Background Mellon Investments Corporation is a corporation organized under the laws of the State of Delaware. We are an indirect subsidiary of The Bank of New York Mellon Corporation (“BNY Mellon”). Advisory Business The Firm is an investment adviser registered as such with the U.S. Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940, as amended (“Advisers Act”). The Firm provides discretionary advice to institutional clients, including U.S. and global pension funds, sovereign wealth funds, central banks, endowments, trusts, foundations, insurance companies, registered mutual funds, other pooled investment vehicles and other institutions. The Firm operates through two separate “Divisions”: Mellon, which specializes in index management; and Dreyfus, which specializes in cash management and short duration strategies. The Divisions operate semi-autonomously under the umbrella of the Firm, subject to the global policies and procedures of the Firm and BNY Mellon, as applicable. Clients typically obtain our investment advisory services pursuant to (i) an investment management or sub-advisory agreement with us; The Bank of New York Mellon, a New York chartered bank (the “Bank”) (when our employees are acting as dual officers of the Bank); or BNY Mellon Investment Adviser, Inc., an affiliated investment adviser (when our employees are acting as dual employees of BNY Mellon Investment Adviser, Inc.); or (ii) by operation of a trust agreement or participation agreement with the Bank (when our employees are managing collective investment funds of the Bank as dual officers of the Bank) or (iii) through participation in a wrap fee program (as described further below). Investors also access our investment advisory services by investing in commingled vehicles which are sponsored or established by the Firm, our affiliates, or unaffiliated third parties. See Item 4 “Dual Officers” for more information about our dual officer arrangements. Additional relationship-based services are provided for existing clients and prospective clients. Such relationship-based services are negotiated individually with each client and in most instances include account monitoring or trading or strategic allocation services. We provide advice through consultations or the provision of research reports. The exact nature of the consultation depends upon the requirements of the client. Topics include, but are not limited to, asset allocation, evaluation of new investment services relative to the client’s needs and product development. On select occasions or as part of a consultation, we prepare special reports or analyses for existing and prospective clients relating to securities, such as a study of security transactions costs (which typically include charts or graphs). Wrap Fee Programs A client in a wrap fee program (“Wrap Fee Program”) typically receives investment management of account assets through one or more investment managers (including the Firm) participating in the Wrap Fee Program, together with trade execution, custodial, performance monitoring and reporting services (or some combination of these or other services) for a single, all-inclusive “wrap-fee” charged by the program sponsor (“Sponsor”) based on the value of the client’s account assets. The Firm serves as a discretionary manager to one or more Wrap Fee Programs. The Firm currently serves as manager for an affiliated Sponsor, BNY Mellon Adviser, Inc. A client in a managed account/wrap fee program (“wrap fee program”) typically receives professional investment management of account assets through one or more investment advisers (including us) participating in the wrap fee program and trade execution, custodial, performance monitoring and reporting services or some combination of these or other services for a single, all-inclusive (or “wrap”) fee charged by the program sponsor based on the value of the client’s account assets. The Sponsor (or another financial intermediary that has the primary relationship with the client) typically assists the client in defining the client’s investment objectives based on information provided by the client, aids in the selection of one or more investment managers to manage the client’s account and periodically contacts the client to ascertain whether there have been any changes in the client’s financial circumstances or objectives that warrant a change in the arrangement or the manner in which the client’s assets are managed. In Wrap Free Programs, the client enters into an advisory agreement with the Sponsor and the Sponsor enters into a related agreement with the Firm under which the Firm is made available as a manager. Accordingly, the Firm is retained by the Sponsor, and clients can select the Firm from among the investment managers that the Sponsor presents to them. Upon accepting management of a Wrap Fee Program account, the Firm provides investment advisory services to the account in accordance with the investment guidelines applicable to the investment strategy selected as well as any other applicable investment guidelines or investment restrictions. Clients participating in Wrap Fee Programs receive a disclosure brochure from the Sponsor detailing the Wrap Fee Program prior to their selection of the Firm as a manager. This disclosure brochure includes a description of the services provided by the Sponsor and the applicable fee schedule. The fees and features of each Wrap Fee Program vary and, therefore, clients in Wrap Fee Programs should consult the Sponsor’s brochure for the fees and features applicable to their account. We do not act as a Sponsor of any Wrap Fee Program. Sponsors, however, are able to obtain brokerage, clearing and other wrap program services from our affiliates. Please refer to Item 8 of this Brochure for a description of the strategies provided by each Division in which we invest client assets. Investment Guidelines The Firm offers a variety of carefully developed investment strategies (“Strategies” and each, a “Strategy”). We tailor our services to meet clients’ investment goals and we work with clients to create investment guidelines that are mutually acceptable to the client and to us. When creating investment guidelines, clients are able to impose investment restrictions in certain individual securities or types of securities. Clients who impose investment

restrictions are advised that the imposition of such restrictions can limit our ability to employ the strategy on that client’s behalf and can potentially result in investment performance that differs from that of the model and other client accounts. The Firm also offers investment advisory services in the form of pooled investment vehicles or “Funds.” Each pooled investment vehicle has an investment objective and a set of investment policies and/or guidelines that we must follow. For these reasons, we cannot tailor the investment guidelines of these vehicles to meet individual investor needs. In addition, we cannot impose individual investment restrictions on our investment strategies for underlying investors in the pooled investment vehicles. Dual Officers Certain employees of the Firm serve as officers or employees of affiliates of the Firm, and certain employees of our affiliates, in turn, serve as officers of the Firm (“dual officers”), each for the purpose of performing investment management and related functions. Such affiliates include the Bank and BNY Mellon Investment Adviser, Inc. (“BNYMIA”). In this dual officer capacity, our employees are authorized to:
• Manage assets of certain of the Bank’s collective investment funds; and
• Manage separate accounts, registered investment companies and other commingled and/or pooled investment vehicles on behalf of the Bank and BNYMIA.
• Perform administrative and other related functions. Other personnel responsible for trade execution for the Firm are employees of xBK LLC, an indirect subsidiary of BNY Mellon. Such trading personnel have been appointed dual officers of the Firm and provide trade execution services to the Firm in this capacity. When the Firm’s personnel act as dual officers or employees of the Bank or BNYMIA, in managing portfolios, the Firm receives compensation. In certain instances, we enter into revenue sharing arrangements with affiliates where we receive a portion of the fee or bill the entire fee to the client and reimburse the affiliate for amounts in excess of our revenue share. Please refer to Item 5 for fee descriptions and Item 8 for investment strategy descriptions. When we share personnel with our affiliates pursuant to these arrangements, such personnel are subject to the Firm’s compliance policies and procedures when acting on behalf of the Firm, and additionally, subject to the policies and procedures of the affiliate when acting on behalf of that affiliate. Assets Under Management As of December 31, 2023, the assets under management of the two divisions under the Firm taken together were $ 842,832,323,701. . This amount includes: $ 168,655,899,628 managed by certain of our officers in their capacity as dual officers of BNY Mellon Investment Adviser, Inc. and the Bank, which are not reported as regulatory assets under management in Form ADV Part 1A. The assets under management figures referenced above differ from the regulatory assets under management required to be reported in Form ADV Part 1A. Regulatory assets under management include only the assets of portfolios deemed to be “securities portfolios.” The SEC has defined a securities portfolio as a portfolio that holds at least 50% of its value in securities. In addition, regulatory assets under management are calculated gross of any fees, unpaid liabilities or outstanding indebtedness. Class Actions: Litigation It is our policy that we do not advise, initiate or take any other action on behalf of clients relating to securities held in the client’s account managed by us in any legal proceeding (including, without limitation, class actions, class action settlements and bankruptcies). The Firm does not file proofs of claims relating to securities held in the client’s account and does not notify the client or the client’s custodian of class action settlements or bankruptcies relating in any way to such account. Typically, custodians submit filings in connection with class action settlements and may also handle bankruptcy filings. Each client should consult with its custodian and other service providers to ensure such coverage. Privacy Policy Our privacy policy applies to entities and individuals who obtain investment management services from us for personal, family or household purposes, or have done so in the past. The policy may be amended at any time. We will notify customers of changes as required by law. Additionally, our customers may request a copy of our privacy policy at any time. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard non-public information. We are careful to limit access to nonpublic information. Our employees have access to customer information based on their responsibilities. This access enables them to assist in completing transactions and resolving any customer service issues that may arise. We collect nonpublic personal information about customers from account opening documentation and transactions with us. We do not share information subject to the privacy policy with anyone, except as authorized by the customer or permitted by law. Personal information is collected and held by Mellon Investments Corporation and its affiliates and is used for the purpose(s) of processing transactions, maintaining account(s), carrying out “know-your-customer checks”, responding to court orders and legal investigations, or report to credit bureaus. This also includes potential use for marketing purposes, to offer our products and services to you. Personal information is shared within the BNY Mellon Corporation and its affiliates. Personal information will not be shared with external third parties unless such disclosure is required by law and/or to meet our regulatory obligations. Mellon Investments Corporation will transfer or store personal information in other countries, including those outside Europe, under the protection of appropriate safeguards. For more information about how we collect, use and share personal information and your legal rights, please select the link below to view the full privacy notice. The Firm’s Privacy Notices for each division can be found here: Mellon Privacy Notice and Dreyfus Privacy Notice