First Sentier Investors: investment adviser

In Australia, FSI AIM is the holder of an Australian Financial Services Licence (AFSL 289017) issued by the Australian Securities and Investments Commission (“ASIC”). Where we provide investment management services through a separate account, we agree the investment objectives with the client and they may specify investment restrictions which would be set out in their investment management agreement with FSI AIM. We tailor the advisory services and fees charged to clients and the type of reporting they receive. The guidelines typically describe the investment parameters and types of securities that are eligible for (or prohibited from) the account. FSI AIM also provides investment management services as a subadvisor to investment advisors of investment vehicles with US and non-US institutional investors. FSI AIM also provides investment management services as a subadvisor to investment advisors that seek advice through the provision of model portfolios. These model portfolios are used by the investment advisor to manage their client accounts. The timing and nature of services provided by FSI AIM with respect to model portfolios are defined separately in the service agreements with relevant investment advisors as the parties see fit in each case and as a result may differ between the agreements. Notwithstanding these differences, FSI AIM has conflicts of interest management procedures in place to ensure all client interests under relevant agreements are treated equitably and fairly. FSI AIM does not participate in any wrap fee programs or act as a custodian. As of 31 December 2025, FSI AIM’s assets under management (“AuM”) were as follows: Discretionary:

US $ 52,930,584,077

Non-Discretionary:

Nil

Total:

US $ 52,930,584,077

This includes assets where we have sub-delegated discretion to an affiliate and assets where an affiliated manager has delegated authority to FSI AIM. Therefore, certain of the assets will also be included in the AuM reported by our affiliated managers.

Management Services Each client account is designed to meet a particular investment goal. Through discussions with the client, the client’s goals and objectives are established. Once the account has been funded, it will be managed in accordance with the objectives, investment guidelines and restrictions. The client retains ownership of the securities which comprise the account or appoints a third-party custodian to retain ownership of the securities which comprise the account on their behalf.

We will not deduct our fees directly from the client account, however, the client can instruct the custodian to pay FSI AIM out of the assets in the client account once the fee calculation has been reviewed and accepted. In addition to FSI AIM’s management fee, clients will incur other fees and expenses charged by third parties in relation to their account, including, for example custody fees, brokerage, foreign exchange fees and other transaction costs. Account termination provisions are specified in the individual client agreements. However, generally the client can terminate the agreement by providing us with written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable.

Thus, the potential for us to receive greater fees from performance-based accounts itself creates a potential conflict of interest regarding the allocation of investment opportunities, as there is potential that we have an incentive to direct the best investment ideas to, or to allocate investments in favour of, the account that pays a performance fee. To reduce potential conflicts, FSI AIM will follow its investment allocation process when deciding how to invest for all discretionary clients who have funds available for the relevant strategy at that time. The FSI AIM allocation process takes into account multiple criteria, including: specific and individual account objectives, account size and capital available for investment, the stage of development of an account’s portfolio, the existing investment mix of an account, the diversification needs of the account, the size of the investment opportunity and the criteria for investment set out in the agreed investment disciplines.

Side by Side Management FSI AIM manages different types of accounts having different investment arrangements. Side-by-side management of institutional accounts gives rise to potential conflicts of interest. Potential conflicts arise where the actions taken on behalf of one account impacts other similar or different accounts (e.g. because such accounts have the same or similar investment styles or otherwise compete for investment opportunities, have potentially conflicting investments or investment styles, or have differing abilities to engage in short sales and similar types of transactions). To acknowledge this conflict, FSI AIM has established policies and procedures that seek to provide assurance in that investment decisions are made in accordance with the fiduciary duties owed to such accounts. Item 12 (Brokerage Practices) of this Brochure describes our policy on allocating trades fairly, which is designed to allocate trades to clients in a fair and equitable manner over time, taking into consideration the interests of each client.

More than just outperforming benchmarks and peers, this means exceeding our clients’ investment objectives and their expectations of service, accountability and initiative. To achieve this, we ensure that our interests are aligned with those of our clients and uphold a culture of always acting in our clients’ best interests.

Key Strategies Global Listed Infrastructure The investment process utilises an active, bottom-up security selection process that aims to exploit market inefficiencies. We target undervalued securities where the market underestimates the level and quality of sustainable free cash flows. We seek to earn excess returns by integrating a rigorous stock selection process, leading to high conviction stock positions with strict portfolio management risk controls. The strategies invest in infrastructure and utility securities which control assets with monopoly characteristics. The assets in which we invest should have high barriers to entry, strong pricing power, sustainable growth and predictable cash flow. We look for companies with robust business models and strong management execution. Global Property Securities

The investment process is primarily focused on bottom-up stock research. We focus on undervalued real estate securities with sound qualitative attributes and sustainable earnings growth. Securities are then ranked according to valuation and qualitative measures. The investment team of regional specialists undertakes rigorous proprietary stock forecasting and analysis identifying mispriced opportunities in a risk-adjusted framework in order to achieve outperformance objectives. A great deal of emphasis is placed on Environmental, Social and Governance (ESG) analysis which is assessed and integrated into the investment process in order to identify undervalued securities.

Material Risks for Investment Strategies As with any investment, loss of principal is a risk of investing with any of the investment strategies described above. The strategies described above are also subject to the risks summarised below. However, the following list of risk factors does not purport to be a complete explanation of the risks involved in an investment strategy. Prospective clients are encouraged to consult their own financial advisors, legal and tax professionals on an initial and continuous basis in connection with selecting and engaging the services of FSI AIM for a particular strategy. In addition, due to the dynamic nature of investments and markets, strategies may be subject to additional and different risk factors not discussed here. Investments in portfolios are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other governmental agency, entity or person. Past results are not predictive of future results, clients should also refer to portfolio guidelines as well as to each portfolio’s governing documents for further information on methods of analysis, investment strategies and risks specific to their portfolio investment. General Risks Changes to Laws and Regulatory Risk - A government or governmental agency in a country in which a security is issued or asset held may amend, repeal, enact or promulgate a new law or regulation, or a government authority or a court may issue a new interpretation of existing law or regulation that could substantially affect the security resulting in a loss. In addition changes in legal, tax and regulatory regimes within the jurisdictions of investments may occur which may materially affect the performance of a security. Company Specific Risk - This is the risk that a company in which FSI AIM invests does not perform as successfully as anticipated. While it is impossible to completely eliminate this risk, the effect of such a situation on the value of the investment can be reduced through diversification. This implies that unless returns of individual securities are perfectly positively correlated, a negative return from one security will be somewhat offset by better returns in others. This principle of diversification acts to reduce risk and reduce the return volatility of our portfolios. Concentration Risk - Concentrating investments in a particular country, region, market, industry or asset class means that performance will be more susceptible to loss due to adverse occurrences affecting that country, region, market, and industry or asset class. A portfolio concentrating in a single jurisdiction is subject to greater risk of adverse economic conditions and regulatory changes than a portfolio with broader geographical diversification. Counterparty Risk - This is the risk that a party to a transaction such as a swap or foreign currency forward fails to meet its obligations such as delivering a borrowed security or settling obligations under a financial contract. Currency Risk - Returns from offshore investments can be impacted by foreign exchange movements. Currency hedges are, therefore, established to ensure that foreign exchange movements do not have a meaningful influence on performance. These facilities are reviewed on an on-going basis. Cybersecurity Risk - There is a risk of fraud, data loss, business disruption or damage to the portfolio or to investors’ personal information as a result of a threat or failure to protect the information or personal data stored within the IT systems and networks of FSI AIM or other service providers. Deflation Risk - Deflation risk is the risk that prices throughout the economy decline over time, which may have an adverse effect on the market valuation of companies, their assets and revenues. In addition, deflation may have an adverse effect on the creditworthiness of issuers and may make issuer default more likely, which may result in a decline in the value of a portfolio.

Derivatives Risk - Some of the portfolios use derivatives, specifically options, index options, interest rate caps, collars, futures contracts, options on futures contracts, and forward currency exchange contracts, to manage various types of risk, enhance a portfolio’s return, reduce transaction costs, maintain full market exposure, manage cash flows, preserve capital or hedge against adverse movements in currency exchange rates. The use of derivatives presents risks different from, and possibly greater than, the risks associated with investing directly in traditional securities. The use of derivatives can lead to losses because of adverse movements in the price or value of the underlying asset, index or rate, which may be magnified by certain features of the derivatives, and changes in the value of the derivative, may not correspond, as intended, with changes in the value of the underlying asset, index or rate. These risks are heightened when the adviser uses derivatives to enhance a fund’s return or as a substitute for a position or security, rather than solely to hedge (or offset) the risk of a position or security held by the portfolio. In addition, when the portfolios invest in certain derivative securities, there is the possibility that they are effectively leveraging their investments, which could result in exaggerated changes in the net asset value of the portfolios’ shares and can result in losses that exceed the amount originally invested. Force Majeure Risk - Force majeure is the term generally used to refer to an event beyond the control of any party, including acts of God, fires, floods, earthquakes, wars, strikes and acts of terrorism. Some force majeure risks are uninsurable and, if such events occur, they may adversely affect the value of a security. Inflation Risk - Inflation risk is the risk that the value of assets or income from investments will be worth less in the future as inflation decreases the value of money. As inflation increases, the real value of an account and distributions can decline. Liquidity Risk - Liquidity risk refers to the difficulty in selling an asset for cash quickly without an adverse impact on the price received. Assets such as shares in large listed companies are generally considered liquid, while ‘real’ assets such as direct property and infrastructure are generally considered illiquid. Under abnormal or difficult market conditions, some normally liquid assets may become illiquid, restricting the ability to sell them and to make withdrawal payments or process switches for investors without a potentially significant delay or discount to value. Management Risk - The investment strategies, techniques and risk analyses employed, while designed to enhance returns, may not produce the desired results. The assessment of a particular security or assessment of market, interest rate or other trends could be incorrect, which can result in losses. Market Risk - Investment returns are influenced by the performance of the market as a whole. This means that the investments can be affected by things like changes in interest rates, investor sentiment and global events, depending on which markets or asset classes our clients invest in. Non-Diversification Risk - Non-diversification of investments means a portfolio may invest a large percentage of its assets in securities represented by a small number of issuers. As a result, the portfolio’s performance may depend on the performance of a small number of issuers. Political and Economic Risks - International investing is subject to the risk of political, regulatory, social, or economic instability in the country of the issuer of a security, the difficulty of predicting international trade patterns, the possibility of the imposition of exchange controls, expropriation, limits on removal of currency or other assets, and nationalization of assets. Potential Environmental Risk - The portfolio may hold securities in an issuer who may be liable for the costs of removal or remediation of hazardous or toxic substances. The costs of any required remediation or removal of such substances may be substantial. The presence of such substances, or the failure to remediate such substances properly and any regulatory penalties may adversely impact the value of the securities causing a loss. Preferred Security Risk - Preferred securities are subordinated to bonds and other debt instruments in a company’s capital structure and therefore will be subject to greater credit risk than those debt instruments. Sanctions Risk - The portfolio may hold securities that subsequently become sanctioned by governments or international bodies restricting the sale of the securities or devaluing such securities. Security and Investment-Specific Risk - Within each asset class and each option, individual securities like mortgages, shares, fixed interest securities or hybrid securities can be affected by risks that are specific to

that investment or that security. For example, the value of a company’s shares can be influenced by changes in company management, its business environment or profitability. These risks can also impact on the company’s ability to repay its debt. Style-Specific Risk - Different types of stocks tend to shift in and out of favour depending on market and economic conditions. To the extent a portfolio emphasizes a value style of investing, it runs the risk that undervalued companies’ valuations will never improve. Underlying Asset Currency Risk - The assets of a company may be held in a country other than where the security is issued. This has the potential to create an additional underlying currency risk for that security. Specific Strategy Risks – Global Listed Infrastructure Demand Risk - The level of demand, usage or patronage for the service provided by an infrastructure asset may fall below expectations and adversely affect the performance of the investment. Exogenous Risks – Securities with an exposure to infrastructure assets may be impacted by exogenous events. For example, the essential nature of infrastructure assets may increase the risk of terrorist attacks while their capital intensity may increase the risk stemming from natural disasters. While these events are difficult to predict, we seek to minimise exogenous risks through portfolio diversification. Interest Rate Risks - Owing to the stable nature of cash flows, many securities with an exposure to infrastructure assets can be relatively highly geared. Consequently, they are exposed to movements in interest rates and to contractual repayment obligations with financiers. Movements in interest rates also affect the discount rates used in the valuation of these long duration assets. We seek to minimise interest rate risk by identifying assets with strong market positions, sustainable growth opportunities, inflation protected income and relatively low or hedged debt levels. Operating Risk - The investment strategies will ultimately be exposed to the operating risk of the underlying businesses. Specialist skills are required in running an infrastructure business such as an airport or power station. An operating failure may adversely affect the profitability of the business and therefore the return of the investment. We seek to minimise the operating risks through portfolio diversification and detailed fundamental analysis. We aim for deep understanding of industry drivers, detailed analysis of company financials, regular meetings with management to understand and assess company strategy and execution, plus effective reviews of environmental, social and governance issues. Personnel Risks – The performance of a security which derives income from infrastructure assets may be impacted by the loss of key asset management personnel. We seek to minimise personnel risks by allocating significant resources to the investments. Remuneration is competitive and directly linked to the performance of the investment. Teams are mandated to grow funds under management and are backed by internal resources, including product development, information technology, trading and distribution. Specific Strategy Risks – Global Property Securities Property Market Risk - demand and supply - The movement of capital in and out of both direct property and listed property securities can have a major impact on valuations. Consideration is given to the level of property investment sophistication and historic volatility of capital inflows/outflows before establishing an investment in a particular region. Oversupply may develop in a particular region or segment of the property market as vacancy levels increase, rental demand declines or as new supply is added. Such an occurrence may result in downward pressure on valuations, possibly leading to declining trust distributions and capital values. This risk is partially mitigated by ensuring that there is a diversified spread of holdings by region and sector and by type of security held.

Affiliated Broker Dealers FSI AIM is associated with several broker dealers: MUFG Securities Americas Inc., Intrepid Investment Bankers LLC, and Mitsubishi UFJ Securities Holdings Co., Ltd (and its’ subsidiaries). MUFG, FSI AIM’s indirect parent, owns more than 20% but will not own more than 25% of Morgan Stanley. Under SEC rules, ownership of more than 25% of an entity’s voting securities creates a presumption of control, while ownership of 25% or less creates a presumption of no control. Because MUFG does not control Morgan Stanley, Morgan Stanley is not considered an affiliate of FSI AIM for Form ADV purposes. FSI AIM receives no compensation, incentives, or preferential treatment from Morgan Stanley and Morgan Stanley does not influence the FSI AIM’s investment recommendations, brokerage selection, or trading practices. FSI AIM maintains policies and procedures reasonably designed to identify, manage, and mitigate conflicts of interest related to its affiliated broker-dealers. FSI AIM may engage one or more affiliated broker-dealers only when consistent with regulatory requirements, client agreements, and FSI AIM’s fiduciary duty to act in the best interest of clients. Any transactions involving affiliated broker-dealers must meet best execution standards and occur on an arm’s-length basis.

Affiliated Investment Advisers First Sentier Investors (Australia) RE Ltd (“FSI ARE”) is an Australian financial services licence holder, regulated by the Australian Securities and Investments Commission (“ASIC”). It is also an SEC registered investment adviser and is an affiliate of FSI AIM. FSI ARE was established in 1985 and is ultimately 100% owned by MUTB. FSI ARE is an investment advisory firm providing discretionary investment management services to a range of institutional clients and funds. First Sentier Investors International IM Limited (“FSI IIM”) is a registered investment adviser and is an affiliate of FSI AIM. FSI IIM was incorporated in 1982. FSI IIM is ultimately 100% owned by MUTB. FSI IIM is an investment advisory firm providing discretionary investment management and portfolio management services to a range of institutional clients and funds. FSI IIM has historically specialised in investing in Asia Pacific and Global Emerging markets but continue to expand their range of investment strategies. First Sentier Investors (Singapore) (“FSI SG”) is an SEC registered investment adviser and is an affiliate of FSI AIM. FSI SG was incorporated in 1969and is ultimately 100% owned by MUTB. FSI SG is a Singapore capital markets services licensee providing discretionary investment management and portfolio management services to a range of institutional clients and funds. First Sentier Investors (US) LLC (“FSI US”) is an SEC registered investment adviser and is an affiliate of FSI AIM. FSI US was established in 2014 and is ultimately 100% owned by the MUFG Group. FSI US provides discretionary management services to institutional clients and funds. Employees of FSI US provide U.S. marketing and solicitation services for the advisory services of FSI AIM. First Sentier Investors (UK) IM Limited (“FSI UKIM”) was incorporated in 1970 and is ultimately 100% owned by MUTB. FSI UKIM is a UK regulated investment advisory firm providing discretionary investment management and portfolio management services to a range of institutional clients and funds. FSI UKIM is also an SEC registered Investment Adviser. First Sentier Investors (UK) Funds Limited (“FSI UK”) was incorporated in 1998, and is part of First Sentier Investors, and ultimately 100% owned by MUTB. FSI UK is a UK regulated entity, acting as investment manager for both US and non-US institutional clients. FSI UK is also an SEC registered Investment Adviser. First Sentier Investors (Ireland) Limited was incorporated in 2018 and is ultimately 100% owned by MUTB. First Sentier Investors (Ireland) Limited is regulated by the Central Bank of Ireland. It is acting as the

Management Company to alternative investment funds and UCITs (Undertakings for Collective Investment in Transferable Securities) for both US and non-US clients. It is a SEC registered investment adviser. First Sentier Investors (Hong Kong) Limited (“FSI HK”) is an SEC registered investment adviser and is an affiliate of FSI AIM. FSI HK was incorporated in 1987 and is ultimately 100% owned by MUTB. FSI HK is a Hong Kong licensed corporation providing discretionary investment management and portfolio management services to a range of institutional clients and funds. FSI AIM is a sub-adviser for accounts or clients for which one or more First Sentier Investors’ affiliates serve as investment manager or investment adviser and FSI AIM has appointed one or more First Sentier Investors’ affiliates as sub-adviser. FSI AIM also provides and receives services in the areas of legal and compliance, risk management, human resources, finance, information technology, trade support, back and middle office support and sales and marketing. FSI AIM will provide introduction services to Albacore Capital LLP and/or Albacore Capital Limited in respect of potential wholesale clients. Albacore Capital LLP is registered with the SEC as an exempt reporting adviser. The Albacore Capital Group is a boutique European alternative credit manager which is part of FSI.

All Supervised Persons have received a copy of the Code and are required on an annual basis to confirm that they have read and understood the content. You can request a copy of our Code of Ethics by emailing AUenquiries@firstsentier.com. Definitions: Supervised Person: is any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of an investment adviser, or other person who provides investment advice on behalf of the investment adviser and is subject to the supervision and control of the investment adviser. Access Person: is a Supervised Person who has access to non-public information regarding clients’ purchase or sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations that are non-public. Related Person/s: any other person or entity whose investment decision making is influenced by a Supervised Person and if the person is an Access Person, this also includes to a spouse or domestic partner, child or any adult family member living in the same household as the Access Person. The Code also outlines the requirements, and where relevant references policies to ensure the standards detailed above are adhered to and include:

Protection of Non-Public Information

It is a crime in the US and many other countries to transact in a company’s securities while in possession of material non-public information about the company. Supervised Persons are responsible for safeguarding non-public information relating to securities recommendations, fund and client holdings. As such, Supervised Persons must not trade based on FSI AIM’s confidential and proprietary investment information or on the nonpublic information of other companies that may be in its possession. Other types of information (e.g. marketing plans, employment issues, client identities, etc.) may also be confidential and should not be shared with individuals outside FSI AIM (except those retained to provide services for FSI AIM).

Personal Securities Trading FSI AIM’s directors, officers, and employees, including Access Persons and their Related Persons buy, sell, and hold for their own and their family members’ accounts public securities, private securities, and other investments in which such FSI AIM personnel have a pecuniary interest. Such investments may also be bought, sold, or held for clients or through accounts (or investments in funds) managed by FSI AIM or otherwise. As a result of differing trading and investment strategies or constraints, positions taken by FSI AIM directors, officers, and employees can be the same as or different from, or made contemporaneously or at different times than, positions taken for clients. As these situations involve potential conflicts of interest, FSI AIM has adopted policies and procedures relating to personal securities transactions, insider trading and other ethical considerations, including the Global Personal Dealing Policy in accordance with Rule 204A-1 under the Advisers Act. These policies and procedures are intended to identify and prevent actual conflicts of interest with clients and to resolve such conflicts appropriately if they do occur The Global Personal Dealing Policy as summarised in the Code governs personal trading by all employees (including Access Persons) and their Related Persons. Employees are permitted to maintain personal securities accounts provided that such accounts are disclosed to FSI AIM and that any personal trading is consistent with the Global Personal Dealing Policy, the Code of Ethics and applicable law. In summary the requirements that apply to employees, including Access Persons and their Related Persons are:

Initial and annual reports of securities and holdings must be submitted

Initial and changes to the broker, dealer or bank accounts in which any securities are held must be submitted

Transactions in listed securities, including highly concentrated ETFs, require pre-approval and are subject to a minimum holding period of 120 days. In some regions securities may be sold inside the minimum holding period where the employee has suffered a minimum 20% loss as evidenced on the employee’s broker statement and Compliance has pre-cleared the trade.

Imposes “blackout” periods on all employees prohibiting transactions in certain securities during time periods surrounding transactions in the same securities or related securities by client accounts.

Not submit more than 20 pre-clearance approval requests per calendar quarter.

Employees located in the US are prohibited from purchasing initial public offerings (IPOs).

Access Persons located jurisdictions outside of the US are prohibited from participating in IPOs that will be listed on a US exchange.

Access Persons must obtain approval before acquiring a beneficial ownership on a limited offering or private placement.

Investment team employees and their related persons cannot invest in any security that may be held in the core investment universe of their investment teams (refer to Conflict of Interest below on the segregation of investment teams).

Gifts and Gratuities The purpose of business entertainment and gifts in a commercial setting is to create good will and sound working relationships; not to gain unfair advantage with clients or vendors. When offering or accepting gifts and/ or entertainment the following principles apply:

FSI AIM does not engage in bribery or corrupt activities.

FSI AIM is responsible for identifying and managing any conflict of interest.

Gifts must not be solicited and all gifts offered and accepted must be reasonable and proportionate.

If there is any doubt about appropriateness of a gift to offer should not be made or the gift politely declined.

Conflicts of Interest In the discharge of its fiduciary duties FSI AIM has in place policies and procedures to manage actual perceived or potential conflicts of interest. In summary this involves:

Avoiding it, where the conflict cannot be satisfactorily managed, for whatever reason, through controls and disclosure, or

Controlling it, through the operation of controls, or

Disclosing it. For the disclosure to be effective, it must be complete providing sufficient detail for the client to decide how the conflict impacts service to them and it must be timely, prominent and meaningful.

FSI AIM from time to time does invest in the same securities that its affiliates invest in. Portfolio management and security recommendations are undertaken at an investment strategy level and each investment team managing these strategies is organised separately. Information barriers and other controls (such as restricting access to each other’s investment management systems and research files) exist between investment teams to manage any potential conflicts that may arise. FSI AIM also provides non-discretionary investment management services as a subadvisor to investment advisors that seek advice through the provision of model portfolios. These model portfolios are used by the investment advisor to manage their client accounts. The timing and nature of services provided by FSI AIM with respect to model portfolios are defined separately in the service agreements with relevant investment advisors as the parties see fit in each case and as a result may differ between the agreements, as well as between non-discretionary and discretionary service arrangements. Notwithstanding these differences, FSI AIM has conflicts of management procedures in place to ensure all client interests under relevant agreements are treated equitably and fairly.

Outside business interests FSI AIM’s fiduciary duties to clients dictate that FSI AIM and its Supervised Persons devote their professional attention to client interests above their own and those of other organizations. Where there is a potential or perceived conflict, permission must be obtained through management and the Compliance team prior to engaging in any outside business activity. FSI AIM can deny approval where the perceived conflict of interest cannot be managed effectively.

Financial crime (anti-bribery corruption and sanctions); and

By whom they are regulated. Generally a counterparty must be regulated by the regulator in the country of their home office.

Counterparties are continually monitored to certain operational and compliance standards and level of engagement. Counterparty issues are presented for the oversight groups to consider as part of the quarterly review process. Certain trigger events will also create the need for a review of the counterparty outside of the scheduled review process. These events can include (but are not limited to):

A change in key personnel;

Consistently poor pricing;

A substantial change in business direction;

Repeated occurrences of operational failures or major operational errors;

Anti-bribery & corruption and sanctions risks;

Changes in financial responsibility;

Adverse changes in administrative resources;

Poor responsiveness.

Use of Dealing Commissions All broker related research services consumed by the Global Listed Infrastructure Securities, Global Property Securities and Stewart Investors investment teams are paid for directly by the firm from our own resources. Thus we will make separate payments to the providers for such services directly. Hence the dealing commission is only for trade execution services. The Securities Exchange Act of 1934 established criteria for “qualified” brokerage and research services. We believe that the research and services received for client commission’s fall within the definition of “qualified” brokerage or research service. The use of client commissions for research and services is a potential conflict of interest with an incentive to allocate trades to a particular broker to obtain research services rather than to the broker who would be expected to provide the best combination of commission and price. No arrangements regarding the use of dealing commission may be entered into that could compromise our ability to seek best execution for our customers. Other services that can be received from brokers include trade settlement.

Directed Commission Directed commission is where a client may instruct us to generate commission on their account in order to pay for a service which they have contracted from one or more particular brokers. As we abide to a ‘Best Execution’ approach to our dealing process, we will not enter into directed commission arrangements if requested to do so by clients or prospective clients.

Cross Transactions Where an internal crossing or “put-through” is undertaken, where one internal fund/client is selling and another is buying, the equity dealer must ensure the price is fair to both customers. Our standard approach in all such cases is to transact through a broker as a net trade, rather than to cross internally: this creates a clear audit trail with an external party and ensures all regulatory reporting is conducted. Crosses are executed only with

client authorization and only for clients that are not plans, trusts or retirement accounts governed by the Employee Retirement Income Security Act of 1974, as amended. Such transactions are only entered into when FSI AIM deems the transaction to be in the best interest of both clients and at a price FSI AIM has determined by reference to independent market source. Neither FSI AIM nor any related party receives any compensation as a consequence of such 'cross' transactions.

Aggregation and Allocation of Orders FSI AIM seeks to aggregate and allocate trade orders in a manner that is consistent with its duty to: (1) seek best execution of client orders; (2) treat all clients fairly and equitably over time; and (3) not systematically advantage or disadvantage any single client or group of clients. FSI AIM follows policies and procedures pursuant to which it can combine or aggregate purchase or sale orders for the same security for multiple client accounts (also known as a bunched order) so that the orders can be executed at the same time. FSI AIM aggregates orders when FSI AIM considers doing so appropriate and in the interests of its clients. FSI AIM’s client accounts can be included in the aggregated orders with clients of FSI AIM’s affiliated advisers. When orders are aggregated, the orders can be placed with one or more brokers for execution. When a bunched order is filled, FSI AIM generally will allocate the securities purchased or proceeds of sale pro rata among the participating client accounts based on the pre-trade allocation. Adjustments or changes can be made under certain circumstances, such as to avoid small allocations or to satisfy cash flows and guidelines. If an order at a particular broker is filled at several different prices, through multiple trades, generally all participating client accounts will receive the average price. Although allocating orders among FSI AIM clients creates potential conflicts of interest because FSI AIM receives greater fees or overall compensation from some clients than received from other clients, allocation decisions will not be made based on such greater fees or compensation. When an investment opportunity is suitable for two or more clients, allocations will be made in a fair and equitable manner, and will take the following factors, among others, into consideration: the relative size of the client account, available cash for investment, investment objectives and restrictions, liquidity considerations, legal and regulatory restrictions, portfolio risk/return objectives, investment horizons, and client instruction.

Periodic written data, including valuations and transaction information, is usually provided on a monthly and/or quarterly basis and may be supplied to the client or the client’s designated representative for accounting, taxation or reconciliation purposes. If FSI AIM considers a major market dislocation, or similar event has occurred, then client accounts would be reviewed and appropriate action and/or communication promptly taken.

We strongly urge all clients to compare the reports they receive from FSI AIM to the statements they receive from their broker-dealers, banks, trustees or custodians. Any issues or discrepancies should be communicated to FSI AIM promptly for investigation.

The guidelines outlines principles of good corporate governance and our approach to voting on specific types of resolutions in accordance with those principles. However, we recognise the unique circumstances of different companies and as a result may vote differently to the guidelines when we consider it to be in the best interests of our clients. The authority and responsibility for exercising proxy votes will be defined within the investment management agreement executed between FSI AIM and each discrete mandate client. However, FSI AIM may still receive proxy voting instructions from each discrete mandate client on a case by case basis (provided FSI AIM is notified in a timely manner) or alternatively, the discrete mandate client may instruct their custodian directly.

Wherever a discrete mandate client delegates responsibility for exercising proxy votes and if requested by the client, FSI AIM will report back to the client how votes were cast on their behalf. Our guidelines on proxy voting or additional information regarding how we voted on our clients’ securities can be obtained upon request by writing to the Chief Compliance Officer at the address list on the cover page of this document.