Mackenzie Investments: investment adviser

As of January 31, 2026, Power Financial Corporation, a wholly-owned subsidiary of Power Corporation of Canada, beneficially owned, directly and indirectly, 67.08% of IGM Financial Inc. (excluding 0.018% held by The Canada Life Assurance Company in its segregated funds or for similar purposes). The Desmarais Family Residuary Trust, a trust for the benefit of the members of the family of the late Mr. Paul G. Desmarais, has voting control, directly and indirectly of Power Corporation of Canada. Types of Advisory Services Offered by Mackenzie Mackenzie currently specializes in delivering quantitative equity strategies which are offered through discretionary investment advisory mandates to the following Clients:

Private Funds;

U.S. Sub-Advised Funds;

Collective Investment Trusts;

UCITS Sub-Advised Funds;

Canadian Sub-Advised Funds; and

Separately Managed Accounts.

In addition, Mackenzie provides model portfolio recommendations to other investment advisers as described in this Brochure (“Model Portfolios”). Tailoring Advisory Services to the Individual Need of Clients Consistent with its fiduciary duty, Mackenzie considers the individual needs of all clients and tailors the advisory services it provides to Clients. However, Canadian Sub-Advised Funds, U.S. Sub-Advised Funds, Collective Investment Trusts, UCITS Sub-Advised Funds and Private Funds are each managed in accordance with the particular investment objectives, strategies and restrictions established for that fund. A fund can impose restrictions on investing in certain securities or types of securities. These funds are not managed in accordance with the individualized needs of any particular interest holder in the fund. Therefore, a fund’s Investors should consider whether the fund meets their investment objectives and risk tolerance prior to investing. Information about the funds can be found in their relevant registration, governing and/or offering documents. For a U.S. Sub-Advised Fund, a Registration Statement can be found on the SEC’s EDGAR website. For Private Funds, relevant information is available in the private placement memorandum or other offering documents as well as the Private Fund’s governing documents, which will be available to current and prospective Investors only through Mackenzie or another authorized party. For the Collective Investment Trusts, the disclosure memorandum is available to current and prospective Investors through Mackenzie. Separately Managed Accounts are managed in accordance with each Client’s investment objectives, strategies, restrictions and guidelines, as communicated to Mackenzie by the Client. Clients can impose restrictions on investing in certain securities or types of securities. In the case of Model Portfolio recommendations, such recommendations are based on investment objectives, strategies, restrictions and guidelines agreed between the applicable investment adviser and Mackenzie. Client Assets Managed by The Firm 7|P a g e

As of December 31, 2025, we managed $18,068,039,261 in client assets on a discretionary basis. We did not manage any client assets on a non-discretionary basis as of that date.

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Advisory and other fees paid by Investors are described generally below and in more detail in the applicable Registration Statement, private placement memorandum, prospectus, subscription agreement, or other applicable disclosure, agreement and/or offering documents. Mackenzie Fee Schedule The chart below provides a general description of the fees charged to Clients. For most Clients, advisory fees paid to Mackenzie are calculated as a percentage of the Client’s assets. However, in our sole discretion, we or an affiliate can negotiate alternative fee arrangements rather than basing our fees on a general fee schedule. When we negotiate fees, we can take into consideration, among other things, the investment mandate, total market value, regulatory requirements, reporting requirements, customization of the investment or reporting process or other special considerations relevant to the particular Client. In appropriate circumstances, all or a portion of the fees charged to a particular Client or Investor can be waived or reduced in our sole and absolute discretion, or, as applicable, in our affiliate’s discretion. For example, we have waived fees in respect of certain Cayman Private Fund interests held by Mackenzie employees and affiliates. Additionally, fees charged by Mackenzie can change over time and there can be differences in fees paid by certain Clients or Investors based on the inception dates of their advisory relationship with Mackenzie or its affiliates. Also, Mackenzie or an affiliate could in its sole discretion agree to bear certain operating expenses of an Investment Fund that exceed a cap determined by Mackenzie. Except as otherwise agreed or required by applicable law, when we negotiate fees, or offer fee waivers, expense caps or similar arrangements to a Client or Investor, we are not obligated to inform, or offer similar arrangements to, other Clients or Investors. Thus, some Clients or Investors might pay more or less than others for the same or similar services depending, for example, on account inception dates, fee negotiations or waivers, number of accounts or value of related accounts, the nature of the mandate, total assets under management by Mackenzie and/or its affiliates or the manner in which Mackenzie’s and/or its affiliates’ services are provided.

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Account Type

Fee

U.S. Sub-Advised Funds

Currently, fees paid to Mackenzie by the fund’s primary investment adviser can be up to 0.19% of the relevant portion of the U.S. Sub-Advised Fund’s assets under management, per annum, with agreed breakpoints reducing such fees at defined asset levels. Each U.S. Sub-Advised Fund’s overall fee and expense structure is described in more detail in the U.S. Sub-Advised Fund’s Registration Statement.

Private Funds

Private Fund fees are based on the nature of the services provided and the investment strategies utilized and can include a management fee calculated as a percentage of the Private Fund’s assets (up to 1.25%) and an incentive compensation component, equal to a percentage of the Private Fund’s capital appreciation during the applicable period (up to 20%). Incentive compensation with respect to Private Funds could be subject to highwater mark and/or hurdle provisions as set forth in the Fund’s governing documents. Certain Private Funds maintain multiple class structures with differing fees paid by each class. Investors in a Private Fund should review the private placement memorandum for further detail on the Private Fund’s fees and expenses.

Canadian SubAdvised Funds

Each Canadian Sub-Advised Fund’s prospectus or other offering document includes information about the fees and expenses paid by the Canadian Sub-Advised Fund.

Collective Investment The disclosure memorandum for the Collective Investment Trusts includes information about the fees and expenses paid by the Collective Investment Trusts. Trusts UCITS Sub-Advised Funds Separately Managed Accounts

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Each UCITS Sub-Advised Fund’s prospectus includes information about the fees and expenses paid by the UCITS Sub-Advised Fund. Fees for Separately Managed Account clients will be determined through negotiation with each client.

How Fees are Charged and Collected Fees are generally charged and determined as follows:

Management fees (if any) in respect of investments in certain Private Funds are paid directly by Private Fund investors. Such fees are calculated on a monthly or quarterly basis and billed monthly or quarterly in arrears.

Fees for U.S. Sub-Advised Funds are accrued daily and paid monthly, in arrears.

Fees for Canadian Sub-Advised Funds that are managed by an affiliate of Mackenzie are accrued and paid daily except in the case of exchange-traded funds where fees are calculated and accrued daily and paid monthly. Fees for Canadian Sub-Advised Funds that are not managed by an affiliate of Mackenzie are charged in accordance with the terms set out in relevant prospectus or other offering document.

Fees for Collective Investment Trusts are accrued daily and paid monthly, in arrears.

Fees for the UCITS Sub-Advised Funds are charged in accordance with the terms set out in the relevant prospectus.

Fees for Separately Managed Accounts will be negotiated and invoiced in accordance with such Account’s investment management agreement.

Fees for Model Portfolios will be negotiated and invoiced in accordance with the applicable model agreement.

Invoices for advisory fees, where applicable, are payable upon receipt or within thirty days of receipt, in accordance with the terms of the applicable agreement. In certain circumstances, where disclosed in the Investment Fund’s offering document or with an Investment Fund Investor’s consent, management fees and any incentive compensation can be deducted directly from an Investment Fund. Mackenzie and its affiliates can, but are not required to, group multiple Accounts of a Client (or group of related Clients) together for fee billing purposes. Fees are ordinarily based on the level of total assets under management within the relevant Account(s), including allocations to cash, on the appropriate valuation day. Additional Fees and Expenses Except as otherwise agreed, each Account bears (and the fees described above do not include) the following costs and expenses: 11 | P a g e

custodial charges, brokerage fees or commissions and related costs and expenses (please see Item 12: Brokerage Practices for more details), taxes, duties and similar amounts payable in any jurisdiction in connection with an Account’s trading and operations, directors’ fees, insurance premiums, costs associated with obtaining and maintaining regulatory licenses and registrations including those required to enable investment of Account assets or the ongoing operation of a Private Fund, external costs incurred in valuation and portfolio pricing, duties and other governmental charges, transfer fees, registration fees and other expenses associated with the purchase, holding or sale of assets, costs and charges associated with making deposits in connection with foreign exchange transactions, withholding taxes payable and required to be withheld by issuers, their agents and others, audit, administrative and other expenses associated with regulatory or tax compliance or investment operations, the costs of negotiating trade-related and account-specific counterparty documentation, legal fees, and such other expenses as set forth in the Account’s relevant governing documents.

For specified Canadian Sub-Advised Funds that are managed by affiliate of Mackenzie, other than exchange-traded funds, many of these fees are covered by a fixed administration fee that the Canadian Sub-Advised Fund pays to Mackenzie Financial Corporation and that is separate from the management fee. Such fees will reduce the assets held in (and the gross returns experienced by) an Account. The Firm has a conflict of interest in determining whether an expense is an expense of an Account or is instead part of the Firm’s general overhead. In addition, the Firm could, from time to time, incur expenses for the benefit of one or more Accounts (and/or for its own benefit or for the benefit of an affiliate). In such cases, Accounts will typically bear an allocable portion of any such expenses in such manner as the Firm considers to be fair, and in accordance with the Firm’s policies and procedures and any applicable Account governing documents. However, to the extent that any such Account’s governing documents prohibit the Account from bearing that expense, the Firm or an affiliate will bear that portion of an expense. In these cases, or where the expense benefits one or more Accounts and the Firm or its affiliates, the Firm has an incentive to allocate relatively more of the expense to Accounts that are able to bear the expense, to reduce the amount that would be borne by the Firm or an affiliate. Subject to a client’s investment objectives and restrictions, the Firm can invest a portion of a client’s assets in shares of mutual funds or other investment companies, including exchange-traded funds. To the extent that such investments are made in an investment company that is advised by an affiliate of the Firm, clients will be rebated any associated advisory fees to the extent necessary to assure that a client does not double pay for advisory services. Investments in a fund are subject to advisory and other fees and expenses, which are paid by the fund but ultimately borne by the client, in addition to management fees assessed by the Firm. Each fund’s fees and expenses are described in the fund’s offering or disclosure documents (such as a prospectus and SAI). Our fees, and the expenses Clients bear in connection with their Accounts will reduce the assets held in (and the returns experienced by) an Account. Please see Item 12: Brokerage Practices for more details on our trading practices and costs related thereto.

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In certain instances, incentive compensation is charged only when gains in an Account exceed a particular rate or agreed upon benchmark (i.e., a hurdle provision), and losses can be carried forward so that no incentive compensation is charged unless the losses have been recouped, subject to certain adjustments (i.e., a high-water mark provision). As discussed below, incentive fees can be based on unrealized gains. MEMLS Fund Management (Cayman) LP, a Cayman Islands exempted limited partnership that is affiliated with the Firm, acts as the general partner to one Cayman Private Fund. Mackenzie EM Funds Management (Cayman) Ltd., a Cayman Islands exempted company that is affiliated with the Firm, acts as the general partner to certain other Cayman Private Funds. Incentive compensation for relevant Cayman Private Funds is generally paid through an annual allocation of profits from each Investor into the capital account of the investment manager, the related general partner, or another Mackenzie affiliate at each calendar year’s end. The ability to earn incentive compensation creates conflicts of interest including that Mackenzie has an incentive to make riskier or more speculative investments for Accounts paying such fees. Such conflicts are mitigated by establishment of investment guidelines for each Account’s fees and expenses. Because the Firm and each relevant affiliate manage various Accounts that charge performance-based fees and other types of fees, there is an incentive to favor certain Accounts over others where fees differ among Accounts and:

the Accounts have the same or similar investment styles or otherwise compete for investment opportunities,

the Accounts have differing abilities to engage in short sales or similar investment strategies, and/or

Mackenzie or its personnel or our affiliates or their personnel have differing personal or proprietary interests.

In particular, there is an incentive to favor Accounts that charge performance-based fees, such as an applicable Separately Managed Account or Cayman Private Fund, or in which Mackenzie or its affiliates and their respective personnel have investments or other pecuniary interests, over Accounts that charge other types of fees, such as a U.S. Sub-Advised Fund, and to favor those Accounts that charge a higher performance-based fees (or in which there are relatively greater pecuniary interests) over those with a lower performance-based fee (or in which there are relatively lesser, or no, pecuniary interests). With Private Funds there is also a conflict of interest between the Firm/affiliate’s interest in earning a profit in the short term with the long term interests of the Private Fund. The Firm/affiliate has an incentive to invest Private Fund assets in investments that are riskier or more speculative than would be the case if the Firm/affiliate was only compensated based on a flat percentage of capital, because these investments can allow the general partner to collect larger performance-based compensation. To mitigate this conflict, we and our affiliates maintain policies and procedures, including the Code (described in Item 11: Side-by-Side Management and Differential Interests, below) and Trade Allocation Policy, reasonably designed to assure that all Accounts are serviced: (1) in a manner consistent with the fiduciary duties an adviser owes its clients and applicable law and without considering such persons’ ownership, compensatory or other pecuniary or financial interests and (2) fairly and equitably over time to mitigate these and other conflicts associated with “side-by-side” management. Please see the discussion in Item 11: Side-by-Side Management and Differential Interests for a further description of these conflicts of interest.

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Other Conflicts of Interest Mackenzie’s management fees and general partner allocations are often based on the market value and/or performance of Accounts. As a result, to the extent that Mackenzie and/or a general partner values a security higher than its current market value (or where such market values are unreliable), Mackenzie and/or the general partner benefits by receiving a management fee or incentive allocation that is increased by the impact, if any, of such valuation discrepancy. Additionally, where an Investor purchases or redeems interests in an Investment Fund at a net asset value that is impacted by a discrepancy in valuation, the Investor could receive a greater or lesser interest in (or increased or decreased redemption proceeds from) such Investment Fund than would have been the case absent the discrepancy. Similarly, existing and continuing Investors can be subject to dilution or accretion. A portion of the assets in which Accounts managed by Mackenzie invest could, at any time or from time to time, be illiquid, thinly traded or otherwise difficult to value. Mackenzie has implemented valuation policies and procedures reasonably designed to mitigate the conflicts and potential for material pricing discrepancies in respect of Account assets and to assure that assets are valued in good faith and as accurately as is reasonably practicable. However, the valuation procedures cannot assure that the fair value assigned to an asset will match the next available and reliable market price or, in retrospect, have been the price at which that asset could have been sold during the period in which the particular fair values were being used in determining an Account’s value for performance, fee calculation or net asset value purposes.

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In addition, the relevant general partner or the directors of a Cayman Private Fund, as applicable, can require the maintenance of a minimum capital account size in the event of a partial withdrawal from a Cayman Private Fund or require an Investor to redeem all or part of its interest in a Cayman Private Fund. U.S. Sub-Advised Funds have a $100,000 minimum initial investment amount for Class A shares as well as minimum subsequent investment amounts. A U.S. Sub-Advised Fund can also impose other eligibility requirements. Notably, these minimum investment amounts and other requirements can change and are described in the U.S. SubAdvised Fund’s Registration Statement. Canadian Sub-Advised Funds other than exchange-traded funds have eligibility requirements including minimum investment requirements, which are different for each series of the funds offered. Details of the requirements are described in the prospectus or other offering document of the fund. Collective Investment Trusts have no stated minimum initial investment. UCITS Sub-Advised Funds have eligibility requirements including minimum investment requirements, which are different for each class of the funds offered. Details of the requirements are described in the prospectus of the fund. Separately Managed Accounts typically require a minimum initial market value of $25,000,000 depending upon the investment mandate. Mackenzie or its affiliates reserve the right to waive or reduce the investment minimums with respect to a specific Investor in a Cayman Private Fund in its sole discretion. Other Eligibility Requirements Investors in certain Investment Funds, including the Private Funds, can be subject to certain minimum income, net worth or other standards or additional qualification requirements imposed by the Investment Fund or applicable law, as set forth in the relevant governing documents. Consistent with these requirements, Private Fund Investors typically consist of:

high net worth individuals and a variety of institutional investors (e.g., trusts, employee benefit plans, endowments, foundations, corporations and other types of entities, including private funds of funds) that wish to invest in accordance with the Private Fund’s investment objective; and

Mackenzie and its affiliates, as well as personnel of Mackenzie and its affiliates (including but not limited to portfolio management personnel responsible for the management of Accounts) who are “knowledgeable employees” (as defined by 1940 Act Rule 3c-5) or otherwise meet the Private Fund’s eligibility requirements.

In no event should this Brochure be considered to be an offer of interests in an Investment Fund or relied upon in determining to invest. It is also not an offer of, or agreement to provide, advisory services directly to any recipient.

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Clients should be aware that while Mackenzie does not limit its advice to particular types of investments, mandates can be limited to certain types of securities (e.g., equities) and might not be diversified. The accounts managed by Mackenzie are generally not intended to provide a complete investment program for a Client or Investor. Clients are responsible for appropriately diversifying their assets to guard against the risk of loss. The following is a description of the significant investment strategies we use for (or currently expect to offer to) Clients and the material risks associated with those strategies and the assets in which they invest. Additional information about the strategies employed by, and risks related to, a Client can be found in the Client’s Prospectus, Statement of Additional Information, Private Placement Memorandum or other client-specific offering document and, to the extent the information in such document differs from what is set forth herein, the information in the client-specific offering document controls. Certain strategies can be customized upon Client request.

The investment strategy or product

Its principal material risks

Mackenzie World Large Cap

Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk

The strategy seeks to seeks to provide long-term capital growth by investing primarily in equity securities issued by larger companies anywhere in the world.

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The investment strategy or product

Its principal material risks

UCITS Sub-Advised Fund - Mackenzie World Large Cap

Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk

The Sub-Fund’s investment objective is to provide long-term capital growth by investing primarily in a portfolio of equity securities of large-capitalization companies anywhere in the world.

The risks indicated above reflect risks of the Fund as a whole Mackenzie World ex North America (EAFE) The strategy seeks to outperform the applicable benchmark through diversified investments in equity securities mainly traded in the global developed countries excluding North American countries.

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Company risk Credit risk Derivatives risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Portfolio Manager risk Regulatory and Tax risk

The investment strategy or product

Its principal material risks

Mackenzie Emerging Markets Small Cap

Cash and Related Investments risk Company risk Competition and Potential Strategy Saturation risk Counterparty risk Currency Exchange Exposure and Currency Hedging risk Currency risk Derivatives risk Dilution risk Emerging Markets risk ESG Strategy risk Equity Securities risk Exchange-Traded Fund risk Foreign Markets risk Forward Contracts risk Frontier Emerging Markets risk Government and Corporate Reporting risk Hedging risk Model risk Portfolio Turnover risk Quantitative risk Regulatory and Tax risk Small Company risk

The strategy seeks to achieve long-term capital growth by investing primarily in the securities of small cap emerging markets issuers. The Firm’s proprietary quantitative security selection model is employed to generate transactions.

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The investment strategy or product Mackenzie International Quantitative Large Cap The strategy seeks to provide long-term capital growth by investing primarily in, or gaining exposure to, the securities of large market capitalization and medium market capitalization issuers in developed international markets other than the United States, in each case as determined by the Firm. The Firm’s proprietary quantitative security selection model is employed to generate transactions.

Mackenzie International Quantitative Small Cap The strategy seeks to provide long-term capital growth by investing primarily in, or gaining exposure to, the securities of small market capitalization and medium market capitalization issuers in developed international markets other than the United States, in each case as determined by the Investment Adviser. The Firm’s proprietary quantitative security selection model is employed to generate transactions.

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Its principal material risks Cash and Related Investments risk Currency Exchange Exposure and Currency Hedging risk Currency risk Derivatives risk Emerging Markets risk ESG Strategy risk Equity-Linked Instruments and Related Options risk Equity Securities risk Exchange-Traded Fund risk Forward Contracts risk Futures risk Government and Corporate Reporting risk Hedging risk Leveraged Investments risk Low Latency Trading risk Mid-Sized Company risk Model risk Portfolio Turnover risk Quantitative risk Small Company risk Uncertainty risk Cash and Related Investments risk Currency Exchange Exposure and Currency Hedging risk Currency risk Derivatives risk Emerging Markets risk ESG Strategy risk Equity-Linked Instruments and Related Options risk Equity Securities risk Exchange-Traded Fund risk Forward Contracts risk Futures risk Government and Corporate Reporting risk Hedging risk Leveraged Investments risk Low Latency Trading risk Mid-Sized Company risk Model risk Portfolio Turnover risk Quantitative risk Small Company risk Uncertainty risk

The investment strategy or product Mackenzie Emerging Markets Long/Short Opportunities The strategy seeks to achieve consistent absolute returns with low correlation to the returns of the equity markets in general primarily through leveraged long and short exposure to the equity securities of emerging markets issuers. The Firm’s proprietary quantitative security selection model is employed to generate transactions. On the basis of the model’s output, the Firm generally expects to implement aggregate:

long positions of approximately 100% of net asset value in securities and instruments the Firm believes will increase in value; and short positions of approximately 80% of net asset value in securities and instruments the Firm believes will decrease in value.

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Its principal material risks Cash and Related Investments risk Competition and Potential Strategy Saturation risk Counterparty risk Currency Exchange Exposure and Currency Hedging risk Currency risk Derivatives risk Emerging Markets risk Equity-Linked Instruments and Related Options risk Equity Securities risk Exchange-Traded Fund risk Forward Contracts risk Frontier Emerging Markets risk Futures risk Government and Corporate Reporting risk Hedging risk Inflation/Deflation risk Leveraged Investments risk Low Latency Trading risk Model risk Portfolio Turnover risk Quantitative risk Regulatory and Tax risk Short-Selling risk Small Company risk Uncertainty risk

The investment strategy or product Mackenzie U.S. Quantitative Amplified Core The strategy seeks to maximize total returns by employing the Firm’s proprietary quantitative security selection model to generate portfolio transactions. On the basis of the model’s output, the Firm generally expects to implement aggregate:

long positions of approximately 120% of net asset value in securities and instruments the Firm believes will increase in value; and short positions of approximately 20% of net asset value in securities and instruments the Firm believes will decrease in value.

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Its principal material risks Cash and Related Investments risk Competition and Potential Strategy Saturation risk Counterparty risk Derivatives risk Equity-Linked Instruments and Related Options risk Equity Securities risk ESG Strategy risk Exchange-Traded Fund risk Forward Contracts risk Futures risk Government and Corporate Reporting risk Hedging risk Inflation/Deflation risk Investment Style risk Leverage risk Leveraged Investments risk Low Latency Trading risk Mid-Sized Company risk Model risk Portfolio Turnover risk Quantitative risk Regulatory and Tax risk Short-Selling risk Small Company risk Uncertainty risk

The investment strategy or product

Its principal material risks

Canadian Sub-Advised Funds - Emerging Markets Strategies

Capital Depletion risk Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk Uncertainty risk

Each strategy seeks to achieve long-term capital growth by investing primarily in equity securities of emerging markets companies. The Firm seeks to achieve this investment objective by looking for undervalued companies with growth prospects and using a quantitative approach to stock selection, portfolio construction, and transaction cost measurement.

Canadian Sub-Advised Funds – International Quantitative Strategies Each strategy seeks to achieve long-term capital growth by investing primarily in equity securities of international markets companies. The Firm seeks to achieve this investment objective by looking for undervalued companies with growth prospects and using a quantitative approach to stock selection, portfolio construction, and transaction cost measurement.

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Capital Depletion risk Company risk Credit risk Derivatives risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk

The investment strategy or product

Its principal material risks

Canadian Sub-Advised Funds – U.S. Quantitative Strategies

Capital Depletion risk Company risk Credit risk Derivatives risk ESG Strategy risk Exchange-Traded Fund risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk

Each strategy seeks to achieve long-term capital growth by investing primarily in equity securities of U.S. companies. The Firm seeks to achieve this investment objective by looking for undervalued companies with growth prospects and using a quantitative approach to stock selection, portfolio construction, and transaction cost measurement.

Canadian Sub-Advised Funds – Global Low Volatility Strategy The strategy seeks to seeks to achieve long-term capital growth by investing primarily in equity securities of large and mid-capitalization companies in developed global markets, while seeking to provide lower volatility. The Firm seeks to achieve this investment objective by looking for undervalued companies with growth prospects and using a quantitative approach to stock selection, portfolio construction, and transaction cost measurement.

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Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk

The investment strategy or product

Its principal material risks

Canadian Sub-Advised Funds – Private Equity Replication Strategy (U.S. Equity Sleeve only)

Company risk Credit risk Derivatives risk ESG Strategy risk Foreign Currency risk Foreign Markets risk Leverage risk Portfolio Manager risk Small Company risk Uncertainty risk

The strategy seeks to provide long-term capital appreciation and to replicate the long-term returns of diversified U.S. private equity investments by investing primarily in listed U.S. equity securities.

Canadian Sub-Advised Funds – Global Strategy The strategy seeks to seeks to provide long-term capital growth by investing primarily in equity securities issued by companies of any size, anywhere in the world.

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Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk

The investment strategy or product

Its principal material risks

Canadian Sub-Advised Fund – Emerging Markets Value Strategy

Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk Uncertainty risk

The Fund is a multi-manager fund, of which the Firm manages a portion, but not all, of the assets. The following describes the Fund’s overall strategy: The iProfile Emerging Markets Private Pool aims to provide long-term capital growth by investing primarily in equities from emerging markets. To achieve the Pool’s investment objective, the Portfolio Advisor allocates investments to a number of Mandates, each of which is separately advised by Sub-Advisor(s) having a complementary management style. The Portfolio Advisor will vary the allocation of investments among the Mandates based on an assessment of overall economic and market conditions.

The risks indicated above reflect risks of the Fund as a whole.

Canadian Sub-Advised Fund – Emerging Markets Large Cap Strategy The Fund seeks to achieve long-term capital growth by investing primarily in a portfolio of equity securities of large-capitalization securities companies in emerging markets.

Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk Uncertainty risk The risks indicated above reflect risks of the Fund as a whole.

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The investment strategy or product

Its principal material risks

UCITS Sub-Advised Fund – Emerging Markets Large Cap Strategy

Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk Uncertainty risk

The Sub-Fund’s investment objective is to provide long-term capital growth by investing primarily in a portfolio of equity securities of largecapitalization companies in emerging markets including China.

Canadian Sub-Advised Funds – Emerging Markets Low Volatility Strategy The strategy aims to provide long-term capital growth by investing primarily in equity securities from emerging markets throughout the world.

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Company risk Credit risk Derivatives risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Small Company risk Uncertainty risk

The investment strategy or product Canadian Sub-Advised Fund – Shariah Global Equity Strategy The Fund seeks to provide long-term capital growth by investing primarily in Shariah-compliant equity securities of companies located anywhere in the world.

Canadian Sub-Advised Funds – Canadian Low Volatility Strategy The strategy aims to provide long-term capital growth by investing primarily in Canadian equity securities while seeking to provide lower volatility. The strategy seeks to provide lower volatility than the broad Canadian equity market over a full market cycle (generally at least three years or more). The strategy invests primarily in Canadian equity securities with a focus on those companies and/or sectors that are believed to have lower sensitivity to broader market movements.

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Its principal material risks Company risk Credit risk Emerging Markets risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Series risk Small Company risk Uncertainty risk Company risk Derivatives risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk REITs risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Small Company risk Uncertainty risk

The investment strategy or product

Its principal material risks

Canadian Sub-Advised Funds – U.S. Low Volatility Strategy

Company risk Derivatives risk Exchange-Traded Fund risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk REITs risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Small Company risk Uncertainty risk

The strategy aims to provide long-term capital growth by investing primarily in U.S. equity securities, while seeking to provide lower volatility. The strategy seeks to provide lower volatility than the broad U.S. equity market over a full market cycle (generally at least three years or more). To achieve its objective, the strategy invests primarily in U.S. equity securities with a focus on those companies and/or sectors that are believed to likely have lower sensitivity to broader market movements.

Canadian Sub-Advised Fund – U.S. Equity Strategy The Fund is a multi-manager fund, of which the Firm manages a portion, but not all, of the assets. The following describes the Fund’s overall strategy: The Fund aims to provide long-term capital growth by investing primarily in U.S. equity securities. The Fund intends to invest in the common shares of U.S. companies, diversified by sector, investment style and market capitalization. The Fund has components focused on value and growth, as well as a core component with no specific style bias. The Fund may employ both fundamental and quantitative investment approaches while achieving the Fund’s objective.

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Company risk Derivatives risk Exchange-Traded Fund risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk REITs risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Small Company risk Uncertainty risk The risks indicated above reflect risks of the Fund as a whole.

The investment strategy or product Canadian Sub-Advised Fund – IG Mackenzie Mutual of Canada The Fund is a multi-manager fund, of which the Firm manages a portion, but not all, of the assets. The following describes the Fund’s overall strategy: The Fund aims to provide an above-average income yield and long-term capital growth by investing primarily in debt and equity investments of Canadian corporations involved in various industries. The Fund is expected to maintain a relatively stable asset mix of primarily equities and some fixed income investments based on preestablished guidelines, but there is no restriction on the weighting that may be placed on any type of investments. Generally, the Fund will not invest more than 50% of its assets in foreign securities.

Its principal material risks Commodity risk Company risk Credit risk Derivatives risk Exchange-Traded Fund risk Fixed Income Investment risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Prepayment risk Regulatory and Tax risk REITs risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Short-Selling risk Small Company risk Uncertainty risk The risks indicated above reflect risks of the Fund as a whole.

Canadian Sub-Advised Fund – Dividend Strategy The Fund is a multi-manager fund, of which the Firm manages a portion, but not all, of the assets. The following describes the Fund’s overall strategy: The Fund has three principal objectives. These are: • to obtain above-average income yield on its investments; • to protect the value of its investments; and • to achieve long-term capital appreciation consistent with the fulfillment of the first two objectives. The Fund selects diversified investments such as equities and fixed income securities which provide current income as well as the opportunity for capital gains. Generally, the Fund’s portfolio will be managed so that over the long term its income yield exceeds that of the median fund in its peer group.

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Company risk Credit risk Derivatives risk Exchange-Traded Fund risk Fixed Income Investment risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Prepayment risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk Uncertainty risk The risks indicated above reflect risks of the Fund as a whole.

The investment strategy or product Canadian Sub-Advised Funds – Global Financial Services Strategy

Its principal material risks

Company risk The strategy aims to provide long-term capital Derivatives risk growth with an income component via dividends, Emerging Markets risk by investing primarily in large leading global Exchange-Traded Fund risk financial services providers and the companies that Foreign Currency risk provide technology and support services to these Foreign Markets risk companies. A portion of the strategy may also be invested in medium and small cap financial services Interest Rate risk companies and/or support services or companies Large Transaction risk engaged in providing financial services electronically via the Internet and/or proprietary Portfolio Manager risk online access. Regulatory and Tax risk The strategy expects to focus on investing primarily REITs risk Securities Lending, Repurchase and Reverse Repurchase in the common shares of companies in industries Transactions risk such as banking, insurance, asset management and Series risk stock brokerages throughout the world. There is expected to be a “best-in-class” sector approach Small Company risk taken with emphasis on large capitalization Uncertainty risk corporations. The strategy uses a blend of growth and value equity management styles, seeking to invest in high-quality companies that are undervalued and have attractive growth prospects. The strategy uses a quantitative approach to stock selection, portfolio construction, and transaction cost measurement. The strategy employs fundamental ideas in a disciplined, risk-aware manner.

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The investment strategy or product

Its principal material risks

Canadian Sub-Advised Fund – North American Strategy

Company risk Derivatives risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk REITs risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk Uncertainty risk

The Fund is a multi-manager fund, of which the Firm manages a portion, but not all, of the assets. The following describes the Fund’s overall strategy: The Fund aims to provide long-term capital growth consistent with preservation of capital by investing primarily in North American markets. The Fund selects primarily common shares of companies diversified by industry and geography based on: • an analysis of the company’s finances; • economic forecasts for the company and industry in which it operates; and •an assessment of whether the company has better-than-average growth prospects.

Canadian Sub-Advised Fund – Core U.S. Strategy

The risks indicated above reflect risks of the Fund as a whole.

Company risk The strategy aims to provide long-term capital Derivatives risk growth by investing primarily in U.S. equity Exchange-Traded Fund risk securities. Foreign Currency risk The strategy intends to invest in the common shares Foreign Markets risk of U.S. companies, diversified by sector, investment style and market capitalization. The strategy has components focused on value and Large Transaction risk growth, as well as a core component with no specific style bias. Portfolio Manager risk The strategy invests primarily in large Regulatory and Tax risk capitalization U.S. companies. A portion of the REITs risk strategy also may be invested in medium Securities Lending, Repurchase and Reverse Repurchase capitalization companies and/or companies based Transactions risk outside of the United States. Series risk Small Company risk Uncertainty risk

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The investment strategy or product

Its principal material risks

Canadian Sub-Advised Fund – International Large Cap Value Strategy

Company risk Credit risk Derivatives risk ESG Strategy risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Small Company risk Uncertainty risk

The Fund is a multi-manager fund, of which the Firm manages a portion, but not all, of the assets. The following describes the Fund’s overall strategy: The iProfile International Equity Private Pool aims to provide long-term capital growth primarily by investing in international equities, excluding North American equities and equities from emerging markets. To achieve the Pool’s investment objective, the Portfolio Advisor allocates investments to a number of Mandates, each of which is separately advised by Sub-advisor(s) having a complementary management style. The Portfolio Advisor will vary the allocation of investments among the Mandates based on an assessment of overall economic and market conditions.

Canadian Sub-Advised Fund – GQE Alpha Extension The Fund seeks to provide long-term capital growth by investing primarily in long and/or short positions of equity securities of companies located in the United States. The Fund may engage in cash borrowing, physical short sales, use leverage, and/or derivatives for hedging and investment purposes.

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The risks indicated above reflect risks of the Fund as a whole.

Company risk Counterparty risk Derivatives risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Long/Short risk Portfolio Manager risk Regulatory and Tax risk REITs risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Series risk Short-Selling risk Small Company risk Uncertainty risk

The investment strategy or product

Its principal material risks

Canadian Sub-Advised Fund – GQE Canadian Equity Strategy The Fund seeks to provide long-term capital growth by investing mainly in equity securities of large and mid-capitalization companies in Canada.

Company risk Derivatives risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk REITs risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Small Company risk Uncertainty risk

Canadian Sub-Advised Fund – GQE Canadian Balanced Strategy (sleeve only) The Fund seeks to provide long-term capital growth and a steady flow of current income by investing primarily in a combination of equity securities, fixed-income securities, and securities convertible into equity and fixed-income securities of issuers in Canada.

Company risk Derivatives risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Large Transaction risk Portfolio Manager risk Regulatory and Tax risk REITs risk Securities Lending, Repurchase and Reverse Repurchase Transactions risk Small Company risk Uncertainty risk The risks indicated above reflect risks of the Fund as a whole.

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The investment strategy or product U.S. Value Strategy The Account seeks to provide long-term capital growth by investing primarily in publicly traded U.S. equities. The Account uses a bottom-up management style focusing on mid to large-capitalization companies trading at attractive valuations and that appear poised to generate a turnaround, or acceleration in earnings.

Canadian Low Volatility Strategy The Account seeks to provide long-term capital appreciation by investing in Canadian equity securities. The Account seeks to provide lower volatility than the broad Canadian equity market over a full market cycle (generally at least three years or more). To achieve its objective, the Account invests primarily in Canadian equity securities with a focus on those companies and/or sectors that are believed to have lower sensitivity to broader market movements.

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Its principal material risks Cash and Related Investments risk Derivatives risk Equity Securities risk ESG Strategy risk Exchange-Traded Fund risk Government and Corporate Reporting risk Inflation/Deflation risk Investment Style risk Mid-Sized Company risk Model risk Portfolio Turnover risk Quantitative risk Regulatory and Tax risk Small Company risk Uncertainty risk

Company risk Derivatives risk Exchange-Traded Fund risk Foreign Currency risk Foreign Markets risk Portfolio Manager risk Regulatory and Tax risk REITs risk Small Company risk Uncertainty risk

The investment strategy or product SEI Institutional Managed Trust – The Large Cap Growth Fund

Its principal material risks

Active Management risk Currency risk Depositary Receipts risk The Fund is a multi-manager fund, of which the Derivatives risk Firm manages a portion, but not all, of the assets. Exchange-Traded Fund risk The following describes the Fund’s overall Foreign Markets risk strategy: Investment Style risk Under normal circumstances, the Large Cap Large Company risk Growth Fund will invest at least 80% of its net Leveraged Investments risk assets (plus the amount of any borrowings for Long/Short risk investment purposes) in equity securities of large Market risk companies. The Fund will primarily seek to Mid-Sized Company risk purchase securities believed to have attractive Non-Diversification risk growth and appreciation potential. For purposes Preferred Stock risk of this Fund, a large company is a company with Quantitative risk a market capitalization in the range of companies REITs risk Warrants risk in the Russell 1000 Growth Index (between $1 billion and $4.5 trillion as of December 31, The risks indicated above reflect risks of the Fund as a 2025) at the time of purchase. The market whole. capitalization range and the composition of the Russell 1000 Growth Index are subject to change. The Fund will invest primarily in common stocks, preferred stocks, warrants, American Depositary Receipts (ADRs), real estate investment trusts (REITs) and exchangetraded funds (ETFs), as well as forward contracts and swaps for hedging and speculative purposes. The Fund may also, to a lesser extent, invest in common and preferred stocks of small capitalization companies. The Fund may invest up to 20% of its assets in foreign securities.

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The investment strategy or product SEI Institutional Investments Trust – The Large Cap Disciplined Equity Fund The Fund is a multi-manager fund, of which the Firm manages a portion, but not all, of the assets. The following describes the Fund’s overall strategy: Under normal circumstances, the Large Cap Disciplined Equity Fund will invest at least 80% of its net assets (plus the amount of any borrowings for investment purposes) in equity securities of large companies. These securities may include common stocks, preferred stocks, depositary receipts, warrants, exchange-traded funds (ETFs) and real estate investment trusts (REITs) based on a large capitalization equity index and equity securities of foreign companies. The Fund will invest primarily in common stocks of U.S. companies with market capitalizations in the range of companies in the S&P 500 Index (between $4.2 billion and $ $4.3 trillion as of July 31, 2025) at the time of purchase. The market capitalization range and the composition of the S&P 500 Index are subject to change. The Fund may also, to a lesser extent, invest in common and preferred stocks of small capitalization companies.

Its principal material risks Credit risk Currency risk Depositary Receipts risk Derivatives risk Exchange-Traded Fund risk Foreign Markets risk Investment Style risk Large Company risk Leveraged Investments risk Portfolio Turnover risk Preferred Stock risk REITs risk Short-Selling risk Small Company risk Warrants risk The risks indicated above reflect risks of the Fund as a whole.

U.S. Small Cap Strategy The strategy seeks to provide long-term capital growth by investing primarily in equity securities of small-capitalization companies in the United States. The investment approach follows a core investment style, looking for companies that are undervalued, of high quality and have good growth prospects. The portfolio manager uses a quantitative approach to stock selection, portfolio construction and transaction cost measurement. The portfolio manager employs fundamental ideas in a disciplined, risk-aware manner. The portfolio invests in small-cap U.S. market stocks.

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Company risk Derivatives risk Exchange-Traded Fund risk Portfolio Manager risk Regulatory and Tax risk REITs risk Small Company risk Uncertainty risk

The investment strategy or product

Its principal material risks

U.S. Large Cap Strategy (Model Portfolio)

Company risk Credit risk ESG Strategy risk Large Company risk Model Portfolio Implementation risk Portfolio Manager risk

The strategy seeks to seeks to provide long-term capital growth by providing a model that when implemented would primarily provide exposure to equity securities issued by larger companies in the United States.

UCITS Sub-Advised Funds (sleeve only) - U.S. Large Cap Strategy The strategy seeks to seeks to provide long-term capital growth by investing primarily in equity securities of large-capitalization companies in the United States.

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Company risk Credit risk ESG Strategy risk Large Company risk Model risk Portfolio Manager risk Portfolio Turnover risk Uncertainty risk

The investment strategy or product

Its principal material risks

Collective Investment Trust - Mackenzie Quantitative Emerging Markets All Cap Strategy

Company risk Credit risk Currency risk Emerging Markets risk ESG Strategy risk Foreign Markets risk Large Company risk Mid-Sized Company risk Model risk Portfolio Manager risk Portfolio Turnover risk Uncertainty risk

The Fund’s investment objective is to provide long-term capital growth by investing primarily in, or gaining exposure to, the securities of emerging markets issuers.

Collective Investment Trust - Mackenzie Quantitative U.S. Small Cap Strategy The Fund’s investment objective is to provide long-term capital growth by investing primarily in, or gaining exposure to, the securities of small cap and mid cap issuers based in the United States.

Collective Investment Trust - Mackenzie Quantitative International Large Cap Strategy The Fund’s investment objective is to provide long-term capital growth by investing primarily in, or gaining exposure to, the securities of large cap and mid cap issuers based in developed international markets other than the United States and Canada.

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Company risk Credit risk ESG Strategy risk Model risk Portfolio Manager risk Portfolio Turnover risk Small Company risk Uncertainty risk

Company risk Credit risk Currency risk ESG Strategy risk Foreign Markets risk Large Company risk Model risk Portfolio Manager risk Portfolio Turnover risk Uncertainty risk

The investment strategy or product

Its principal material risks

Collective Investment Trust - Mackenzie Quantitative International Large Cap Strategy

Company risk Credit risk Currency risk ESG Strategy risk Foreign Markets risk Large Company risk Model risk Portfolio Manager risk Portfolio Turnover risk Uncertainty risk

The Fund’s investment objective is to provide long-term capital growth by investing primarily in, or gaining exposure to, the securities of small cap and mid cap issuers based in developed international markets other than the United States and Canada.

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In addition to the investment strategies set forth in the table above, certain affiliates of Mackenzie can also pursue similar or other strategies. The principal material risks (as set forth in the table above) as well as other material risks are described in more detail below. Active Management risk: An Account is subject to the risk that its adviser’s judgments about the attractiveness, value, or potential appreciation of the Account’s investments may prove to be incorrect. If the investments selected and strategies employed by the Account fail to produce the intended results, the Account could underperform in comparison to other accounts with similar objectives and investment strategies or underperform the markets in which the Account invests. Artificial Intelligence risk: The Firm uses forms of artificial intelligence (“AI”), including forms of generative AI, in its investment process, and it and its affiliates utilize AI tools in other aspects of their operations. AI is a rapidly evolving technology that presents unique risks. Generative AI outputs may appear correct but be incorrect. AIgenerated software may not function correctly or efficiently or may have security weaknesses. Quality control processes may not catch all such issues. There is also a risk that AI-generated investment analyses or recommendations may be deficient, inaccurate, biased, or incomplete, potentially causing errors in judgment, decision-making, or research that could negatively affect Account performance. Additionally, regulation governing the use of AI in investment management is likely to evolve and could significantly impede or restrict future use. Capital Depletion risk: Certain Accounts might invest in mutual funds that aim to make monthly distributions (which generally are comprised of a return of capital) at a target rate. Return of capital reduces the amount of the original investment and could result in a return of the entire amount of the original investment. Return of capital that is not reinvested will reduce the net asset value of the mutual fund, which could reduce the mutual fund’s ability to generate future income. Cash and Related Investments risk: Certain Accounts can invest in cash or cash items pending other investments. These cash items will typically be deemed to be high quality at the time of investment and could include a number of money market instruments such as negotiable or non-negotiable securities issued by, or short-term deposits with, U.S. and non-U.S. governments and agencies or instrumentalities thereof, bankers’ acceptances, high quality commercial paper, bank certificates of deposit, and short- to medium-term debt securities of U.S. or non-U.S. issuers, or such other instruments as the Firm in its sole discretion deems to be appropriate. The Account could also hold interests in investment vehicles that hold cash or cash items. While investments in cash items generally involve relatively low risk levels, they have lower potential expected returns than other types of investments, and could result in losses on an absolute basis or returns that are insufficient to cover fees and expenses. Investments in cash items and money market funds could also provide less liquidity than anticipated by the Account at the time of investment. In addition, demand deposits of cash are generally not collateralized and, in the event of the insolvency of the deposit-taking institution, would give rise to an unsecured claim, which may result in partial or total loss of the deposited amount. Commodity Risk: An Account may invest in commodities or in companies engaged in commodity-focused industries and may obtain exposure to commodities using derivatives or by investing in exchange-traded funds, the underlying interests of which are commodities. Commodity prices can fluctuate significantly in short time periods, which will have a direct or indirect impact on the value of such an Account. Company risk: Equity investments such as stocks and investments in trusts, and fixed income investments, such as bonds, carry several risks that are specific to the company that issues the investments. A number of factors could cause the price of these investments to fall. These factors include specific developments relating to the company, conditions in the market where these investments are traded, and general economic, financial, political, regulatory, geopolitical, environmental and public health conditions in the countries where the company operates. While these factors impact all securities issued by a company, the values of equity securities generally tend to change more frequently and vary more widely than fixed income securities. Because an Account’s value is based on the value of its portfolio securities, an overall decline in the value of portfolio securities that it holds will reduce the value of the Account. Competition and Potential Strategy Saturation risk: Certain Accounts are expected to compete with numerous other private investment funds, financial institutions and other investors pursuing similar strategies, many of which will have substantially greater resources than the Account and the Firm. The profit potential of the Account can be 40 | P a g e

materially reduced as a result of the “saturation” of the alternative investment field and competition for the same or similar types of trades and transactions. Emerging market investing is often more susceptible to becoming “saturated” because of the less liquid, transparent and “deep” nature of many emerging markets, as compared to more developed markets. Concentration risk: Certain Accounts can invest a large portion of their net assets in a small number of issuers, in a particular industry, geographic region or sector, or use a specific investment style, such as growth or value. A relatively high concentration of assets in or exposure to a single issuer, or a small number of issuers, will reduce the diversification of an Account and could result in increased volatility in the Account’s value. Issuer concentration may also increase the illiquidity of the Account’s portfolio if there is a shortage of buyers willing to purchase those securities. An Account concentrates in an issuer, industry, geographic region, style or sector either to provide investors with more certainty about how the Account will be invested or the style of the Account or because a portfolio manager believes that specialization increases the potential for positive returns. If an industry or region faces difficult economic times or if the investment approach used by the Account is out of favor, the Account will likely lose more than it would if it diversified its investments or style. If an Account’s investment objectives or strategies require concentration, the Account could experience negative returns over a prolonged period of time. Counterparty risk: Certain Accounts are subject to the risk of the insolvency of its counterparties (such as brokerdealers, futures commission merchants, banks or other financial institutions, exchanges or clearinghouses). The Account’s assets could be lost or impounded during a counterparty’s bankruptcy or insolvency proceedings and a substantial portion or all of the Account’s assets could become unavailable permanently or for a matter of years. There are increased risks in dealing with non-U.S. brokers and unregulated trading counterparties, including the risk that assets will not benefit from the protection afforded to “customer funds” deposited with regulated brokers and dealers. While applicable SEC rules require, in most instances, that Client assets be deposited only with “qualified custodians,” outside of the United States and the EU, it is often difficult to protect customer assets — even those on deposit with “qualified custodians.” In the case of a counterparty’s bankruptcy or inability to satisfy substantial deficiencies in other customer accounts, the Account could recover, even in respect of property specifically traceable to it, only a pro rata share of all property available for distribution to all of such counterparty’s customers. Credit risk: Certain Accounts are subject to the risk that the issuer of a security or the counterparty to a contract will default or otherwise become unable to honor a financial obligation. In addition, the prices of debt instruments depend in part on the credit quality of the issuer and may fall upon downgrade or negative changes in or perceptions of the financial condition of the issuer. Currency risk: Certain Accounts with investments in securities denominated in, and/or receiving revenues in, foreign currencies, will be subject to currency risk. Currency risk is the risk that foreign currencies will decline in value relative to the U.S. dollar or, in the case of hedging positions, that the U.S. dollar will decline in value relative to the currency hedged. In either event, the dollar value of an investment would be adversely affected. Currency exchange rates can fluctuate in response to, among other things, changes in interest rates, intervention (or failure to intervene) by U.S. or foreign governments, central banks or supranational entities, or by the imposition of currency controls or other political developments in the United States or abroad. Currency Exchange Exposure and Currency Hedging risk: The performance of Accounts that invest in securities that are denominated or quoted in non-U.S. currencies could be significantly affected, either positively or negatively, by fluctuations in the relative currency exchange rates and by exchange control regulations. The Firm can seek to offset, in part, the risks associated with such exposure for an Account through foreign exchange transactions. To the extent the Account seeks to hedge its currency exposure, it might not always be practicable to do so. Moreover, hedging will not always alleviate all currency risks. Furthermore, costs are incurred in connection with conversions between various currencies. There can be no guarantee that instruments suitable for hedging currency exchange-rate risks will be available at the time the Firm wishes to use them or will be able to be liquidated when the Firm wishes to do so. In addition, the Firm could choose not to enter into hedging transactions with respect to some or all of an Account’s positions that are exposed to currency exchange risk. Cyber Security risk: With the increased use of technologies such as the internet to conduct business, a portfolio is susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate 41 | P a g e

attacks or unintentional events and are not limited to, gaining unauthorized access to digital systems, and misappropriating assets or sensitive information, corrupting data, or causing operational disruption, including the denial-of-service attacks on websites and ransomware attacks that render systems inoperable until a ransom or other action is taken. New attack methods continue to develop, and attacks may not be detected promptly, which can magnify the risks described herein. Cyber security failures or breaches by a third party service provider and the issuers of securities in which the portfolio invests, have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, and/or additional compliance costs, including the cost to prevent cyber incidents. Depositary Receipts risk: Certain Accounts invest in depositary receipts, such as ADRs, which are certificates evidencing ownership of shares of a foreign issuer that are issued by depositary banks and generally trade on an established market. Depositary receipts are subject to many of the risks associated with investing directly in foreign securities, including, among other things, political, social and economic developments abroad, currency movements and different legal, regulatory and tax environments. Derivatives risk: Certain Accounts use derivatives to pursue their investment objectives. Generally, a derivative is a contract between two parties, whose value is determined with reference to the market price of an asset, such as a currency, commodity or stock, or the value of an index or an economic indicator, such as a stock market index or a specified interest rate (the “underlying interest”). Most derivatives are options, forwards, futures or swaps. An option gives the holder the right, but not the obligation, to buy or sell the underlying interest at an agreed price within a certain time period. A call option gives the holder the right to buy; a put option gives the holder the right to sell. A forward is a commitment to buy or sell the underlying interest for an agreed price on a future date. A future is similar to a forward except that futures are traded on exchanges. A swap is a commitment to exchange one set of payments for another set of payments. Some derivatives are settled by one party’s delivery of the underlying interest to the other party; others are settled by a cash payment representing the value of the contract. The use of derivatives carries several risks:

There is no guarantee that a market will exist for some derivatives, which could prevent the Account from selling or exiting the derivative prior to the maturity of the contract. This risk could restrict the Account’s ability to realize its profits or limit its losses.

It is possible that the other party to the derivative contract (“counterparty”) will fail to perform its obligations under the contract resulting in a loss to an Account.

When entering into a derivative contract, the Account could be required to provide margin or collateral to the counterparty. If the counterparty becomes insolvent, the Account could lose its margin or its collateral or incur expenses to recover it.

Securities and commodities exchanges could set daily trading limits on exchange-traded derivatives, such as options and futures. Such rule changes could prevent the Account from completing a futures or options transaction, causing the Account to realize a loss because it cannot hedge properly or limit a loss.

Where an Account holds a long or short position in a future whose underlying interest is a commodity, the Account will typically seek to close out its position by entering into an offsetting future prior to the first date on which the Account might be required to make or take delivery of the commodity under the future. There is no guarantee the Account will be able to do so. This could result in the Account having to make or take delivery of the commodity.

Some Accounts could use derivatives to reduce certain risks associated with investments in foreign markets, currencies or specific securities. Using derivatives for these purposes is called hedging. Hedging will not always be effective in preventing or mitigating losses. Hedging can also reduce the opportunity for gain if the value of the hedged investment rises, because the derivative could incur an offsetting loss. Hedging can also be costly or difficult to implement.

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Dilution risk: When a strategy is new or is relatively small in size, or has significant cash flows relative to its size, it can be difficult for the portfolio manager to fully invest its assets pursuant to the investment strategy. This could result in the strategy holding a larger than expected proportion of its assets in cash, which could decrease relative performance of any strategy in a rising market. Effect of General Economic Conditions: General economic conditions often affect investments. Changing economic, political, geopolitical, regulatory or market conditions, interest rates, inflation rates, general levels of economic activity, the price of securities and debt instruments and participation by other investors in the financial markets can affect the value and number of investments made by the firm or considered for prospective investment. The imposition of tariffs, trade barriers, and the threat or imposition of retaliatory tariffs by domestic or foreign governments can adversely affect the financial performance of portfolio companies, increase input costs, disrupt supply chains and contribute to broader market volatility. The value of investments often fluctuate in accordance with changes in the financial condition of portfolio companies and other factors that affect the markets in which the firm invests. Economic, political, regulatory or market developments can affect a single obligor, obligors within an industry, economic sector or geographic region, or the market as a whole. Different parts of the market and different types of investments can react differently to these developments. Every investment has some level of market volatility risk. Economic slowdowns or downturns could lead to financial losses in the firm’s investments. In addition, many portfolio companies could be similarly subject to the same economic conditions, which could adversely impact investment returns. Government shutdowns and fiscal policy uncertainty can also adversely affect economic conditions, market confidence, and the operations and valuations of portfolio companies. Emerging Markets risk: Emerging markets have the risks described under foreign currency risk and foreign markets risk. In addition, they are more likely to experience political, economic and social instability and can be subject to corruption or have lower business standards. Instability can result in the expropriation of assets or restrictions on payment of dividends, income or proceeds from the sale of an Account’s securities. In addition, accounting and auditing standards and practices are often less stringent than those of developed countries resulting in limited availability of information relating to an Account’s investments. Further, emerging market securities are often less liquid and custody and settlement mechanisms in emerging market countries are often less developed resulting in delays and the incurring of additional costs to execute trades of securities. The costs of executing transactions in emerging markets can be substantially higher than in more developed markets, and the settlement process more protracted and uncertain. Trade execution risk tends to be materially increased in emerging markets. Equity-Linked Instruments and Related Options risk: Certain Accounts invest in certain financial instruments that are referenced to underlying equities but also incorporate other components — duration, strike price, premiums, etc. — which can result in the Account’s positions being unprofitable even if the Firm correctly assessed the market value of the underlying equity instrument. The Firm can trade in put and call options, which involve qualitatively different risks than owning the underlying common stock. Options trading involves risks substantially similar to those involved in trading futures and forward contracts in that options are speculative and highly leveraged. Equity Securities risk: Certain Accounts invest in equity securities and equity derivatives. The value of these instruments generally will vary with the performance of the issuer and movements in the equity markets. As a result, the Account could suffer losses if it invests in equity instruments of issuers whose performance diverges from the Firm’s expectations or if equity markets generally move in a single direction and the Account has not effectively hedged against such a general move. The Account also could be exposed to risks that issuers will not fulfill contractual obligations, such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering restricted securities for public resale. ESG Strategy risk: The Firm’s proprietary quantitative security selection model incorporates certain environmental, social and governance (“ESG”) factors. Applying ESG criteria to the investment process could limit the number and types of investment opportunities available and as a result, Accounts which have had ESG criteria applied could perform differently compared to similar accounts which have not had ESG criteria applied or there is no or a different focus on ESG investing. Accounts which have had ESG criteria applied to their investment process could forgo opportunities to buy certain securities when it might otherwise be economically advantageous to do so or could sell securities for ESG reasons when it might otherwise be economically disadvantageous to do so. Furthermore, ESG criteria are subject to uncertainty, discretion and subjective application. The determination of the ESG criteria to apply and the assessment of the ESG characteristics of a company or industry by a portfolio management team can differ

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from the criteria or assessment applied by others. As a result, securities selected by a portfolio management team can at times not reflect the values or principles of any particular investor. Exchange-Traded Fund risk: Certain Accounts could invest in exchange-traded funds (“ETFs”) in accordance with their mandates. ETFs represent shares of ownership in either funds or unit investment trusts that hold portfolios of common stocks or bonds, which are designed to generally correspond to the price and yield performance of their underlying indices, either broad stock market, stock industry sector, international stock, or bond. ETF shareholders are subject to risks similar to those of holders of other diversified portfolios. A primary consideration is that the general level of stock or bond prices could decline, thus affecting the value of an equity or fixed income ETF, respectively. Moreover, the overall depth and liquidity of the secondary market could fluctuate. A sector ETF can also be adversely affected by the performance of that specific sector or group of industries on which it is based. Although ETFs are designed to provide investment results that generally correspond to the price and yield performance of their respective underlying indices, ETFs might not be able to exactly replicate the performance of the indices because of their expenses and other factors. Extension risk: Certain Accounts are subject to the risk that, in a rising interest rate environment, fixed income securities with stated interest rates will have the principal paid later than expected. This may negatively affect the Account’s returns, as the value of the security decreases when principal payments are made later than expected. In addition, because principal payments are made later than expected, the Account may be required to invest the proceeds at generally higher interest rates. Fixed Income Investment risk: There are certain general investment risks applicable to fixed income investments in addition to Credit risk and Interest Rate risk (see Credit Risk and Interest Rate Risk). The value of fixed income investments may be affected by developments relating to the issuer as well as by general financial, political and economic conditions (aside from changes in the general level of interest rates), and by conditions in the fixed income markets. If an Account purchases investments that represent an interest in a pool of assets (for example, mortgages in the case of mortgage-backed securities), then changes in the market’s perception of the issuers of these investments (or in the value of the underlying assets) may cause the value of these investments to fall. The ability of an Account to sell a particular fixed income security at its fair value may change from time to time based on prevailing market conditions and perceptions about the issuer or other recent events (such as market disruptions, company takeovers and changes in tax policy or regulatory requirements). This can result in the Account not being able to sell that fixed income security or having to sell it at a reduced price. In addition, to the extent a fixed income security has a predetermined maturity date, there is a risk that an Account may have to reinvest the principal at lower prevailing market interest rates at maturity. There also exists the risk that certain fixed income securities (such as asset-backed securities) may be prepaid unexpectedly prior to maturity (see Prepayment risk). In either event, there is a risk that the reinvested amounts may provide less income and lower potential for capital gains. Foreign Currency risk: Most foreign investments are purchased in currencies other than the U.S. dollar. As a result, the value of those investments will be affected by the value of the U.S. dollar relative to the value of the foreign currency. If the U.S. dollar rises in value relative to the other currency but the value of the investment otherwise remains constant, the value of the investment in U.S. dollars will have fallen. Similarly, if the value of the U.S. dollar has fallen relative to the foreign currency, the value of the Account’s investment will have increased. Some Accounts could use derivatives such as options, futures, forward contracts, swaps and customized types of derivatives to hedge against losses caused by changes in exchange rates. However, the use of derivatives for this purpose might not be effective in preventing or mitigating losses. Foreign Markets risk: The value of an investment in a foreign issuer depends on general global economic factors and specific economic and political factors relating to the country or countries in which the foreign issuer operates. The regulatory environment in some foreign countries is less stringent than in the U.S., including legal and financial reporting requirements. There could be more or less information available with respect to foreign companies. The legal systems of some foreign countries might not adequately protect investor rights. Stock markets in foreign countries often have lower trading volumes and sharper price corrections. Some or all of these factors could make a foreign investment more or less volatile than a Canadian or U.S. investment. 44 | P a g e

Forward Contracts risk: Certain Accounts could trade forward contracts, primarily for purposes of exchange-rate hedging. The imposition of credit controls by governmental authorities could limit such forward trading to less than that which the Firm would otherwise recommend, to the possible detriment of an Account. Accounts trading forward contracts are subject to the risk of the failure of, or the inability or refusal to perform with respect to its forward contracts by, the principals with which the Account trades. Frontier Emerging Markets risk: Certain Accounts will have exposure to the securities of frontier emerging markets issuers. All of the risks associated with investing in emerging markets are even more extreme in frontier emerging markets which are characterized by, among other things, smaller and less diverse economies, less developed capital markets, greater market volatility, lower trading volume, less liquidity, trade barriers, political and economic instability, greater risk of a market shutdown and more governmental limitations on foreign investments, and new or unsettled securities laws even as compared to emerging markets (let alone the more developed markets). Futures risk: Certain Accounts could trade futures for hedging and speculative purposes. Futures are often inherently highly leveraged and can become illiquid due to exchange-imposed price fluctuation limits. Accordingly, a relatively small price movement could result in immediate and substantial losses to the Account to the extent it utilizes futures in its trading strategy. Like other leveraged investments, any trade could result in losses in excess of the amount invested. Government and Corporate Reporting risk: The Firm relies on the information made available by the individual issuers of the financial instruments in which it invests. The Firm has no ability independently to verify the information disseminated by these issuers, and is dependent upon the integrity of both the management of the issuers and the financial reporting process in general. Past and recurring events have demonstrated that material losses in the Account can incur as a result of inaccurate — and sometimes purposefully misleading or fraudulent — information provided by portfolio companies (as well as government agencies). Hedging risk: The Firm can choose, but is not required, to attempt to hedge certain market or other risks inherent in an Account’s positions, and, in cases where it does hedge, could choose to do so only partially. Specifically, the Firm can choose not, or determine that it is economically unattractive, to hedge certain risks — either in respect of particular positions or in respect of an Account’s overall portfolio. An Account’s portfolio composition commonly results in various components of directional market risks remaining unhedged. Even if the Firm is successful in establishing hedging positions, the hedging could reduce an Account’s returns or possibly increase losses and/or cause material losses. Furthermore, it is possible that the Firm’s hedging strategies will not be effective in controlling risk, due to unexpected changes in correlation between the hedging instrument and the position being hedged, increasing rather than reducing both risk and losses. Illiquidity risk: A security is illiquid if it cannot be sold at an amount that at least approximates the amount at which the security is valued. Illiquidity can occur for a number of reasons, including the following: (a) if the securities have sale restrictions; (b) if the securities do not trade through normal market facilities; or (c) if there is a shortage of buyers. In highly volatile markets, such as in periods of sudden interest rate changes or severe market disruptions, securities that were previously liquid could suddenly and unexpectedly become illiquid. Illiquid securities are more difficult to sell and an Account could be forced to accept a discounted price. Some high yield debt securities, which include but are not limited to security types commonly known as high yield bonds, floating rate debt instruments and floating rate loans, as well as some fixed income securities issued by corporations and governments in emerging market economies, can be more illiquid in times of market stress or sharp declines. In addition, the liquidity of individual securities often vary widely over time. Illiquidity in these instruments could take the form of wider bid/ask spreads (i.e., significant differences in the prices at which sellers are willing to sell and buyers are willing to buy that same security). Illiquidity can also take the form of extended periods for trade settlement and delivery of securities. In some circumstances of illiquidity, it could be more difficult to establish a fair market value for particular securities, which could result in losses to an Account that has invested in these securities. Inflation/Deflation risk: The markets in which certain Accounts invest are susceptible to periods of extreme inflation and deflation. Not only can such periods erode the value of an Account’s investments in terms of such investments’ intrinsic value, but such periods can also cause businesses in which an Account is invested to fail despite otherwise sound business models.

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Interest Rate risk: Changes in interest rates (or the expectation of such changes) impact the cost of borrowing for governments, companies and individuals, which in turn impacts overall economic activity. Interest rates could rise during the term of a fixed income investment. If interest rates rise, then the value of that fixed income investment generally will fall. During periods of declining interest rates, because the interest rates on adjustable-rate securities generally reset downward, their market value is generally unlikely to rise to the same extent as the value of comparable fixed-rate securities. In addition, the income received from such securities will likely be adversely affected by a decline in interest rates. Changes in monetary policy may exacerbate the risks associated with changing interest rates. Longerterm bonds and strip bonds are generally more sensitive to changes in interest rates than other kinds of securities. The cash flow from debt instruments with variable rates can change as interest rates fluctuate. Changing interest rates can also indirectly impact the share prices of equity securities. When interest rates are high, it could cost a company more to fund its operations or pay down existing debt. This can impair a company’s profitability and earnings growth potential, which can negatively impact its share price. Conversely, lower interest rates can make financing for a company cheaper, which can potentially increase its earnings growth potential. Interest rates can also impact the demand for goods and services that a company provides by impacting overall economic activity as described above in Effect of General Economic Conditions. Investment Style risk: An Account’s investment strategy could underperform other segments of the equity markets or the markets as a whole. Large Company risk: Accounts that invest in large capitalization companies are subject to the risk that these companies could be unable to respond quickly to new competitive challenges such as changes in technology and consumer tastes. Additionally, larger companies might not be able to obtain the high growth rates of successful smaller companies. Large Transaction risk: For Accounts that are funds, large transactions in the fund’s interests can create risks for investors. A large addition to an Account will create a relatively large cash position in that Account’s portfolio. The presence of this cash position could adversely impact the performance of the Account, and the investment of this cash position could result in significant incremental trading costs, which are borne by all of the investors in the Account. Conversely, a large redemption in an Account will often require the Account to sell portfolio investments so that it can pay the redemption proceeds. This sale could impact the market value of those portfolio investments and result in significant incremental trading costs, which are borne by all of the investors in the Account and it could accelerate or increase the payment of capital gains distributions or capital gains dividends to these investors. Legislation risk: Securities, tax, or other regulators make changes to legislation, rules and administrative practice. Those changes will sometimes have an adverse impact on the value of an Account. Leverage risk: When an Account makes investments in derivatives, borrows cash for investment purposes, or uses physical short sales on equities, fixed income securities or other portfolio assets, leverage will likely be introduced into the Account. Leverage occurs when the Account’s notional exposure to underlying assets is greater than the amount invested. It is an investment technique that can magnify gains and losses. Consequently, any adverse change in the value or level of the underlying asset, rate or index will likely amplify losses compared to those that would have been incurred if the underlying asset had been directly held by the Account and can result in losses greater than the amount invested in the derivative itself. Leverage can increase volatility, impair the Account’s liquidity and cause the Account to liquidate positions at unfavorable times. Leveraged Investments risk: Losses incurred on an Account’s leveraged investments increase in direct proportion to the degree of leverage employed. An Account also incurs interest and other expenses on the borrowings used to leverage its positions. To the extent that the assets of an Account have been leveraged through the borrowing of money, the purchase of securities on margin, or otherwise, the interest expense and other costs and premiums incurred in relation thereto might not be recovered. If gains earned by an Account’s portfolio fail to cover such costs, the net asset value of the Account is likely to decrease faster than if the Account had not engaged in such borrowing transactions. Long/Short risk: There is no guarantee that the returns on an Account’s long or short positions will produce positive returns and the Account could lose money if either or both the Account’s long and short positions produce negative returns.

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Low Latency Trading risk: It is estimated that over 50% of the equity trades executed by securities exchanges are implemented by “low latency” computerized strategies trading in massive volume and high turnover on the basis of technical market factors. Such trading has little, if anything, to do with the qualitative analysis of the prospects for an issuer’s success. Low latency trading typically seeks to identify mispricings, an opportunity an Account might otherwise have sought, but also could be a dominant factor in determining market prices making it difficult for the investment approach to succeed. Market risk: An Account’s holdings can decline in response to adverse issuer, political, regulatory, market or economic developments or conditions that cause a broad market decline or volatility in the financial markets, both U.S. and foreign. Different parts of the market, including different sectors and different types of securities, can react differently to these developments. Global economies and financial markets are becoming increasingly interconnected, which increases the likelihood that conditions in one country or region will adversely affect issuers in another country or region, which in turn could adversely affect securities held by the Account. These circumstances also have decreased liquidity in some markets and could continue to do so. In addition, certain events, such as natural disasters, terrorist attacks, war, epidemics and pandemics, crises or concerns affecting the financial services industry or banking sector, and other geopolitical events, have led, and could in the future lead, to increased short-term market volatility and could have adverse long-term effects on world economies and markets generally. Finally, there are risks associated with being invested in the equity and fixed income markets generally. The market value of an Account will rise and fall based on specific company developments and broader equity or fixed income market conditions. Market value will also vary with changes in the general economic and financial conditions in the countries where the investments are based. Trade tensions and protectionist measures, including the imposition of tariffs, retaliatory tariffs, export controls and other restrictions on international trade, could have material adverse effects on the global economy and on the value of an Account’s investments, including investments in portfolio companies whose operations are directly or indirectly dependent on international trade. In addition, AI, including machine learning technology and generative AI, is rapidly evolving. Technological developments in AI could disrupt the markets in which an Account invests and result in increased competition, legal and regulatory risks and compliance costs. The full extent of current or future risks related to AI is not possible to predict. Mid-Sized Company risk: Certain Accounts can be expected to invest a material portion of capital in issuers that are considered to be “mid cap” by conventional market standards. Small-cap and mid-cap issuers often lack the management experience, financial resources and product diversification of larger companies, making them more susceptible to market pressures and business failure. The small-cap and mid-cap equities markets are, in general, subject to a number of materially greater risks than the larger capitalization equity market. In particular, the securities of smallcap and mid-cap issuers are often more volatile and less liquid than investments in larger issuers, and more likely to be adversely affected by poor economic or market conditions. Among the reasons for such increased risk are: the generally smaller amount of information that is available concerning small-cap and mid-cap issuers or stocks rather than largecap issuers or stocks; the tendency of all small-cap and mid-cap stocks to trade down during periods of market crisis; the greater chance for management misconduct or incompetence to materially adversely affect the prospects for the issuer as a whole; and the comparative illiquidity of the small-cap and mid-cap market, creating the possibility of unusually wide bid-ask spreads and increasing the expected delay before the market value is brought into equilibrium with actual or realizable value. Small- and mid-capitalization issuers are particularly vulnerable to changes in economic conditions, including, for example, interest rates, inflation rates, industry conditions, competition, regulatory environment, technological developments, political and diplomatic events and trends, tax laws and innumerable other factors outside the control of the Firm, that can substantially and adversely affect the business and prospects of the Account. Model risk: Trading models are based on quantitatively-based pricing theories as well as valuation models developed from research and inferences drawn from studies of historical patterns and data. Models employ assumptions that abstract a number of variables from complex financial markets or instruments they attempt to replicate. Any one or all of these assumptions, whether or not supported by past experience, could prove over time to be incorrect. Even if such assumptions are not incorrect, there can be no assurance that the algorithms and software code used by an investment adviser will successfully or optimally translate an investment adviser’s pricing theories and valuation models into successful trading results. Because trading models must be updated regularly as market dynamics shift, a previously highly successful model could become outdated or inaccurate. Trading models can also become less effective if and as other managers begin to employ similar models over time. There can be no assurance that an investment adviser will be successful in developing and maintaining effective quantitative models. The use of any 47 | P a g e

computer program contains an inherent risk that the software and hardware used or relied upon could malfunction, or contain or develop defects. Such defects could include, but are not limited to, design errors, inaccurate data, computer viruses and vulnerability to hacking and unauthorized access. Model Portfolio Implementation risk: There are inherent limitations with implementing investment advice via Model Portfolios. For example, there could be considerable lags between the time when Mackenzie: (i) transacts for portfolios of other similar Accounts and the time when Mackenzie provides related information for Model Portfolios in accordance with applicable procedures; and (ii) provides information for Model Portfolios and the time of implementation of related trades for Model Portfolios when security pricing or market conditions may have changed materially. Further, applicable investment advisers may encounter times when full implementation of Model Portfolio recommendations is not efficient or desirable from a trading or portfolio management perspective. Non-Diversification risk: SEI Institutional Managed Trust – The Large Cap Growth Fund is non-diversified, which means that it may invest in the securities of relatively few issuers. As a result, the Fund may be more susceptible to a single adverse economic or political occurrence affecting one or more of these issuers and may experience increased volatility due to its investments in those securities. However, the Fund intends to satisfy the asset diversification requirements under the Internal Revenue Code, as amended, for classification as a regulated investment company. Portfolio Manager risk: Certain Accounts are dependent on their portfolio manager or sub-adviser to select its investments. Accounts are subject to the risk that poor security selection decisions will cause the Account to underperform relative to its benchmark or other Accounts with similar mandates. Portfolio Turnover risk: Certain Accounts engage in strategies that involve a high degree of portfolio turnover, which could result in significant transaction costs. Although the Firm is mindful of overall transaction costs, the Firm’s trading decisions are based on the output of the Firm’s quantitative trading models and portfolio turnover rate will not be considered a limiting factor when implementing the Firm’s strategies. Preferred Stock risk: Preferred stock represents an equity or ownership interest in an issuer that pays dividends at a specified rate and that has precedence over common stock in the payment of dividends. In the event an issuer is liquidated or declares bankruptcy, the claims of owners of bonds take precedence over the claims of those who own preferred and common stock. Prepayment risk: Certain Accounts are subject to the risk that, in a declining interest rate environment, fixed income securities with stated interest rates will have the principal paid earlier than expected, requiring the Account to invest the proceeds at generally lower interest rates. Quantitative risk: Quantitative models that generate trading signals (“quantitative trading systems”) that rely on historical pricing and market data. The profitability of any trading system involving quantitative analysis depends upon major price moves or trends in at least some of the markets traded. There can be no assurance that the valuation models developed by an investment adviser will accurately identify price dislocations or capture the existence of major price moves. Periods without discernible trends have occurred in the past and, most likely, these periods will continue to occur in the future. A quantitative trading system could underperform other trading methods when macroeconomic factors dominate price moves within a given market. Because quantitative analysis generally does not take into account macroeconomic factors such as supply, demand and political and economic events (except to the extent they influence the data used as input information for the trading program), a quantitative trading method might be unable to respond to macroeconomic causation events until after their impact has ceased to influence the market. Positions dictated by the resulting price movements could be incorrect due to the macroeconomic factors then affecting the market. When macroeconomic factors dominate the markets, strict application of the trading signals generated by the an investment adviser’s trading models can result in substantial losses due to their inability to respond to macroeconomic factors until they have a sufficient effect on the market to create a trend of enough magnitude to generate a reversal of trading signals. By then, a precipitous price change could already be in progress, preventing liquidation at anything but substantial losses. The success of an Account relying on such quantitative trading systems can be substantially dependent on general market conditions over which the Firm has no control. Furthermore, the profit potential of trendfollowing systems could be diminished by the changing character of the markets, which could make the data on which the Firm’s trading models are based only marginally relevant to future market patterns.

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Regulatory and Tax risk: From time to time, certain of the Firm’s and/or an Account’s activities will be subject to regulatory inquiries, investigations and/or enforcement proceedings from U.S. and non-U.S. governmental agencies, regulatory bodies and securities commissions, which can be costly and occupy significant staff time and resources of the Firm. Tax reform and other financial markets regulatory reform both in the U.S. and abroad could impact the Account and securities in which the Account invests. REITs risk: REITs are trusts that invest primarily in commercial real estate or real estate-related loans. An Account’s investments in REITs will be subject to the risks associated with the direct ownership of real estate, including: fluctuations in the value of underlying properties, defaults by borrowers or tenants, changes in interest rates and risks associated with general or local economic conditions. REITs that have limited diversification are also subject to concentration risk. Securities Lending, Repurchase and Reverse Repurchase Transactions risk: Certain Accounts are eligible to enter into securities lending, repurchase and reverse repurchase transactions. In a securities lending transaction, the Account lends its securities through an authorized agent to another party (often called a “counterparty”) in exchange for a fee and a form of acceptable collateral. In a repurchase transaction, the Account sells its securities for cash through an authorized agent while at the same time it assumes an obligation to repurchase the same securities for cash (usually at a lower price) at a later date. In a reverse repurchase transaction, the Account buys securities for cash while at the same time it agrees to resell the same securities for cash (usually at a higher price) at a later date. We have set out below some of the general risks associated with securities lending, repurchase and reverse repurchase transactions:

When entering into securities lending, repurchase and reverse repurchase transactions, the Account is subject to the risk that the counterparty could go bankrupt or default under the agreement and the Account would be forced to make a claim in order to recover its investment.

When recovering its investment on a default, an Account could incur a loss if the value of the securities loaned (in a securities lending transaction) or sold (in a repurchase transaction) has increased in value relative to the value of the collateral held by the Account.

Similarly, an Account would incur a loss if the value of the portfolio securities it has purchased (in a reverse repurchase transaction) decreases below the amount of cash paid by such Account to the counterparty, plus interest.

Series risk: Canadian Sub-Advised Funds or other Accounts that offer more than one series, including series that are sold under different prospectuses create cross-series risk. If one series is unable to pay its expenses or satisfy its liabilities, then the assets of the other series could be used to pay the expenses or satisfy the liability, lowering the investment returns of the other series. Short-Selling risk: Certain Accounts are permitted to engage in a limited amount of short-selling. A short-sale is a transaction in which an Account sells, on the open markets, securities that it has borrowed from a lender for this purpose. At a later date, the Account purchases identical securities on the open market and returns them to the lender. In the interim, the Account must pay compensation to the lender for the loan of the securities and provide collateral to the lender for the loan. Short-selling involves certain risks:

There is no assurance that the borrowed securities will decline in value during the period of the short-sale by more than the compensation paid to the lender, and securities sold-short could instead increase in value.

An Account could experience difficulties in purchasing and returning borrowed securities if a liquid market for the securities does not exist at that time.

A lender can require an Account to return borrowed securities at any time. This could require an Account to purchase such securities on the open market at an inopportune time.

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If a lender from whom an Account has borrowed securities, or the prime broker who is used to facilitate the shortselling, becomes insolvent, the Account could lose the collateral it has deposited with the lender and/or the prime broker.

Small Company risk: Certain Accounts make investments in equities and sometimes fixed income securities issued by smaller-capitalization companies. These investments are generally riskier than investments in larger companies for several reasons. Smaller companies are often relatively new and often do not have an extensive track record. This lack of history makes it difficult for the market to place a proper value on these companies. Some of these companies do not have extensive financial resources and, as a result, they could be unable to react to events in an optimal manner. In addition, securities issued by smaller companies are sometimes less liquid, meaning there is less demand for the securities in the marketplace at a price deemed fair by sellers. Structural risk: As a passive investor, the Accounts will be dependent on the quality of the management of its underlying investments. In the case of many of the portfolio companies in which the Account invests, the Firm would not itself have the expertise or the resources to manage the companies. There have been a number of well-publicized instances in which management has materially, if not fraudulently, mismanaged companies which otherwise appeared to have superior business models. Structured Products risk: Certain Accounts could acquire or otherwise participate in a variety of different structured investment products; for example, swaps, participating notes and options. In certain cases, structured investment products are the most efficient means of obtaining exposure to issuers, including emerging market issuers. These structured products involve not only the risks of the underlying “reference asset,” but also the risks (including acceleration of the financing embedded in the structure and/or restrictions imposed on the management and nature of the permissible reference assets) and costs of creating the structured products. Structured products are also subject to the credit risk of the counterparties. Uncertainty risk: Political, social and economic uncertainty creates and exacerbates risks and could impact our investment strategies, processes and methods of analysis. Social, political, economic and other conditions and events (such as threatened or actual imposition of tariffs, trade disputes or other changes in trade relationships and trade agreements, natural disasters, war, epidemics and pandemics, terrorism, conflicts and civil or social unrest) will occur that create uncertainty and have significant impacts on issuers, industries, governments and other systems, including the financial markets, to which Client investments are exposed. Supply chain disruptions arising from geopolitical events, trade restrictions, natural disasters or other causes can compound these impacts. For example, armed conflict involving the United States, Israel and Iran, as well as other regional states, has led to significant volatility and uncertainty in energy prices. Markets experiencing these and other conditions and events can have substantial, and in some periods extremely high, rates of inflation for many years. Inflation and rapid fluctuations in inflation rates can have negative effects on economies and securities markets. As global systems, economies and financial markets are increasingly interconnected, events that once had only local impact are now more likely to have regional or even global effects. Events that occur in one country, region or financial market will, more frequently, adversely impact issuers in other countries, regions or markets, including in established markets such as the United States. These impacts can be exacerbated by failures of governments and societies to adequately respond to an emerging event or threat. For example, the COVID-19 pandemic led to disruptions in local, regional, national and global markets and economies. It can be difficult to predict the scope of an outbreak; how long any such outbreak, market disruption or uncertainties will last; the effect any governmental actions will have; or the full potential impact on us, the issuers in which we invest and our Clients. Similarly, geopolitical tensions can result in new or enhanced risks. For example, the ongoing Russia-Ukraine conflict has resulted in significant sanctions imposed by the United States and other Western countries, including significant restrictions on access by Russia to certain financial systems. Such sanctions and related actions could significantly inhibit our ability to invest on behalf of a Client in securities of issuers in Russia. In addition, in response to the armed conflict between Israel and Hamas, the United States has imposed sanctions and other measures against Hamas-related persons and organizations, and the United States and/or other countries may announce further sanctions related to the ongoing conflict in the future. These conflicts and related sanctions also have had, and likely will continue to have, significant macroeconomic impacts and can create additional risks, even for Clients who are not directly exposed to securities tied to the region. 50 | P a g e

Although it is impossible to predict the precise nature, severity, duration and consequences of these (or similar) events, or of any political or policy decisions and regulatory changes occasioned by emerging events or uncertainty on applicable laws or regulations that impact us, our Clients and their investments, it is clear that these types of events do (and will, for at least some time, continue to) have an impact that in many instances is adverse and profound. There can be no assurance that such emerging events will not cause a Client to suffer a loss of any or all of its investments or interest thereon. A Client would also be negatively affected if our operations and effectiveness or those of our affiliates or an issuer (or any of the key personnel or service providers of Mackenzie, its affiliates or the issuers in which we invest) is compromised or if necessary or beneficial systems and processes are disrupted. Warrants risk: Certain Accounts can invest in warrants, which are instruments that entitle the holder to buy an equity security at a specific price for a specific period of time. Warrants are typically more speculative than other types of investments. The price of a warrant can be more volatile than the price of its underlying security, and a warrant can offer greater potential for capital appreciation as well as capital loss. A warrant ceases to have value if it is not exercised prior to its expiration date. As a result, each of the risks discussed in Item 8 of this Brochure is subject to, and should be considered in light of, the foregoing risks and uncertainties. Methods of Analysis Mackenzie primarily advises Accounts by implementing quantitative analysis in which a proprietary model (the “Model”) is used to manage portfolios. The Model currently operates using a number of different investment factors, the composition of which the Firm can alter from time to time. The Model currently comprises four super-factors: Value, Revisions, Quality and Informed Investor. The “Value” factor attempts to assist with the valuation of a security, relative to its peers, from different perspectives including company cash-flow, dividends, and company earnings. The “Revisions” factor attempts to take account of trends in analyst forecasts for a security. The “Quality” factor focuses on a company’s capital allocation, operating efficiency and the use of accounting by management. The “Informed Investor” factor attempts to take account of investor activity, including the short interest in a security. Other techniques Mackenzie can use in advising Accounts include:

Temporary investment in short-term market instruments: In certain Accounts, although the composition of the managed portfolios will not be governed by consideration of income, there can be times when, in Mackenzie’s or its affiliate’s judgment (as applicable), security price levels or adverse business prospects indicate that preservation of capital can be best achieved by temporary investments in short-term market instruments.

Short sale transactions: Certain Accounts can engage in “short sale” transactions and use margin in connection with such transactions. Short sales, which anticipate the decline in the value of a security, would normally be made when it is believed that intrinsic values of the specific security are significantly exceeded by current market prices or as a hedge against an investment position. A short sale is effected by selling a security which the Account does not own, or, if it does own the security, is not to be delivered upon consummation of the sale. Short sales can be made “against the box” ( i.e., selling short a stock owned by the Account for hedging purposes) or can be “naked,” that is, sales of securities which the Account does not own. Selling securities short runs the risk of having to repurchase the security at a higher price than the sale price and thus losing an amount greater than the initial investment in a relatively short period of time.

Borrowed money: Certain Accounts also borrow in order to enhance investment leverage, and there could be few if any restrictions on borrowing capacity other than limitations imposed by lenders and any applicable credit regulations. Loans generally can be obtained from securities brokers and dealers or from other financial institutions; and such loans would be secured by securities or other assets of the Account pledged to such institutions.

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While the use of borrowed funds to purchase securities can substantially improve the return on invested capital if the securities purchased increase in value, their use can also substantially increase losses if the securities purchased decrease in value.

Investing in mutual funds and/or ETFs: In certain cases, an Account will purchase the securities of mutual funds and/or ETFs as a means of following the techniques, strategies and instruments used in its portfolio.

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In addition, Mackenzie is currently employed by affiliates to provide investment advisory and sub-advisory services to certain Private Funds, Separately Managed Accounts and Canadian Sub-Advised Funds. Certain of the Accounts we sub-advise are advised by an affiliated adviser. The Firm currently provides certain referral, marketing and client intake services to Mackenzie Financial Corporation and MIEL. The relevant affiliate compensates the Firm for these services and/or any referrals. Clients do not pay such fees directly to Mackenzie, nor are the fees paid by a client impacted by these arrangements. Material Conflicts of Interest Involving Related Parties To avoid a conflict of interest with respect to investment in securities issued by a related party named above, the Firm and its affiliates have adopted policies and procedures relating to investment in securities of related companies (“Related Issuers”). These policies seek to manage and, to the extent possible, avoid a conflict of interest with respect to investment in Related Issuers by requiring that a purchase, sale, or holding of such securities, among other requirements, must: (i) be made free from any influence by a related company; (ii) represent the business judgment of the portfolio manager uninfluenced by considerations other than the best interest of the Account; and (iii) be reasonably expected to achieve a fair result for the Account.

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invest in the same securities that Mackenzie, an affiliate, or a related person recommends to clients.

Mackenzie and its affiliates or related persons are not obligated to recommend, buy or sell, or to refrain from recommending, buying or selling any security that Mackenzie, its affiliates or their respective supervised and access persons can buy or sell for its or their own account or for any other managed Account. Such persons are also not obligated to refrain from investing in securities held in the managed Accounts, except to the extent that such investments violate policies and procedures applicable to or adopted by Mackenzie (including the Code, described below) or by such affiliates. Additionally, Mackenzie (or its affiliates) personnel can invest in the U.S. Sub-Advised Funds, Canadian Sub-Advised Funds, Cayman Private Funds and certain other pooled investment vehicles managed by Mackenzie which, in turn, can invest in securities held in other discretionary Accounts managed by Mackenzie. From time to time, officers and employees of Mackenzie or its affiliates can have interests in securities held by or recommended to Clients. Mackenzie has and its affiliates have implemented policies and procedures reasonably designed to address conflicts of interest relating to personal securities transactions and insider trading that are designed to identify and prevent or mitigate conflicts of interest. These policies and procedures, including the Code, are intended to avoid conflicts of interest with Clients and to resolve such conflicts appropriately, if they do occur. Any Covered Person who fails to observe the Code and other relevant compliance policies risks serious sanctions, including dismissal and personal liability. Code of Ethics (“Code”) A basic tenet of the Code is that Covered Persons must adhere to the highest principles of conduct in the discharge of their duties with respect to managed Accounts. Mackenzie values its adherence to the highest standards of integrity and ethical business conduct in ensuring the fair treatment of Clients. As such, the Code requires Covered Persons to comply with stated standards of business conduct, including compliance with Mackenzie’s policies and procedures, relevant fiduciary duties owed by an investment adviser to its Clients and applicable legal standards. Employees are expected to avoid situations in which their personal interests conflict with their professional duties and to disclose any such conflicts to Mackenzie Investment’s legal department. Covered Persons are also expected to report to the compliance department any violations of the Code which come to their attention. The Code sets forth Covered Persons’ obligations when dealing in covered securities for their own accounts, as well as various requirements designed to ensure that personal trading activity is reported to relevant personnel within Mackenzie Investments.

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Mackenzie has adopted policies and procedures relating to personal securities transactions, insider trading (discussed below) and other ethical considerations to address conflicts of interest associated with personal trading. These policies and procedures are intended to identify and manage actual conflicts of interest with Clients. The Personal Trading Policy, which is included in the Code, contains provisions regarding Covered Persons’ personal trading and reporting requirements that are designed to address conflicts of interest. The Personal Trading Policy requires Covered Persons to submit initial and periodic reports regarding transactions in holdings in certain securities and obtain pre-clearance authorization from the compliance department for trades involving certain types of securities. The Personal Trading Policy also addresses conflicts of interest by, for example, prohibiting, for a period of time, Covered Persons from engaging in trades involving a security of the same issuer where a Client account also seeks to transact or has transacted in the same security. Mackenzie’s policies and the Code also include ethical restraints relating to Clients and their Accounts, including restrictions on gifts and provisions intended to prevent violations of laws prohibiting insider trading. Clients and prospective clients can obtain a copy of the Code by contacting the Firm, in writing, at Two International Place, Suite 2320, Boston, Massachusetts 02110. Each of our relevant affiliates is subject to the Code, or maintains a similar Codes of Ethics which is available to clients and prospects as set forth in the relevant affiliate’s Form ADV, Part 2A. Insider Trading Policies Mackenzie, its affiliates and its related persons could, from time to time, come into possession of material nonpublic and other confidential information which, if disclosed, might affect an investor’s decision to buy or sell a security (“Inside Information”). Inside Information could relate to, among other things, Mackenzie, its affiliates, Accounts which offer publicly traded securities, or other issuers. Under applicable law, Mackenzie, its affiliates and their related persons are prohibited from improperly disclosing or using Inside Information for their personal benefit or for the benefit of any other person, regardless of whether that person is a Client. Accordingly, should such persons come into possession of Inside Information with respect to any issuer, they will be prohibited from communicating such information to, or using such information for the benefit of, their clients when following policies and procedures designed to comply with applicable law. Mackenzie (and its affiliates) has also adopted policies and procedures to prevent the misuse of Inside Information by officers, directors and employees, which are designed to comply with applicable law including, but not limited to, Section 204A of the Advisers Act. These policies and procedures include, among other things, blackout periods and restricted lists that prohibit the trading of a company until the company is removed from the restricted list. As a result of a company being placed on the restricted list, an Account (or the personal accounts of a Covered Person) is precluded or restricted with respect to purchases or sales of that security. Other Conflicts of Interest Inconsistent Investment Positions and Timing of Competing Transactions From time to time, Mackenzie (or, where applicable, an affiliate) could take an investment position or action for one or more Accounts that is different from, or inconsistent with, an action or position taken for one or more other Accounts having similar or differing investment objectives and such actions could be taken at differing, and potentially inopportune, times. When a position is established or disposed of for one Account ahead of, or contemporaneously with, similar portfolio decisions or strategies for another Account, market impact, liquidity constraints, or other factors could result in one or more Accounts receiving less favorable trading results, the costs of implementing such portfolio decisions or strategies could be increased, such Accounts could be diluted, the values, prices or investment strategies of another Account could be impaired or such Accounts could otherwise be disadvantaged. Conflicts can also arise in cases where Accounts invest in different parts of an issuer’s capital structure, including circumstances in which one or more Accounts own private securities or obligations of an issuer and other Accounts own public securities of the same issuer.

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This can result in circumstances where Mackenzie will pursue or enforce rights of certain Accounts with respect to an issuer in which other Accounts have invested, even though this could have an adverse effect on the price, availability, liquidity, and terms of the second Account’s investment and vice versa, and transactions for such Accounts could as a result be effected at less favorable prices or terms or otherwise impaired. To mitigate such conflicts, Mackenzie or its affiliate could refrain from participating or could exercise the rights for Accounts that have the right to participate to the fullest extent of each Account’s interest and right to do so, even though doing so might disadvantage other Accounts. Side-by-Side Management and Differential Interests As discussed above, the nature and amount of compensation paid to Mackenzie or its affiliates by certain Accounts (including, particularly, Separately Managed Accounts and Private Funds), some of which can be managed to investment strategies that involve investing in similar, competing or conflicting investments, can differ from the compensation paid by such Accounts (including, particularly, the U.S. Sub-Advised Funds and the Canadian SubAdvised Funds). Additionally, Mackenzie, its affiliates, and its personnel can have differing investment or pecuniary interests in different Accounts and personnel could similarly have differing compensatory interests with respect to different Accounts. A conflict of interest exists when: (1) the actions taken on behalf of one Account could impact other similar or different Accounts (e.g., because such Accounts have the same or similar investment strategies or otherwise compete for investment opportunities, have potentially conflicting investment strategies or investments, or have differing ability to engage in short sales and economically similar transactions) and (2) Mackenzie, its affiliates and its personnel have differential interests in such Accounts (i.e., expose Mackenzie or its related persons to differing potential for gain or loss through differential ownership interests or compensation structures), to the extent that Mackenzie or its affiliates could have an incentive to favor certain Accounts over others that could be less lucrative. Such conflicts can present particular concern when, for example, Mackenzie or an affiliate places, or allocates the results of, securities transactions that Mackenzie or such affiliate believes would more likely result in favorable performance, engages in cross trades or executes potentially conflicting or competing investments. To mitigate these conflicts, our policies and procedures have been reasonably designed to require that investment decisions are made in accordance with the fiduciary duties owed to such Accounts and without consideration of pecuniary, investment or other financial interests.

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appropriate steps to mitigate excessive market impact, (4) maintain confidentiality of client and proprietary information related to trading decisions, and (5) review the results of executions on a periodic basis. On a periodic basis, Mackenzie or an affiliate reviews Mackenzie’s trading practices and results including the quality of executions received, and commissions paid, by discretionary accounts. Among the items considered in this review are: a broker-dealer’s trading history, administrative quality and responsiveness; examinations of failed trades and a broker-dealer’s response thereto; conflicts of interest; commission rates and execution costs. The goal, when evaluating its efforts to seek best execution is to exercise reasonable, good faith judgment to select broker-dealers that will consistently provide quality execution. The following summarizes the policies with respect to its exercise of investment and brokerage discretion on behalf of its Accounts. Selection Criteria for Trade Execution Mackenzie places all orders for the purchase or sale of securities with the primary objective of maximizing the overall value to the Account at the time and under the circumstances. In doing so, the portfolio managers and traders seek to obtain best execution from responsible broker-dealers at competitive commission rates (or equivalents). Mackenzie insists on a high standard of quality regarding execution services and deals only with broker-dealers that we believe meet this standard. Commissions paid by Mackenzie are reviewed on a regular basis. As discussed below, Mackenzie also places value on broker-dealers who are able to provide useful research and brokerage assistance and Mackenzie can consider whether it maintains a soft dollar arrangement with the broker-dealer. The objective in effecting portfolio transactions is to seek to obtain the best combination of price and execution. The best net price, giving effect to brokerage commissions, spreads and other costs, is normally an important factor in execution decisions, but a number of other, judgmental factors are also considered as they are deemed relevant. In applying these factors, Mackenzie recognizes that different broker-dealers have differing execution capabilities with respect to different types of securities and transactions. The factors that can be considered include, but are not limited to:

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knowledge of negotiated commission rates and spreads currently available and the competitiveness and reasonableness of rates offered; the nature of the security being traded; the size and type of transaction; the nature and character of the markets for the security to be purchased or sold; the desired timing of the trade and the broker-dealer’s ability to meet the required or requested speed of execution; the activity existing and expected in the market for the particular security;

the broker-dealer’s access to primary markets and quotation sources; the broker-dealer’s ability to execute orders with minimal market impact; the ability of the broker-dealer to locate sources of liquidity and to effect transactions when a large block of securities is involved or where liquidity is limited; confidentiality; the execution, clearance and settlement capabilities and history as well as the reputation and perceived soundness of considered broker-dealers; knowledge of actual or apparent operational problems of any broker-dealer; the broker-dealer’s execution services rendered on a continuing basis and in other transactions; the broker-dealer’s reliability in executing trades, keeping records and accounting for and correcting trade errors and failed trades or settlements to Mackenzie’s satisfaction; the broker-dealer’s ability to accommodate Mackenzie’s needs with respect to one or more trades – including its ability and willingness to maintain quality execution in unusual or volatile market conditions; the broker-dealer’s block trading and arbitrage capabilities; and the broker-dealer’s access to other markets.

When buying or selling securities in dealer markets, Mackenzie can, subject to its duty to seek best execution, deal directly with market makers either on a commission basis or on a “net” basis, without paying the market maker any commission, commission equivalent or mark-up/mark-down, other than the spread. Net trades mean that the market maker profits from the spread (i.e., the difference between the price paid or received by Mackenzie and the price received or paid by the market maker in trades with other broker-dealers or customers). In appropriate circumstances, Mackenzie can also use an electronic communication network (“ECN”) or alternative trading system (“ATS”) to effect over-the-counter trades when, in its judgment, the use of an ECN or ATS could result in equally or more favorable overall execution quality for the transaction. Mackenzie can trade in this manner when it believes that any commissions paid to the ECN or ATS, when added to the price and considering all relevant circumstances, still results in equal or better qualitative execution than might have otherwise been obtained trading “net” with a market maker. In circumstances where one or more Accounts seek to dispose of securities which would be appropriate or desirable for one or more other Accounts, Mackenzie can utilize “cross-trading,” if consistent with applicable law. When crosstrading, Mackenzie can, in some cases, as a result of applicable legal or contractual requirements or market conventions, be required to execute through a brokerage firm and/or exchange or registered dealer, consistent with applicable law. When executing a cross-trade, the traded securities will be valued at a market price that is fair to each participating Account. This generally involves obtaining market information from at least one market source prior to execution. Cross-trades involving certain Accounts, including Accounts subject to the Employee Retirement Income Security Act of 1974, the U.S. Sub-Advised Funds, the UCITS Sub-Advised Funds and Canadian Sub-Advised Funds, are subject to additional restrictions. In some cases, Mackenzie will engage in a transaction not involving a public market or for which only a single avenue for execution is available (e.g., where securities can be purchased or redeemed only through the issuer or the issuer’s specified agent). Similarly, certain of the markets in which Mackenzie trades on behalf of Accounts are “emerging markets” where there is limited or no choice of brokers, where commission rates (or commission equivalents) are “fixed” or heavily regulated or where there is not the same level of transparency as to execution costs and quality as is the case in more developed markets such as the U.S., Canada or European Union countries. In those cases, Mackenzie could be limited in its ability to negotiate costs or terms but will seek, as practicable and consistent with relevant market regulations and conventions, to obtain the most favorable terms reasonably available under the circumstances and to minimize costs, consistent with achieving the desired investment objective and seeking an acceptable quality of execution. Where there is a lack of choice or transparency as to execution related costs and expenses, Mackenzie will typically focus primarily on securities prices and certainty of execution in determining how to execute a trade and in examining its efforts to seek best execution in the relevant market.

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Commission Rates or Equivalents Policy Mackenzie endeavors to remain aware of current charges of eligible broker-dealers and to minimize the expense incurred for effecting portfolio transactions to the extent consistent with the interests and policies of its Clients. As noted above, Mackenzie or its affiliate periodically review the quality of executions received from its brokers and considers, where appropriate, the services of other brokers (or other execution venues) that are available to execute Client transactions, when evaluating its efforts to seek best execution. Any broker (or execution venue) that has provided (or could be expected to provide) acceptable performance and whose financial condition and commission rates are acceptable can be selected to execute Account transactions. Where Mackenzie or an affiliate believes that, over time, a particular broker-dealer has consistently and materially engaged in activity that is not in the best interest of Clients, Mackenzie or an affiliate can determine to restrict or prohibit future execution of transactions through that broker-dealer. Mackenzie or an affiliate will set ranges for commission rates and negotiate with broker-dealers, when appropriate. However, broker-dealers will not be selected solely on the basis of “posted” commission schedules nor will Mackenzie always seek in advance competitive bidding for the most favorable rate applicable to a particular transaction. Although Mackenzie generally seeks competitive commission rates, Clients will not necessarily pay the lowest commission or commission equivalent. Mackenzie believes that paying fair and reasonable commissions to broker-dealers in return for quality services benefits Clients. Moreover, transactions that involve specialized services on the part of the broker-dealer will usually result in higher commissions or other compensation to the broker-dealer than would be the case absent such services for more routine transactions. Mackenzie utilizes several different broker-dealers and favors those whose execution abilities or other legitimate and appropriate services are particularly helpful in seeking favorable investment results for Clients. As part of this determination, Mackenzie recognizes that some brokerage firms are better at executing some types of orders than others. Thus, it can be in the best interest of Clients to utilize a broker whose commission rates are not the lowest but whose abilities result in lower overall transaction costs or more favorable results. The overriding consideration in routing orders for execution is to seek to maximize Client profits (or minimize losses) through a combination of controlling transaction and securities costs and seeking the most effective uses of brokers’ capabilities.

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Thus, in our view, the reasonableness of commissions is based on market conditions and the opinion of the broker’s ability to provide professional services, competitive commission rates and other permissible services which will help in providing investment advisory services to Clients. Recognizing the value of these factors, Mackenzie can pay to a broker who provides such services a commission in excess of that which another broker, which offers no additional services and minimal transaction assistance (i.e., “execution-only” service), might have charged for effecting the same transaction. Mackenzie or an affiliate regularly evaluate the placement of brokerage and the reasonableness of commissions paid. In the same vein, Mackenzie or an affiliate make a good faith determination that the amount of commission paid is reasonable in relation to the value of the services rendered, and relative to market norms when viewed in terms of either a specific transaction or the overall responsibilities to its Clients. However, the extent to which commission rates or net prices charged by brokers reflects the value of these services often cannot be readily determined. “Soft Dollar” Benefits In allocating brokerage, and consistent with Mackenzie’s policies and procedures, Mackenzie takes into account the value of eligible brokerage and research products and services (each a “soft dollar item”) provided by applicable broker-dealers, as long as such consideration does not jeopardize the objective of seeking best execution. Certain broker-dealers provide a bundle of services, including research and execution of transactions. When appropriate under its discretionary authority and consistent with its duty to seek best execution, Mackenzie can direct brokerage transactions for Client Accounts to broker-dealers who provide Mackenzie with useful soft dollar items. The brokerage commissions used to acquire soft dollar items in these arrangements are commonly referred to as “soft dollars”. Soft dollar items are either proprietary (created and provided by the broker-dealer, including tangible research products as well as access to analysts and traders) or third-party (created by a third party but provided by the brokerdealer) and include:

advice relating to the value of a security or the advisability of effecting a transaction in a security;

an analysis, or report, concerning a security, portfolio strategy, issuer, industry or an economic or political factor or trend; or

a database, or software, to the extent that it supports research goods or services.

Consistent with applicable law, Mackenzie can use soft dollars to acquire proprietary or third-party research, and execution products or services; however, Mackenzie will not enter into any agreement or understanding with a broker-dealer that would obligate it to direct a specific amount of brokerage business to that broker-dealer in return for a soft dollar item. Nonetheless, certain broker-dealers could state in advance the amount of brokerage commissions they require for certain soft dollar items and the applicable cash equivalent. Mackenzie can use soft dollars to acquire soft dollar items that are also available for cash, where appropriate and permissible by law. When Mackenzie uses client brokerage commissions (or, where consistent with applicable law and regulatory interpretations, markups or markdowns) to obtain soft dollar benefits, Mackenzie receives a benefit because, except as noted otherwise, Mackenzie generally does not have to produce or pay for the benefits. This creates an incentive for Mackenzie to select or recommend a broker-dealer based on the interest in receiving the soft dollar benefits, rather than on the Client’s interest in receiving the most favorable execution.

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Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended, provides a “safe harbor” which allows an investment adviser to pay for eligible soft dollar items with commission dollars generated by client securities transactions. When an adviser pays more than the lowest available commission in recognition of the receipt of soft dollar items, the adviser is said to be “paying up.” Under SEC interpretations, soft dollars are permitted to be used for, among other things, eligible soft dollar items that assist Mackenzie in meeting its Clients’ investment objectives and Mackenzie’s relevant responsibilities to its Client Accounts. The receipt of soft dollar items in exchange for soft dollars benefits an adviser by, among other things, allowing the adviser, at no cost to it, to supplement its own research, analysis and execution facilities. It also allows the adviser to receive the views and information of individuals and research staffs at other securities firms and those of issuer personnel and to gain access to persons having special expertise on certain companies, industries, economic areas and market factors, relieving Mackenzie of expenses that it might otherwise bear in obtaining the same or comparable products or services on its own. Procedures Mackenzie uses to Direct Client Transactions to a Broker-Dealer in Return for Soft Dollars Consistent with U.S. regulatory requirements and interpretations, Mackenzie generally uses soft dollars generated with respect to trades consistently with the safe harbor described above. As such, in determining whether to pay up for a relevant execution, Mackenzie evaluates whether the soft dollar item(s) provided by the broker-dealer:

(i) consist of advice, analyses or reports containing substantive content with respect to appropriate subject matters, as set forth in section 28(e) and related SEC interpretations thereof, or (ii) are sufficiently related to the effectuation, clearance or settlement of a transaction and are provided and/or used during the time period commencing when Mackenzie communicates with the relevant brokerdealer for the purpose of transmitting an order for execution and concluding when the funds or securities are delivered or credited to the Account or the accountholder’s agent;

provide lawful and appropriate assistance in carrying out its relevant responsibilities to Client Accounts; and

are acquired for an amount of soft dollars that is reasonable in relation to the value of the soft dollar item(s) provided.

These determinations are based primarily on the professional opinions of the persons responsible for the placement and review of such transactions. These opinions are formed on the basis of, among other things, the experience of these individuals in the securities industry and information available to them concerning the level of commissions paid by other investors of comparable size and type. In selecting broker-dealers, Mackenzie considers the brokerdealer’s ability to provide quality execution and its belief that the research, information and other soft dollar items provided by such broker-dealers will benefit Clients. It is often not possible to place, with precision, a dollar value on the quality executions or on the soft dollar items received from broker-dealers effecting transactions in portfolio securities. Mackenzie can also use soft dollars to pay for a portion of certain “mixed use” items (i.e., items which provide both eligible and non-eligible benefits or encompass multiple functionalities some of which are not eligible for the safe harbor). Although the allocation between soft dollars and cash is not always capable of precise calculation, a good faith effort is made to allocate payment for such items appropriately by paying cash for that portion of the cost of the soft dollar item which is attributable to a use or functionality which is not, itself, eligible under the safe harbor. Records of such allocations and payments are maintained. With respect to certain non-U.S. Clients where discretionary authority is exercised by an affiliate, the affiliates can, under certain circumstances, use “soft dollars” in conformity with standards established under relevant local law, which can differ from the U.S. standards described above.

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The Receipt of Soft Dollar Benefits can result in Higher Transaction Costs Accordingly, as discussed above, broker-dealers selected by Mackenzie can be paid commissions (or, as applicable, markups or markdowns) for effecting portfolio transactions for Accounts in excess of amounts other broker-dealers might have charged for effecting similar transactions when a determination is made, in good faith, that such amounts are reasonable in relation to the value of the soft dollar items, or superior qualitative executions, provided by those broker-dealers, viewed either in terms of a particular transaction or Mackenzie’s overall duty to its discretionary Clients. How Soft Dollar Benefits Are Distributed Among Client Accounts Soft dollar items, including research, are not always utilized by Mackenzie, in whole or in part, for the specific Account that generated the soft dollars, and Mackenzie does not usually attempt to allocate the relative costs or benefits of research or other soft dollar items among Accounts because it believes that, in the aggregate, the soft dollar items it receives benefit Clients by assisting it in fulfilling its overall duty to its Clients. In the same vein, it should be noted that the value of many soft dollar items including, particularly, proprietary research cannot be measured precisely and commissions paid for such items cannot always be allocated to Clients in direct proportion to the value of the item to each Client. Moreover, brokerage commissions attributable to one or more Client Accounts will sometimes be allocated to brokers who provide soft dollar items (such as statistical data or research) used in managing the Accounts of other Clients, and vice versa. For this reason, it is inevitable (at least in the short term) that commissions paid in one Account will, in effect, subsidize soft dollar items that benefited another Account. Further, Mackenzie has agreed and can further agree, in its discretion, to Client requests that trades for relevant Accounts be executed on an execution-only basis, meaning that such Accounts could benefit from those soft dollar items without bearing the related costs. Therefore, some Accounts may have a higher average commission rate than other Accounts because of the different directions from Clients regarding soft dollar commissions. Additionally, consistent with the section 28(e) safe harbor, Mackenzie is permitted to use soft dollars generated in respect of trades for one type of Account (e.g., equity) to acquire soft dollar items which benefit other types of Accounts (e.g., fixed income). Soft dollars involving certain Accounts, including Accounts subject to the Employee Retirement Income Security Act of 1974, are subject to additional restrictions. Mackenzie does not enter into arrangements with, or make commitments to, any broker-dealer that would bind it to compensate that broker-dealer, directly or indirectly, for Client referrals through the placement of brokerage transactions with that broker-dealer. Of course, Clients can, as discussed below, limit Mackenzie’s discretion by directing that trades be executed through a particular broker-dealer, including one which referred that Client to Mackenzie. Additionally, Mackenzie can exercise its discretion to execute transactions with broker-dealers that also refer Clients, when the use of such broker-dealer is consistent with a duty to seek best execution and following procedures reasonably designed to ensure that such referrals are not a factor in the decision to execute a trade, or a particular amount of trades, through such broker-dealer. Client Directed Brokerage Transactions While Mackenzie generally selects broker-dealers to execute transactions for Client Accounts, it will accept, in limited instances, direction from Clients as to which broker-dealer is to be used. If a Client wishes to direct the use of a particular broker-dealer, Mackenzie asks that the Client also specify, in writing (i) general types of securities for which a designated firm should be used and (ii) whether the designated firm should be used for all transactions, even though it might be able to obtain a more favorable net price and execution from another broker-dealer in particular transactions. In certain instances, Mackenzie has agreed to a list of eligible broker-dealers to be used for a Client, which list may only be amended upon agreement between Mackenzie and the applicable Client. For Model Portfolios, recommended transactions are provided to the specified investment adviser who is responsible for implementing such recommended transactions. In certain circumstances, Mackenzie receives directives from certain Clients to make a “best effort” attempt to transact, all or a portion of that Client’s brokerage through a Client-designated broker-dealer in consideration for services received solely by that Client from the broker. Unless contrary instructions are provided, in writing, by the Client, consideration is still given to seeking best execution of such client-designated transactions. 63 | P a g e

Clients who, in whole or in part, direct Mackenzie to use a particular broker-dealer to execute transactions for their Account should be aware that, in doing so, they are limiting Mackenzie’s ability to, among other things, obtain volume discounts on bunched orders or to obtain best execution by, for example, executing over-the-counter transactions through a market maker. Directing brokerage could cost Clients more money and reduce performance. Transactions for a Client that directs brokerage are generally unable to be combined or “bunched” for execution purposes with orders for the same securities for other Accounts managed by Mackenzie. In these instances, a Client that has directed Mackenzie to use a particular broker-dealer to execute its trades will generally have its trades placed at the end of bunched trading activity for a particular security. Accordingly, directed transactions are often subject to price movements, particularly in volatile markets, that can result in the Client receiving a price that is less favorable than the price obtained by the bunched order. Clients who choose to direct a brokerage to a particular broker or dealer to execute transactions should be aware that, in doing so, they could be subject to higher commissions, greater spreads or less favorable net prices or lower quality execution than might be the case if Mackenzie could negotiate commission rates or spreads freely, or select brokers or dealers based on quality of execution. Consequently, best price and execution might not be achieved. Trade Allocation or “Bunching” Policies Because the size and mandate of Client Accounts often differ, the securities held in such Accounts are unlikely to be identical. Mackenzie’s portfolio managers make investment decisions for managed Accounts based on suitability factors and other circumstances which can differ from Account to Account, resulting in a particular security being acquired, held, or sold for some Accounts and not others. In accordance with the Trade Allocation Policy (the “Policy”), portfolio managers seek to allocate suitable transactions among eligible accounts in a manner believed to be fair and equitable over time. The Policy is intended to promote fairness, to mitigate conflicts of interest, and to conform to applicable regulatory and fiduciary principles. The Policy strictly forbids any allocation request or allocation decision that favors one account over another based on the self-interest of the Account’s portfolio manager or Mackenzie. In appropriate circumstances, any Account managed by Mackenzie could purchase or sell a security prior to other Accounts. This could occur, for example, as a result of the specific investment objectives of an Account, different cash resources arising from contributions or withdrawals or specific, client imposed, restrictions. However, Accounts that are managed in similar styles by the same portfolio manager often have similar or identical portfolio composition and weightings. In other circumstances multiple Accounts could seek to acquire or dispose of the same security for other reasons. Given Mackenzie’s existing quantitative investment process, Mackenzie will typically seek to acquire or dispose of the same securities for multiple Accounts contemporaneously via separate trade orders placed through Mackenzie’s trading desk and in accordance with the Policy. Mackenzie will generally not aggregate or bunch into a single trade order, several contemporaneous Client orders for a single security, although it could determine to do so subject to the terms of applicable law and Client agreements. In the event Mackenzie aggregates trade orders it attempts to do so 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 over time. If a decision is made to aggregate transactions on behalf of more than one Account, such transactions will be allocated to all participating Client Accounts in a fair and equitable manner over time. When such an order is filled in its entirety, each participating Client Account generally participates at the average share price for the aggregated order, and transaction costs are shared pro rata based on each Client’s participation in the aggregated order. When a bunched order is partially filled, Mackenzie will allocate the order in accordance with the Policy, as described below.

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Mackenzie can allocate pro rata when a bunched order cannot be fully executed in a single day, with the portion of the order filled on that particular day generally being allocated among participating Accounts based on the size of each Account’s original order, subject to rounding to achieve “round lots” and Mackenzie’s ability to cancel an order for particular Account(s) if, due to the Account potentially receiving a de minimis amount of securities or otherwise, it believes that, as a result of the incomplete fill, the order is no longer appropriate for the relevant Account(s). Mackenzie can also apply a minimum order allocation amount, which could vary depending upon the market convention associated with the particular security. Where remaining positions are too small to satisfy the minimum allocation amount, Mackenzie can decide to allocate the remaining shares to those Accounts seeking large positions which remain unfilled or to allocate remaining shares to those Accounts whose order would be completed as a result of the allocation. Mackenzie can also allocate on a basis other than pro rata if, under the circumstances, such other method is reasonable, equitable, does not result in improper or undisclosed advantage or disadvantage to a particular Account or group of Accounts and results in fair access, over time, to trading opportunities for all eligible managed Accounts. Methods other than pro rata can be appropriate where Mackenzie identify investment opportunities that are more appropriate for certain Accounts than others. In these cases, Mackenzie could determine to allocate a partial fill to such Accounts. Factors that are considered in making allocation decisions could include, among others: investment objectives and restrictions; whether the security is currently held; relative size and rate of growth; and cash flow changes (including available cash, redemptions, exchanges, capital additions and capital withdrawals). Other allocation methods that are sometimes used by Mackenzie include random and rotational allocation, such as when the transaction size is too limited to be effectively allocated pro rata among all eligible Accounts. Mackenzie generally will not aggregate trades for Clients who have limited Mackenzie’s brokerage discretion with trades for other Accounts. Notwithstanding the foregoing, Mackenzie can seek, when circumstances permit, to include transactions of Clients who have directed the use of a particular broker-dealer in a bunched order, if the executing broker-dealer agrees to give up or step out that portion of the bunched order relating to Clients who have directed the use of a particular broker-dealer to the specified broker-dealer. If the executing broker-dealer does not agree to give up or step out, the order for the same security on behalf of the directing Clients, the order will be effected through the specified broker-dealer and the cost of the transaction could be greater. Mackenzie does not place trade orders for Model Portfolios. Trade orders for Model Portfolios are typically placed by the specified investment adviser after Mackenzie has placed trade orders for other similar Accounts.

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These reviews include consideration and analysis of: current market activity and conditions; individual issuers; portfolio composition and performance of each Account, as well as comparisons across similar Accounts. Client Reports Institutional Clients receive such reports as are agreed upon between the Client and Mackenzie or an affiliate. The nature and frequency of these reports is typically set forth in the relevant investment advisory contract and can vary from Account to Account. Mackenzie or an affiliate also make representatives available to discuss investments in a Client’s Account with that Client on a periodic basis as agreed with the Client. Investors in Cayman Private Funds receive reports as described in the applicable private placement memorandum. Such reports typically include quarterly investment commentary and analysis. Where required by law, Investors in Cayman Private Funds are also provided Form K-1 for tax purposes. To comply with the Custody Rule, Investors in relevant Cayman Private Funds receive audited financial statements, within 120 days following the Cayman Private Fund’s fiscal year end. In some cases, Mackenzie can provide certain information about a Cayman Private Fund to some Investors but not others or provide information to some Investors at a different time than such information is provided to others. With regard to U.S. Sub-Advised Funds, Mackenzie engages in monthly, quarterly, and annual reporting as detailed in the applicable sub-advisory agreement. Quarterly and annual reporting includes conversations with the adviser to the U.S. Sub-Advised Funds and Mackenzie reports to the board of the U.S. Sub-Advised Funds at least once every two years. Clients often also receive custodial statements from their Account’s custodian and transaction reports from executing brokers. For Accounts with respect to which Mackenzie or its affiliate is subject to the Custody Rule, as a result of fee billing arrangements or otherwise (other than the Private Funds), Clients will receive account statements directly from the Custodian, no less frequently than quarterly, in addition to any statements provided by Mackenzie or an affiliate. If the Client receives an account statement from the Custodian, the Client should carefully review such account statement, and Clients are encouraged to contact Mackenzie if they see any discrepancies. Please see Item 15: Custody for more information on our compliance with the Custody Rule. In addition to written reports, Mackenzie or an affiliate often have formal or informal discussions with Clients regarding their Account.

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The services NCP provides to Mackenzie include the promotion and sale of Mackenzie strategies to relevant prospects via introduction, referral or assistance with solicitation and assisting with arranging roadshow or webinar events at the request of Mackenzie. Additionally: (i) Mackenzie has engaged a third-party, unaffiliated placement agent to place interests in the Cayman Private Funds and Collective Investment Trusts; and (ii) representatives of Mackenzie Financial Corporation provide certain marketing and client intake services to Mackenzie. Disclosures from a solicitor or placement agent should be reviewed carefully; they generally contain important information with respect to, among other things, the material terms of the compensation paid, the nature of any relationship or affiliation with Mackenzie, whether the Client or Investor bears any costs with respect to the solicitation and whether the fees paid by such a Client or Investor would differ from fees paid by similarly situated persons who are not so introduced, as a result of the solicitation. Currently, it is not expected that fees charged to those who are introduced by a solicitor or placement agent will, as a result of the introduction, be higher than those charged to persons who were not so introduced. However, as discussed above, fees are negotiable, so some Clients or Investors not introduced by a solicitor or placement agent could, as a result of negotiation, pay fees that are lower than those who are otherwise similarly situated but introduced by a solicitor or placement agent. As discussed above, the Firm currently provides certain marketing and client intake services to Mackenzie Financial Corporation and MIEL and could in the future provide such services to other affiliates. Certain personnel of the Firm are compensated for successful referrals.

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If Mackenzie or an affiliate separately provides reports or account statements, Clients should compare these carefully to the custodian’s account statements. Clients should contact Mackenzie immediately if there appears to be any discrepancy between the custodian’s statements and Mackenzie’s. Where an affiliate of the Firm serves as trustee of one or more Canadian Sub-Advised Funds, the Firm is deemed to have “custody” in respect of each such Canadian Sub-Advised Fund within the meaning of the Custody Rule. To comply with the Custody Rule, each Investor in such a Canadian Sub-Advised Fund receives audited financial statements in accordance with Canadian law. If you have invested in such a Canadian Sub-Advised Fund and have not received audited financial statements timely, please contact us immediately. In addition, because an affiliate of the Firm serves as general partner of one or more Cayman Private Funds advised by the Firm, the Firm is deemed to have “custody” in respect of each such Cayman Private Fund’s assets under the Custody Rule. Each Investor in such a Cayman Private Fund receives audited financial statements within 120 days following the Cayman Private Fund’s fiscal year end and (when applicable) upon liquidation of such Cayman Private Fund. If you have invested in such a Cayman Private Fund and have not received audited financial statements timely, or have any questions about the Cayman Private Fund’s Financial Statements, please contact us immediately.

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Mackenzie can, however, accept Accounts with limited discretion. Further, as noted above in Item 4, Clients are permitted, and some choose, to impose restrictions on Account investments, including reasonable limits on the types of securities held as well as prohibitions or limitations on particular securities or issuers. In addition, as described in Item 4, Mackenzie can provide Model Portfolio recommendations to other investment advisers.

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Under these policies and procedures, Mackenzie votes proxies relating to portfolio securities in accordance with proxy voting policies and procedures and in the best interests of its Clients, unless the Client has requested, in writing, that alternate procedures (including, but not limited to, a Client’s own proxy voting policies and procedures) be applied. Mackenzie considers the “best interests of its Clients” to be the best economic interests over the long term – that is, the common interest that all Clients, as owners of interest in an issuer, share in seeing the value of their investment increase over time. Mackenzie has engaged Glass, Lewis & Co. (“Glass Lewis”), a third-party proxy advisory firm, to provide proxy voting recommendations. An agreement of general voting guidelines and policies has been established between Mackenzie and Glass Lewis. Such guidelines and policies provide that environmental, social and governance factors be taken into account by Glass Lewis where appropriate. Mackenzie also periodically reviews Glass Lewis’ voting guidelines and processes. Mackenzie has also engaged Glass Lewis’ Viewpoint solution to pre-populate each client’s votes on its electronic voting platform with Glass Lewis’ recommendations and then automatically submits Mackenzie’s clients’ proxy votes. Pre-population and automated voting generally occur prior to the submission deadline for proxies to be voted at the shareholder meetings and Mackenzie relies on Glass Lewis to ensure proxy voting materials that are received close to the submission deadline are incorporated into its voting recommendations and Mackenzie’s clients’ votes. Mackenzie will generally vote in accordance with Glass Lewis’ recommendations. Should a situation arise where Mackenzie believes voting in a manner other than agreed upon in the guidelines, or abstaining from a vote, is in the best interest of its clients, Mackenzie will exercise its discretion to vote or abstain accordingly. Mackenzie does not vote proxies with respect to Model Portfolios – voting for those proxies will be organized by the applicable investment adviser, who should be contacted with questions about a particular solicitation instead of Mackenzie. Conflicts of Interest Circumstances could occur where there is a conflict of interest between an Account and Mackenzie with respect to voting the Client’s securities. Where a Mackenzie portfolio manager believes he or she has a conflict or potential conflict, he or she will notify the applicable Mackenzie Investments CIO, and either the Senior Vice-President, Legal (“SVP, Legal”) or the Chief Compliance Officer (“CCO”). Should that CIO and either the SVP, Legal or the CCO conclude that a material conflict exists, the CCO will document the conflict and inform the Mackenzie Investments Investment Operations Department. The Investment Operations Department will maintain a Proxy Voting Watch List (“Watch List”) that includes the names of issuers that could subject Mackenzie or a portfolio manager to a conflict and will notify the applicable CIO, and either the SVP, Legal or CCO of any meeting circulars and proxies received from an issuer on the Watch List. That CIO and either the SVP, Legal or CCO will discuss the voting matter(s) with the internal portfolio manager and ensure that the proxy voting decision is based on the proxy voting policies and the best interests of the Account. These conflicts could also be mitigated by use of the proxy voting advisor. All voting decisions made in these circumstances are documented and filed by the Investment Operations Department. How to Learn More About the Voting of Proxies Clients can obtain a copy of Mackenzie’s proxy voting policies and procedures and/or information on how their securities were voted by contacting Mackenzie Investments, in writing, at Two International Place, Suite 2320, Boston, Massachusetts 02110. Mackenzie will not disclose proxy votes for a Client to other Clients or third-parties, 70 | P a g e

unless specifically requested, in writing, by the Client or required by law (e.g., U.S. mutual funds). Where Mackenzie serves as a sub-adviser to an Account, Mackenzie will be deemed to be authorized to provide proxy voting records to the Account’s adviser.

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