New England Asset Management, Inc. (“NEAM”) specializes in offering investment management services primarily to the insurance industry. NEAM was founded under the name of New England Asset Management, Inc. in 1984. NEAM is a wholly-owned subsidiary of General Re Corporation, which is wholly owned by Berkshire Hathaway Inc. Types of Services Offered Asset Management Services NEAM provides asset management services primarily to insurance company clients. These services are specified in a written Investment Management Agreement and/or Investment Services Agreement (collectively “IMA”) between NEAM and each client. Clients authorize NEAM to monitor and direct the investment of securities on a discretionary or non-discretionary basis in accordance with written client investment guidelines and/or other written client instructions or restrictions. NEAM provides clients with periodic market commentary and investment research pieces at no additional charge. Fixed Income Mandates Most discretionary client portfolios managed by NEAM are investment grade fixed income mandates. These portfolios are actively managed on a separate account basis relative to either a broad market or customized benchmark. Preferred Securities Strategy NEAM’s Preferred Securities strategy seeks to generate high levels of after-tax investment income and competitive total returns via investment in preferred stocks and hybrid securities Structured Products Yield Enhancement Strategy NEAM’s Structured Products Yield Enhancement strategy is a specialized income-driven total return strategy aimed at higher yielding fixed income opportunities within the structured securities sector. Equity Strategies NEAM offers two actively managed equity strategies: Focused Value Equity Management strategy (“FVEM”) applies a value-driven approach that seeks to outperform its benchmarks with less volatility over full market cycles by investing in equity investments primarily among the top 1,500 U.S. capitalized stocks and select international stocks. Dividend Select Equity strategy (“Dividend Select”) seeks income enhancement by investing in high-dividend equities from companies with stable earnings profiles. Form ADV Part 2A March 31, 2024 Page 5 NEAM’s ETF strategies seek to provide generic exposure to specific sectors, markets and/or geographic regions by utilizing specific ETFs. The selection of specific ETFs is informed by the research carried out by NEAM’s equity group, the investment guidelines set by the client, and discussions with the client. High Yield Strategies Through a sub-advisory arrangement with Polen Capital Credit, LLC (“Polen Credit”), NEAM offers the following strategies: U.S. Opportunistic High Yield; U.S. High Yield;

Credit Opportunities; and Bank Loan (See Item 8 for strategy descriptions). Clients investing in these strategies will receive Polen Credit’s Form ADV Part 2A from NEAM. They should review it for more information about the sub-adviser’s strategies, risks, and potential conflicts of interest. NEAM offers, through a revenue sharing arrangement with Polen Credit, recommendations to participate in the Institutional Class of the Polen Opportunistic High Yield Fund; Polen U.S. High Yield Fund; Polen Credit Opportunities Fund; or the Polen Bank Loan Fund (each, a “Fund” and collectively the “Funds”) (See Item 5). As a result of this arrangement, NEAM’s Assets Under Advisement (“AUA”) is $266,503,150.73 as of December 31, 2023. Investment Accounting and Reporting Services In addition to providing asset management services, NEAM offers investment accounting and reporting services primarily to insurance company advisory and non-advisory clients. This includes assistance in Schedule D data preparation on an annual and quarterly basis. Enterprise Capital Strategy Services NEAM’s Enterprise Capital Strategy services provide a framework and the analytics to support insurance company clients in achieving their capital management financial goals and enterprise risk management objectives. The primary deliverable is an asset allocation analysis customized to the unique needs of insurance companies, called Enterprise Based Asset AllocationTM (EBAATM). Additional information about NEAM’s Enterprise Capital Strategy services is available upon request. Capital and Risk Analytic (CARA®) Platform The CARA® platform is a web-based investment risk management platform that allows clients to monitor and evaluate their investment portfolios daily. Pooled Investment Vehicles/Private Funds NEAM serves as collateral manager for three collateralized debt obligations (which are no longer offering interests to new investors). The interests in these funds are privately placed security offerings that are exempt from registration under the Securities Act of 1933, as amended, and the funds are exempt from registration under the Investment Company Act of 1940, as amended. Form ADV Part 2A March 31, 2024 Page 6 Tailored Advisory Services NEAM tailors its advisory services to meet the unique needs of its clients. Assets are managed on a separate account basis and investment strategies are developed within guideline constraints unique to each client. Clients may impose restrictions on investing in certain securities or types of securities by specifying in their investment guidelines and/or by notifying NEAM in writing. NEAM’s Assets Under Management (“AUM”) as of 12/31/2023 Discretionary $69,796,781,753 Non-Discretionary $25,438,246,827 Total Assets under Management $95,235,028,581