FIRM OVERVIEW Allspring Investments, was incorporated in the State of California in 1981 and converted to a Delaware limited liability company in 2021. Allspring Investments has been registered as an investment adviser with the SEC since April of 1984. Allspring Investments is a direct wholly- owned subsidiary of Allspring Global Investments Holdings, LLC (“Allspring Global Investments Holdings”), a holding company indirectly owned by Allspring Group Holdings. LLC (“Allspring Group Holdings”). Allspring Group Holdings is owned by certain private funds of GTCR LLC (“GTCR”) and Reverence Capital Partners, L.P. (“Reverence Capital Partners”), as well as certain others described below. Allspring Investments has offices located throughout the United States, as well as internationally. Certain employees of the Allspring Global Investments Holdings group of companies1 indirectly own non-voting interests in Allspring Group Holdings, the indirect parent of Allspring Investments and the other Allspring Global Investments group of companies. Such Allspring employees hold less than 25% of the fully diluted equity interests of Allspring Group Holdings. In addition, Wells Fargo owns a passive non-voting equity interest of less than 8.3% of the fully diluted equity interests of Allspring Group Holdings and continues to serve as an important client and distribution partner. Founded in 1980, GTCR is a leading private equity firm that pioneered The Leaders Strategy™ – finding and partnering with management leaders in core domains to identify, acquire and build market-leading companies through organic growth and strategic acquisitions. GTCR is focused on investing in transformative growth in companies in the Business & Consumer Services, Financial Services & Technology, Healthcare and Technology, Media & Telecommunications sectors. Since its inception, GTCR has invested more than $24 billion in over 270 companies, and the firm currently manages over $27 billion in equity capital. GTCR is based in Chicago with offices in New York and West Palm Beach. Reverence Capital Partners is a private investment firm focused on thematic investing in leading 1 Allspring Global Investments is the trade name for the asset management companies of Allspring Global Investments Holdings, LLC, that includes Allspring Investments; Allspring Funds Management, LLC (“Allspring Funds Management”), Allspring Global Investments (UK) Limited (“Allspring UK”), Allspring Funds Distributor, LLC (“Allspring Funds Distributor”), Allspring Global Investments Luxembourg S.A. (“Allspring Luxembourg”), Allspring Global Investments (Singapore) Pte. Ltd.; Allspring Global Investments (Hong Kong) Limited (“Allspring Hong Kong”) and Allspring Global Investments (Japan) Limited (“Allspring Japan”). Associated with Allspring, but not part of the Allspring trade name/GIPS firm, is Galliard Capital Management, LLC (“Galliard”). global, middle-market financial services businesses through control and influence-oriented investments in five sectors: (1) Depositories and Finance Companies, (2) Asset and Wealth Management, (3) Insurance, (4) Capital Markets and (5) Financial Technology/Payments. The firm was founded in 2013 by Milton Berlinski, Peter Aberg, and Alex Chulack, who collectively bring over 90 years of advisory and investing experience across a wide range of financial services sectors. Prior to November 1, 2021, Allspring was owned by Wells Fargo & Company (“Wells Fargo”). Given the large scale and complexity of the divestiture of Allspring from Wells Fargo to new ownership, some technology infrastructure, operational processes and Allspring employees will temporarily remain at Wells Fargo to manage critical processes and systems that transition over time, under a Transition Services Agreement (“TSA”) between Allspring and Wells Fargo. Additionally, subject to applicable fiduciary duties and other considerations, Wells Fargo remains an important distribution partner with respect to Allspring’s products in a manner similar to their role prior to the divestiture. TYPES OF ADVISORY SERVICES Allspring Investments provides investment management services to mutual funds, private funds, offshore funds, collective investment trusts (“CITs”), pooled vehicles, retail clients and other institutional clients, including corporations, endowments, foundations, pension plans, healthcare organizations, educational organizations, public agencies, multi-employer plans, sovereign organizations, insurance companies, Taft-Hartley plans, other investment advisers and high net worth individuals. Allspring Investments’ investment management services are offered on both a discretionary and non-discretionary basis. When Allspring Investments offers advice on a discretionary basis, the client relies on Allspring Investments to formulate and, in most cases, to implement the investment decisions consistent with parameters and information that the client provides in advance. Allspring Investments will tailor its investment management services to the individual needs of its clients, including by incorporating client specific restrictions, as necessary. However, Allspring Investments will not be able to accommodate investment restrictions that are unduly burdensome, including any requested restrictions on underlying securities held in a fund/commingled vehicle in which the client invests. Allspring Investments reserves the right to decline to accept, or terminate, client accounts with such restrictions. Investment restrictions requested by a client may cause the performance of its account to differ from that of the portfolio recommended by Allspring

Investments, possibly producing lower overall results. Allspring Investments also provides non-discretionary investment management services that include providing securities ranking information and model portfolios to other investment advisers, including one affiliated investment adviser. As explained in Item 8 below, Allspring Investments’ non-discretionary services are used by other investment advisers to provide advisory services to their clients. Where Allspring Investments is the investment adviser to a pooled investment vehicle (e.g., mutual fund or private investment fund), investments will not be tailored to the individualized needs of any particular investor in the pooled investment vehicle (each an “Investor”). Investors may not impose restrictions on investing in certain securities or certain types of securities but rather will be subject to the investment guidelines as described in the vehicle’s prospectus or other offering document. Allspring Investments utilizes proprietary and vended investment allocation systems in conjunction with the securities selection services provided by its portfolio managers to create and maintain actively managed investment portfolios intended to meet the requirements of its clients’ investment needs. Allspring Investments offers a variety of equity, multi-asset, and fixed income investment strategies and these investment strategies (collectively) may invest in a wide variety of financial instruments. In circumstances where a client is willing to accept greater risk in pursuit of potential higher total return, Allspring Investments also uses certain types of techniques, including buying securities on margin, and selling securities short. WRAP FEE PROGRAMS Allspring Investments provides investment sub-advisory services to its affiliate, Allspring Funds Management, LLC (“Allspring Funds Management”), in connection with separately managed account programs (referred to as “wrap fee programs” or “SMA programs”) for which Allspring Funds Management provides investment advisory services. The wrap fee or SMA programs are sponsored by certain broker dealers or investment advisers (“Sponsors”). With respect to a traditional wrap fee program, the Sponsor typically offers clients the ability to have their accounts managed by one or more participating investment advisers, including Allspring Investments’ affiliate, Allspring Funds Management, in the form of separately managed accounts. For a single, unified or wrap fee, that typically includes investment management, brokerage, custody and other program services, these Sponsors provide a variety of services to their clients in these programs including selecting and monitoring the services of the participating investment advisers, defining client investment objectives and risk tolerances, evaluating performance, and maintaining records relating to the account. The Sponsor typically pays Allspring Funds Management a portion of the wrap fee that the client pays to compensate Allspring Funds Management for its investment advisory services. The fee is based on the assets of clients invested in the applicable strategy in the wrap fee program. Allspring Funds Management pays a portion of the fee it receives from the Sponsor to Allspring Investments. In most cases, Allspring Investments provides model portfolios to Allspring Funds Management, and, depending on the program, Allspring Funds Management or its outsourced provider will either implement the model portfolio for program participant accounts according to account guidelines – which are provided by the Sponsor – or communicate the model portfolio to the Sponsor to implement for the account. In both instances, Allspring Investments is providing the model portfolio to Allspring Funds Management on a non-discretionary basis. When Allspring Investments is providing investment advice to Allspring Funds Management on a non- discretionary basis, it does not consider the program participant to be an Allspring Investments client. Pursuant to an agreement, Allspring Funds Management relies on Allspring Investments to provide trading and/or other support services related to these programs. In instances where Allspring Investments is providing overlay service via strategy or account optimization, Allspring Investments is considered to have discretion. With respect to fixed income strategies that are available in wrap programs, Allspring Investments shares discretionary investment authority over the program participants’ accounts that are invested in these strategies. Under these circumstances, Allspring Investments considers and manages the account according to the program participant’s individual needs and guidelines which are provided by the Sponsor. Unlike Allspring Investments’ institutional clients, however, Allspring Investments does not communicate directly with these program participants. Wrap fee program accounts may not be managed identically to institutional accounts so, purchases that are implemented for institutional accounts will not always be reflected or fully reflected in a wrap account that follows the same or a substantially similar strategy. To the extent that a sponsor of an SMA program provides Allspring Investments’ Form ADV Part 2A to SMA program clients with whom Allspring Investments has no advisory relationship, or when it is not legally required to be delivered, it is provided for informational purposes only. CURRENT ASSETS UNDER MANAGEMENT As of December 31, 2022, Allspring Investments had $367,020,434,482 in regulatory assets under management on a discretionary basis and $146,640,494 in regulatory assets under management on a non-discretionary basis.