A. General Description of GAMCO GAMCO Investors, Inc. (“GAMCO Investors”) is known for its research-driven value approach to equity investing (known as Private Market Value with a Catalyst™). This investment philosophy has been utilized in client portfolios since GAMCO Investors, Inc.’s inception in 1977. The investment advisory business of GAMCO Investors is conducted through two wholly-owned affiliates: GAMCO Asset Management Inc. (“GAMCO” or the “Firm”), and Gabelli Funds, LLC (“Gabelli Funds”). GAMCO was established in 1978 by founder Mario J. Gabelli, CFA, and manages institutional and separate account portfolios. As of December 31, 2024, GAMCO managed approximately $10.4 billion of assets under management (AUM) for clients, including sub-advisory mandates. GAMCO Investors is a Delaware corporation, whose Class A Common Stock is traded on the OTCX under the symbol (“GAMI”). Mario J. Gabelli, CFA, is deemed to be the controlling person of GAMCO on the basis of his ownership of a majority of the stock of GGCP, Inc., a privately held Wyoming corporation, which holds a controlling interest in GAMCO Investors. B. Description of Advisory Services GAMCO offers investment management services across numerous asset classes and solutions, including: value, growth, sustainability, convertibles, industry sector- specific funds, event-driven merger arbitrage, and fixed income. The firm manages client-directed custom separate accounts for a variety of client types, including corporate employee defined benefit and defined contribution plans, endowments and foundations, Taft- Hartley plans, domestic and offshore investment companies (generally as a sub-advisor), limited partnerships, trusts, estates, and private investors. In addition to investment management services GAMCO provides limited asset allocation services to a small number of clients. Clients that want GAMCO’s investment management service may seek advice on how those assets should be allocated amongst GAMCO managed products. GAMCO receives no fee for this service other than the fees charged by the underlying investment product (i.e. Managed Account, Mutual fund, Private Fund). To the extent GAMCO allocates to unaffiliated products GAMCO will receive a fee based on the amount of underlying assets invested in those unaffiliated products. GAMCO may allocate to ETF’s or other products managed by outside advisers to the extent GAMCO does not offer a similar product. The majority of the firm’s revenues are derived from investment management services. GAMCO generally manages assets on a fully discretionary basis and revenues are based primarily on GAMCO’s assets under management. By asset class, GAMCO manages the following institutional separate account composites, among others:
• All Cap Value – Gabelli Value, GAMCO Value
• Sustainability – Gabelli Socially Responsive, GAMCO SRI Value
• Small Cap Value – Gabelli Small Cap Value, GAMCO Small Cap Value
• Small-Mid (SMID) Cap Value – Gabelli SMID Cap Value, GAMCO SMID Cap Value
• Large Cap Value – GAMCO Large Cap Value
• Growth – GAMCO Large Cap Growth, Gabelli International Growth
• Specialty Funds – GAMCO Gold
• Convertible Securities – GAMCO Convertible
• Fixed Income – GAMCO High Yield Mario J. Gabelli, CFA serves as CEO of GAMCO Investors and Chief Investment Officer, Value, and founded GAMCO Investors in 1977. Mr. Gabelli serves as portfolio manager for the following GAMCO institutional separate account composites: Gabelli Value, Gabelli Socially Responsive, Gabelli SMID Cap Value, GAMCO Convertible. From time to time Mr. Gabelli may allocate discretion over assets in portfolios he manages to other portfolio managers to manage in a manner consistent with client investment guidelines. Kevin V. Dreyer and Christopher J. Marangi are GAMCO Investors co-Chief Investment Officers, Value. Mr. Dreyer and Mr. Marangi serve together as a portfolio manager team for the following institutional separate account composites: GAMCO Value, GAMCO SRI Value, GAMCO SMID Cap Value, GAMCO Large Cap Value. Howard Ward, CFA is GAMCO Investors Chief Investment Officer, Growth. Mr. Ward serves as lead portfolio manager for GAMCO Large Cap Growth. Caesar Bryan is a

Portfolio Manager for Growth at GAMCO Investors, and serves as lead portfolio manager for Gabelli International Growth. Wayne Plewniak is a Portfolio Manager for Fixed Income at GAMCO Investors, and serves as lead portfolio manager for GAMCO High Yield. Value Philosophy GAMCO is credited by the academic community with establishing the Private Market Value (PMV) with a Catalyst™ investment philosophy and applying this to the analysis of public equity securities. The Firm’s value-oriented stock selection process is based on the investment principles first articulated in 1934 by Graham and Dodd, the founders of modern security analysis, and further augmented by our Firm’s founder, Mario J. Gabelli, at the inception of GAMCO Investors in 1977. The PMV with a Catalyst philosophy, and our investment beliefs, have not changed since this time. The Value team believes mispriced companies with strong businesses and the presence of a catalyst to surface value lead to investment opportunities through fundamental research and bottom-up stock selection. Growth Philosophy The Growth team seeks to invest in the innovative leaders of the world demonstrating sustainable revenue and earnings growth and attractive valuations. Secular growth themes and fundamental analysis is combined with a top-down macro overlay. Business cycle analysis is utilized as a macro overlay to inform geographic and sector weightings. C. Availability of Tailored Services for Clients GAMCO will tailor an account to the needs of a client. Clients may furnish GAMCO with investment guidelines that are aligned with their specific investment policies and objectives. Clients may also impose restrictions on investing in certain securities or certain types of securities. As part of its willingness to tailor accounts to specific client needs, GAMCO may from time to time agree to provide investment management services on a basis that includes payment of all brokerage commissions by GAMCO. Such arrangements are atypical and will have fees that reflect the size of the account, and the degree of active management given to the portfolio. D. Wrap Fee Programs GAMCO does not sponsor any “wrap-fee” programs, but participates as a non-discretionary sub-adviser in “wrap fee” or unified managed account (“UMA”) arrangements in which a third party program sponsor offers our firm’s strategies to its clients. GAMCO provides investment advisory services either directly to the SMA Program Sponsor (“Single Contract SMA”) or SMA Program participants (the agreement referred to herein as a “Dual Contract SMA”) depending on the program (collectively the “SMA Program”). GAMCO provides investment advice to UMA programs (“UMA Programs Sponsors”) through model investment portfolio or unified managed account programs (“UMA Portfolio Programs”). GAMCO receives a fee for investment advisory services from the wrap program sponsor. Given that GAMCO delivers model portfolios to wrap sponsors, GAMCO does not execute trades, monitor participant accounts or otherwise have a relationship with participants. GAMCO manages such accounts in a substantially similar manner to its other accounts, except that GAMCO does not execute trades for these accounts. In evaluating such a program, a client should understand that brokerage commissions are not negotiated by GAMCO. Transactions are effected “net” and a portion of the wrap fee is generally in lieu of commissions. Trades will be generally executed only with the referring broker, so as to avoid incurring the incremental brokerage costs that would be incurred by use of other brokers. Clients in these wrap programs must look to the sponsor of the program to monitor best execution. Clients should be aware of the potential conflicts of interest arising from referral and directed brokerage practices. GAMCO recommends that a client in a wrap fee program request and review the wrap sponsor's Form ADV. E. Client Assets Under Management At December 31, 2023, GAMCO managed approximately $10.4 billion, including sub- advisory mandates, of client assets on a discretionary basis in approximately 1,645 accounts and approximately $24 million on a non-discretionary basis in approximately 6 accounts.