Westwood Management Corp. (“Westwood”) is an investment advisory firm that has been in business since 1983. Westwood is a wholly owned subsidiary of Westwood Holdings Group, Inc. (“WHG”), a publicly held company listed on the New York Stock Exchange since July 1, 2002. WHG’s subsidiaries include the following entities: Broadmark Asset Management, LLC (“Broadmark”), an SEC-registered investment adviser and CFTC-registered commodity trading advisor; Forward Securities, LLC (“Forward Securities”), an SEC-registered broker-dealer and FINRA member; Salient Advisors, LP (“Salient Advisors”) an SEC-registered investment adviser and CFTC-registered commodity pool operator; Salient Capital, LP (“Salient Capital”), an SEC- registered broker-dealer; Westwood Advisors, L.L.C. (“Westwood Advisors”), an SEC-registered investment adviser; Westwood Trust, a Texas-chartered Trust company headquartered in Dallas, Texas. Salient Advisors, Salient Capital, Westwood, Westwood Advisors and Westwood Trust are wholly owned by WHG. Broadmark is a majority-owned subsidiary of WHG. In addition, WHG owns 50% of The Salient Zarvona Energy Fund GP, LP, an SEC-registered investment advisor and private fund sponsor. In November 2022, Westwood Holdings Group, Inc. completed the acquisition of the asset management business of Salient Partners, LP and its subsidiaries (generally, “Salient”). Salient, based in Houston, Texas with an office in San Francisco, California, provided investment advisory services through Salient Capital Advisors, LP and Forward Management, LLC, both SEC- registered investment advisors. Pursuant to the transaction, Westwood Holdings Group, Inc. and its subsidiaries acquired substantially all of the assets of Salient and its subsidiaries. Generally, investment advisory agreements with Salient Capital Advisors and Forward Management were assigned to Westwood Management Corp. upon client notice and consent. In addition, Westwood Holdings Group, Inc. also purchased all of the equity ownership in Salient Advisors, Salient Capital and Forward Securities as well as Salient’s equity ownership in The Salient Zarvona Energy Fund GP, LP. Westwood Holdings Group, Inc. purchased all of Salient’s minority interest in Broadmark and also purchased additional equity ownership of Broadmark in January 2023, giving Westwood Holdings Group, Inc. a majority ownership stake in Broadmark. Westwood provides portfolio management services to individuals, investment companies, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, state and municipal government entities, pooled investment vehicles, and sovereign wealth funds. Westwood provides investment management services to investment companies, private funds and other pooled investment vehicles both directly as the primary investment adviser and on a sub-advised basis when retained by a fund’s investment adviser. Westwood provides investment management services to clients by providing ongoing implementation of its investment strategies, or in the case of model portfolios or other non-discretionary services, provides ongoing updates to its investment advice. Generally, in the case of model portfolio services, Westwood provides investment recommendations to other advisers in the form of a model portfolio which these advisers have full discretion to implement for their own clients. Westwood tailors its services to specific client needs. Westwood carries out its investment management responsibilities in accordance with the investment guidelines and policy directives provided by the client. In these written guidelines, clients may impose restrictions on investing in certain securities or types of securities. Clients may also impose restrictions on investments in certain industries, sectors, or asset classes. Westwood typically implements and monitors a client’s guidelines by entering restrictions in its trade compliance system that interfaces with its trade order management system. At account setup and as client guidelines are revised, a Compliance Officer identifies all guideline restrictions and inputs the information into the trade compliance system. Restrictions entered into the trade compliance system are checked and verified by investment personnel. The trade compliance system electronically monitors and enforces guideline restrictions including stock, industry, and sector specific restrictions. The Compliance Officer and investment personnel monitor account guidelines on a daily basis via the trade compliance system. Any restrictions that cannot be entered into the trade compliance system are monitored manually and reported to the Portfolio Teams on a periodic basis. In addition, Westwood reviews all accounts annually to ensure that the investment guidelines are current and correctly entered into the trade compliance system. Westwood provides portfolio management services for wrap fee programs and other separately managed account platforms (including platforms that charge separate fees for investment advice and brokerage services) for the following investment strategies:
• AllCap Value
• High Income SMA
• Income Opportunity SMA
• LargeCap Value
• MidCap Value
• MLP SMA
• SmallCap Value
• SMidCap Value
• Tactical Growth
• Total Return SMA Strategies in these programs are implemented substantially the same as in Westwood’s institutional accounts; however, wrap account and separately managed account trades are not aggregated with Westwood’s other trades because they typically trade on the sponsors’ platforms or have directed brokerage relationships. Wrap program sponsors and other investment advisers receiving Westwood model portfolios are primarily responsible for evaluating suitability and adhering to client-imposed investment restrictions. Retail separately managed accounts are generally subject to a minimum account size requirement of $100,000. Program sponsors may have additional minimum requirements. Westwood is typically compensated for its services in wrap fee and other managed account programs by receiving a portion of the fees charged to clients by program sponsors. The fee is typically based on the sponsor’s assets under management attributable to Westwood’s investment strategies and is calculated and paid by the sponsors. Investment Opportunity Allocation Westwood’s investment strategies and advisory services are provided across a variety of types of relationships including mutual fund and other pooled investment vehicles,

institutional separate accounts, separately managed accounts and model portfolio-based separately managed account programs or platforms (“Model Portfolio Programs”) in which Westwood’s model portfolios are implemented and traded by the Sponsor or other brokerage firm (“Model Program Sponsor”). Westwood has designed a rotational process designed to achieve an equitable allocation of investment opportunities among its advisory clients for strategies available through wrap programs, other separately managed account platforms and Model Portfolio Programs. This practice is generally referred to as Westwood’s Trade Rotation Policy even though, in the case of Model Portfolio Programs, Westwood does not conduct the trading. For purposes of implementing its Trade Rotation Policy, Westwood has established three groups of account or relationship types based on the manner in which Westwood implements investment services:
• The Institutional Trade Rotation Group which includes mutual funds, other collective investment vehicles and most institutional separate accounts;
• The Managed Account Group or MAG Trade Rotation Group which includes separately managed accounts traded by Westwood as well as certain institutional separate accounts; and
• The Model Portfolio Rotation Group which consists of Model Portfolio Programs. Westwood trades or provides model portfolio updates, as applicable, to these account groups based on an order set each calendar month. Subject to exceptions summarized below, all internal model updates started during the month will be implemented in that order and the order is indexed for the following month such that the group that traded second during the month will trade first during the next month, the group that traded third will trade second and the group that traded first will trade third. Westwood has set a threshold of a 50 basis points model change as the trigger for its Trade Rotation policy. Changes in the internal model portfolio associated with an investment strategy which do not result in a model weight change of at least 0.50% from the prior model portfolio update are not subject to the Trade Rotation Policy. For model updates below this threshold, Westwood typically implements trading in institutional accounts first, followed by the MAG Trade Rotation Group second and by providing updated models third. Relationships in which Westwood Management Corp. provides a model portfolio to Westwood Trust or Westwood Advisors, LLC but which are traded by Westwood’s Dallas-based trading team will be included in the MAG Trade Rotation Group for purposes of the Trade Rotation Policy. For the Model Portfolio Rotation Group, in lieu of trading, Westwood notifies the Model Program Sponsors by providing an updated model portfolio pursuant to the normal model delivery process for each program. Westwood provides an updated model portfolio to all model portfolio recipients as contemporaneously as practicable. Except as noted below, the following U.S. value strategies are covered by the Trade Rotation Policy:
• AllCap Value
• LargeCap Value
• MLP SMA
• SmallCap
• SMidCap (with legacy SMidCap Plus accounts) Trades and model portfolio updates in these strategies will be subject to the trade rotation policy if Westwood has advisory relationships in a strategy in more than one of the rotation groups. Strategies that do not have accounts in more than one of these groups are not subject to the Trade Rotation Policy. Westwood will generally assume that a Model Program Sponsor has completed trading on the earlier of: (1) two trading days have passed since Westwood delivered a model update, (2) the Model Program Sponsor confirms that it has completed its implementation of the model update, or (3) Westwood determines that sufficient time has elapsed for a Model Program Sponsor to have completed implementation of a model update based on a reasonable estimate of the aggregate quantity of shares to be executed by the Model Program Sponsors and observed trade volume. The Trade Rotation Policy does not apply to the following scenarios:
• Trades based on cash flows and corporate actions;
• New issues, such as IPOs and secondary offerings;
• In certain scenarios, such as material news events, in which Westwood determines to implement trades and model updates contemporaneously; or
• If a strategy subject to rotation is participating in a trade with a strategy not subject to rotation, Westwood may trade outside of the applicable rotation sequence with an equitable adjustment for future trades. Only non-directed accounts that Westwood trades directly will participate in IPOs, other new issues and secondary offerings. Generally, accounts in the MAG Trade Rotation Group will be considered as directed and therefore will not participate in IPOs, other new issues or secondary offerings. However, new positions within the internal model portfolio resulting from participation in the new issue will typically be implemented after completion of the new issues trades in the MAG account trade and in the Model Portfolio Group in the relevant order then applicable. Trading in Multi-Asset SMA Accounts: Income Opportunity SMA, High Income SMA and Total Return SMA Accounts Westwood generally updates and trades accounts assigned to the following multi-assets strategies once a month: Income Opportunity SMA, High Income SMA and Total Return SMA. These Multi- Asset SMA strategies are traded as separate strategies from their respective institutional strategies and trades for the same security are not typically subject to aggregation or rotation with institutional accounts. Tactical Growth Accounts Tactical Growth accounts are traded primarily using volume-weighted average pricing orders and similar trading strategies for exchange traded funds in which substantially all advisory accounts participate. Therefore, trades for the Tactical Growth Strategy are typically not rotated among types of clients. Assets under Management and Non-Discretionary Services Westwood provides non-discretionary services to certain clients on a case-by-case basis. As of December 31, 2023, Westwood managed 307 accounts on a discretionary basis with a value totaling approximately $11,916,051,045Westwood did not have any non-discretionary assets under management. However, Westwood provides non-discretionary investment advice through several model portfolio programs as well as with respect to MLP PE SMA accounts.