Jupiter Asset Management Limited: investment adviser

Jupiter is a high conviction active asset manager committed to growth through investment excellence with a focus on delivery of investment outperformance to clients. Central to Jupiter’s philosophy is a culture of independent thought, investment managers are not constrained by a “house view”, which allows them to focus on delivering value to clients through genuinely active investing. Jupiter provides investment management services to a broad range of clients, across four core asset classes: equities; fixed income; alternatives and multi-asset. These asset classes are offered through a range of actively managed investment products including separately managed accounts, mutual funds, and investment trusts. In 2020, Jupiter entered a strategic partnership with NZS Capital LLC (“NZS”), a U.S. based asset management firm registered with the U.S. Securities and Exchange Commission (“SEC”). Jupiter holds a 25% minority stake in NZS. As part of this partnership, Jupiter has been appointed as a distributor of NZS’ strategies in certain jurisdictions. Up to December 31, 2023, Jupiter had exclusive global distribution rights to market NZS strategies in segregated mandate and pooled fund form. Following the wind-down of Jupiter’s on the ground presence in the US, Jupiter and NZS have agreed that from December 31, 2023, Jupiter’s exclusive distribution rights will be limited to Europe, the Middle East and Africa with the additional ability to market the NZS sub-fund of the Jupiter Global Fund SICAV (a Luxembourg UCITS fund) to investors in Latin American, Asia and US Offshore. In 2025, JAM launched the Jupiter GEARx Master Fund Limited, a Cayman-domiciled master fund advised by JAM and managed on a day-to-day basis by the Jupiter Systematic Team, led by Amadeo Alentorn. Two feeder funds invest all of their assets into the master fund: Jupiter GEARx Fund Limited (a corporate feeder for U.S. tax-exempt and non-U.S. investors) and Jupiter GEARx Fund LP (a Cayman limited partnership feeder for U.S. taxable investors). These funds are privately offered and are exempt from registration under the Securities Act of 1933 and the Investment

Company Act of 1940, relying on the exemption from registration under Rule 506(b) of Regulation D of the Securities Act of 1933 and excluded from the definition of investment company under Section 3(c)(7) of the Investment Company Act of 1940. JAM tailors its advisory services to the investment objectives of the Private Fund. In general, for any underlying investors of a Private Fund, the investors may not impose restrictions on investing in certain securities or types of securities. Marketing to certain qualified U.S. investors is conducted under a broker-dealer chaperoning arrangement with ACA Foreside in accordance with SEC Rule 15a-6. Jupiter Asset Management Limited acts entirely in its own name in these marketing activities. U.S. persons may invest in Jupiter strategies (detailed at Item 8) through separately managed accounts, in respect of which they may impose their own investment restrictions on individual securities or types of securities, or through the privately offered Jupiter GEARx LP feeder fund described above. Investors in the GEARx feeder funds may not impose individual investment restrictions. For certain strategies, Jupiter will delegate day-to-day responsibility for portfolio management to its affiliates, as well as third-party investment management firms. Please see Item 10 for further information on Jupiter’s relationship with its affiliates, and Item 8 for detail on Jupiter’s oversight of delegated managers. Model Portfolio Services In addition to its discretionary investment management services, JAM provides non-discretionary Model Portfolio Services to certain clients. Under these arrangements, JAM constructs and maintains model portfolios which are made available to clients or their intermediaries for implementation. JAM does not have discretion to execute trades on behalf of model portfolio recipients; responsibility for trade execution and suitability rests with the client or their appointed intermediary. Model Portfolio Services are not offered to U.S. persons.

Managed Assets As of December 31, 2025, JAM manages approximately USD 68.22 billion in regulatory assets under management on a discretionary basis across 98 client accounts, including separately managed accounts and pooled investment vehicles.

Fee calculations are generally based on the market value of the assets under management in a client account and will usually be billed in arrears on an annual, quarterly, or monthly basis. Fees are due upon receipt of a billing statement and clients may choose whether to have them deducted from assets or make payment separately. Clients will incur brokerage and transaction costs which are described further in Item 12. There may be further fees and expenses applicable to a client account which will depend on the negotiation of each mandate. Management and Performance Fees – Private Funds (GEARx) JAM advises private pooled investment vehicles, including the Jupiter GEARx Master Fund and its feeder funds. These vehicles are subject to a fee structure distinct from that of segregated mandates. Management fees for the GEARx funds range from 0.75% to 2.00%, depending on the share class (Classes F, I, A, and T). In addition, a 20% performance fee is applied to returns exceeding a classspecific hurdle, which is typically the prevailing cash rate in the relevant share class currency (e.g., Effective Federal Funds Rate (USD), ECB Main Refinancing Rate (EUR), Bank of England Base Rate (GBP), etc.).

Fee billing is generally based on the market value of the investor’s capital account and is calculated and billed monthly or quarterly in arrears, as specified in the relevant offering documents. Performance fees are typically crystallised annually or upon redemption, subject to a high-water mark or hurdle as applicable. Fees are due upon issuance of a billing statement, and investors may elect to have fees deducted from fund assets or to settle them separately. Redemption and exchange fees of up to 1% may also apply, as outlined in the fund’s offering documentation.

Other Fees and Expenses The fees and expenses relevant to a client’s separately managed account will vary and depend on the negotiation of each mandate and the circumstances of individual clients. However, Jupiter’s clients may be liable for costs payable under the terms of an advisory agreement, including all reasonable expenses, liabilities, charges and costs related to the mandate including, but not limited to, any brokerage charges (discussed further at Item 12), commissions, custodial fees, banking charges, transfer fees, registration fees, exchange fees, settlement fees, and stamp duty, tax or other fiscal liabilities or any other transaction related expenses and fees arising out of transactions for an account incurred by Jupiter, its delegates or third parties in performing the services under an advisory agreement. Further, clients may incur any costs and expenses associated with compliance by Jupiter with any client instructions to the extent that such instruction would require Jupiter to take any action which is outside the scope of its normal duties and would result in Jupiter incurring material costs and/or spending a significant amount of time in relation thereto. JAM has engaged with Foreside Global Services LLC to provide Broker-Dealer Chaperoning services to JAM at a cost of $40,000 per annum. JAM bears the fees and expenses of this service. The chaperoning arrangement allows JAM to market in the U.S. to U.S Institutional Investors and Major U.S. Institutional Investors without registering as a broker-dealer or as a registered representative. Private Funds (GEARx) – Fund-Level Expenses In addition to management and performance fees, investors in the Jupiter GEARx funds bear a range of fund-level operating expenses, as outlined in the fund’s Offering Memorandum and governing documents. These expenses are borne by the fund and indirectly by its investors and may include, but are not limited to: • Fund administration and accounting fees, including services provided by the administrator and any sub-administrators; • Custody and depositary-lite services; • Legal, regulatory, and compliance costs, including Cayman Islands, Irish, UK, and US legal advice, CIMA registration and maintenance, and regulatory filing fees (e.g., under CFTC Rule 4.13(a)(3));

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Audit and tax reporting costs, including preparation of financial statements and tax information for investors; • Director fees and governance-related expenses, including costs of independent nonexecutive directors of the Fund and/or the General Partner; • Banking and brokerage expenses, including fees charged by prime brokers, trading counterparties, or other agents; • Costs associated with permitted use of SPVs (special purpose vehicles); • Expenses associated with side letters, including any class-specific servicing, reporting, or negotiated rights (e.g., MFN, transparency or liquidity terms); • Redemption and exchange fees, up to 1% as permitted in the fund documentation; • Hold-back amounts of up to 5%, typically paid within 30 days following finalisation of the fund’s audited accounts; • Establishment of side pockets, gating, and in-specie redemptions if permitted and triggered under extraordinary circumstances; • Taxes, duties, levies, and other fiscal charges incurred by the fund. All such expenses are disclosed in the fund’s Offering Memorandum and are subject to change. A summary is available upon request, and investors should consult the fund documentation for full details.

Miscellaneous No supervised persons, including sales staff receive any compensation for the sale of securities or other investment product. Base salaries for sales staff are assessed on an ongoing basis to ensure they are in line with the market rate. Bonuses for sales staff are 100% discretionary, are not formulaic or commission based and are subject to the same controls and oversight as the rest of the company (for example, amounts awarded are dependent on the company’s performance, the division’s performance, and an individual’s own objectives – which include supporting the team and displaying behavior worthy of merit). In addition, sales staff are not rewarded for selling a specific strategy.

Receipt of performance-based compensation creates a potential conflict of interest in providing investment management services to clients that are charged a performance fee, as it could create an incentive to favor such clients over other clients who do not have a performance fee arrangement should Jupiter have such clients. Further, a performance fee can present an additional issue in that it could encourage excessive risk taking to achieve the enhanced fee, to the detriment of clients. To mitigate this conflict, Jupiter recognizes that it is a fiduciary and as such must act in the best interests of all of its clients and must refrain from favoring one client’s interests over another client. This is managed through Jupiter’s implementation of a fair and equitable investment allocation process. Conflicts are managed by the monitoring of portfolio activity and how performance is derived and where investment risks are taken. Additional controls exist to mitigate potential conflicts of interest through internal policies which mandate the monitoring of non-pro-rata of IPO allocations, as well as non-pro-rata of trade allocations. These are supported by the segregation of trading duties whereby investment managers can raise orders, but these are executed by the Trading Desk. Jupiter’s policy is not to permit cross trades on U.S. client accounts.

Jupiter GEARx Fund LP, a Cayman Islands limited partnership offered to U.S. taxable investors who qualify as both accredited investors under Regulation D of the Securities Act of 1933 and qualified purchasers under Section 2(a)(51)(A) of the Investment Company Act of 1940. The fund is offered in reliance on the exemption from Securities Act registration under Rule 506(b) of Regulation D and is excluded from the definition of investment company under Section 3(c)(7) of the Investment Company Act of 1940.

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Jupiter GEARx Fund Limited, a Cayman Islands corporation offered to non-U.S. investors who are institutional or professional investors and to U.S. tax-exempt investors who qualify as both accredited investors and qualified purchasers. The fund is offered in reliance on the exemption from Securities Act registration under Rule 506(b) of Regulation D and is excluded from the definition of investment company under Section 3(c)(7) of the Investment Company Act of 1940.

These pooled investment vehicles are offered on a private placement basis and are intended for sophisticated investors capable of evaluating the risks associated with such investments.

The strategy seeks strong risk-adjusted returns by investing in typically 35-45 high-quality companies that in our view are leading the transition to a more sustainable world through how they behave and the real-world outcome of what they sell. Strategies with low correlation to mainstream equity and credit markets seek to produce attractive risk-adjusted returns across diverse market environments. Strategic Absolute Return Bond Strategy Absolute return objective. Dynamic, macro-driven strategy with the general risk profile of fixed income and positive return when equity, credit and rates markets were negative. Systematic Equity Market Neutral Strategy Market neutral, rules-based, and factor-driven global equity strategy seeks to dynamically harvest proven equity risk premia. Systematic Long Only (Global Equity, North American and Asian Equity) Rules based and factor driven equity portfolios that seek to dynamically harvest equity risk premia. Systematic Absolute Return – GEARx Strategy The Jupiter GEARx strategy is a systematic, absolute return-focused equity strategy that seeks to deliver positive returns over rolling 12-month periods. The strategy is managed by the Jupiter Systematic Team and relies on factor-driven models, proprietary screening algorithms, and disciplined portfolio construction. It targets a maximum annualised volatility of 12% and may use gross leverage up to 500%, though it is typically expected to operate at or below 400%. Internal constraints apply at the sector, country, industry and single stock level. Investments are made globally, with no U.S. IPO exposure, and the strategy may use investment vehicles (SPVs) and derivatives to achieve its investment objective.

Origin The Origin team employs a quantitative screening approach to Global Small Cap, Global Emerging Markets that combines proprietary algorithms and data with qualitative due diligence. Global Emerging Markets The Global Emerging Markets portfolio will have typically 60-150 names with a target tracking error of 4-8%. Global Small Cap The Global Small Cap portfolio will have typically 150-200 names with a target tracking error of 58%. European Equities In 2025, Jupiter appointed a new European Equity team with a long-term track record of investment performance and asset gathering. The team manages concentrated, high-conviction European equity portfolios with a focus on fundamental company analysis and long-term capital growth. Portfolios are actively managed with a benchmark-aware but unconstrained approach to stock selection across European markets.

Methods of Analysis Jupiter believes investment managers are best positioned to provide investors with outperformance when they are empowered with the necessary flexibility to manage their portfolios as they feel is appropriate, while considering current market conditions and acting within the appropriate regulatory framework. Jupiter’s investment philosophy is to seek to generate investment outperformance after fees against relevant benchmarks over the medium to long-term, without exposing its clients to unnecessary risk. Jupiter believes that talented investment managers perform best if they are given the freedom to invest as they deem appropriate, subject to the constraints set by a client’s investment objectives and policy. In February 2026, Jupiter appointed Piers Hillier as Chief Investment Officer, a newly created role. The CIO provides enhanced oversight and connectivity across Jupiter’s investment platform, supporting the development and scaling of investment capabilities, processes and talent, while maintaining the independence of specialist investment teams. Jupiter has continued to invest in technology and data-driven tools to support its investment and operational processes. The Group uses artificial intelligence and automation platforms across operational functions, including research workflows, client reporting, and administrative tasks. These tools are designed to improve efficiency and support decision-making. It is important to note that Artificial Intelligence is not used to generate investment decisions but may be used as a tool in the broader analytical approach deployed.

Jupiter’s Investment Risk team and Performance Reporting team meets with investment managers on a quarterly basis to discuss performance, key exposures, concentrations, and trends including but not limited to Market Risk and Liquidity Risk. Jupiter’s Risk & Compliance Committee operates a second line process, where any concerns can be further escalated if necessary. Jupiter’s Risk and Compliance teams use several tools, software and metrics to support its understanding of portfolio construction and perform in-depth analyses of portfolios on an ex-ante and ex-post basis. These include Aladdin, FactSet, Northfield, ICE, Bloomberg and Style Analytics. Environmental, Social & Governmental Criteria Our investment teams consider material ESG issues identified by their investment processes, which includes the use of our centralized specialist resources, to ensure that we protect and enhance the value of our clients’ investments to deliver risk-adjusted returns in line with mandates. The investment management teams are supported by dedicated Stewardship and ESG Research and Integration teams that assist with asset monitoring, company research, and proxy voting as well as direct and collaborative engagement. The approach to the consideration of material ESG issues differs among Jupiter’s investment teams given the autonomy granted to them under Jupiter’s ‘no house view’ position. We take a pragmatic approach towards the integration of ESG drivers within our investment decisions. ESG factors are complex and can overlap and demonstrate interdependence. Furthermore, good quality data may not be available or may be inherently subjective. We have an experienced ESG Research & Integration team that work alongside our fund managers in order to integrate these drivers into investment decisions. Oversight on ESG is provided by Jupiter’s Investment Oversight Committee. ESG Risk “ESG Investing” is not defined in US Federal Securities Laws, may be subjective, and may be defined in different ways by different managers, advisers, or investors. There is no SEC “rating” or “score” of ESG investments that could be applied across a broad range of companies, and while many different private ratings based on different ESG factors exist, they often differ significantly from each other. Different managers may weigh ESG factors differently. Some ESG managers may consider data from third party providers which could include “scoring” and “rating” data compiled to help managers compare companies. Some of the data used to compile third party ESG scores and ratings may be subjective. Other data may be objective in principle but are not verified or reliable. Third party scores also may consider or weigh ESG criteria differently, meaning that companies can receive widely different scores from different third-party providers. A fund’s mandate in relation to ESG factors may significantly influence performance. Because securities may be included or excluded based on ESG factors rather than traditional fundamental analysis or other investment methodologies, the account’s performance may differ (either higher or lower) from the overall market or comparable accounts that do not employ similar ESG practices. Some mutual funds or ETFs that consider ESG may have different expense

ratios than other funds that do not consider ESG factors. Paying more in expenses will reduce the value of your investment over time. Risk of Loss Capacity Constraints Jupiter’s management fee is calculated against the value of the assets under management, which creates a natural incentive to raise assets in a strategy. However, past a certain point a strategy can meet capacity constraints in terms of additional performance generation because of the size of the funds applied to the strategy. Jupiter manages this conflict by monitoring liquidity risk, capacity, and concentration of investors, which is discussed with investment managers as part of periodic supervisory processes. This allows for early identification of capacity constraints to be managed by investment managers and relevant forums to be notified where necessary. Investment Risks The investment strategies offered by Jupiter, as summarized above, will be subject to normal market fluctuations and other risks inherent in investing in securities. The Group has exposure to Liquidity, Market, Credit/Counterparty and Market risks (the level 1 risk categories). These are, where applicable, further broken down into level 2 subcategories within the Group enterprise risk taxonomy. A brief overview of associated risks of investments in Jupiter’s investment strategies are as follows: Liquidity Risk - The risk that we have insufficient financial resources to meet our obligations as they fall due or can only secure such resources at excessive cost. a) Redemption Risk – The risk that redemptions are not able to be met due to exceptional circumstances relating to broader market conditions or specific asset/liability dynamics within the fund itself. Certain portfolio characteristics may make a portfolio more vulnerable to redemption risk. For example: • Smaller companies typically have lower trading volumes compared with larger capitalization companies. This differential may become more pronounced in more stressed market conditions and may mean (a) higher costs associated with managing redemptions or (b) in extreme cases, Liquidity Management Tools. • Emerging market companies typically have lower trading volumes compared with developed market companies. This differential may become more pronounced in more stressed market conditions and may mean (a) higher costs associated with managing redemptions or (b) in extreme cases, Liquidity Management Tools. • Unlisted Asset Risk – Some portfolios may invest in unlisted assets for alpha generation subject to regulatory and internal limits in place. These cannot easily be sold in public markets and therefore they may have a detrimental impact on portfolio liquidity and their weight may increase in the event of material redemptions. b) Funding Risk – The risk relates to the financial market or company specific obligations.

Market Risk – The risk of loss arising from market movements. This includes the risk that any market risk mitigation techniques prove less effective than expected. a) Currency (FX) Risk – Currency Risk, sometimes referred to as exchange rate risk, is the risk of currency movements negatively affecting the value of assets, investments and their related interest and dividend payment streams, especially those securities denominated in foreign currency. b) Interest Rate Risk – The risk of that the value of a position held will suffer as the result of a change in interest rates. c) Inflation Risk – The risk of adverse movements in breakeven inflation. d) Pricing Risk – The risk of adverse movements in prices. For example, this could refer to: • Equity Price Risk – Portfolio performance will depend on the broader movements of equity markets as well as systematic and idiosyncratic characteristics of the portfolio. • Commodity Price Risk – Portfolios may be sensitive to changes in the prices of commodities which will cause the value of investments to increase or diminish. This may entail direct exposure to the underlying commodity price or exposure to companies whose earnings are sensitive to underlying commodity prices. e) Credit Spread Risk – The risk of adverse movements in credit spreads. f) Market Concentration Risk – The risk of market concentration to a specific sector, geographical region or individual company: • Sector Concentration Risk – Portfolios may be heavily invested in particular sectors with specific risk considerations (as an example, elevated levels of regulatory risk). • Geographic Concentration Risk – Portfolios may be heavily invested in countries with less predictable political regimes or groups of countries where institutions are less developed, and financial markets have less depth (like Emerging Markets). • Single Name Risk – Portfolios may have exposure to a limited number of individual positions, meaning that they have a high level of single name concentration risk and are significantly exposed to idiosyncratic under-performance of positions. g) Basis Risk – The risk of incurring a loss due to offsetting positions in assets with similar risk characteristics but different reference underlying’s. Derivative Risk – Some portfolios may invest in derivatives for efficient portfolio management purposes while others (typically funds that use the VaR approach for global exposure purposes) may use derivatives for investment purposes. Using derivatives introduces the following potential risks: • Counterparty Risk – There is a risk that investors experience a loss as a result of a counterparty defaulting on a payment. This risk is mitigated via collateralization, P&L resets and only entering into contracts with counterparties that are deemed to be creditworthy. • Market Risk – The underlying exposure on the derivative may expose investors to market risk and in particular to any of the Level 2 risks described in the wider Market Risk disclosure.

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Liquidity Risk – Derivatives may expose investors to both Level 2 risks described. Where there is no liquid market to reduce derivative exposure, this may impact the ability of the fund to process redemptions in an orderly manner. In addition, derivatives face funding requirements in the form of margin and collateral.

Credit/ Counterparty Risk – The risk of default on a financial or contractual obligation. a) Counterparty Risk – The risk that the counterparty to a transaction (e.g., derivative) could default before the final settlement of the transaction’s cash flows. b) Credit Risk – The risk of loss being incurred or occurring due to an entity defaulting on its credit obligations. c) Settlement Risk – The risk of loss arising from failed trades. To help mitigate Market, Liquidity, and Credit/ Counterparty risk, Jupiter operates a Quarterly Risk and Performance Review process which involves the Investment Risk team and Performance Reporting team meeting with investment managers to discuss performance, key exposures, concentrations and trends across matters including, but not limited to, Market Risk and Liquidity Risk. Jupiter’s Investment Risk team produces a suite of metrics, including stress tests and scenario analysis, to provide investment managers with the data required to mitigate risks. The Investment Oversight Committee serves as the primary escalation point for any issues identified during the process. Clients are provided account statements on at least a quarterly basis that includes performance, commentary, asset allocation and key portfolio activity, as well as a statement on portfolio valuation. Systematic Investment Process Risk - Strategies managed by the Jupiter Systematic Team rely heavily on algorithmic models, quantitative screening, and automated trade execution. These systematic approaches are based on historical data and assumptions that may not predict future outcomes under all market conditions. Model risk may arise due to incorrect assumptions, data quality issues, or structural market changes. Portfolio performance may also be affected by market behaviours that deviate from model expectations. Leverage and Derivatives Risk – GEARx - The GEARx strategy may employ significant gross leverage (up to 500%) through the use of derivatives and synthetic exposures. While leverage is used to enhance return potential, it also increases the risk of rapid and substantial losses. Leverage magnifies exposure to market movements, and in extreme scenarios, may impair liquidity or result in forced de-leveraging. The strategy is subject to internal exposure limits and ongoing oversight, but investors should be aware of the elevated volatility and downside risk associated with leveraged investment programmes. Preferential Terms and Side Letter Risk - The GEARx funds may offer preferential terms to certain investors via side letters, including fee rebates, enhanced transparency, or modified

liquidity terms. These arrangements may give rise to potential conflicts of interest. Jupiter manages this through a combination of compliance oversight and fair treatment frameworks. Operational Risk – The risk of actual or potential loss and or client harm emanating from weaknesses or failures in our systems and controls, related to people systems, processes or from external events. This includes risk arising from failing to properly manage key outsourced relationships and cyber security. a) Technology and Information Security – The risk of deliberate attacks including or accidental events that have disruptive effects on interconnected technologies. b) Cyber Risk – The risk of systems failing to operate or becoming disabled due to events wholly or partly beyond our or their control. Our strategy for the management of information security and cyber security continues to evolve, to ensure that vulnerabilities are identified and remedied as quickly as possible. We have invested in ongoing training and awareness on the risks of phishing and similar attacks, and we continue to work with our third-party suppliers to ensure that they are able to demonstrate compliance with Group standards and internationally recognized good practice. Jupiter is certified in accordance with the UK government-backed Cyber Essential Plus scheme, demonstrating our ongoing commitment to reducing the likelihood of a successful cyber security attack, despite the rising number of external attacks seen across the industry. Outsourcing and Supplier Risk – The risk of incidents or failure of providers of services to deliver on their obligations, or inadequate selection or oversight of providers. Jupiter will delegate portfolio management responsibilities for certain strategies to affiliates and third-party investment management firms. The Group has established the Central Investment Manager Oversight team (“CIMO”) to coordinate and align the monitoring, oversight and due diligence of delegate managers. CIMO ensures suitable reporting is provided to Group entities in relation to delegate managers and to satisfy governance and regulatory requirements. CIMO coordinates initial due diligence by issuing a questionnaire to the proposed delegate manager. Based on the response, CIMO issue a due diligence report to Jupiter which provides commentary on the delegate manager’s governance and control environment; regulatory permissions; policies and procedures; controls and processes; substance and resources; and organizational structure. The results of initial due diligence, as well as any issues encountered in ongoing monitoring, determine the nature and scope of the ongoing due diligence in respect of that delegate manager. The day-to-day oversight and monitoring of delegate managers are performed by relevant Jupiter business functions, which may include, but not be limited to, the Investment Management team, Risk and Compliance, Operations, Distribution and Marketing. CIMO consolidates information

from relevant Jupiter business functions to produce a quarterly oversight report along with score cards (with supplementary reporting prepared as required) to evidence to Jupiter’s Board that adequate ongoing monitoring and oversight is being conducted. Delegate managers will usually be required to confirm compliance with certain responsibilities via a periodic attestation. CIMO receives attestations and includes them as part of ongoing monitoring and reporting. Any issues arising from an attestation are flagged to the relevant business function. Pandemic/ Infectious Disease Risk- Outbreaks of infectious diseases, including pandemics, may have a significant negative impact on performance. Such events can result in border closures, movement restrictions, supply chain disruptions, reduced business activity and heightened economic uncertainty. The impact on economies, individual companies and financial markets may be difficult to foresee and could be prolonged. Emerging and developing market countries may be disproportionately affected due to less established healthcare systems and infrastructure. Pandemic-related risks may crystallise through Market Risk, Liquidity Risk and Outsourcing and Supplier Risk. Becoming an advisory client of Jupiter involves risk and potential loss of capital. The strategies offered may not be suitable for all investors. Past performance is not indicative of future results. This list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in connection with Jupiter’s investment management activities. The description of general investment risks is qualified in its entirety by reference to the risks outlined in an investment management agreement or the relevant fund offering documentation. In addition, prospective clients should be aware that, as an investment portfolio develops and changes over time, it may become subject to additional and different risks.

In Q4 2017, MGI identified a breach that resulted in a number of net short positions not being disclosed across 11 jurisdictions. The breach occurred over a four-year period. Upon identifying the issue, MGI voluntarily notified the relevant National Competent Authorities. On August 22, 2019, MGI received correspondence from the Dutch Authority for Financial Markets (the “AFM”) informing MGI that it has decided to impose an administrative fine of €350,000 on MGI in respect of the issue. The amount was reduced from the base amount of €500,000 because of MGI’s cooperation with the AFM. MGI decided to appeal to the AFM based on the grounds of proportionality. This fine was subsequently reduced to €250,000. As a result of the breach, the following fines were also issued by National Competent Authorities: • In 2018 the Comisión Nacional del Mercado de Valores in Spain (“CNMV”) issued a fine of €120,000. • On January 24, 2019, the Commissione Nazionale per le Società e la Borsa in Italy (“CONSOB”) issued a fine of €160,000. • In June 2021, Finansinspektionen, the Swedish regulator issued a fine of SEK 700,000. Additionally, Finanstilsynet, the Danish FSA decided to publicly reprimand MGI, although no fine was issued. Background According to regulations on short selling, investment managers are required to file net short position disclosures with National Competent Authorities, as and when certain prescribed thresholds have been crossed. In November 2017, the MGI compliance function identified errors in respect of the disclosure reports which had resulted in a number of disclosures not being made. The breach did not relate to prohibited naked short sales.

There were two root causes which contributed to the issue: (i) an incorrect threshold trigger was applied; and (ii) an inaccurate reporting criterion, which resulted in some positions being excluded from the internal exposure report was utilized to review the positions. The breach related to the disclosure of short positions held by MGI, as opposed to individual funds. We can confirm that the funds were, and continue to be, managed in accordance with their investment restrictions and regulatory obligations. Clients have not suffered any loss as a result of this issue. The errors were of an inadvertent nature and self-identified. On detection of the breach the relevant National Competent Authorities were voluntary notified. All disclosures that had been missed have been retrospectively reported, as necessary. No profit was made by MGI as a result of the missed disclosure. Corrective Action Following detection of the breach, MGI completed an in-depth analysis of all disclosure requirements in order to establish the underlying cause and to determine the extent of the issue. Further, MGI engaged with external legal counsel experts to assist the business with (i) its overall response to the issues; (ii) validation of our initial conclusions; and (iii) advice on, and review of, any required operational or process enhancements, to ensure that there is no recurrence of this issue.

Jupiter Asset Management (Europe) Limited is also Alternative Investment Fund Manager (AIFM) of the Jupiter GEARx Fund Limited and Jupiter GEARx Master Fund Limited. Jupiter Asset Management International S.A Jupiter Asset Management International S.A. (“JAMI”) is a Luxembourg-based fund management company and investment management firm, authorized and regulated by Luxembourg’s Commission de Surveillance du Secteur Financier. It acts as the management company to the Group’s Luxembourg mutual funds and delegates portfolio management responsibilities to Jupiter. JAMI also has discretionary portfolio management permissions and is the contracting party for any EU segregated mandates but delegates investment management to JAM. It has branches in Germany, Spain, Sweden and Italy through which it carries out marketing activities. Jupiter Investment Management Limited Jupiter Investment Management Limited, formerly known as Merian Global Investors (UK) Limited, is a London based investment management firm, authorized and regulated by the UK’s Financial Conduct Authority. It provides portfolio management services to an institutional client base and is appointed as the investment portfolio manager to a range of mutual funds, domiciled in the UK and Ireland. Jupiter Unit Trust Managers Limited Jupiter Unit Trust Managers Limited is a London-based fund management company, authorized and regulated by the UK’s Financial Conduct Authority. It acts as the management company to Jupiter’s UK mutual funds and delegates portfolio management responsibilities to Jupiter. Jupiter Fund Managers Limited Jupiter Fund Managers Limited (formerly Merian Investment Management Limited) was a Londonbased investment management firm. It is no longer authorized and regulated by the UK’s Financial

Conduct Authority . It remains part of the Jupiter group and is disclosed as a related person in Part 1A of Form ADV. Jupiter Management Cayman GP LLC Jupiter Management Cayman GP LLC, an affiliated Cayman entity, serves as the General Partner of Jupiter GEARx Fund LP. While it is not SEC-registered, it is part of the Jupiter group and provides governance support in respect of the feeder fund. The Group maintains oversight of this entity through its delegate monitoring framework. CCLA Investment Management Limited CCLA Investment Management Limited ("CCLA IM") is a London-based investment management firm, authorised and regulated by the UK's Financial Conduct Authority. CCLA IM specialises in the management of assets on behalf of charities, religious organisations, local authorities and other non-profit institutions. It was acquired by the Jupiter Group in February 2026. CCLA IM operates its own investment teams and client engagement model independently from JAM. It does not provide advisory services to JAM's U.S. clients and does not manage any assets reported in JAM's regulatory assets under management. CCLA Fund Management Limited CCLA Fund Management Limited ("CCLA FM") is a London-based fund management company, authorised and regulated by the UK's Financial Conduct Authority. It acts as the authorised fund manager for certain CCLA pooled investment vehicles. CCLA FM was acquired by the Jupiter Group alongside CCLA IM in February 2026 and is disclosed as a related person of JAM in Part 1A of Form ADV. Jupiter Asset Management (Asia) Private. Ltd Jupiter Asset Management (Asia) Pte. Ltd (“JAM Asia”) is a Singapore-based entity within the Jupiter group, licensed and regulated by the Monetary Authority of Singapore (MAS). JAM may sub-delegate day-to-day investment management responsibilities to JAM Asia for select mandates. This delegation arrangement is not SEC or U.S. client-facing; JAM retains oversight of delegated activities through its Investment Manager Oversight framework. NZS Capital LLC (“NZS”) NZS is a strategic partner of the Group and is a U.S. based investment adviser registered with the SEC. The Group holds a 25% minority stake in NZS. As part of this partnership, the Group has been appointed as distributor of NZS’ strategies in certain jurisdictions, for which it is compensated by NZS through the payment of a percentage of the total net fee revenue earned by it in relation to a client where the Group: • delegates portfolio management services to NZS in respect of a client; and/or • solicits a client on behalf of NZS.

If a company within the Group contracts directly with a relevant client and appoints NZS as the delegated manager, NZS will charge the Group a management fee for the services provided. Prospective clients should be aware that when delegating portfolio management to NZS, Jupiter may not be inclined to appoint any other investment adviser to the mandate, even if doing so might be in the client’s best interests. The Group’s oversight process in respect of delegate managers is described further in Item 8. In addition to the Group’s affiliations outlined above, JAM has also engaged with ACA Foreside, through Foreside Global Services LLC to provide Broker-Dealing Chaperoning services to JAM. This service provides JAM with the ability to market in the U.S. to U.S. Institutional Investors and Major U.S. Institutional Investors without registering as a broker-dealer or as a registered representative. Conflicts of Interest To address potential conflicts of interest across affiliates and in general, Jupiter maintains a Code of Ethics and Conflicts of Interest Policy that are intended to prevent potential conflicts of interest from constituting or giving rise to a material risk of damage to the interest of its clients. Where potential conflicts are identified and recorded, appropriate controls are agreed to manage the conflict to prevent client detriment. The Group maintains and operates organizational and administrative procedures and arrangements designed to prevent conflicts of interest from constituting or giving rise to a material risk of damage to the interests of clients. These include, but are not limited to: • a Code of Ethics containing: o A PA Dealing policy applicable to employees and their connected persons; o An Inducements Policy addressing the provision and receipt of gifts and entertainment by employees; and o rules governing the prior approval of outside business interest sought by employees, in order to minimize the potential risk of conflict with the group’s activities; • deal execution, aggregation, and allocation rules; • an Order Execution Policy provided to clients; • transaction Cost Analysis tools to review execution effectiveness; • control of Inside Information Policy and related rules and guidance designed to prevent Market Abuse; • Stop List and Referral List procedures; • rules governing significant holdings and clients crosses; • corporate governance arrangements, clear reporting lines and segregation of duties; • remuneration policies; • investment process and pre and post trade investment controls;

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product governance arrangements; a Register of external interests of statutory directors of Group companies to the extent that the interest may represent a conflict with the Group’s activities.

While Jupiter maintains relationships with a number of affiliated entities that support its advisory and fund management operations, we have reviewed these relationships and confirm that none currently give rise to material conflicts of interest that affect client outcomes. Where operational interactions with affiliates (e.g., delegation, governance, or distribution arrangements) have the potential to create a conflict, such risks are assessed and addressed through Jupiter’s established oversight and conflict management policies. Jupiter continues to monitor its affiliate relationships on an ongoing basis. If any relationship is determined to present a material conflict of interest, appropriate disclosures will be included in this brochure and relevant mitigation steps will be taken in accordance with our regulatory obligations.

The Code also sets out policies and procedures to deal with conflicts of interest in relation to outside business interests, gifts and entertainment and political contributions. The Code is applicable to all employees of JAM, as well as trades conducted by or on behalf of employees’ spouses, civil partners, dependent children, and any other immediate family members (including relationships such as boyfriends/ girlfriends) residing with the employee, and any other account in which the employee will be deemed to have a beneficial interest. JAM’s Chief Compliance Officer can require other Jupiter employees to comply with the Code where deemed appropriate. It is a requirement of the Code that employees adhere to all applicable federal securities laws. This includes an absolute prohibition from trading in the securities (or encouraging another person to

trade in the securities) of a company whilst in possession of material non-public information relating to that entity. Employees must obtain approval from a delegate of the Chief Compliance Officer to conduct personal account trades in financial instruments that are subject to the Code. The request will be declined if an actual or potential conflict of interest is identified. Pre-clearance is similarly required for employee participation in initial public offerings and private offerings. Employees must provide broker confirmation notes as evidence of personal account transactions, as well as attesting to quarterly and annual holding declarations. Employee personal account activity is subject to ongoing automated and manual monitoring to assess for conflicts of interest and/or suspicious trading patterns. JAM employees (or an employee’s family member) may engage in business activities external to Jupiter which could present a conflict of interest if they require material time commitments from an employee, or where the nature of the outside business involves Jupiter’s investee companies or service providers. Employees are required to disclose such activities to Compliance as they arise and then annually thereafter to ensure any such conflict is adequately managed. Any external activities that give rise to unmanageable conflict will be denied. Participation or Interest in Client Transactions When managing assets on behalf of separately managed account clients, investment managers within the Group may invest or seed funds which are managed or advised by other investment managers within the Group. This could result in increased revenues through management fees and other charges levied on the underlying funds to the benefit of Jupiter and to the potential detriment of clients. In order to mitigate this risk, Jupiter funds are only purchased where consistent with a client’s investment objectives and policy, and where it is in accordance with Jupiter’s duty to act in the best interests of our clients. Investment performance is monitored to ensure any investments contravening the terms of a client’s investment management agreement or fund objectives (or that are deemed unsuitable for the portfolio), are rectified and compensation considered where appropriate. Where a client portfolio holds a fund managed by a member of the Group, the value of those holdings will be deducted from the value of the client's portfolio for the purpose of calculating the investment management fee. Employees of the Group are permitted to trade securities that may also be held within client portfolios. This presents a potential conflict of interest between the employee’s personal trading activity and the best interests of Jupiter’s clients, which is managed through Jupiter’s personal account dealing arrangements. This includes in-scope employee trade requests being subject to review against client orders. Trades are denied where they would breach our personal account dealing policy or otherwise conflict with the interest of clients. Further, Jupiter’s Compliance team

retrospectively monitors personal account trades against client transactions to check for any activity that could give rise to a conflict of interest and/or indicate a suspicious trading pattern. The exposure of one fund to another can be governed by regulatory rules and in those circumstances is closely monitored. Any conflict of interest identified will be investigated and justification for the transaction sought from the relevant investment manager. Members of the Group do not trade with clients on a principal basis and do not engage in proprietary trading activity.

Counterparties are selected following careful consideration of their execution arrangements. Jupiter reviews execution commission rates on a monthly basis to ensure that there is no divergence from the agreed rate card. Further, broker execution rates are agreed on an ongoing basis with due regard to turnover levels and peer group market surveys. Best Execution Jupiter takes all sufficient steps to achieve the best possible result on behalf of clients when executing orders or transmitting them for execution. The Trading Desk considers a range of execution factors, including: • price of the financial instrument; • costs related to execution; • speed and likelihood of execution; • size and nature of the order; • counterparty risk and settlement; and • any other applicable factor relevant to the execution of the order (e.g. ability to maintain anonymity in the market). Jupiter monitors the effectiveness of its execution arrangements on a regular basis in accordance with its Order Execution Policy, enabling it to identify any deficiencies and implement enhancements where deemed necessary. Research and Other Soft Dollar Benefits Jupiter does not receive research or any other soft dollar benefit from broker-dealers in connection with client securities transactions executed by Jupiter or any member of the Group. Client Referrals Jupiter does not take into account client referrals made to it or any member of the Group as a relevant factor with regards to the consideration of broker dealer relationships relevant to the Group.

Directed Brokerage Jupiter does not routinely recommend, request, or require that a client direct the use of a specific broker-dealer. Jupiter may, according to specific client instructions, permit a client to direct brokerage to a particular broker-dealer. In those circumstances, execution quality may be compromised, and clients could incur higher brokerage commissions as it may not be possible to aggregate orders to reduce transaction costs. Further, clients may receive less favorable prices than would be available through other broker-dealers. Aggregated Trades When two or more client accounts are simultaneously engaged in the purchase or sale of the same security, Jupiter may, but is not required to, aggregate client orders into one transaction. In those circumstances, the clients will receive the average price of the transaction in that security for the day. Through the aggregation of orders, clients may be able to benefit from the price achieved through larger bulk transactions, although may not necessarily do so. Jupiter must not carry out an aggregation of client orders/ transactions unless it is unlikely that the aggregation will work overall to the disadvantage of any client involved. Jupiter has adopted a policy of using a “pro rata allocation” to allocate resulting trades from orders that have been aggregated. Under a pro rata allocation, as securities are being purchased or sold as part of a block, the securities are allocated in the proportion by which each account’s order size (as determined by the investment manager at the point the order was raised) makes up a percentage of the entire block. This is the default setting for Jupiter’s order management system and is applied unless there are justifiable reasons for applying an alternative allocation criterion or where market convention does not permit for pro-rata allocation. Cross Trades Jupiter’s policy is not to permit cross trades on U.S. client accounts.

Jupiter’s Investment Risk team produces a suite of metrics, including stress tests and scenario analysis, to provide investment managers with the data required to mitigate risks. The Investment Oversight Committee serves as the primary escalation point for any issues identified during the process. Reporting to clients Jupiter can provide the following reports, periodic statements, and valuations: • Monthly valuations of the Portfolio – containing a list of individuals investment, their respective acquisition costs, their value at the valuation date and performance for the period. • Monthly account statements – containing a valuation as at the end of the reporting period. • Quarterly schedule of transactions – containing a list of transaction activity over the quarter, including purchases and sales. • Quarterly performance report – containing a valuation as at the end of the period, performance over the period including attribution and any voting rights exercised over the period.

JAM itself has not been delegated authority to move client assets and is not deemed to have custody for the purposes of the rule. The general partner relies on the “annual audit exception” to satisfy the Custody Rule requirements. Specifically, the fund is audited annually by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (PCAOB). Audited financial statements are distributed to fund investors within 120 days of the fund’s fiscal year-end. The qualified custodians for the Jupiter GEARx Master Fund and its feeder funds are Goldman Sachs International, Merrill Lynch International, and Morgan Stanley & Co. International PLC, each acting in its capacity as prime broker. The fund administrator is BNY Mellon Fund Services (Ireland) Designated Activity Company. The independent auditor is Ernst & Young Ltd, George Town, Cayman Islands.

Under these arrangements, JAM furnishes model portfolio recommendations, including suggested securities selections and weightings, based on an agreed investment objective. The client retains full authority over all investment decisions and is responsible for determining whether to implement, modify, or disregard any recommendation. JAM does not have trading authority over these accounts and does not execute transactions on the client's behalf. These arrangements are governed by a separate agreement with each client.

For our systematic investment strategies, the high volume of trading activity and varying hold periods are factors that influence our proxy voting approach. The systematic strategy utilises third party recommendations, but these may be overridden where deemed appropriate and subjected to an assessment by the Stewardship team. Our publicly available Proxy Voting and Engagement Policy sets out our approach to voting and stewardship responsibilities. Our website disclosures reflect voting transparency at fund and security level Jupiter recognizes the importance of managing conflicts of interest when voting client securities and engaging with investee companies. Jupiter will always vote in the best interests of the client. Where applicable, in the event that a conflict of interest is identified, Jupiter will obtain advance approval from its clients prior to voting. Subject to the following paragraph, Jupiter’s clients may also choose to vote their own proxies (or designate a third party to do so). In those circumstances, the client must notify Jupiter so that proxy solicitations can be sent directly to clients or the third-party designee. If Jupiter does not have the authority to vote proxies on behalf of the client, the client may contact Jupiter with questions about a particular solicitation, however Jupiter will not have the ability to accept direction from clients on such solicitations. Clients may obtain a copy of Jupiter’s proxy voting policies and procedures by e-mailing CCO@jupiteram.com. In accordance with Rule 206(4)-6 under the Advisers Act, Jupiter has adopted and implemented written policies and procedures governing the proxy voting of client securities or acting with respect to corporate actions. The general policy is to vote proxy proposals, amendments, consents, or resolutions related to securities in a manner that serves the best interests of the client, as determined by Jupiter in its full discretion.