Fundsmith, LLP: investment adviser

The objective of The Foundation is, in part, to provide for the long-term succession of Fundsmith’s business interests and to ensure employees, partners and investors are sufficiently protected and for the provision for beneficiaries. 4.B. Types of Advisory Services Fundsmith sponsors and provides advisory services to the following pooled investment vehicles (the “Funds” and each, a “Fund”): (1) Fundsmith Equity Fund, L.P., a Delaware limited partnership; and (2) Fundsmith Sustainable Equity Fund, L.P., a Delaware limited partnership. Fundsmith has appointed its affiliate, Fundsmith Investment Services Limited (“FISL”), as sub-adviser to the Funds pursuant to a sub-advisory agreement. In addition, Fundsmith provides advisory services to certain non-U.S. pooled investment vehicles (the “Non-U.S. Funds”), which are not available for purchase by third party investors in the U.S. The Funds and Non-US Funds are collectively referred to as “Clients”. 4.C. Investment Objectives/Restrictions Fundsmith, on behalf of the Funds, invests in equities on a global basis employing a buy-and-hold investment strategy that seeks to achieve long-term growth in value. Fundsmith’s approach is to be a long-term investor in its chosen stocks and it does not adopt short-term trading strategies for the Funds. Fundsmith adheres to strict investment criteria, through which it seeks to invest only in high-quality businesses that it believes will deliver attractive risk-adjusted returns to investors over the long term. The information set forth herein is qualified in its entirety by reference to applicable registration statements, confidential private placement memoranda (“PPMs”), or other offering documents, limited partnership agreements (“LPAs”), investment management agreements, and/or other governing documents (collectively, the “Governing Documents”) for each Fund. In the event of a conflict between the information set forth in this Brochure and the information in the Governing Documents, the Governing Documents shall prevail. Investors and prospective investors in each Fund should read the applicable Governing Documents for complete information on the investment objectives and investment restrictions with respect to a particular Fund. There is no assurance that any of the Funds’ investment objectives will be achieved. 4.D. Wrap Fee Programs Fundsmith does not participate in, nor is it a sponsor of, any wrap fee programs. 4.E. Assets Under Management As of March 31, 2026, Fundsmith manages approximately $18,508,143,977 in regulatory assets under management on a discretionary basis and $0 assets on a non-discretionary basis.

Fundsmith has sole discretion to reduce, waive or calculate differently the management fee with respect to certain investors, including but not limited to, investors who invest in a Fund pursuant to a relationship with certain intermediaries. 5.B. Direct Billing of Advisory Fees Fundsmith is authorized under the Governing Documents of the Funds to charge and deduct advisory fees directly from the Fund’s assets, at the times and in the amounts described in the Governing Documents. 5.C. Other Non-Advisory Fees In addition to the fees payable to Fundsmith, the Funds (with certain exceptions described in the Governing Documents) pay for all costs and expenses incurred in connection with the investments in their accounts, which may include (but may not be limited to): (i)

the fees and expenses payable to the custodian;

(ii)

expenses incurred in acquiring and disposing of investments, including brokerage commission, fiscal charges and other disbursements which are necessarily incurred in effecting transactions for the Fund and normally shown in contract notes, confirmation notes and difference accounts as appropriate;

(iii)

fees and expenses for fund administration, pricing, valuation, fund accounting and related services;

(iv)

any cost incurred in preparing, printing and distributing reports, accounts, statements, contract notes and other like documentation;

(v)

any fees, expenses or disbursements of any legal, tax or other professional adviser of the Fund;

(vi)

any costs incurred in taking out and maintaining any insurance policy in relation to the Fund and/or the general partners or Fundsmith;

(vii)

interest on permitted borrowings and charges incurred in effecting or terminating such borrowings or in negotiating or varying the terms of such borrowings;

(viii)

taxation payable in respect of the Fund assets or on the issue or withdrawal of interests;

(ix)

the audit fees of the auditors and any properly incurred expenses of the auditors;

(x)

any costs incurred in amending the Fund’s LPA or PPM;

(xi)

any amount payable by the Fund under any indemnity provisions contained in the LPA or any agreement with any service provider to the Fund;

(xii)

any costs incurred in the formation of the Fund and the offering of the interests; and

(xiii)

any other payments permitted to be paid out of the assets of the Fund as provided in the LPA, as described in greater detail in the Governing Documents for each Fund.

The section below titled “Item 12. Brokerage Practices” describes the factors that Fundsmith considers in selecting or recommending broker/dealers for client transactions and determining the reasonableness of their compensation (e.g. commissions). 5.D. Advance payment of fees Management fees are not due in advance.

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5.E. No Compensation for Sale of Securities or Other Investment Products Neither Fundsmith nor its supervised persons will receive any compensation with respect to the purchase or sale of securities or other investment products.

Allocating investment opportunities to Clients where an employee, Fundsmith, or an affiliate has a proprietary interest.

Executing trades for a Client that may adversely impact the value of securities held by a different Client.

If there is limited availability of an investment opportunity, Fundsmith may not be able to allocate such opportunity to all eligible Clients which could have otherwise participated in the investment opportunity.

Trading and securities selected for a particular Client may affect the performance of other Clients that have similar strategies.

To address conflicts of interest, Fundsmith has adopted various policies and procedures designed to ensure that all Clients are treated equitably and that no account receives favorable treatment. For more information about how Fundsmith addresses certain conflicts of interest, see “Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” below. See also “Item 12 - Brokerage Practices” below for more information about conflicts of interest related to portfolio transactions and trade allocation.

Funds have not been and will not be registered under the Securities Act and they may not be offered, sold or transferred, in the U.S., its territories and outlying areas or offered or sold to any U.S. person not affiliated with Fundsmith. -6-

Minimum Investment Requirements As noted above, limited partner interests in the Funds may only be offered to persons who qualify as both “accredited investors” as defined in Regulation D under the Securities Act and “qualified purchasers” as defined in Section 2(a)(51) of the 1940 Act. Investors in the Funds are required to make a minimum initial investment of $250,000, although the general partners of the Funds have discretion to accept lower amounts.

businesses whose valuation is considered by Fundsmith to be attractive.

Fundsmith’s principal sources of information regarding specific investments include quarterly and annual reports, offering materials, SEC filings (if available), general industry knowledge, and other publicly available information. The descriptions set out below are a summary only of the specific strategies managed by Fundsmith on behalf of the Funds. Investing in securities involves a high degree of risk including the risk that the entire amount invested may be lost. Investors in the Funds should be prepared to bear such risk of loss. Fundsmith Equity The strategy aims to achieve long-term growth in value by investing in listed equities on a global basis. Potential investee companies will have large market capitalizations. It is envisaged the portfolio will be concentrated, generally comprising between 20 and 30 companies. Fundsmith Sustainable Equity The strategy aims to achieve long-term growth in value by investing in listed equities on a global basis. The investment portfolio does not invest in businesses which have substantial interests in aerospace and defense; brewers, distillers and vintners; casinos and gaming; gas and electric utilities; metals and mining; oil, gas and consumable fuels; pornography; and tobacco. Fundsmith applies further criteria to screen for sustainable investments and evaluates sustainability in the widest sense, taking account not only the companies’ handling of environmental, social and governance policies and practices, but also their policies and practices on research and development, new product innovation, dividend policy and the adequacy of capital investment. It is envisaged the portfolio will be concentrated, generally comprising between 20 and 30 companies.

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8.B. Material Risks Although investments in the Funds may result in significant returns, they also involve a substantial degree of risk. Investors should be able to bear the financial risk of the investment strategy for an indefinite period of time and be able to sustain the loss of all or a significant part of their investment. Investors and prospective investors in the Funds should carefully review the risks described in this Brochure and the applicable Governing Documents and should evaluate the merits and risks of an investment in the context of their overall financial circumstances. The risk factors below are not intended to be exhaustive and should be considered carefully together with the full text of the applicable Governing Document. Concentration. Fundsmith’s investment approach is to invest in a relatively small number of securities (subject to spread and concentration limits). This may result in portfolio concentration in particular sectors, countries, or other groupings. Concentrated portfolios may be more volatile than other portfolios, and the values of their investments may go up and down more rapidly. This means that a loss arising in a single investment may cause a proportionately greater loss to a Fund than if a larger number of investments were made. Counterparty Risk. The Funds may be subject to the risk of the inability of any counterparty to perform with respect to transactions, whether due to insolvency, bankruptcy or other causes. It should be noted that transactions may not always be delivery versus payment and this may expose a Fund to greater counterparty risk and potentially to loss in excess of the counterparty’s obligations to the Fund. Economic and Market Events Risk. Events in certain sectors historically have resulted, and may in the future result, in an unusually high degree of volatility in the financial markets, both domestic and foreign. These events have included, but are not limited to: bankruptcies, corporate restructurings, and other similar events; bank failures; governmental efforts to limit short selling and high frequency trading; measures to address U.S. federal and state budget deficits; social, political, and economic instability in Europe; economic stimulus by the Japanese central bank; dramatic changes in energy prices and currency exchange rates; and China’s economic slowdown. Interconnected global economies and financial markets increase the possibility that conditions in one country or region might adversely impact issuers in a different country or region. Both domestic and foreign equity markets have experienced increased volatility and turmoil, with issuers that have exposure to the real estate, mortgage, and credit markets particularly affected. Financial institutions could suffer losses as interest rates rise or economic conditions deteriorate. Political turmoil within the U.S. and abroad may also impact a Fund’s investments. Although the U.S. government has honored its credit obligations, it remains possible that the U.S. could default on its obligations. While it is impossible to predict the consequences of such an unprecedented event, it is likely that a default by the U.S. would be highly disruptive to the U.S. and global securities markets and could significantly impair the value of a Fund’s investments. Similarly, political events within the U.S. at times have resulted, and may in the future result, in a shutdown of government services, which could negatively affect the U.S. economy, decrease the value of many investments, and increase uncertainty in or impair the operation of the U.S. or other securities markets. The imposition by the U.S. of import tariffs on goods from foreign countries and reciprocal tariffs levied on U.S. goods may lead to price volatility and instability in U.S. and global investment markets. Among other effects, tariffs may increase the cost of production for certain goods or reduce demand for products, which could affect the performance of the Funds’ investments. It is not known whether, or to what extent, any tariff or other trade protections may affect the Funds or their investments. Equity Investing Risk. Common and preferred stocks represent equity ownership in a company. Stock markets are volatile. Asset values of equity investments may be sensitive to stock market volatility, and the stocks to which the Funds have exposure may be more volatile than the stock market as a whole. The value of equity investments and related instruments may decline in response to conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations, as well as issuer or sector specific events. Market conditions may affect certain types of stocks to a greater extent than other types of stocks. If the stock market declines, the asset values of equity investments will also likely decline and although stock values can rebound, there is no assurance that values will return to previous levels. As such investors may not get back the amount they invested and a subscription in the Funds should only be considered by persons financially able to maintain their investment and who can accept a loss of all of their investment. An issuer’s -8-

financial condition could decline as a result of poor management decisions, competitive pressures, technological obsolescence, undue reliance on suppliers, labor issues, shortages, corporate restructurings, fraudulent disclosures, irregular and/or unexpected trading activity among retail investors, or other factors. Changes in the financial condition of a single issuer can impact the market as a whole. Foreign Investment Risks. Investing in securities issued by companies whose principal business activities are outside the U.S. may involve significant risks not present in domestic investments. For example, because foreign companies may not be subject to uniform accounting, auditing and financial reporting standards, practices and requirements and regulatory measures comparable to those applicable to U.S. companies, there may be less publicly available information about a foreign company than about a domestic company. Volume and liquidity in most foreign debt markets is less than in the U.S. and securities of some foreign companies are less liquid and more volatile than securities of comparable U.S. companies. There is generally less government supervision and regulation of securities exchanges, broker-dealers and listed companies than in the U.S. In addition, with respect to certain foreign countries, there is the possibility of nationalization, expropriation or confiscatory taxation, currency blockage, political or social instability, or diplomatic developments, which could affect investments in those countries. Any of these actions could adversely affect securities prices, impair Fundsmith’s ability to purchase or sell foreign securities on behalf of the Funds, or transfer the Funds’ assets or income back to the U.S., or otherwise adversely affect Fund operations. In the event of nationalization, expropriation or confiscation, the Fund could lose its entire investment in that country. Other potential foreign market risks include exchange controls, difficulties in valuing securities, defaults on foreign government securities, and difficulties in enforcing favorable legal judgments in foreign courts. Moreover, individual foreign economies may differ favorably or unfavorably from the U.S. economy in such respects as growth of gross national product, reinvestment of capital, rate of inflation, capital reinvestment, resource self-sufficiency, and balance of payments positions. Certain economies may rely heavily on particular industries or foreign capital and are more vulnerable to diplomatic developments, the imposition of economic sanctions against a particular country or countries, changes in international trading patterns, trade barriers, and other protectionist or retaliatory measures. Foreign securities markets are generally not as developed as those in the U.S. Foreign countries may not have the infrastructure or resources to respond to natural and other disasters that interfere with economic activities, which may adversely affect issuers located in such countries. Settlement and clearance procedures in certain foreign markets differ significantly from those in the U.S. Payment for securities before delivery may be required and in some countries delayed settlements are customary, which increases the Funds’ risk of loss. The Funds generally hold their foreign securities and related cash in foreign banks and securities depositories. Some foreign banks and securities depositories may be recently organized or new to the foreign custody business. In addition, there may be limited or no regulatory oversight over their operations. Also, the laws of certain countries may put limits on the Funds’ ability to recover its assets if a foreign bank, depository or issuer of a security or any of their agents goes bankrupt. Certain countries may require withholding on dividends paid on portfolio securities and on realized capital gains. In addition, it is often more expensive to buy, sell and hold securities in certain foreign markets than in the U.S. Foreign brokerage commissions are generally higher than commissions on securities traded in the U.S. and may be non-negotiable. The fees paid to foreign banks and securities depositories generally are higher than those charged by U.S. banks and depositories. The increased expense of investing in foreign markets reduces the amount earned on investments and typically results in a higher operating expense ratio for a Fund as compared to investment companies that invest only in the U.S. Investment Currency Risks. Investing in securities denominated in a foreign currency, entails risk of being exposed to a currency that may not fully reflect the strengths and weaknesses of the economy of the country or region utilizing the currency. Currency risk includes both the risk that currencies in which a Fund’s investments are traded, or currencies in which a Fund has taken an active investment position, will decline in value relative to the U.S. In addition, it is possible that a currency (such as, for example, the euro) could be abandoned in the future by countries that have already adopted its use, and the effects of such an abandonment on the applicable country and the rest of the countries utilizing the currency are uncertain but could negatively affect a Fund’s investments denominated in the currency. The Funds will not hedge any currency exposure arising from within the operations of an investee -9-

business nor from the holding of an investment denominated in a currency other than U.S. dollars. Many countries rely heavily upon export-dependent businesses and any strength in the exchange rate between a currency and the U.S. dollar or other currencies can have either a positive or a negative effect upon corporate profits and the performance of investments in the country or region utilizing the currency. Adverse economic events within such country or region may increase the volatility of exchange rates against other currencies, subjecting a Fund’s investments denominated in such country’s or region’s currency to additional risks. In addition, certain countries, particularly emerging market countries, may impose foreign currency exchange controls or other restrictions on the transferability, repatriation or convertibility of currency. Liquidity Risk. There is a risk that an investment cannot be liquidated in a timely manner at a reasonable price. There is also a potential risk that low levels of liquidity in relation to investee companies can impact their value and this could affect the performance of a Fund as a whole. There is no active secondary market for interests in the Funds, and it is not expected that such a market will develop. There can be no assurance that the liquidity of the investments of the Funds will always be sufficient to meet withdrawal requests as, and when, made. Any lack of liquidity may affect the liquidity of interests in the Funds and the value of the Funds’ investments. Long-Term Investment Strategy. Fundsmith’s investment philosophy is to seek long-term growth in value. Fundsmith does not seek to engage in short-term trading strategies to generate returns. Accordingly, any investment should be viewed as a long-term investment (5 years plus). Public Health Emergencies. A widespread health crisis such as a global pandemic could cause substantial market volatility, exchange trading suspensions and closures, which may lead to less liquidity in certain instruments, industries, sectors or the markets generally, and may ultimately affect a Fund’s performance. For example, the coronavirus (COVID-19) pandemic resulted in significant disruptions to global business activity and market volatility due to disruptions in market access, resource availability, facilities operations, imposition of tariffs, export controls and supply chain disruption, among others. The impact of a health crisis and other epidemics and pandemics that may arise in the future, could affect the global economy in ways that cannot necessarily be foreseen at the present time. A health crisis may exacerbate other pre-existing political, social and economic risks. Any such impact could adversely affect a Fund’s performance, resulting in losses to your investment. Political and/or Environmental Risks. The investee companies may operate in countries where ownership rights may be uncertain and the development of the resources of investee companies may be subject to disruption due to factors including civil disturbances, industrial actions, interruption of power supplies, as well as adverse climatic conditions. Global markets are interconnected, and changes in U.S. and non-U.S. economic and political conditions also could adversely affect individual investee companies or related groups of companies, securities markets, interest rates, credit ratings, inflation, investor sentiment, and other factors affecting the value of account investments. At such times, a Fund’s exposure to a number of other risks described elsewhere in this section can increase. Settlement Risks. Any investment in stocks and shares involves a level of settlement risk. This arises where a settlement in a transfer system does not take place as expected because a counterparty does not pay or deliver on time or as expected. Usually such transactions will settle later, when the appropriate payment or delivery has been made but occasionally the transaction will fail. Delays or failures in settlement can cause loss. Sustainability Risks. The Fundsmith Sustainable Equity Fund, LP is unable to invest in certain sectors and companies. This may mean that the Fund is more sensitive to certain market movements than other funds, and the Fund may underperform funds that do not utilize a sustainability strategy. Moreover, Fundsmith uses third-party classifications to determine whether an investment falls within certain prohibited sectors. A third-party may categorize different issuers as associated with different industries and such categorizations may not always align with an investor’s expectations. The sustainability considerations assessed as part of the research and investment approval process may vary across eligible investments, and not every sustainability factor may be identified or evaluated for every investment.

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Furthermore, a company’s sustainability or Fundsmith’s assessment of a company’s sustainability may change over time, which could cause the strategy to temporarily hold securities that do not comply with Fundsmith’s sustainability policy. In evaluating a company, Fundsmith is dependent upon information and data that may be incomplete, inaccurate, or unavailable, which could cause Fundsmith to incorrectly assess a company’s sustainability performance. Successful application of Fundsmith’s sustainability strategy will depend on the Firm’s skill in properly identifying and analyzing material sustainability issues. Sustainability factors may be evaluated differently by different managers, may be evaluated differently by the same manager at different times, and may mean different things to different people. Cybersecurity and operational risk. With the increased use of technologies, such as mobile devices and cloud-based service offerings and the dependence on the internet and computer systems to perform necessary business functions, Fundsmith, and its service providers are susceptible to operational and information or cybersecurity risks that could result in losses to the Funds. Intentional cybersecurity breaches include unauthorized access to systems, networks, or devices (such as through “hacking” activity or “phishing”); infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cyber-attacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on the service providers’ systems or websites rendering them unavailable to intended users or via “ransomware” that renders the systems inoperable until appropriate actions are taken. In addition, unintentional incidents can occur, such as the inadvertent release of confidential information (possibly resulting in the violation of applicable privacy laws). A cybersecurity breach could result in the loss or theft of customer data or funds, loss or theft of proprietary information or corporate data, physical damage to a computer or network system, or costs associated with system repairs. Such incidents could cause the Funds, Fundsmith and its affiliates, or other service providers to incur regulatory penalties, reputational damage, additional compliance costs, or financial loss. In addition, such incidents could affect issuers in which Fundsmith invests on behalf of the Funds, and thereby cause the Funds’ investments to lose value. The use of artificial intelligence or other evolving or emerging technologies presents significant risks and may exacerbate the aforementioned risks. Whilst Fundsmith has developed and implemented appropriate systems and procedures to control operational risk, these systems and procedures may not account for every actual or potential disruption of the Firm and the Funds’ operations. Fundsmith’s operations are dynamic and complex, and as a result, certain operational risks are intrinsic to the Firm and the Funds’ operations and business. Fundsmith is highly dependent on its ability to process transactions across numerous and diverse markets. Consequently, the Firm relies heavily on its financial, accounting and other data processing systems to trade, clear and settle transactions, to evaluate certain financial instruments, to monitor its portfolio and net capital, and to generate risk management and other reports that are critical to oversight of the Funds’ activities. In addition, certain portions of the Funds’ and the Firm’s operations interface will be dependent upon systems operated by third parties, including the administrator, market counterparties and their sub-custodians and other service providers, and Fundsmith may not be able to verify the risks or reliability of such third-party systems. Failure of such systems could result in mistakes made in the confirmation or settlement of transactions, or in transactions not being properly booked, evaluated or accounted for. These and other similar disruptions in Fundsmith’s operations may cause the Firm and the Funds’ to suffer, among other things, financial loss, the disruption of its businesses, liability to third parties, regulatory intervention, or reputational damage. Cyber-events have the potential to materially affect Fundsmith’s relationships with accounts, shareholders, clients, customers, employees, products, and service providers. Fundsmith has established risk management systems reasonably designed to seek to reduce the risks associated with cyber-events. There is no guarantee that Fundsmith will be able to prevent or mitigate the impact of any or all cyber-events. Fundsmith and the Funds are exposed to operational risk arising from a number of factors, including, but not limited to, human error, processing and communication errors, errors of the Firm’s service providers, counterparties, or other third parties, failed or inadequate processes and technology or system failures. In addition, other disruptive events, including (but not limited to) natural disasters and public health crises may adversely affect Fundsmith’s ability to conduct business, in particular if the Firm’s employees or the employees of its service providers are unable or unwilling to perform their responsibilities as a result of any such event. Even if Fundsmith’s employees and the employees of its service providers are able to work remotely, those remote work arrangements could result in Fundsmith’s business operations being less efficient than - 11 -

under normal circumstances, could lead to delays in its processing of transactions, and could increase the risk of cyber-events.

FISL has been retained by Fundsmith to provide sub-advisory services to the Funds and is compensated for this arrangement by Fundsmith paying the firm a percentage of the management fee for each Fund. In addition, FISL provides Fundsmith with certain non-advisory services, including: (1) product control activities relating to the first line control of investment risk; (2) provision of data and analytics; and (3) marketing and sales services involving introducing and relationship management. Moreover, Fundsmith provides research and certain back-office support services to FISL pursuant to intercompany services agreements. As discussed in the section titled “Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”, Fundsmith’s principals and employes are permitted to invest in the Funds and the Non-U.S. Funds. 10.D. Recommendations of Other Investment Advisers As detailed at “Item 10.C. – Material Relationships or Arrangements”, Fundsmith has entered into a research services agreement with FISL and, pursuant to sub-advisory agreements, has appointed FISL as the sub-adviser to each of the Funds. These arrangements present a potential conflict of interest as Fundsmith is required to exercise independent and effective oversight of FISL as a sub-adviser to the Funds, however, it has a corresponding interest in its affiliate’s success and profitability.

independence in the investment decision making process must be maintained at all times.

The Code also places restrictions on personal trades by employees, including requiring that they disclose their personal securities holdings and transactions to Fundsmith on a periodic basis, as well as requiring pre-clearance by Fundsmith of certain types of personal securities transactions. Fundsmith also maintains insider trading policies and procedures (the “Insider Trading Policies”) that are designed to prevent the misuse of material, non-public information (“MNPI”). Fundsmith personnel are required to certify to their compliance with the Code, including the Insider Trading Policies, on a periodic basis. The Insider Trading Policies prohibit Fundsmith and its personnel from trading for themselves, or recommending trading, in securities of a company while in possession of MNPI about such company, and from disclosing such information to any person not entitled to receive it. By reason of its various activities, Fundsmith may have access to MNPI or be restricted from effecting transactions in certain investments that might otherwise have been initiated. Fundsmith has designed and implemented policies and procedures to shield its investment professionals in most cases from access to MNPI so that investment decisions may be made on the basis of public information only. Among other things, such policies and procedures seek to control and monitor the flow of MNPI to and within Fundsmith, as well as to prevent trading based on MNPI. Notwithstanding such policies and procedures, there may be certain cases where Fundsmith may receive MNPI due to its various activities on behalf of itself or its Clients. If this were to happen, Fundsmith may be restricted from trading in the affected securities until such time as the information becomes public. Fundsmith seeks to minimize those cases whenever possible, consistent with applicable law and its Insider Trading Policies, but there can be no assurance that such efforts will be successful and that such restrictions will not occur. Investors or prospective investors in the Funds may request a copy of the Code by contacting Fundsmith at the address, email address or telephone number listed on the cover page of this Brochure. 11.B. Participation or Interest in Client Transactions As a matter of policy, Fundsmith does not engage in principal transactions. Moreover, Fundsmith does not ordinarily engage in cross trading or agency cross transactions. Any exceptions to this policy must be approved in advance by the Chief Compliance Officer. 11.C. Personal Trading Fundsmith prohibits its principals and employees from buying securities for themselves that are also recommended for Clients. The Code contains policies and procedures designed to prevent improper practices and to ensure compliance with the Code by Fundsmith, its principals and employees. The policies and procedures contained in the Code are the primary method employed to address the conflicts of interest that arise with respect to personal account transactions. For example, the principals and employees of Fundsmith must pre-clear certain types of personal securities transactions within the scope of the Code through Fundsmith’s Compliance Department. Certain Fundsmith principals and employees are investors in some of the Funds and the Non-U.S. Funds and may spend substantially all of their business time on one or more of the Clients.

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Fundsmith oversees the effectiveness of NT’s execution quality on an ongoing basis, which includes an analysis of price achieved, transaction costs, speed of execution, size of order, a broker-dealer’s ability to effect a transaction, and any other consideration relevant to the execution of an order. Neither Fundsmith nor the Funds utilize the services of a prime broker. Research and Other Soft Dollar Benefits Fundsmith does not currently engage in any soft dollar arrangements in which Fundsmith receives third-party services. Brokerage for Client Referrals Fundsmith does not receive client referrals from a broker-dealer or third party. Directed Brokerage Fundsmith does not recommend, request or require the Funds to direct it to execute transactions through a specified broker-dealer. 12.B. Aggregation of Orders When it is determined that it would be appropriate for a Fund to participate in an investment opportunity, Fundsmith will seek to aggregate orders for all of the participating investment accounts on an equitable basis and only where it is unlikely to work to the overall disadvantage of a participating Fund. However, Fundsmith has no obligation to obtain any particular investment opportunity for any particular Fund, and Fundsmith may be precluded from offering to certain Funds, particular securities in certain situations, including where Fundsmith or its affiliates have a prior contractual commitment with other Clients. If any order is not filled at the same price, they must be allocated on an average price basis. Similarly, if an order on behalf of more than one account cannot be fully executed under prevailing market conditions, securities may be allocated among the different accounts on a basis which Fundsmith or its affiliates considers equitable. There is no assurance that the Funds will hold the same investments or perform in a substantially similar manner as Clients with similar strategies.

13.B. Factors that May Trigger an Account Review Outside of Regular Review Not applicable. 13.C. Content and Frequency of Reports Investors in the Funds are provided monthly written reports which include detail on market value and performance. Investors are requested to refer to the Governing Documents of each Fund for further information on the reports provided to its investors.

Fundsmith’s general policy is to vote proxy proposals, amendments, consents or resolutions relating to a Fund’s securities, if any (collectively, “Proxies”), in a manner that serves the best interests of the Funds, as determined by Fundsmith in its discretion, taking into account the following factors: (i) the impact on the value of the investments; (ii) the anticipated associated costs and benefits; (iii) the continued or increased availability of portfolio information; and (iv) prevailing industry and business practices. The majority of proxy related issues generally fall within the following five categories: (a) corporate governance; (b) takeover defense; (c) compensation plans; (d) capital structure; and (e) social responsibility. Fundsmith will generally vote in favor of matters that follow an agreeable corporate strategic direction, support an ownership structure that enhances shareholder value without diluting management’s accountability to shareholders and/or that present compensation plans which are commensurate with manager performance and market practices. In limited circumstances, Fundsmith may refrain from voting Proxies where Fundsmith believes that voting would be inappropriate taking into consideration the cost of voting the Proxy and the anticipated benefit to the Fund. Prior to exercising any voting authority, Fundsmith reviews the relevant facts and determines whether or not a material conflict of interest may arise due to business, personal or family relationships of Fundsmith, its owners, its employees or its related persons having an interest in the - 15 -

outcome of the vote. If a material conflict exists, Fundsmith takes steps to ensure that its voting decision is based on the best interests of the Fund and is not a product of the conflict. Fundsmith may, at its discretion, disclose the conflict of interest to investors in the relevant Fund and defer to the voting recommendation of an independent third-party provider of proxy voting services, or take any other action which would serve the best interest of the Fund. Depending on the particular circumstances involved, the appropriate resolution of one conflict of interest may differ from the resolution of a conflict of interest with another Client, even though the general facts underlying both conflicts may be similar or identical. A copy of the Proxy Voting Policies and Procedures of Fundsmith is available to investors in the Funds upon request. Upon request, Fundsmith will also disclose to investors in a Fund how they can obtain information about how the Fund’s proxies were voted.