Samsung Asset Management Company, Ltd.: investment adviser

It is headquartered in Seoul and has wholly-owned subsidiaries in Seoul, New York, London, Hong Kong. SAMC’s Seoul-based subsidiaries are Samsung Active Asset Management Co., Ltd. (“Samsung Active”), and Samsung Hedge Asset Management Co., Ltd. (“Samsung Hedge”).We have a participating affiliate agreement with Samsung Active. Types of Advisory Services SAMC exercises discretion over separately managed accounts (“Managed Accounts”) and pooled investment vehicles. SAMC provides expert discretionary investment advice on Korea and Asian markets. SAMC’s investment strategy focuses on a wide array of equity and fixed income products centered in Korea and the broader Asian markets. We do have non-discretionary clients. SAMC currently provides these investment management services: 1.

manager to other investment advisers (“Advisers”) and foreign investment funds (“Foreign Funds”), including collective investment schemes which are offered to Korean retail investors through a third-party sponsor or distributor; and

2.

adviser to Managed Accounts (with Advisers and Foreign Funds, “Clients”) in accordance with Client investment objectives as specified in the applicable investment management agreement.

SAMC also provides administrative services. These include: 1.

administrative matters related to the operation of Foreign Funds and/or Managed Accounts, including coordination amongst broker dealers, custodians, transfer agents, administrators, record-keepers, accountants, legal counsel, and other pertinent service providers;

2.

supervising sub-managers where retained by SAMC;

3.

managing compliance oversight functions in accordance with applicable laws and regulations; and

4.

maintaining or supervising the maintenance of books and records as required by applicable laws and regulations.

How Services are Tailored to Fit Client Needs SAMC directs and manages the investment strategies of its Clients in accordance with the confidential offering memorandum, prospectus, investment management agreement or other applicable constituent

document in connection with a Client’s investment (collectively, “Client’s Constituent Documents”). Depending on a Client’s investment objectives, the Client may select from a number of investment strategies offered by SAMC. Subject to SAMC’s consent, a Client may impose certain reasonable investment guidelines and restrictions. Client assets may be managed in separately managed accounts or by investing in a number of pooled investment vehicles. Wrap Fee Programs SAMC does not participate in “Wrap Fee” Programs. Management of Client Assets SAMC manages US$ 300,817,292,631 in assets under management, of which $ 300,770,396,733 is under discretionary management and $ 46,895,898 is non-discretionary.

Fee Billing Subject to negotiation, fees are calculated based on a percentage of the market value of a Client’s assets under management or historical cost (or book value) in certain circumstances and are payable in agreed terms. Fee payment due dates are negotiable; generally, fees are due monthly, quarterly or yearly in arrears. Each Client’s fees are negotiable and fall either within or outside such range, depending upon a variety of factors including the type of Client, the strategy being employed, the size of the account, SAMC’s relationship with the Client and the amount or type of services required. The way fees are charged by SAMC is established in the Client’s Constituent Documents or other written agreement with SAMC. Generally, SAMC will invoice its fee in arrears each agreed period. Clients may elect to be billed directly for fees or to authorize SAMC to directly debit fees from Client accounts. If a Client elects to authorize SAMC to directly debit fees from an account, the Client should review the billing invoice to verify the fee calculation and the corresponding debit as reflected in their account statement provided by their custodian. Other fees and Expenses SAMC’s fees are exclusive of brokerage commission, transaction fees and other related costs and expenses which are incurred directly by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third-party service providers. Such fees may include, but are not limited to, custodian fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and

electronic fund fees, management fees and other fees and taxes on brokerage accounts and securities transactions. Where SAMC invests in or otherwise recommends an investment in a mutual fund, ETF or similar collective investment vehicle, such fund may also charge internal management fees and expenses, which are in addition to SAMC’s fees, and are disclosed in the fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to SAMC’s fee, and SAMC does not receive any portion of these commissions, fees or charges. Item 12 describes the factors that SAMC considers in selecting or recommending broker-dealers for Client transactions and determining the reasonableness of compensation (e.g., commission rates). SAMC will exercise discretion and invest Client assets in SAMC managed funds. This is a conflict of interest, and SAMC will only make such an investment if it is established that this would be suitable for the Client and where there is a reasonable basis for the action. Advanced Payment: Termination of Services SAMC’s fees are not payable in advance. Investment management agreements may be terminable by either party as negotiated. In the case of any termination, management fees will be determined on a pro rata basis through the date of termination. Sales-Based Compensation Neither SAMC nor SAMC’s supervised persons receive compensation for the sale of securities or other investments, including asset-based sales charges or service fees from the sale of mutual funds.

SAMC’s receipt of performance-based fees can incentivize SAMC to make investments that are riskier or more speculative than it would make in the absence of performance-based fees. With respect to certain private Foreign Funds that SAMC manages, the performance-based fee cannot be the product of arm’s length negotiations. SAMC manages Client accounts that are charged an asset-based percentage fee as well as a performance-based fee. This arrangement is commonly referred to as “side-by-side” management. While a performance-based fee serves to align SAMC’s interests with those of its Clients, it results in a conflict of interest. Such conflict arises, for example, because SAMC may be motivated to devote more resources or allocate more favorable investment opportunities to Client accounts that offer SAMC the opportunity to collect a performance-based fee. SAMC does not charge the same fees or fee-types to all Clients. As a result, SAMC has a conflict of

interest between its interest in treating all Client accounts alike and its interest in favoring certain Clients over others because such Clients may pay more in fees. SAMC will not knowingly or deliberately favor any Client account over any other Client account. SAMC applies a rigorous and consistent approach to investment management across all Client assets regardless of the particular fee structure. SAMC has an allocation policy that mitigates the risk that investment opportunities will be allocated to Client accounts based, even in part, on fees. Client assets under management receive the same detailed attention. We monitor compliance with this.

Investment models include, but are not limited to, earnings multiples, cash flow, leverage, sales, costs and other variables. SAMC’s portfolio construction process diversifies holdings across sectors, market capitalization, weightings and other variables in order to mitigate risk. Equity Investment SAMC has transferred to Samsung Active the management of certain equity funds that pursue more active investment strategies (generally aiming to profits higher than stock index or benchmark objectives) but retained the management of the equity funds that pursue passive investment strategy (generally aiming to make consistent returns aligned with stock index). Model Portfolio Construction: Using SAMC’s proprietary earnings model, investment teams identify companies with higher upside potentials and based on earnings momentum and valuation. Strategic Portfolio Construction: Investment teams identify momentum shifts by using SAMC’s proprietary earnings and investment grade tracking system and utilize SAMC’s portfolio management system to construct a Strategic Portfolio. Portfolio Management: Investment teams construct actual portfolios based on the strategic portfolio

reflecting the Client’s risk profile and investment horizon. Fixed Income Investment Research: Research analysts forecast the general economic outlook and yield curve and generate relative value analysis of the yield curve and relative value analysis of specific sectors and credit. Portfolio Construction: Investment teams design an investment style and strategy in line with Client objectives. Monitoring Feedback: Investment teams continually reappraise the investment style and strategy for optimization through regular base performance attribution analysis. Investment teams may also use quantitative performance analytics such as Lehman Brothers Attribution Model. Risks Health related outbreaks, epidemics and/or pandemics can and do have a significant impact on investments. Impacts can result in economic downturns and cause operational, contractual and other market disruptions. Such events can cause consumer confidence and spending to fluctuate or result in increased volatility in the U.S. and worldwide financial markets. The Coronavirus pandemic had a severe impact on the Korean, Asian and world markets and economies. It is not possible to understand its medium- and long-term effects or how this may further affect the performance of securities or the portfolios of SMAs or pooled investment vehicles. Our Business Continuity Plan is in effect and we are monitoring the situation carefully. Material Risks Associated with Investment Strategies The material risks for SAMC’s significant methods of analysis and investment strategies lie in the particular risks of the securities in which SAMC’s Clients invest as set forth below. SAMC cannot guarantee that it will achieve the investment objectives of its Clients. Material Risks of Particular Security Types SAMC invests in various types of securities and non-security assets to achieve Client investment objectives. Below is a non-exhaustive list of risks that are associated with SAMC’s investments. Foreign Investment Generally: Investments made outside of the U.S. and the economies of non-U.S. countries may differ favorably or unfavorably from the U.S. economy in such respects as:

Growth of gross domestic product; Rate of inflation; Currency depreciation; Asset reinvestment; Resource self-sufficiency; and Balance of payments position.

Further, certain non-U.S. economies are heavily dependent upon international trade and, accordingly, have been and may continue to be adversely affected by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade. The economies of certain non-U.S. countries may be based, predominantly, on only a few industries and may be vulnerable to changes in trade conditions and may have higher levels of debt or inflation.

Emerging Markets Risk: The risks of foreign investments are typically greater in less developed countries, which are sometimes referred to as emerging markets. For example, political and economic structures in these countries may be changing rapidly, which can cause instability and greater risk of loss. These countries are also more likely to experience higher levels of inflation, deflation or currency devaluation, which could hurt their economies and securities markets. For these and other reasons, investments in emerging markets are often considered speculative. Geographic Concentration Risk: A small number of companies and industries may represent a large portion of the market in a particular country or region, and these companies and industries can be sensitive to adverse social, political, economic or regulatory developments in that country or region. Equity Securities Risk; Stock Market Volatility: Equity securities include common and preferred stocks. Stock markets are volatile. The value of equity securities is affected by changes in a company’s financial condition and overall market and economic conditions. Preferred stock may be subject to optional or mandatory redemption provisions. Foreign Securities Risk: Foreign investments may be subject to different and, in some cases, less stringent regulatory and disclosure standards than U.S. investments. Also, political concerns, fluctuations in foreign currencies and differences in taxation, trading, settlement, custodial and other operational practices may result in foreign investments being more volatile and less liquid than U.S. investments. Because foreign investments are typically issued and traded in foreign currencies, their values may be significantly affected by changes in exchange rates between foreign currencies and the U.S. dollar. Foreign regulatory and fiscal policies may affect the ability to trade securities across markets. Foreign markets may also differ widely in trading and execution capabilities, liquidity and expenses, including brokerage and transaction costs. Brokerage and transaction costs are generally higher for foreign securities than for U.S. investments. Inflation Risk: Inflation risk is the risk that the present value of assets or income from investments will be less in the future as inflation decreases the value of money. The present value of a Fund’s assets and distributions can decline as inflation increases. Large-Cap Securities Risk: Securities issued by large-cap companies tend to be less volatile than securities issued by smaller companies. However, larger companies may not be able to attain the high growth rates of successful smaller companies, especially during strong economic periods, and may be unable to respond as quickly to competitive challenges. Non-Diversification Risk: A Client portfolio may not be diversified. Because SAMC may in securities of a smaller number of issuers, such portfolios may be more exposed to the risks associated with and developments affecting an individual issuer than a portfolio that invests more widely. Selection Risk: The securities selected by SAMC may underperform the market or other securities selected by other advisers or managers. Small and Mid-Cap Securities Risk: Securities of small and mid-sized companies may be more volatile and subject to greater risk than securities of larger companies. Small and mid-cap companies may have limited financial resources, product lines and markets, and their securities may trade less frequently and in more limited volumes than the securities of larger companies, which could lead to higher transaction costs. Illiquidity of Investments: Certain investments made by SAMC may be long-term in nature and may require several years before they are suitable for sale. Realization of value from such investments may be difficult in the short-term or may have to be made at a substantial discount compared to other freely tradable investments.

ESG Risk: Considering ESG factors during investment decision-making is no longer a choice but an essential requirement. SAMC comprehensively reflects ESG factors in all processes, including product development, research, operations, and risk management, to identify opportunities and control risk to realize sustainable excess returns for investors.

In October 2012, FSS issued a warning letter to SAMC, finding that SAMC violated the prohibition of cross-trading without justifications when it caused 12 collective investment funds that it manages to sell the same security to 12 other collective investment funds that it manages. A warning letter and reprimands were also issued by FSS to four SAMC employees. This matter was resolved with FSS in August 2013. Additional information regarding these and other disciplinary matters involving certain SAMC affiliates is set out in SAMC’s Form ADV Part 1 and DRPs, on file with the SEC.

Samsung Fire & Marine Insurance Co., Ltd.

Samsung Securities Co., Ltd.

The largest non-life insurance company in Korea. Its principal products include automobile, long-term and commercial insurance, enterprise risk management, and annuities. Full-service Korean securities firm licensed with the Financial Services

Commission with a focus on wealth management and investment banking. It provides financial services including brokerage, asset management, investment funds and corporate finance.

A wholly-owned subsidiary of SAMC, focusing on management of Korean Samsung Active

equity funds that pursue active investment strategies (generally aiming to profits higher than stock index or benchmark objectives). It provides investment advisory services to SAMC and is a participating affiliate.

Samsung Hedge

A wholly-owned subsidiary of SAMC and specializes in managing hedge funds. It provides investment advisory services to SAMC.

Samsung Asset Management

An SFC registered investment adviser, a wholly-owned subsidiary of

(Hong Kong), Ltd.

SAMC based in Hong Kong and provides investment advisory services to SAMC.

Samsung Asset Management (New York), Inc.

An SEC registered investment adviser, a wholly-owned subsidiary of SAMC based in New York, provides investment advisory services to SAMC.

Samsung Asset Management

An investment adviser based in London, UK. It is a wholly-owned

(London) Ltd.

subsidiary of SAMC. It provides investment advisory services to SAMC.

For the transactions with each Samsung Group company, we are guided by following internal policies: 1. in the event the Samsung Group company shall be the investment target company, the Samsung Group company shall comply with such limits and restrictions as required by the relevant laws, and have objective and reasonable bases considering its duty of care to the investor; 2. in the event the Samsung Group company shall be the counterparty in relation to other businesses, there shall be objective and appropriate bases of that the terms of the agreement with such Samsung Group company are not more favorable or unfavorable than those of the agreement with a third party. See Item 12, “Brokerage Practices,” for information on the controls SAMC uses in selecting brokers. As discussed above, SAMC also manages assets for Clients other than the Samsung Group company. SAMC is guided by its internal policies and procedures in allocating recommendations among Clients. Allocations are made based upon adherence to a Client’s investment objectives and for suitability and a reasonable basis for recommendations. SAMC manages one non-discretionary account for Samsung Securities Co. Ltd., a related person. In order to ensure equal treatment of all clients and to address the conflict of interest arising out of this, SAMC will monitor activity and engage in testing to ensure that the advice and recommendations

given to this company for its clients are not given in a way that favors it over SAMC’s other clients (timing), and that the advice and recommendations are suitable for the portfolio and are based on the specific investment objectives/restrictions and related laws/regulations. SAMC receives a fee within a reasonable range and agreed in writing in the contract and shall not receive or provide any preferential treatment without justifiable reasons. SAMC uses sub-advisers, including other Samsung Group companies, in the management of Foreign Funds to provide investment advisory services to all or a portion of the portfolios. The use of other Samsung Group companies as sub-advisers to SAMC managed Foreign Funds presents conflicts of interest, even if the sub-adviser is not a “related person” to SAMC. SAMC has established policies and procedures to supervise sub-advisers and manage the conflicts of interest that arise. SAMC regularly monitors the performance of the portions of portfolios managed by sub-advisers and may terminate any sub-advisers as it deems appropriate and in the best interests of Clients. Moreover, SAMC generally limits the discretionary authority of its sub-advisers through the investment guidelines included in its written sub-management agreement. Mr. Choi Ikchul is a head of Audit team of SAMC and an auditor of Samsung Hedge and Samsung Active. Mr. Kim Yongmin is a head of SAMC’s Business Administration Division and a director of Samsung Active and Samsung Hedge. Mr. Howard Jung is a director of Samsung Active and Samsung Hedge. This is a conflict of interest. Board meeting documents passed to Messrs Choi, Kim and Jung do not contain any confidential client information. Both will recuse themselves from discussions and voting on a matter that concerns the companies involved. The receipt of inducements, gifts or entertainment from affiliates, third party service providers or others would result in influencing decisions, trading and judgement matters. To address this conflict, SAMC staff are not allowed to solicit or accept any advantage from any person having business dealings with SAMC. Staff can accept (i) advertising or promotional gifts of a nominal value or (ii) gifts given on festive or special occasions subject to a maximum limit of US$ 30 in value. Staff are required to decline any offer of gift if acceptance of which would affect their objectivity or cause SAMC to breach any laws, rules and regulations. Staff must seek prior written clearance from the Compliance Officer, indicating the value of the gift and the circumstances in which it is received. We manage funds and separately managed accounts for a number of institutions. They are clients and include funds such as NPS (Korean National Pension Service). To address the conflicts of interest involved, the sharing of portfolio information among them and our staff other than on a documented need to know basis is prohibited. All investment decisions must be documented as being in the best interests of our clients and must not disadvantage any client. When a conflict cannot be addressed, SAMC will notify the client of the fact and not engage in trading and other transactions. SAMC acts to prevent its staff from misusing confidential client information. This raises conflicts of interest and possible breaches of fiduciary duty. Supervised persons and access persons must comply with the SAMC Code of Ethics for personal investments and general comportment. Fund managers manage more than one fund or separately managed account at a time. To address this conflict, there must be a documented basis for suitability and recommendations for each investment decision to ensure each account is managed in accordance with each client's stated objectives investment guidelines. Fair order allocation must be observed. Trades may be assigned in favor of a particular broker. To prevent abuses and conflicts, brokers are selected on the basis of objective criteria (see Item 12) and are evaluated periodically in accordance with the Broker Selection Policy.

We use Samsung Securities, a related person, as a broker for SAMC funds and separately managed accounts. To address this conflict, Samsung Securities is used based upon broker selection criteria and the fees involved are maintained in lien with the fees that SAMC pays to other brokers. Service providers are identified and selected, but the compensation that they are paid is not always disclosed. To address this conflict, the selection and appointment process and the remuneration arrangements are subject to the prior review of the Compliance team and are monitored regularly. SAMC will not carry out any connected party transaction on behalf of a client with a related person or affiliate unless consent is obtained, the transaction is pre-cleared and carried out on arm’s length terms, is consistent with best execution standards and is effected at a commission rate no higher than customary institutional rates. Employees have outside activities that conflict with their duties in SAMC. All staff must disclose their outside activities and obtain CCO's clearance before taking up such activity. In certain instances, conditions are imposed, or a clearance is denied. We have a participating affiliate agreement with Samsung Active. This agreement complies with the terms of the SEC Staff no-action letters. Activities are subject to review by the Compliance team. We have a consignment contract with Samsung Securities for Samsung funds. There is a conflict because the Samsung funds will be given special benefits and fund sales will be increased. To address this conflict, SAMC pays a fee within a reasonable range and agreed in writing in the contract between the two companies, taking into consideration the quality and volume of the services received and the rate of fee paid to other brokerage firms, and shall not give preferential treatment (including payment of higher fees) to its affiliated company, etc., without justifiable reasons. SAMC will effect cross trades between Samsung funds. To address this conflict, consent is required, the trade must be documented to be in the interests of both funds, the price must be at the prevailing market price and satisfy our best execution requirement and otherwise comply with related laws and regulations, and detailed guidelines on cross trading.

The Code of Ethics sets forth limitations on employees receiving gifts and entertainment from third parties. Employees may not solicit gifts or entertainment from any person or firm with which SAMC conducts or is likely to conduct business;

Employees are prohibited from trading either in their personal accounts or on behalf of Client accounts based on material non-public information; and

Employees must obtain consent of the Chief Compliance Officer for any outside business activities and may not use their position for a personal benefit.

Employees who violate the Code of Ethics or SAMC’s Compliance Manual are subject to disciplinary action including, but not limited to, written warnings, fines and termination of employment. Supervised persons must acknowledge the terms of the Code of Ethics in writing at least annually. From time-to-time, SAMC’s supervised persons will transact in or hold the same securities as Clients. The Code of Ethics is designed to ensure that the personal securities transactions, activities and interests of the employees of SAMC do not interfere with (i) making decisions in the best interest of SAMC’s Clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code of Ethics, certain classes of securities cannot be bought, held or sold and certain others have been designated as exempt or transactions as de minimis, based upon a determination that these would not materially interfere with the best interest of Clients. Also, the Code requires pre-clearance of certain transactions and restricts trading in close proximity to Client trading activity (blackout periods). Furthermore, to prevent supervised persons from inappropriately profiting from effecting personal securities transactions and to prevent the appearance of impropriety, SAMC imposes a holding period. However, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as Clients, employees would benefit from market activity by a Client in a security held by an employee. Pre-clearance, blackout periods and holding periods are designed to prevent or address (mitigate) conflicts of interest. Employee trading is monitored by the Chief Compliance Officer and the compliance department to detect and prevent breaches of the Code of Ethics with respect to employee trading activity. There are Chinese walls between SAMC and each of SAMC’s wholly-owned subsidiaries. All SAMC’s wholly-owned subsidiaries are operationally independent, including separate accounting, investment management and trading systems. From time-to-time, certain employee accounts and certain Samsung Group company accounts that are managed by SAMC may trade in the same securities as are held in Client accounts. Such trading cannot take place at the same time as Client transactions. This is a conflict of interest. To address this, Samsung Group company accounts cannot trade before or with Clients and are subject to controls to prevent the misuse of confidential client information. We subject employee accounts to our Code of Ethics requirements and do not permit front running or trading with clients. We monitor all such trading and will act to address any violations of this. SAMC may affect Clients’ transactions through its related person broker-dealers: Samsung Securities Co., Ltd, and Samsung Securities (America), Inc. Each such transaction must comply with the Brokerage Practices as described in Item 12 below. Transactions are sent to such firms only where it is documented that the selection of such broker has been undertaken in an objective manner and is in the best interests of Clients. SAMC will provide a copy of its Code of Ethics to any Client or prospective Client upon request.

SAMC does not always choose the lowest available commission rate or the best price for the security being transacted depending upon the range of factors considered as set forth above. Accordingly, the commission rate and other fees charges by brokers selected by SAMC may be higher than those charged by other broker-dealers. Research and Other Soft Dollar Benefits As is customary in the industry, brokers may provide research or services to investment advisers paid through commissions and other transaction costs, commonly referred to as “soft dollars” (i.e., consideration other than cash in exchange for services). SAMC may, from time to time, receive research services including analyses and reports, from brokers and securities firms. SAMC does not receive any other benefits, including, but not limited to, benefits in the form of brokerage services, non-research products, software or systems. These research services include information on the economy, industries, groups of securities, individual companies, statistical information, political developments, legal developments affecting portfolio securities, technical market action, and credit analysis. Practically, it is impossible for SAMC’s research staff to generate all the research and information brokers and securities firms presently provide. SAMC receives research services primarily as written reports, information databases and personal meetings with security analysts. Research services also take the form of meetings arranged with corporate and industry spokespersons, economists, academicians and government representatives. The research services brokers and securities firms provide are supplemental to SAMC’s own research efforts and, when utilized, are subject to SAMC’s internal analysis before incorporation into its investment process. SAMC pays directly for certain research services generated by external sources, including brokers and securities firms. SAMC’s research expenses could materially increase if it attempted to generate a substantial portion of the additional research currently provided by brokers and securities firms. All non-research services or products utilized by SAMC are paid for directly by SAMC. SAMC relies upon the safe harbor provisions of Section 28(e) of the U.S. Securities Exchange Act of 1934 (“Section 28(e)”). This permits an investment adviser to cause an account to pay commission rates in excess of another broker’s rates for effecting the same transaction, if the adviser determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services provided. SAMC uses the research brokers provide for the benefit of all institutional and retail accounts not just for the account that generated the commissions. SAMC has arrangements whereby it obtains research services in addition to brokerage services from brokers in exchange for directing client trades to these brokers. These arrangements are known as “soft dollar” arrangements and are common in the investment advisory business. The research services these soft dollar

arrangements provide assist SAMC in investment decision making for its client accounts. The research services are proprietary (created and provided by the broker) or third party (created by a third party but provided to SAMC by the broker) and include:

economic research; industry and company research; interest rate and bond research; technical research; commodity research; portfolio management research; stock and bond quote services; and financial news and other publications.

In accordance with Section 28(e), SAMC ensures that soft dollar arrangements pay for bona fide research. Brokerage for Client Referrals SAMC does not consider client referrals when selecting brokers for Client transactions. However, from time-to-time, brokers and their employees may refer potential Clients to SAMC. We do not provide compensation for this. It is SAMC’s policy to select brokers based solely on best execution and not to direct transactions and commissions to brokers for such referrals. However, SAMC, at its discretion, may effect transactions through these brokers provided they are able to provide best execution. See Item 14 below for additional information with respect to payment for Client referrals. Directed Brokerage SAMC does not, but related entities can, recommend to, request or require Clients to direct brokerage. Clients may, at their discretion without recommendation, request or requirement from SAMC, direct SAMC to effect some or all of their transactions with certain brokers subject to SAMC’s consent, which is rare does not routinely occur. In the event that SAMC agrees to accept the Client’s directed brokerage instructions, the Client should be aware that SAMC may not be able to obtain best execution for their transactions and may receive less favorable prices and pay higher commission rates or incur higher transactions costs for execution these transactions. When SAMC or related entities recommend affiliated broker dealers, this creates a conflict of interest, as more fully described in Item 10 Other Financial Industry Activities and Affiliations. Generally, directed trades will be executed subsequent to the execution of non-directed trades which may result in the Client realizing a less favorable (or more favorable) execution price. However, when feasible and at the discretion of SAMC, SAMC may aggregate directed trades with non-directed trades for execution and “step out” to the directed broker the Client’s trades to that broker. In such case, Clients that provide directed brokerage instructions will receive the same average price as the other Clients in the aggregation. Aggregation of Orders SAMC may simultaneously aggregate orders for more than one Client account managed by SAMC or with accounts of the Samsung Group companies. In accounting for such aggregated order, price, commission and other expenses shall be averaged on a per transaction basis. SAMC has a fiduciary obligation to use its best efforts to ensure that no Client is treated unfairly in relation to any other Client in the allocation of securities or investment opportunities or in the order in

which transactions are executed. SAMC will seek to allocate orders and investment opportunities among Clients in a manner that it believes is equitable and in the best interests of all of its Clients. While such allocations may be pro rata among participating Clients, they will not necessarily be so where SAMC’s strategic allocation policies dictate a different result. There can be no assurance that a particular order or investment opportunity will be allocated in a particular manner. In dealing on its clients’ behalf, SAMC will at all times strive to obtain best execution of each trade.

Applicable laws and regulations, Client’s Constituent Document restrictions on investment (if any) Conflicts Client-directed restrictions on investment Market conditions Performance deviation

Monthly Basis

Monthly broker allocation limitations Performance deviation “Style drift” and strategy conformance

SAMC provides Clients with quarterly and yearly account statements that include portfolio holdings, transaction information and performance information. SAMC provides Clients with written reports from time to time, which may include, among other things, general information about economic conditions, capital markets conditions and portfolio outlook. In addition, the following reviews shall be conducted in respect of the Client accounts: Administrator Reconciliation, if applicable Each Client’s administrator may perform a reconciliation of cash, investor activity, and investment as part of its independent determination of the net asset value for such Client account. Custodian Reconciliation Each Client’s custodian may review and reconcile the Client’s accounts on a monthly basis. See Item

15 for additional information with respect to custody of assets.

Fees for such solicitation services are paid by SAMC and the investor or Client will not be subject to any increased or additional direct fees or charges. Non-U.S. third-party solicitors may be registered with a non-U.S. regulatory body to the extent such registration is required in the applicable non-U.S. jurisdiction.

Authority to trade securities may also be limited by certain laws or regulations that require diversification of investment and favor the holding of investments once made. SAMC exercises investment discretion in a manner consistent with the stated investment objectives and restrictions for the Client account. When selecting securities and determining amounts, SAMC complies with the investment policies, limitations and restrictions of its Clients. Non-Discretionary Management SAMC manages non-discretionary accounts for Samsung Securities Co. Ltd. Clients retain the investment authority whether to accept or reject recommendations and effect their own trading.

SAMC has adopted written proxy voting policies and procedures, which are designed to ensure that SAMC votes proxies in the best interest of its Clients and addresses how it will address any conflict of interest that may arise when voting proxies. The general policy of SAMC is to vote proxy proposals, amendments, consents or resolutions relating to Client securities in a prudent manner that serves the best interests of it Clients, as determined by SAMC in its discretion and taking into account relevant factors, including, but not limited to: (1) the impact on the value of the securities; (2) the anticipated costs and benefits associated with the proposal; (3) the effect on liquidity; and (4) customary industry and business practices. In addition, SAMC follows procedures that are designed to address conflicts of interest that arise between its own interests and its Clients’ interests. If a conflict of interest arises, appropriate SAMC personnel will endeavor to agree upon a method to resolve such conflict before voting proxies affected by the conflict or fail to so vote. SAMC will provide a copy of its guidelines for exercising voting rights to any Client or prospective Client upon request to us, contact details on this Brochure’s cover page.