Acadian Asset Management: investment adviser

While each of these affiliates is registered/licensed as appropriate by their local regulatory authority, Acadian Asset Management (Australia) Limited and Acadian Asset Management (Singapore) Pte Ltd are also registered with U.S. Securities and Exchange Commission as an investment adviser. Acadian Affiliate Holdings LLC, part of the Acadian Asset Management Inc., owns 100% of the Class A (voting) interest of Acadian Boston while an Acadian Key Employee Limited Partnership (“Acadian KELP LP”) owns 100% of the Class B interest which provides financial participation in the profitability of the combined Acadian entities. The Acadian KELP LP is comprised of senior staff and a majority of senior investment team members. Acadian Affiliate Holdings LLC is owned by Acadian Inc. which is owned by Acadian Asset Management Inc. (“AAMI”) (a publicly traded company). Acadian Australia primarily utilizes a systematic, quantitative investment process to manage investment strategies which is described in more detail below. General Overview of Investment Process Acadian Australia utilizes the investment processes, databases, systems, and technology developed and utilized by Acadian Boston. Further, pursuant to a service level agreement between both entities, staff in both offices fully support the business activities of the other, in essence functioning as a global team. Strategies are managed using a team-based approach and a systematic, quantitative investment process overseen by Acadian Boston’s Chief Investment Officer. This process relies extensively upon a number of proprietary computer driven models and extensive third-party data. Our investment team is comprised of a team of researchers, portfolio managers, portfolio analytics and construction specialists, traders, data managers, and IT professionals. This systematic, quantitative investment process is flexible and easily tailored and coded to meet the specific needs of our clients. We manage each separate account in accordance with the terms and conditions of a written agreement negotiated with and agreed to by each client. As each client agreement results from a separate negotiation with the client, the terms and conditions of the investment relationship and the fees paid pursuant to the agreement may and do vary by client even within the same investment

mandate or account composite. This includes, but is not limited to, client-imposed requirements and restrictions related to benchmark, individual security restrictions or “do not invest” lists, industry restrictions, country restrictions, ESG related restrictions, investment types, investment universe, and risk targets. These client specific requirements, in addition to other timing issues, may cause performance dispersion between portfolios in the same composite over time. Client specific mandate restrictions are implemented and adhered to utilizing a number of systematic and manual checks. During the initial account set-up process and any subsequent changes thereafter, all clientspecific restrictions are noted and may be coded by the investment team, along with any Acadian or regulatory-specific restraints applicable to the mandate and underlying benchmark, into proprietary portfolio construction software. Pre-optimization coding can be as broad or narrow as required, typically including specific stocks, types of stocks (e.g., “sin lists”), countries, sectors, and ownership percentages. Further, each account and all client-specific restrictions are independently coded by our compliance team into an automated compliance monitoring system that allows for pre-trade, post-trade, and daily compliance monitoring of all accounts. Acadian Australia’s portfolio managers typically do not select specific stocks to buy or sell. In addition to contributing to the research process to enhance our overall quantitative investment process, portfolio managers aim to ensure that the investment process is operating as intended and that each client account is being managed consistent with the client’s investment objectives and in compliance with the client’s contractual requirements. The systematic investment process is supported by extensive proprietary computer code. Researchers, software developers, and IT teams follow structured design, development, testing, change control, and review processes during the development of its systems and the implementation within our investment process. We have control systems and processes that are intended to identify in a timely manner any errors that could have a material impact on the investment process. The majority of these controls and their effectiveness are subject to regular internal and external audits including a SOC audit. However, despite these extensive controls it is possible that errors may occur in coding and within the investment process, as is the case with any complex software or data-driven model, and no guarantee or warranty can be provided that any quantitative investment model is completely free of errors. Any such errors could have a negative impact on investment results. There is no performance guarantee associated with investing in any investment strategy. Investing in securities involves risk of loss of principal that clients should be prepared to bear. Acadian Australia negotiates with each client the terms and conditions under which we will manage their account. This will result in clients within the same investment composites assuming different types and levels of risk, as well as different performance results. Acadian Australia encourages clients to reference strategy-specific risk descriptions (contained in the prospectus and/or private placement memorandum, as appropriate to fund structure) for any of the strategies that we manage. Wrap Fee Program Acadian Australia is not involved with any wrap fee programs.

If a client requests, Acadian Australia will charge fees based upon the investment performance we achieve in managing a client’s portfolio. Such fees are individually negotiated with the client. Additional details regarding performance fees and potential conflicts related to them are provided in response to Item 6 of this Brochure. The timing and method of how a client will pay its management fee to Acadian Australia is negotiable and specified in the written agreement between Acadian Australia and each client. Typically, management fees will be payable monthly or quarterly in arrears, however some may pay monthly or quarterly in advance. The management fee is typically calculated based upon valuation information maintained by the client or fund custodian or prime broker, the fund administrator, or maintained by Acadian Australia as agreed to with the client. A client may be billed directly, or they may authorize their chosen custodian to debit fees from their account upon receipt of a request from Acadian Australia. Management fees shall typically be prorated for each capital contribution and withdrawal made during the applicable calendar month or quarter, as applicable. Accounts initiated or terminated during a calendar month or quarter, as applicable, will be charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Each client typically negotiates termination provisions within their investment management agreement. Acadian Australia does not assess termination charges for separate accounts. For separately managed accounts, the only fee paid by a client to Acadian Australia is the management fee and/or performance fee negotiated in the Investment Management Agreement. All other fees and expenses that may be associated with the account are the sole responsibility of the client. These fees may include, but may not be limited to, brokerage commissions, transaction fees, taxes, custodial fees, administrator fees, trustee fees, and fees for audit, tax and legal advisers. Acadian Australia markets our investment capabilities related to specific investment strategies. We do not typically recommend or market specific products. Subject to certain investment minimums, clients choose the method in which that want to invest with Acadian Australia. This includes via a separate account option or, if available, a fund structure. Acadian Australia pays compensation to Acadian Australia employees who market firm investment strategies. Compensation is determined based upon a number of factors that include a percentage of the management fee paid to Acadian Australia by the client for managing the assets.

Under a performance-based fee arrangement, Acadian Australia may receive increased compensation with regard to unrealized appreciation as well as unrealized gains in the client’s portfolio. When compensation is based in part on unrealized appreciation of securities for which market quotations are not readily available, the client’s chosen custodian is the party that typically values the security at issue and sets the official price for valuation. Some concerns regarding performance fee accounts are that a manager will have a financial incentive to follow a more risky or speculative trading approach within the account or that the manager may allocate investment opportunities to a performance fee account at the expense of other non-performance fee accounts. Such fee arrangements also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. Acadian Australia has procedures designed and implemented to ensure that all clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among clients. Individual Portfolio Managers at Acadian Australia have very limited discretion in terms of their ability to influence trades outside of our process. This gives individual Portfolio Managers limited ability to affect broad changes in the portfolios outside the scope of our systematic and disciplined process. Additionally, Acadian Australia does not compensate individual Portfolio Managers based on direct performance of the separate accounts or funds under their supervision. Instead, Portfolio Managers are compensated for their contributions to the investment process more broadly and the overall profitability of the firm. Acadian Australia believes it mitigates the conflicts presented by “Side by Side Management”. Acadian utilizes a quantitative investment approach to manage mandates, including Long-Only strategies and strategies which utilize leverage, on behalf of a diverse client base. Client portfolios are managed uniquely in accordance with client mandates, restrictions, and instruction. The risk controls Acadian maintains strive to ensure all clients are treated fairly and simultaneously holding a security long and short across Client portfolios (a “Boxed Position”) does not result in a conflict. Acadian considers a boxed position as one where a long position in a security in one Client portfolio and a short position in different Client portfolio. By nature of the quantitative investment approach utilized by Acadian, it is logical that Acadian may hold some securities at a benchmark-relative underweight in one portfolio and at a benchmark-relative overweight in another portfolio.

Business continuity and disaster recovery plans have been developed that seek to identify and plan for potential disruptions. Any significant limitation on the use of our facilities or our software applications, operating systems and networks, could result in financial losses. Similar types of business disruption risks are also present for issuers of securities in which we invest, which could result in material adverse consequences for such issuers and could cause your investments to lose value. Responsible Investing Acadian incorporates Environmental, Social, and Governance (“ESG”) metrics into our core investment process in two distinct ways. The first is as return-seeking signals integrated into security selection across all portfolios. Acadian’s investment philosophy is built on the idea that markets are inefficient due to behavioral mispricings, information asymmetry, and market frictions. ESG considerations are often overlooked or misinterpreted by the market, particularly when they relate to intangible assets that are not reflected on company balance sheets. By systematically incorporating ESG data, we aim to identify mispricings and improve our model’s ability to forecast returns and mitigate risks. We integrate alpha signals into the core investment process only when there is strong evidence of predictive efficacy. ESG signals are treated no differently than any other alpha signal - they undergo the same rigorous testing and validation process. Our research finds that markets often underreact to nonfinancial information, such as corporate culture, human capital management, and governance quality.

These mispricings can be exploited using systematic investing methods. Proprietary ESG metrics will be incorporated into the return forecasting model only when there is demonstrable evidence of efficacy. To be integrated into the process, a signal must not only be predictive of excess returns but also add value when combined with other signals in the model. The second is as portfolio-level constraints implemented only upon client direction and request in separately managed accounts to meet specific client sustainability goals. We offer custom solutions to interested clients to meet their specific sustainability goals. Examples include controversial weapons, fossil fuel exposure, perceptions of UN Global Compact violators, and tobacco. In addition, we offer portfolio constraints to target specific ESG exposures. Examples include decarbonizing portfolios, Net Zero glidepaths, tilting towards the SDGs and Sustainable Investments for SFDR purposes. Artificial Intelligence Acadian uses natural language processing (NLP) and other types of machine learning (ML) in our process for signal construction. These range from using ML to derive features for downstream use in signal construction (for example, within our peer model), to building ML-driven signals, to ensembles of deeplearning-based (including generative-AI) models which leverage numerous existing model components to capture complementary insights. We utilize machine learning techniques when we believe the approach will better capture the relationships that exist in the data. These can be nonlinearities or interactions which would otherwise be difficult to unearth with traditional techniques. We deploy a battery of regularization techniques and rigorous train/validation/test procedures in an effort to ensure that the results will generalize and remain repeatable going forward. Importantly, even in the most computationally-intensive deep learning projects, there is still be a heavy dose of “human engineering” – for example, in selection of input features and the other methodological choices that will define the contours of feasible solutions (e.g., we have at times imposed constraints based on priors on the functional form that a machine learning estimator must conform to). Similarly, we will, where warranted, utilize the latest interpretable-ML tools in an effort to ensure MLderived insights are behaving in intuitive ways. Our use of machine learning undergoes the same rigorous research process that all of our signal and process enhancements adhere to. There is no performance guarantee associated with investing in any investment strategy. Investing in securities involves risk of loss of principal that clients should be prepared to bear. Acadian Australia has identified common risks associated with investing in our strategies. The following identifies these risks and describes how we attempt to manage such risks. Active Risk Under Acadian Australia’s core-equity investment process each portfolio is optimized to a desired range of ex-ante active portfolio risk (defined as standard deviation of returns relative to the client’s relevant benchmark). The portfolio construction and review process includes a detailed analysis of the sources of portfolio risk, including stock, region, industry, size, and style factors. We also track realized residual active risk over rolling periods. Security Risk To control specific security risks, we apply fixed stock weight bounds for each stock. Beyond the fixed bounds, we may also apply dynamic active stock weight bounds, based upon recent stock volatility, in an effort to further limit uncompensated risk from the short-term price movements of individual stocks.

In addition, we control specific stock liquidity risk by keeping a database of daily trading volume of all the covered securities in our universe and monitoring firm-wide holdings of illiquid positions. When we rebalance a portfolio, the estimated liquidity of each security and its expected transaction costs are explicitly considered. During the rebalancing process, we may also include additional stock- and factorbased constraints on the recommendation of our Investment Policy Committee. Our process is designed to limit our firm-wide transactions. For each security, we carefully monitor the average daily trading volume and the aggregate amount held across all portfolios firm-wide to help determine when to stop increasing exposure to a specific stock or to begin trimming our exposure. Market Risk To minimize market risk, we apply a number of investability and liquidity quantitative screens to our investment universe. If a market does not meet certain standards in these areas (e.g., certain emerging markets and small-cap securities), it will automatically be excluded from consideration for client portfolios. That said, our strategies do not try to time market exposures and strive to fully invest in all market environments. Our clients understand this as part of our process and are generally managing market risks at the plan-sponsor level. Currency Risk Currency risk is addressed in the portfolio construction process along with other risk sources, including market, industry and style exposures. More generally, currency effects are integrated into our overall attractiveness rating for each market and stock in our universe rather than treated as a separate input or overlay. Beyond the above, we do not typically try to add value through currency trading. If currency hedging is called for by client mandate, the process typically involves a hedged or partially hedged index as the portfolio benchmark. The currency hedges are typically implemented using spot transactions, forward currency contracts and non-deliverable forwards. At client request or in some funds, we may manage currency in an effort to add value through as FX overlay portfolio or some other means in a risk-controlled manner. Compliance Risk Acadian Australia uses a highly structured and disciplined process in the management of client portfolios, which enables us to offer customized portfolios with tailored risk control, guideline, benchmark, and constraint characteristics. Acadian Australia uses a number of systematic and manual checks and balances to ensure consistent compliance with desired portfolio guidelines. For separately management accounts, all investment guidelines are discussed and agreed upon with the client prior to account inception and documented in the client/manager Investment Management Agreement. For funds, the terms of the fund are documented within the fund prospectus and/or offering documents along with any applicable legal or regulatory restrictions. Both the investment and compliance teams independently review all aspects of the client’s mandate prior to account inception. The Investment team, both manually and through coding into Acadian Australia’s portfolio management software, attempt to ensure that all client, firm, and regulatory objectives and requirements will be complied with each time the portfolio trades. The Compliance team independently

codes all client, firm, and regulatory restrictions specific to each client account into third-party compliance software to enable daily and ongoing monitoring of each account for mandate compliance. Any subsequent changes to the original specifications are handled by the respective teams in the same manner and all changes over time are recorded. Portfolio Risk Our investment management team oversees the risk controls of our investment processes utilizing internally developed risk models. Client mandate restrictions, along with firm and regulatory restrictions applicable to a client portfolio, are coded by members of the investment team into our portfolio construction software and applied systematically to the account during each rebalance. The same are also coded by members of our compliance team into third party compliance systems for monitoring. In the limited instances where restrictions cannot be translated to coding, manual monitoring may be performed. Once approved, the portfolio is traded and then continuously monitored for compliance using a suite of internally developed software tools and automated third-party compliance systems. Acadian Australia negotiates with each client the terms and conditions under which we will manage their account. This may result in clients within the same investment strategy assuming different types and levels of risk as well as different performance results. Clients are also encouraged to reference strategy specific risk descriptions contained in the prospectus and/or private placement memorandum for any of the strategies that we manage available via investment through a fund structure. The following describes some strategy-specific risks that could have a negative impact on investment performance: Lack of Liquidity of certain investments Acadian Australia may purchase securities on behalf of clients that are relatively liquid when acquired but that become illiquid after investment. The sale of any such illiquid investments may be possible only at substantial discounts. Further, such investments may be extremely difficult to value with any degree of certainty. Volatility of Investment Results The value of client investments in equity securities may experience sudden, unpredictable drops in value or long periods of decline in value. This may occur because of factors that affect the securities markets generally, such as adverse changes in economic conditions, the general outlook for corporate earnings, interest rates or investor sentiment. Investments may also lose value because of factors affecting an entire industry or sector, such as increases in production costs, or factors directly related to a specific company, such as decisions made by its management. Turnover and Trading Costs Client accounts are actively managed, which will result in higher transaction costs than would be the case if a client account employed a buy-and-hold strategy. The transaction costs associated with an active trading strategy may lower returns.

Exchange Rate Risk Certain client accounts, where the client’s preferred or functional currency does not match the native currency of the portfolio’s holdings, may require that any cash in their account be exchanged back to their local currency. This results in exchange rate risk. Small Cap Stocks For client accounts investing in small-cap stocks, investment in the securities of smaller-to-medium sized companies may involve significantly greater risks than the securities of larger, better-known companies. Smaller companies may have limited product lines, resources and managerial talent. Small cap stocks have also experienced a high degree of volatility in the past. Investing in Foreign Securities Client accounts investing in securities of non-U.S. governments and companies which are generally denominated in non-U.S. currencies involve certain considerations comprising both risks and opportunities not typically associated with investing in securities of United States issuers. These considerations include changes in exchange rates and exchange control regulations, political and social instability, expropriation, imposition of non-U.S. taxes, less liquid markets and less available information than are generally the case in the United States, higher transaction costs, less government supervision of exchanges, brokers and issuers, difficulty in enforcing contractual obligations, lack of uniform accounting and auditing standards and greater price volatility. Foreign investments can be riskier and more volatile than investments in the United States. Adverse political and economic developments or changes in the value of foreign currency can make it more difficult for an account to sell its securities and could reduce the value of the account. Differences in tax and accounting standards and difficulties in obtaining information about foreign companies can negatively affect investment decisions. Investing in Emerging and Frontier Market Securities For client accounts investing in emerging or frontier market securities, many emerging and frontier market countries have experienced political, economic and/or social instability. They have also experienced dramatic swings in the value of their national currency. There can be no assurance given that such instability or such fluctuations will not occur in the future and, if they do occur, that they will not have a materially adverse effect on the performance of the accounts with exposure to these markets or managed within these strategies. The laws and regulations in some of these countries are subject to frequent changes driven by economic, social, and political instability. The legal systems in certain countries may be transitional and the laws regulating securities transactions, protection of investors and ensuring market discipline, which are customary in countries with developed securities markets, are not available. Where the legal and regulatory framework is in place, the enforcement may be inadequate or insufficient. Some countries may not recognize regulation by the exchanges and self-regulatory organizations as law that can be enforced through the judiciary or by means otherwise available to the investors in developed markets.

The investments made may not be recognized as securities protected by the securities laws in the countries where the investments are made. Investments that are recognized as securities under the local laws are often traded on foreign exchanges with very little liquidity, thus adversely affecting the ability of securities holders to liquidate their investment holdings. Some of the countries currently have or may in the future introduce foreign exchange control regulations which can limit the ability of an account to repatriate the dividends, interest or other income from the investments or the proceeds from sale of securities. Risks associated with investment in these markets, including but not limited to the risks described above, could adversely affect the performance of an account and result in substantial losses. No assurance can be given as to the ability of an account with exposure to these markets or managed within these strategies to achieve any return on its investments. Concentrated Strategies (both in number of names or regions) Strategies that are less diversified across geographic regions, countries, industries, or individual companies generally are riskier than more diversified strategies. Thus, strategies that invest solely in the stocks of one country or one region have more exposure to specific economic cycles, stock market fluctuations, currency exchange rates, government actions, and other country or region-specific issues than a more diversified fund. Similarly, strategies that invest in only a limited number of securities, or where one security may constitute a significant percentage of a portfolio, may suffer substantial declines in value related to the performance of one security. Long-Only Strategies Long-only strategies may not use short-selling or other hedging techniques which could reduce the risks of an account’s investments in the event of a downturn in the securities markets. As a result, if the market or the value of a particular security declines, an account may lose value since it may not offset such declines through short-selling or other hedging techniques that can capitalize on market decreases. Long Short (“Market Neutral” and “Levered”) Strategies An account managed within an Equity Alternative strategy may engage in short sales by selling equity securities that it does not own at the time of sale. By doing so, the account becomes obligated to purchase and deliver equity securities against the short position. In the event that the price of an equity security increases between the short sale and the account’s subsequent purchase of shares of that security, the account will suffer a loss on that transaction, and the total value of the account will decrease accordingly. In theory, short sales involve the possibility of unlimited loss. There can be no assurance that an account will not suffer losses on short sales. Special risks exist because at least some of the assets of an account managed within an Equity Alternative strategy are held by a prime broker as collateral rather than a custodian bank. Due to the presence of short positions, some or all of an account’s assets are held in one or more margin accounts which may provide less segregation of customer assets than would be the case with a more conventional custody arrangement. In the event that the prime broker experiences severe financial difficulty, an account’s assets could be frozen and inaccessible for withdrawal or subsequent trading for an extended period of time while the prime broker’s business is liquidated, resulting in a potential loss to an account due to

adverse market movements while the positions cannot be traded. Such an account may not be fully market neutral and may in some cases be affected in a material way by market trends. The following risks are typically associated with strategies that engage in both long and short selling, but some may also be applicable to Equity Alternative strategies: Short Sales A strategy may engage in short sales by selling equity securities that it does not own at the time of sale. By doing so, an account becomes obligated to purchase and deliver equity securities against the short position. In the event that the price of an equity security increases between the short sale and an account’s subsequent purchase of shares of that security, the account will suffer a loss on that transaction, and the value of the account will decrease accordingly. There can be no assurance that the account will not suffer such losses. In theory, a short sale has the potential for unlimited loss. Use of Borrowed Funds Acadian Australia may cause an account to leverage its investment positions by borrowing funds from securities broker-dealers, banks, or others. Such leverage increases both the possibilities for profit and the risk of loss. In a downward trending market, the use of leverage for long positions could have a material adverse effect on an account’s profitability and operations. Extensions of credit and guarantees by broker-dealers of performance of an account’s obligations will typically be secured by securities and other assets in the account. Under certain circumstances, a broker-dealer may demand an increase in the collateral that secures an account’s obligations, and if an account were unable to provide additional collateral, the broker-dealer could liquidate assets held in the account to satisfy the account’s obligation to the broker-dealer. Liquidation in such manner could have materially adverse consequences. In addition, the amount of the account’s borrowings and the interest rates on those borrowings, which will fluctuate, could have a significant effect on the account’s profitability. Trading in Forward Contracts to Hedge Currency Risk Certain clients may instruct Acadian Australia to hedge the client’s exposure to fluctuations in the United States Dollar or other currency relative to foreign currency by entering into forward contracts with respect to the specific currency pairs. A forward contract is similar to a futures contract but unlike a futures contract the terms of a forward contract are not standardized nor are forward contracts traded on exchanges designated by the United States government. A forward contract is subject to the credit risk of the principal or its refusal to perform and the imposition of exchange controls. Forward contracts are not guaranteed by an exchange or a clearing house and the failure of a principal with whom a forward contract is made would likely result in a default. It may be difficult to enforce the contractual obligations of a non-United States principal in the event that a principal refuses to perform under a forward contract. The United States Commodity Futures Trading Commission (the “CFTC”) does not regulate foreign currency forward contract trading. Futures Certain client accounts may permit Acadian Australia to invest and trade in futures contracts. A futures contract is an agreement between two parties which obligates the purchaser of a futures contract to buy and the seller of a futures contract to sell a security or basket of securities for a set price on a future date.

Unlike most other futures contracts, a stock index futures contract does not require actual delivery of securities but results in cash settlements based upon the difference in value of the index between the time the contract was entered into and the time of its settlement. The risk of loss in trading futures can be substantial. If an account purchases a futures contract it may sustain a total loss of the initial margin funds and any additional funds deposited with a broker to establish and maintain its position in the future. If the market moves against an account’s position, the account may be required to deposit a substantial amount of additional margin funds in order to maintain its position. The placement of contingent or stop orders for the account will not necessarily limit its losses to the intended amounts, as market conditions may make it impossible for such orders to be executed. There can be no assurance that, at all times, a liquid market will exist for offsetting a futures contract that an account has bought or sold. This could be the case if, for example, a futures price has increased or decreased by the maximum allowable daily limit and there is no one presently willing to buy the futures contract an account wants to sell or sell the futures contract an account wants to buy. The high degree of leverage that can be used in trading futures can lead to large losses. Swap Transactions Although an account invests primarily in publicly traded equity securities, it may engage in over-thecounter equity swaps, credit default swaps, total return swaps, and other swap transactions (including interest rate derivatives and currency derivatives) if permitted by the account’s investment guidelines. Swap contracts may not be traded on exchanges, and the swap markets in general are not yet subject to the same type or degree of regulation and supervision as are regulated exchanges, although the regulation of the swap markets has increased in recent years and will further increase in the future. As a result, many of the protections afforded to participants on regulated exchanges are not available in connection with swap transactions and other over the counter (“OTC”) transactions. For example, currently the swap and other OTC markets generally are “principals’ markets” in which performance with respect to a swap contract is the responsibility only of the counterparty to the contract, and not of any exchange or clearinghouse, although certain swaps are now subject to clearing. As a result, an account maybe subject to the risk of the inability or refusal of the counterparties with which Acadian Australia trades to perform with respect to swap contracts. The regulation of certain swap transactions remains in process, and the CFTC, European Union and Australian regulators have released various rules regarding swap dealers and swap participants. The form and implementation of such regulation could impact the Fund investments in swap transactions and the market for such swap transactions. Counterparty Risk An account may purchase and sell derivative instruments such as swaps in “over the counter” or “interdealer” markets. The participants in these markets typically are not subject to credit evaluation and regulatory oversight to the same degree as are members of “exchange-based” markets. This exposes an account to the risk that a counterparty will not settle a transaction in accordance with contractual obligations whether due to insolvency, bankruptcy, or other causes. Moreover, disputes over the terms of a derivatives contract (whether or not bona fide) may cause settlement delays because such markets may lack the established rules and procedures for swift settlement of disputes among market participants found in “exchange-based” markets, although there has been enhanced regulation with respect to dispute resolution in recent years. These factors may cause the account to suffer a loss due to adverse market movements while replacement transactions are executed or otherwise. Such “counterparty risk” is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where an account has concentrated its transactions with a single or small group of counterparties.

Use of a Prime Broker to hold Assets Special risks exist when the assets of an account are held by a prime broker rather than a bank. Due to the presence of short positions, some or all of the account’s assets are held in one or more margin accounts which may provide less segregation of customer assets than would be the case with a more conventional custody arrangement. In the event that the prime broker experiences severe financial difficulty, an account’s assets could be frozen and inaccessible for withdrawal or subsequent trading for an extended period of time while the prime broker’s business is liquidated, resulting in a potential loss to the account due to adverse market movements while the positions cannot be traded. Furthermore, if the prime broker’s pool of assets is determined to be insufficient to meet all claims, the account could suffer a loss. Changes in Laws and Regulations Adverse changes to existing laws or regulations, or the adoption of new laws or regulations, have the potential to negatively affect previous investment decisions and ongoing investment strategies. Such changes could result in the force sale of certain account holdings and limiting of investment opportunities previously available. Options The trading of options is highly speculative and may entail risks that are greater than those present when investing in other securities. Prices of options are generally more volatile than prices of other securities. To the extent that the account purchases options that it does not sell or exercise, it will suffer the loss of the premium paid in such purchase. To the extent that an account sells options and must deliver the underlying securities at the option price, the account has a theoretically unlimited risk of loss if the price of such underlying securities increases. To the extent that an account must buy the underlying securities, it risks the loss of the difference between the market price of the underlying securities and the option price. Any gain or loss derived from the sale or exercise of an option will be reduced or increased, respectively, by the amount of the premium paid. The expenses of option investing include commissions payable on the purchase and on the exercise or sale of an option. Special risks are associated with the use of options. A decision as to whether, when and how to use options involves the exercise of skill and judgment which are different from those needed to select securities, and even a well-conceived transaction may be unsuccessful to some degree because of market behavior, currency fluctuations or interest rate trends. When options are used as a hedging technique, there can be no guaranty of a correlation between price movements in the option and in the portfolio, securities being hedged. A lack of correlation could result in a loss on both the hedged securities and the hedging vehicle, so that the return might have been better had hedging not been attempted. Commodities The commodities markets have historically been highly volatile and exhibited dramatic swings in returns. The commodities markets are subject to a variety of risks, including but not limited to (i) changes in global economic demand for certain commodities due to recessions, world events or other factors, (ii) implementation of import or export controls or other government regulation, (iii) natural disasters, weather, political instability or other events which may create a shortage of a commodity, and (iv) the discovery of new sources of supply for a commodity or the depletion of existing sources. Government instability in key commodity producing countries or government or other actor intervention in the commodity markets can have a substantial impact on prices (such as OPEC actions with respect to oil prices). Some commodities have limited supply, and the prices may be subject to manipulation or control by a handful of key players or suppliers.

Securities and Exchange Commission, and Acadian UK, authorized and regulated as an investment manager by and with the UK Financial Conduct Authority), and the various AAMI entities in the Acadian ownership chain was described in the response to Item 4. Acadian Boston has separate service level agreements in place between it and Acadian Australia, Acadian Singapore, and Acadian UK, whereby each party may provide services to clients of the other as deemed necessary and appropriate. This may and does include the use of the same underlying investment process, databases and personnel to support the business activities of each office. As SEC registered advisers, Acadian Boston and Acadian Australia intend to expand their sub-advisory and service level agreement whereby portfolio managers and trading personal in each office may begin to exercise investment and trading discretion over accounts that may be directly contracted with the other office. We believe this will be of benefit to clients of both offices and will not result in a material conflict.

Acadian Australia’s Code of Ethics is designed to protect Acadian Australia’s clients by deterring misconduct; guarding against violations of the securities laws; educating Access Persons regarding Acadian Australia’s expectations and the laws governing their conduct; reminding Access Persons that they are in a position of trust and must act with complete propriety at all times; protecting the reputation of Acadian Australia; and to establish procedures for Access Persons to follow so that Acadian Australia may determine whether Access Persons are complying with our ethical principles and regulatory requirements. The definition of “Access Person” may include employees, consultants, contractors and certain immediate family members or persons subject to the financial support of the Access Person. A person whose job responsibilities require him or her to spend a significant amount of time working on-site or that require him or her to access Acadian Australia’s research and/or trading databases will typically be characterized as an Access Person as well as any other individual as determined by Acadian Australia. An immediate family member is defined to include any relative by blood or marriage living in an Access Person’s household subject to the Access Person’s financial support or any other individual living in the household subject to the Access Person’s financial support (spouse, minor children, a domestic partner etc.). Acadian Australia’s Code of Ethics stresses Acadian Australia’s principles and philosophy regarding ethics and Acadian Australia’s overarching fiduciary duty to its clients and the obligation of its Access Persons to uphold this fundamental duty. Acadian Australia has adopted the following general principles to guide the actions of its Access Persons:

The interests of clients are paramount. All Access Persons must conduct themselves and their operations to give maximum effect to this belief by placing the interests of clients before their own.

All personal transactions in securities by Access Persons must be accomplished so as not to conflict materially with the interests of any client.

All Access Persons must avoid actions or activities that allow (or appear to allow) a person to profit or benefit from his or her position with respect to a client, or that otherwise bring into question the person’s independence or judgment.

Personal, financial, and other potentially sensitive information concerning the firm, our clients, prospects, and other Access Persons will be kept strictly confidential. Access Persons will only access this information if it is required to complete their jobs and will only disclose such information to others if it is required to complete their jobs and to deliver the services for which the client has contracted.

All Access Persons will conduct themselves honestly, with integrity and in a professional manner to preserve and protect Acadian Australia’s reputation.

All Access Persons will comply with all laws and regulations applicable to our business activities.

Among other areas, the Code of Ethics addresses policies, procedures, and reporting requirements related to such topics as conflicts of interest, insider trading, confidentiality of client information, personal

trading, political contributions, and the offer or receipt of entertainment and gifts. The Code of Ethics further describes the methods of implementing and enforcing these requirements including the preclearance of the personal securities trades of Access Persons, trading restrictions, ongoing reporting, record-keeping requirements, and how Acadian Australia will address any violations. All Access Persons and supervised persons must acknowledge receipt and terms of the Code of Ethics annually and are subject to annual training. Acadian Australia provides investment management services to our clients in accordance with the terms and conditions of specific written agreements negotiated with each client. The performance of such investment management or other services for one client shall not be deemed to violate or give rise to any duty or obligation to provide the same or similar service for a different client. Acadian Australia will only make investment decisions on behalf of a client if it believes such investments would be appropriate for the specific client’s mandate. Acadian Australia anticipates that, in appropriate circumstances, consistent with clients’ investment objectives and subject to the terms of our Code of Ethics, it will cause accounts over which it has management authority to affect the purchase or sale of securities in which Acadian Australia, our related persons, and/or clients, directly or indirectly, have a position of interest. Acadian Australia recognizes that such activity may present a conflict in that there is a possibility that a client may feel that one client is being favored over another or that employees might benefit from market activity by a client in a security held by an employee. We believe our Code of Ethics and quantitative investment process address such conflict. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with our making decisions in the best interest of advisory clients. Personal trading by Acadian Australia’s Access Persons must comply with Acadian Australia’s Code of Ethics. This includes the requirement to pre-clear trades in certain securities prior to proceeding with execution. A personal trade will typically not be approved unless is complies with the Code. Code restrictions related to personal trading include personal trading in the same security on the same day we are trading it for our clients, short-term holding restrictions, restrictions against “front running” client portfolios, and prohibitions related to “inside information.” Access Persons are required to report personal trading activity to the Compliance Group on a quarterly and year-end basis. Acadian Australia may further request to be made an interested third-party for the receipt of duplicate account statements for certain personal investment accounts in which a security subject to the Code approval and reporting requirements is eligible for purchase or sale. Employee trading is continually monitored to ensure compliance under the Code of Ethics, and to reasonably prevent conflicts of interest between Acadian Australia and our clients.

Acadian Australia may recommend that two of its eligible clients execute a cross transaction. Any cross transaction that may occur will be done through a brokerdealer agreeable to the clients and independent of Acadian Australia. No compensation in the form of commissions or remuneration for the transaction will be earned by Acadian Australia. Errors Should Acadian Australia be the direct cause of a trade error or mandate breach it is our typical policy to permit the impacted client to keep the benefit of the error or breach or to reimburse the impacted client for any direct losses that may result from the error or breach. Best Execution Acadian Australia’s policy is to execute orders on behalf of clients in a manner which is consistent with the best interest of the client and uses a trading process which attempts to provides the most beneficial economic result under the circumstances. Acadian Australia considers numerous factors when selecting a counterparty, including, but not limited to, commission rate (if applicable), financial stability, ability to settle the order, responsiveness, and execution capabilities For trades where we do not have discretion to choose the counterparty, such as those subject to any clientimposed direction or restrictions (e.g., if the client has mandated the use of specified counterparties for certain transactions or where we have to use the client custodian for currency trading) we may not be able to achieve best execution for that client or transaction. Acadian Australia maintains a list of approved counterparties with whom we trade. Before a counterparty can be approved for trading it must pass a due diligence review and be approved by senior management in operations, investments, and compliance/risk. Counterparty performance is then reviewed quarterly and each approved counterparty is subject to at least annual due diligence review. Acadian Australia may use a number of factors to assess counterparty execution capabilities including, but are not limited to, the following: - Prompt and reliable execution.

- The competitiveness of commission rates, spreads, mark-ups, and markdowns, if applicable. - The financial strength and stability and/or reputation of the counterparty. - The willingness and ability of the executing counterparty to execute transactions (and commit capital) of size in liquid and illiquid markets without disrupting the market for the security. - Local laws, regulations, or restrictions. - Competency of block trading coverage. - The ability of the executing counterparty to maintain confidentiality; - The availability of electronic communications networks for trading and execution management systems (“EMS”) to Acadian Australia. - Market share. - Liquidity. - Price. - History of execution of orders. - Clearance and settlement capabilities, especially in high volume market environments. - Sophistication of the counterparty’s trading capabilities and infrastructure/facilities. - The operational efficiency with which transactions are processed and cleared, taking into account the order size and complexity. - Responsiveness to Acadian Australia. - Access to secondary markets; and/or - Counterparty exposure The specific criteria used will vary depending upon the nature of the transaction, the market in which it is executed, and the extent to which it is possible to select among multiple counterparties. Transactions will not always be executed at the lowest available price, rate, spread or commission. Acadian Australia may use alternative trading systems when it deems appropriate. Trade Order Aggregation and Allocation Acadian Australia may aggregate trade orders for multiple clients to maximize efficiency and minimize trading costs and place the aggregated trades with one or multiple counterparties in an effort to achieve best execution. In certain cases, where the aggregated order is executed in a series of transactions at various prices on a given day, each client’s proportionate share of the order will reflect the average price received and, where applicable, commission rate paid with respect to the total orders in which the client’s account participated on that day. Acadian Australia may, but is not obligated to, aggregate trade orders in any case. Although aggregation of trade orders is generally intended to benefit client accounts by reducing overall trading costs, it is possible in any case that aggregation might instead increase client account commissions or trading costs or have other unintended adverse effects. Certain client trades that are not aggregated may achieve superior execution. Acadian Australia strives to ensure that each client accounts receives equitable exposure and execution quality in the same security. Acadian Australia does not have trading authority for Model Portfolio accounts. Acadian Australia will negotiate with each Model Portfolio client as part of their Investment management Agreement how and when each model is delivered to the client.

In addition, each separate account client selects their own account custodian. Acadian Australia is in daily communication with account custodians. Additional client reporting may be provided directly by the custodian to the client.

While industry consultants may recommend Acadian Australia’s investment management services to their clients for certain strategies, it is not Acadian Australia’s practice to pay industry consultants a fee for the referral of business or to involve itself in any “pay to play” relationships. Consultants’ fees are typically the responsibility of the client. Clients or fund participants associated with a specific consultant may also benefit from a relationship fee negotiated between Acadian Australia and the consultant in relation to specific strategies or funds for so long as they are represented by the consultant and invested with Acadian Australia. Acadian Australia does not sell, purchase or receive any other products or services as a result of any client referrals.

Examples of restrictions that may be imposed by clients include the prohibition on investing in specific industries, companies or countries, the number of securities that can be held in their portfolio, the percentage limits of specific holdings and markets in their portfolio, and environmental, social, and governance specific screens. In addition to client specific restrictions found in the investment management agreement, additional restrictions on Acadian Australia’s investment discretion may come from internal firm policies, laws, regulations and tax policies that may impact specific client portfolios. Examples of non-discretionary accounts are those that require pre-approval from the client of each proposed account rebalance and those where the client is provided only a suggested buy/sell/hold list (a “model portfolio”). A model portfolio client is responsible for the ultimate decisions on what to trade and executing such trades.

policy. Should the client wish to retain voting responsibility themselves, Acadian Australia would have no further involvement in the voting process but would remain available to provide reasonable assistance to the client as needed. Policy This Proxy Voting Policy (“Policy”) sets forth the principles and procedures by which the Firm exercises voting authority on behalf of clients for securities held in their accounts. The Firm has a fiduciary duty to vote proxies in the best interests of its clients and to adopt and implement written policies reasonably designed to ensure that such votes are cast in a manner consistent with those interests. This Policy applies to all client accounts for which the Firm has been delegated proxy voting authority pursuant to an advisory agreement or other governing document. We have voting responsibility for all Acadian Australia branded private funds. A. Client Specific Guidelines Where clients provide individualized proxy voting policies or instructions, Acadian Australia will vote proxies in accordance with those requirements, unless the Firm determines it is unable to do so (in which case the client will be notified). Acadian Australia is not involved in the voting process for Clients which do not delegate control of proxy voting to Acadian Australia, with the exception of those Clients with whom Acadian Australia has agreed to provide proxy guidance on an ad hoc basis. B.

Use of Third Party Proxy Advisor Services

Acadian Australia utilizes the services of Institutional Shareholder Services (“ISS”), an unaffiliated proxy firm, to help manage the proxy voting process and to research and vote proxies. Acadian Australia will adopt the appropriate ISS voting policies for use when contractually directed by the client to votes proxies on their behalf in accordance with our proxy voting policy. We review the ISS policies at least annually and believe that they are reasonably designed to ensure that we vote proxies in the best interest of clients and that our voting decisions are insulated from any potential material conflicts of interest. Should a client contractually direct Acadian Australia to vote proxies on their behalf in accordance with Client specific voting policies and procedures, we will still utilize the services of ISS to cast the votes in accordance with the client’s instructions. When voting proxies on behalf of our clients, Acadian Australia assumes a fiduciary responsibility to vote in our clients' best interests. In addition, with respect to benefit plans under the Employee Retirement Income Securities Act (ERISA), Acadian Australia acknowledges its responsibility as a fiduciary to vote proxies prudently and solely in the best interest of plan participants and beneficiaries. So that it may fulfill these fiduciary responsibilities to clients, Acadian Australia has adopted and implemented these written policies and procedures reasonably designed to ensure that it votes proxies in the best interest of clients. C. Procedures

Proxy Voting Guidelines Acadian Australia acknowledges it has a duty of care to its clients that requires it to monitor corporate events and vote client proxies when instructed by the client to do so. To assist in this effort, Acadian Australia has retained ISS to research and vote its proxies. ISS provides proxy-voting analysis and votes proxies in accordance with predetermined guidelines. Relying on ISS to vote proxies is intended to help ensure that Acadian Australia votes in the best interest of its clients and insulates Acadian Australia’s voting decisions from any potential material conflicts of interest. Acadian Australia will also accept specific written proxy voting instructions from a client and communicate those instructions to ISS to implement when voting proxies involving that client’s portfolio. In specific instances where ISS will not vote a proxy, will not provide a voting recommendation, or other instances where there is an unusual cost or requirement related to a proxy vote, Acadian’s Head of Investment Operations will coordinate with members of our investment team to conduct an analysis to determine whether the costs related to the vote outweigh the potential benefit to our client. If we determine, in our discretion, that it is in the best of interest of our client not to participate in the vote Acadian Australia will not participate in the vote on behalf of our client. If we determine that a vote would be in the best interest of our client, Acadian Australia will provide voting direction back to ISS and ensure the vote is cast as they instruct. Unless contrary instructions are received from a client, Acadian Australia has instructed ISS to not vote proxies in so-called "share blocking" markets. Share-blocking markets are markets where proxy voters have their securities blocked from trading during the period of the annual meeting. The period of blocking typically lasts from a few days to two weeks. During the period, any portfolio holdings in these markets cannot be sold without a formal recall. The recall process can take time, and in some cases, cannot be accomplished at all. This makes a client’s portfolio vulnerable to a scenario where a stock is dropping in attractiveness but cannot be sold because it has been blocked. Shareholders who do not vote are not subject to the blocking procedure. Acadian Australia also reserves the right to override ISS vote recommendations under certain circumstances. Acadian Australia will only do so if they believe that voting contrary to the ISS recommendation is in the best interest of clients. The reasons for any overrides and for voting against the ISS recommendation will be documented. Conflicts of Interest Occasions may arise during the voting process in which the best interest of our clients conflict with Acadian Australia’s interests. In these situations, ISS will continue to follow the same predetermined guidelines as formally agreed upon between Acadian Australia and ISS before such conflict of interest existed. Conflicts of interest generally include (i) business relationships where Acadian Australia has a substantial business relationship with, or is actively soliciting business from, a company soliciting proxies, or (ii) personal or family relationships whereby an employee of Acadian Australia has a family member or other personal relationship that is affiliated with a company soliciting proxies, such as a spouse who serves as a director of a public company. A conflict could also exist if a substantial business relationship exists with a proponent or opponent of a particular initiative. If Acadian Australia learns that a conflict of interest exists, the Head of Investment Operations will work with our compliance and investment team as needed to document (i) the details of the conflict of interest, (ii) whether or not the

conflict is material, and (iii) procedures to ensure that Acadian Australia makes proxy voting decisions based on the best interests of clients. If Acadian Australia determines that a material conflict exists, it will defer to ISS to vote the proxy in accordance with the predetermined voting policy. Voting Policies Acadian Australia has adopted the proxy voting policies developed by ISS, summaries of which can be found at http://www.issgovernance.com/policy and which are deemed to be incorporated herein. The policies have been developed based on ISS’ independent, objective analysis of leading corporate governance practices and their support of long-term shareholder value. Acadian Australia may change its proxy voting policy from time to time without providing notice of changes to clients. Voting Process Acadian’s Head of Investment Operations acts as coordinator with ISS including ensuring proxies Acadian Australia is responsible to vote are forwarded to ISS, overseeing that ISS is voting assigned client accounts and maintaining appropriate authorization and voting records. After ISS is notified by the custodian of a proxy that requires voting and/or after ISS cross references their database with a routine download of Acadian Australia holdings and determines a proxy requires voting, ISS will review the proxy and make a voting proposal based on the recommendations provided by their research group. Any electronic proxy votes will be communicated to the proxy solicitor by ISS Global Proxy Distribution Service and Broadridge’s Proxy Edge Distribution Service, while non-electronic ballots, or paper ballots, will be faxed, telephoned or sent via Internet. ISS assumes responsibility for the proxies to be transmitted for voting in a timely fashion and maintains a record of the vote, which is provided to Acadian Australia on a monthly basis. Proxy voting records specific to a client’s account are available to each client upon request. Proxy Voting Record Acadian Australia will maintain a record containing the following information regarding the voting of proxies: (i) the name of the issuer, (ii) the exchange ticker symbol, (iii) the CUSIP number, (iv) the shareholder meeting date, (v) a brief description of the matter brought to vote; (vi) whether the proposal was submitted by management or a shareholder, (vii) how Acadian Australia/ ISS voted the proxy (for, against, abstained) and (viii) whether the proxy was voted for or against management. Obtaining a Voting Proxy Report Clients may request a copy of these policies and procedures and/or a report on how their individual securities were voted please contact us at +61 2 9093 1000 and/or by email at compliance-reporting@acadian-asset.com

Acadian’s Privacy Policy Acadian Australia is committed to maintaining the trust and confidence of our clients and keeping personal information or other non-public information we may collect from our clients confidential and secure. We want you to understand how we protect your privacy when we collect and use information about you, and the measures we take to safeguard that information. Keeping client information secure and private is a priority for us. The following describes how we may collect, use, protect, and shares nonpublic personal information (“NPI”) of our clients, in compliance with SEC Regulation S-P (17 CFR Part 248) and other applicable privacy laws. Please review this information and feel free to contact us with any questions. NPI Information We May Collect

Personal identifiers: Name, address, date of birth, Social Security number, taxpayer identification number, passport number and other identifying information. Financial information: Account balances, investment holdings, transaction history, income, assets, and investment objectives. Contact information: Email addresses, telephone numbers, and mailing addresses. Regulatory and compliance data: Information collected for “Know Your Customer” (KYC), anti-money laundering (AML), or other regulatory requirements.

This information is collected directly from our clients, custodians, intermediaries, and other authorized representatives. How We Use Client Information We use client information for the following purposes:

To open and maintain accounts. To execute investment transactions and manage portfolios. To communicate with clients about their accounts and our services. To meet legal and regulatory obligations including KYC and AML requirements. To conduct internal compliance monitoring, audits, and risk management.

Disclosure of Client Information We do not sell or share client information with non-affiliated third parties for marketing purposes. We may disclose client information only as permitted by Regulation S-P, including:

To our wholly owned affiliates as required to provide the investment services contracted for. To our parent company under our ownership and governance structure. To service providers that assist in account administration, transaction processing, or other business functions. To custodians, brokers, or other intermediaries involved in executing client transactions. To auditors, attorneys, and regulators as required by law. To other parties with the client’s explicit consent.

Acadian Australia’ third-party service providers are contractually obligated to maintain the confidentiality of client information and use it solely for the purpose for which it was disclosed. Safeguarding Client Information The Firm maintains physical, electronic, and procedural safeguards designed to protect client NPI from unauthorized access or use. These measures include:

Secure networks and encryption of electronic data. Access controls restricting client data to authorized personnel only. Regular employee training on privacy and data security practices. Incident response procedures for data breaches or unauthorized disclosures.

Opt-Out Rights Under Regulation S-P, clients have the right to opt out of certain information disclosures to non-affiliated third parties. Because Acadian Australia does not share client information for marketing or non-essential purposes, no opt-out action is currently required. If this policy changes, clients will be provided advance notice and instructions on how to exercise their opt-out rights. Former Clients If you decide to close your account(s) or become an inactive client, we will adhere to the privacy policies and practices as described in this notice.

Accuracy and Retention We strive to keep client information accurate and up to date. Clients should promptly notify us of any changes to their personal or financial information. Client records are retained only as long as necessary to fulfill our business and regulatory obligations. Policy Updates We may update this Policy periodically to reflect changes in business practices or regulatory requirements. We reserve the right to change this policy at any time and you will be notified if any material changes occur. The most current version will be or provided upon request.

Contact Information Any questions regarding Acadian’s Privacy Policy should be addressed by contacting us at +61 2 9093 1000 and/or by email at compliance-reporting@acadian-asset.com.

Acadian’s Class Action Policy Related to Holdings Acadian Australia believes that whether to participate in a class action lawsuit involving an investment holding is a decision to be made by each separate account client in conjunction with their appointed custodian, not by Acadian Australia. As a result, if not contractually obligated to respond to a class action claim on behalf of a separate account client, it is not Acadian Australia’s typical practice to do so.

Potential conflicts associated with Acadian Australia’s investment processes and day-today operations Conflict assessments are an ongoing and a consistent focus at Acadian Australia. Acadian Australia’s disciplined, quantitative investment approach greatly reduces the potential for material conflicts that may exist with fundamental managers. Many typical conflict areas are eliminated entirely by or can be mitigated through the disciplined, quantitative systematic portfolio construction process that is utilized to manage all our investment strategies. Please reach out to us should you require additional information on how these conflicts are managed and mitigated internally so as not to have a material impact on any of our clients. We identify some of these conflicts below. A perceived conflict may exist where portfolio managers manage both standard fee accounts and performance-based accounts potentially resulting in favoring the performance-based accounts over the standard fee accounts. A perceived conflict may exist should portfolio managers engage in “portfolio pumping,” “cherry picking” or “window dressing” to improve the appearance of performance of a portfolio. A perceived conflict may result from “side-by-side” management of portfolios where the investment model recommends one portfolio hold a security “long” while another holds the same security “short.” A perceived conflict may exist where Acadian Australia may provide model portfolios for UMA programs or either license or sell our investment process or investment models that are an output of such process to third parties who will then use the same to manage accounts on behalf of their own clients and compete with Acadian Australia for liquidity in the markets. A perceived conflict exists where Acadian Australia may purchase a security for one account that it does not purchase for another account, including purchasing securities for an account in which the firm or a firm employee has personally invested or an account with a performance fee. This may raise issues with respect to inequitable access to investment opportunities. A perceived conflict may exist with respect to the release of account management data and portfolio holdings for a representative account in a given strategy or for a commingled fund when the information

that may be released may not be available to all potential investors or current investors in a commingled fund. A perceived conflict may exist relating to the frequency of portfolio trading, trade aggregation and trade allocation between all accounts, particularly those trading on the same day. A perceived conflict exists when Acadian Australia trades with a broker who may also be a client or affiliated with a client. A perceived conflict exists with respect to Acadian Australia agreeing to side letter terms and most favored nation clauses, including fees, with certain investors in commingled funds that are not available to other investors in the same fund. A perceived conflict exists where Acadian Australia purchases for a client portfolio the stock of another client. This may create the appearance that we are favoring one client. A perceived conflict may exist should Acadian Australia choose to execute trades for a client through a broker-dealer affiliated with a consultant. A perceived conflict may exist where the stock of Acadian Asset Management Inc. (“AAMI”) may be eligible for purchase within a client account. A perceived conflict may exist relating to the identification and correction of trade errors. A perceived conflict may exist as Acadian Australia employees are permitted to trade in stocks that are purchased for client accounts and are permitted to invest in mutual funds and private funds managed on behalf of clients. A perceived conflict may exist as Acadian Australia employees are permitted to receive and give gifts and entertainment from and to those with whom the firm conducts business. A perceived conflict may exist as Acadian Australia permits its employees to make political and charitable contributions. A perceived conflict may exist as Acadian Australia permits its employees to participate on the Boards of public companies. A perceived conflict may exist as Acadian Australia pays an annual fee to attend a conference offered by a consultant who also may recommend Acadian Australia to clients. A perceived conflict may exist as Acadian Australia may be obligated to compensate certain non-U.S. based search firms if selected for a mandate. A perceived conflict may exist with respect to how Acadian Australia votes proxies as Acadian Australia has been authorized to vote proxies on behalf of clients that may have competing interests with each other and with Acadian Australia.

A perceived conflict may exist regarding the valuation of portfolios for the purposes of reporting performance and calculating management fees due. A perceived conflict may exist in that certain commingled funds managed by Acadian Australia contain a significant percentage of related party investment to be considered a proprietary fund. A perceived conflict may exist as Acadian Australia will actively attempt to avoid temporary overdraft charges and/or reimburse any overdraft charges that occur for certain client accounts only if requested to do so by the client. A perceived conflict may exist in that one client may be paying a higher investment management fee than another client in the same strategy. A perceived conflict may exist in that unintended consequences may result from the extensive computer code that supports Acadian Australia’s quantitative investment process that may impact investment performance but may not be transparent to or specifically disclosed to clients. A perceived conflict may exist in that Acadian Australia awards trades and the commissions related to those trades to certain brokers that provide Acadian Australia with proprietary research. A perceived conflict may exist in that Acadian Australia as a signatory of the UN PRI applies an ESG criteria to the management of certain accounts but not to others.