investment objectives. Additionally, funds are subject to the risks of the underlying investments, including general market risks (e.g., real estate, equities, etc.); currency risks; geographic and sector focus risks; foreign securities and emerging markets risks; credit and counterparty risks; regulatory risks and individual investment risks. In addition, NLGIA will have no ability to assess the accuracy of the valuations received

from the private funds since asset values will typically be estimates, subject to revision through the end of each underlying fund's annual audit.

Cyber Security Risk – as the use of technologies, such as the internet, has become more common in conducting business, NLGIA may be more susceptible to operational, information security, and related risks in connection with breaches in cyber security. Generally, a cyber security failure may result from either intentional attacks or unintentional events and include, but are not limited to, gaining unauthorized access to digital systems, misappropriating assets or sensitive information, causing NLGIA and/or its clients to lose proprietary information, corrupting data, or causing operational disruption, including denialof-service attacks on websites. A cyber security failure could cause NLGIA and/or its clients to become subject to regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial losses. Cyber security failures may involve third-party service providers, joint venture partners, and investments made by, or counterparties in transactions with, NLGIA or its clients. NLGIA has established policies and procedures reasonably designed to reduce the risks associated with cyber security failures; however, there can be no assurance that these policies and procedures will prevent or mitigate the impact of cyber security failures.

Force Majeure Events – client holdings may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of infectious disease, pandemic or any other serious public health concern, war, terrorism, labor strikes, major plant breakdowns, pipeline or electricity line ruptures, failure of technology, defective design and construction, accidents, demographic changes, government macroeconomic policies, social instability, prolonged changes in climatic conditions, etc.).

Use of Artificial Intelligence Risk: We use certain artificial intelligence (“AI”) tools to support components of our investment research and analysis. While AI may enhance efficiency, its use introduces specific investment‑related risks. These include the possibility that AI models rely on incomplete, inaccurate, or biased data, which may lead to flawed investment insights or predictions that could negatively affect investment performance. AI tools may also operate as “black boxes,” making it difficult to fully understand or validate their recommendations, which can limit our ability to identify embedded model risks. Additionally, rapid changes in AI regulation across jurisdictions may affect how AI can be used within our investment process, potentially altering or constraining our analytical capabilities. As with any investment methodology, the use of AI does not eliminate the risk of loss. Clients should be aware that AI‑supported insights may not perform as expected under all market conditions.

Place the integrity of the investment profession and the interests of clients above one’s own personal interest;

Adhere to the fundamental standard that employees should not take inappropriate advantage of their position;

To act solely in the best interest of the client and make full and fair disclosure of any conflict of interest;

To the extent practicable, avoid or disclose any conflicts of interest that are material to providing investment advisory services to clients;

Conduct all personal securities transactions in a manner consistent with the Code;

Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities; and

Abide by the requirements contained in the Investment Advisers Act of 1940, as amended, and rules thereunder, as well as applicable provisions of the Federal Securities laws.

NLGIA’s Code prohibits employees from trading in certain securities and also requires employees to: 1) pre-clear certain personal securities transactions, 2) report personal securities transactions on at least a quarterly basis, and 3) provide NLGIA with a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such employees have a direct or indirect beneficial interest. A copy of NLGIA’s Code shall be provided to any client or prospective client upon request.

In making its decisions regarding the allocation of brokerage transactions, NLGIA will consider a variety of factors including but not limited to: (i) the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); (ii) the operational efficiency with which transactions are affected (such as prompt and accurate confirmation and delivery), taking into account the size of order and difficulty of execution; (iii) the financial strength, integrity, and stability of the broker-dealer or counterparty; (iv) the competitiveness of commission rates in comparison with other broker-dealers; (v) provision or payment of the costs of research and other services or property; and (vi) ability to provide corporate access (such as the number of corporate meetings arranged). Although NLGIA generally seeks competitive commission rates and commission equivalents, it will not necessarily pay the lowest commission or equivalent. Transactions may involve specialized services on the part of a brokerdealer, which may justify higher commissions and equivalents than would be the case for more routine services. NLGIA does not participate in any soft dollar arrangements outside of eligible “research or brokerage services” under Section 28 (e) of the Securities Exchange Act of 1934 such as receiving research reports analyzing the performance of a particular company or stock. These services received from brokers and dealers are supplemental to NLGIA’s own research effort. Research and related services furnished by brokers may include written information and analyses concerning specific securities, companies, or sectors; market, financial and economic studies, and forecasts; statistics and pricing services; as well as discussions with research personnel and software, seminars, or conferences that provide content relating to a permissible subject matter, post-trade matching of information. Since commission rates are negotiable, selecting brokers on the basis of considerations which are not limited to applicable commission rates may at times result in higher transaction costs than would otherwise be obtainable. NLGIA executes certain fixed income transactions through a third-party electronic trading platform (the “Platform”) that supports various classes of fixed income securities. The access fees assessed

by the Platform are paid by NLGIA and not its clients, and, depending on the volume of trades, the Platform provides NLGIA with a small discount off of these fees. The receipt of this discount could be viewed as a conflict of interest in that NLGIA could have an incentive to trade through the Platform in order to receive the discount. However, NLGIA believes this potential conflict is mitigated or minimized because the size of the discount relative to NLGIA’s trading volume and the assessed fees is small. The Platform is widely used in the industry and NLGIA believes its usage increases its ability to achieve best execution for its clients. Furthermore, NLGIA trades through the Platform at the best net price considering all relevant circumstances. It does not base its trading decisions on whether or not the Platform provides NLGIA with a discount. NLGIA implements investment decisions based on the investment guidelines of each account. When an investment decision is appropriate for more than one client, it is NLGIA’s policy to allocate the investment on a pro-rata basis. However, in case of limited investment opportunities and partial fills, the Portfolio Manager may allocate the investment in a manner other than pro-rata after obtaining approval from the President, CCO, or head of the portfolio management team.

If the company fails the screening process, NLGIA will closely examine the proxy before determining how it will vote. NLGIA has not identified any material conflicts of interest in connection with past proxy votes or with ISS. Absent specific client instructions, if NLGIA identifies a material conflict of interest, it will seek the client’s direction on such vote. A copy of NLGIA’s proxy voting policies and procedures, as well as specific information about how NLGIA has voted in the past, is available upon written request, by contacting NLGIA’s Chief Compliance Officer.