Advisory Business A. General Description of Advisory Firm Brandywine Global Investment Management, LLC (“Brandywine Global” “The Firm” “we” or “our”) is registered as an investment adviser with the SEC. Brandywine Global is a wholly-owned indirect subsidiary of Franklin Resources, Inc., (“Franklin Resources”), a publicly-held global asset management company. Founded in 1986, Brandywine Global offers an array of equity, fixed income, and balanced portfolios that invest in U.S., international, and global markets. Brandywine Global is headquartered in Philadelphia with office locations in Columbus, Singapore and London. B. Description of Advisory Services Brandywine Global provides discretionary investment management services to a variety of clients including institutions, individuals, and various registered and unregistered pooled investment vehicles. In addition, Brandywine Global is the sub-adviser to affiliated and non-affiliated mutual funds, UCITS funds, and other pooled investment vehicles, and acts as a sub-adviser to several wrap programs sponsored by unaffiliated program sponsors (“Sponsors”). Brandywine Global also provides portfolio research services in the form of model investment portfolios to affiliated and non-affiliated investment advisers or other financial service providers for negotiated fees. C. Client Restrictions Each client portfolio is tailored to meet the individual needs of each client. Clients have the ability to provide Brandywine Global with specific investment parameters in the form of investment guidelines. The guidelines may include, for example, restrictions on investing in certain securities, industries, security types, issuers or securities with certain credit ratings. The investment guidelines form a part of our management agreement with a client, and Brandywine Global manages the client’s account within these parameters. Clients should be aware, however, that some restrictions can limit our ability to act, and as a result, the account’s performance may differ from and be less successful than that of other accounts that have not limited our discretion. Clients should also be aware that investment guidelines sometimes do not anticipate every investment scenario and can therefore sometimes be open to multiple interpretations. In such circumstances, Brandywine Global will use its best efforts to interpret

the investment guidelines in a manner that is consistent with a client’s investment goals and such interpretations will govern the management of the account. D. Wrap Programs Brandywine Global serves as an investment adviser in one or more “wrap” programs that are offered by third-party wrap program Sponsors (typically broker-dealers). A wrap 2 Brandywine Global Investment Management, LLC ADV Part 2A Brochure – 2023 program is an investment advisory program under which a client typically pays a single fee to the Sponsor based on assets under management, and client fees paid to the Sponsor typically are not based directly upon transactions in the client’s account or the execution of client transactions. Wrap program clients typically select Brandywine Global from a list of investment advisers presented to clients by registered representatives of the Sponsor. Wrap program clients are typically high net worth individuals. The Sponsor has primary responsibility for client communications and service, and Brandywine Global provides investment management services to the clients. The Sponsor typically executes a client’s portfolio transactions, and in most cases, provides custodial services for the client’s assets for a single fee paid by the client to the Sponsor. Brandywine Global is paid a portion of the wrap fee (management fee) for its services by the program Sponsor. Brandywine Global also advises several “model only” investment programs whereby Sponsors utilize a Brandywine Global “model” portfolio to implement an investment program for investors. In such cases, Brandywine Global receives a management fee from the Sponsor based on the assets managed by the Sponsor in accordance with the model portfolio. Investment decisions for wrap program clients through Sponsor programs and other non- wrap accounts are managed in the same investment style. There may be differences, however, at the individual account level due to restrictions or limitations imposed on Brandywine Global by the wrap program account holder and/or the wrap program Sponsor, or differences in both the time of order execution and price for different account types. E. Assets Under Management As of September 30, 2023, Brandywine Global managed $53,057,098,257.00 on a discretionary basis and $2,969,287,578.00 on a non-discretionary basis.