Fidelity Diversifying Solutions LLC (“FDS”) is an investment management firm primarily providing discretionary advisory and sub-advisory services to registered and unregistered investment companies, business development companies, real estate investment trusts, and various institutional clients. FDS also shares its investment research as described below. FDS has been in business since 2022. FDS is a Fidelity Investments company, and is wholly owned by FMR LLC. FDS is part of the Fidelity Asset Management Solutions (FAMS) business unit which, together with its affiliates, FIAM LLC and Fidelity Institutional Asset Management Trust Company, provides a broad array of investment solutions with its Global Institutional Solutions (GIS), Global Asset Allocation (GAA), and institutional equity, fixed income, high income, and alternative asset management teams. FDS employs different strategies in providing investment advice depending on the type of client and their investment objectives and mandate. FDS offers advice on a variety of investment security types including but not limited to fixed income securities, equity securities, exchange-traded funds (“ETFs”), commodities, futures, options, swaps and other derivatives, real assets, leveraged loans, and private credit instruments (collectively, “Investments”) on a discretionary basis. FDS provides and seeks to provide investment advisory services to open-end investment companies (also referred to as “mutual funds”), exchange-traded funds, and closed-end investment companies registered under the Investment Company Act of 1940 (the “1940 Act”), as well as business development companies (“BDCs”), real estate investment trusts and private (unregistered) funds, other collective investment vehicles (collectively, the “Funds” and each a “Fund”) and various institutional clients (collectively, “Clients” and each, a “Client”). FDS acts as investment adviser under the terms of its management contract with each Client and has overall responsibility for directing the Investments of each Client in accordance with its investment objective, policies, and restrictions as provided in its registration statement filed with the SEC, offering memorandum (or similar disclosure document), limited partnership agreement, investment management agreement or other governing document (“Governing Documents”). Such advisory services provided to certain registered Funds, such as mutual funds, BDCs, closed-end investment companies (“Registered Funds”, each a “Registered Fund”), are subject to the supervision of each such Fund’s Board of Trustees. Generally, FDS and its affiliates provide all necessary office facilities and personnel for servicing the Funds' Investments and pays the salaries and fees of all officers of the Funds, members of the Boards of Trustees who are “interested persons” of the Funds, FDS or its affiliates, and of all personnel of the Funds, FDS or its affiliates who perform services relating to research, statistical, and investment activities. FDS sub-advises Funds or accounts for affiliated and unaffiliated advisers. Further, FDS may also serve as an adviser or subadviser to various accounts for which FDS’ affiliates, FIL Limited, FIL’s subsidiaries or affiliates (“FIL”) have contracted to provide investment advisory services. These accounts may include collective investment vehicles authorized in jurisdictions outside the United States. FDS disclaims that it is a related person of FIL. FDS may in the future have institutional clients, including pension and profit-sharing plans, corporate entities, charitable organizations, state or municipal government entities or other separately managed account clients (“separately managed accounts”), other investment advisers, or non-U.S. investment vehicles. In addition, FDS or its affiliates, subject to the supervision of the Board of Trustees of each relevant Registered Fund, provides the management and administrative services necessary for the operation of the Registered Funds, including business development companies. Additionally, FDS or its affiliates provide management and administrative services to certain privately offered unregistered investment funds and institutional client accounts. These services include, as applicable, providing facilities for maintaining each client’s operations; supervising the Funds, or otherwise facilitating, on behalf of other clients, relations with custodians, transfer and pricing agents, accountants, underwriters and other persons dealing with clients; at the direction of the Funds or otherwise for other clients, preparing all general shareholder communications and conducting shareholder relations; maintaining each Fund’s, if applicable, records, registration and notice filing status of each client’s shares under applicable law, respectively; developing 5 of 64 management and shareholder services for each Fund, if applicable; and furnishing reports, evaluations and analyses. FDS is registered with the

Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor (“CTA”) and commodity pool operator (“CPO”). FDS is also a member of the National Futures Association (the “NFA”). FDS filed a notice of claim for exemption pursuant to CFTC Rule 4.7 on March 24, 2022. Rule 4.7 exempts a CTA and a CPO that files a notice of claim for exemption from having to provide a CFTC-mandated Disclosure Document to certain highly accredited clients known as Qualified Eligible Participants (“QEPs”) who consent to their accounts being Rule 4.7-exempt QEP accounts. Accordingly, FDS is exempt from the requirement to provide a CFTC Disclosure Document with respect to its Rule 4.7- exempt QEP accounts. In addition, certain FDS supervised persons are registered with the NFA as “associated persons” of FDS, if necessary or appropriate to perform their responsibilities. From time to time, a manager, analyst or other employee of FDS or its affiliates will express views regarding a particular company, security, industry, or market sector. The views expressed by any such person are the views of only that individual as of the time expressed and do not necessarily represent the views of FDS or its affiliates or any other person in their organizations. Any such views are subject to change at any time based upon market or other conditions, and FDS and its affiliates disclaim any responsibility to update such views. These views may not be relied on as investment advice and, because investment decisions for an account managed by FDS or its affiliates are based on numerous factors, may not be relied on as an indication of trading intent on behalf of an account. FDS or its affiliates generally have authority to determine which Investments to purchase or sell, the total amount of such purchases and sales, and the brokers or dealers through which transactions are effected as well as the hold period of each Investment. However, with respect to each discretionary account, FDS’s and its affiliates’ authority is subject to certain limits, including applicable investment objectives, policies, and restrictions. These limitations are based on a variety of factors, such as regulatory constraints, as well as policies imposed by a Client’s Governing Documents or its governing body (e.g., board of trustees, general partner, and/or investment committee) and may cause differences in an account’s holdings, risk profile, commission rates, timing of trades and overall execution. With respect to certain of FDS’s collective investment vehicle clients (e.g., investment companies, private funds), many of the applicable investment policies and limitations are set out in each client’s Governing Documents, as well as certain regulatory filings, when and if required. With regard to accounts or collective investment products governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), the client is responsible for a plan’s compliance with requirements concerning Investments in “employer securities,” “employer real property,” “qualifying employer securities” or “qualifying employer real property” (as such terms are defined in Section 407 of ERISA) (collectively, “restricted securities”) and for identifying certain financial intermediaries or parties in interest that could result in prohibited transactions under ERISA, including, but not limited to, broker-dealers affiliated with such plan. The client is also responsible for informing FDS in writing of any restrictions on account Investments (including identifying such restricted securities or parties in interest to the plan) required in order for that plan to comply with ERISA. In the absence of such information or notification from a client, FDS takes no responsibility to limit Investments in such restricted securities or monitor transactions with client-affiliated financial intermediaries or other parties in interest to the plan to the extent such restrictions are necessary to avoid a non-exempt prohibited transaction under ERISA. FDS does not generally provide claims filing services seeking recovery as a potential class member of a securities class action or enter into securities litigation on behalf of its separate account clients. For FDS’s collective investment products, FDS handles such activities according to its policies and procedures. These policies and procedures provide for, among other things, the handling of certain events, such as dissolution of a collective investment product prior to receipt of certain class action proceeds, and the disposition of de minimis amounts and/or proceeds. Upon request, FDS may provide pricing information to a client about securities held in that client’s account that have been subject to a fair market valuation. However, FDS does not provide pricing services. 6 of 64 Regulatory Assets Under Management: As of January 3, 2023, FDS managed $86,361,473 of client assets on a discretionary basis. As of January 3, 2023, FDS did not have any non-discretionary regulatory assets under management.