Firm Description Harris Associates L.P. (“Harris”) or its predecessors have served as investment advisers to individuals and institutions since 1975. Harris is a limited partnership with Harris Associates, Inc. as its general partner. Harris and Harris Associates, Inc. are indirect subsidiaries of Natixis Investment Managers, LLC, which is an indirect subsidiary of Natixis Investment Managers (“Natixis IM”), an international asset management group based in Paris, France that is part of the Global Financial Services division of Groupe BPCE. Natixis IM is wholly owned by Natixis, a French investment banking and financial services firm. Natixis is wholly owned by BPCE, France’s second largest banking group. Harris’ principal owners are BPCE, Natixis, Natixis Investment Managers, Natixis Investment Managers Participations 1 and Natixis Investment Managers, LLC. Types of Investment Advisory Services Discretionary Investment Advisory Services Harris primarily provides discretionary investment advisory services to individuals and institutions, including registered investment companies. As of December 31, 2023, Harris managed approximately $101,220,749,567 on a discretionary basis. When Harris has sole investment discretion, it is authorized to make all investment decisions and to direct the execution of all transactions for the client's account (subject to the investment objectives, guidelines and restrictions that a client may impose on an account) without consulting the client in connection with each transaction. Harris’ discretionary investment advisory services include a variety of investment strategies from which clients may select. These strategies include U.S. equity, U.S. concentrated equity, equity and income, core plus fixed income, global all cap equity, global equity, global concentrated equity, international equity, international small cap equity, Japan equity, balanced, U.S. mid cap equity, private client balanced and private client equity. Harris also provides variations of certain of these strategies to accommodate, among other things, currency hedging or country exclusions. Harris also provides U.S. equity and balanced portfolios to Private Wealth Management clients. In the future, Harris may offer new strategies as opportunities arise. In addition, Harris provides discretionary investment advisory and administrative services to mutual funds, private investment partnerships and other pooled investment vehicles. Harris provides access to these investment vehicles to eligible clients, other advisers’ clients, and financial intermediaries. For more information about an investment vehicle, including investment objectives, risks, and charges and expenses, a client should carefully review such vehicle’s prospectus or offering memorandum before investing. Harris also has arrangements with other advisory firms wherein, while Harris has discretionary authority over certain assets of the other advisory firms’ clients, Harris is not the client’s primary adviser and instead acts in a subadvisory capacity. Wrap Fee Programs, Model Portfolios and Non-Discretionary Advisory Services Harris serves as an adviser or subadviser to third-party sponsored wrap fee programs, whereby the program clients generally receive, in exchange for an all-inclusive "wrap" fee, assistance in determining investment objectives, choosing investment managers, trade execution, custodial services, periodic performance reports and certain other services provided by the program sponsor or broker-dealer, as well as investment management services from investment managers (including Harris) that act as advisers or subadvisers to the program. With respect to certain wrap programs, Harris provides a model portfolio to the program sponsor or broker-dealer that Harris updates from time to time whereby the program sponsor trades the securities in the model portfolio on behalf of their clients. When Harris has sole investment discretion, Harris provides individualized portfolio advice for certain wrap program clients that have selected Harris to manage their program account. Harris manages such program accounts in accordance with the investment policies and any instructions from, and reasonable investment restrictions imposed Harris Associates L.P. Page 5 of 28 by, the client. The program sponsor generally pays Harris a fee based on the assets managed by Harris in connection with these programs, and that fee is generally a portion of the wrap fee paid by the wrap program client. Harris generally does not negotiate advisory fees with any wrap fee program client. Rather, Harris' advisory fees are agreed to with the program sponsor or broker-dealer. The fees received by Harris in connection with wrap programs may vary from fees charged to Harris' other clients and may vary between program sponsors and/or broker-dealers. Harris also provides model portfolios and other investment advisory services to institutional clients or sponsors of certain advisory programs. Sponsors may use Harris’ model portfolios, as well as any ongoing updates to the model portfolio, independently or with other model portfolios to manage the accounts of their clients. Harris provides investment advisory services to certain clients designated by a sponsor to act as investment adviser to each such client and in that capacity, to exercise discretion in selecting securities for the client’s account by delivering the model portfolio. In these arrangements, intermediary sponsors retain the ultimate decision making and discretionary responsibility for the determination of which securities are to be purchased and sold for their account and effect all security transactions in connection with such determinations.

Harris generally does not have any transparency into which securities were ultimately purchased or sold, or the ending portfolio weighting of the institutional client account(s), or the accounts of such advisory programs. There may be differences between the portfolios for which Harris provides a model and the portfolios Harris manages for other clients that follow the same investment strategy. These differences may result from various factors, including but not limited to: cash availability, investment restrictions, timing of transactions (as directed by the client in certain instances), account size, holding limits, tax considerations and trade execution. As a result, the performance of Harris’ discretionary advisory client portfolios and that of a model portfolio following the same investment strategy may differ. For more information regarding transactions involving model portfolios, see the section entitled “Brokerage Practices”. Harris also provides non-discretionary services related to certain private wealth client assets. In these instances, private wealth clients retain the ultimate decision-making and discretionary responsibility for the determination of which securities will be purchased, held and sold, and the timing of such transactions. When Harris is retained on a non-discretionary basis, all investment decisions are made by the private wealth client, and account transactions are executed only in accordance with the private wealth client's non-discretionary agreement or other authorization from the client. The timing of such non-discretionary investment decisions varies relative to transactions for clients that have given Harris discretionary authority, and depend on, among other things, the investment strategy, the degree of transparency of and attribution to Harris’ portfolios to certain underlying clients and client agreements. Harris does not conduct research on the securities in non-discretionary accounts or where it provides non- discretionary services, and therefore does not provide ongoing monitoring of said securities. Given these securities are not followed by Harris’ analysts, it is likely said securities are not operationally set-up in Harris’ trading systems and, therefore, the private wealth client’s trades will not be effected at the time the client provides authorization, but rather within a reasonable amount of time thereafter, and client understands that Harris does not monitor for price movements after the client has provided authorization. The private wealth client must be willing to accept that Harris cannot effect any account transactions without obtaining prior verbal or written consent to any such transaction(s) from the client. Harris reserves the right to deny certain transaction(s) in cases of fraud or abuse. To the extent a private wealth client directs Harris to purchase an Oakmark mutual fund in a Pershing account, the client will be eligible for the Oakmark mutual fund’s least expensive share class. To the extent the client directs Harris to purchase an Oakmark mutual fund, or third-party mutual fund, outside of a Pershing account, the client remains responsible for seeking the least expensive share class to which they are eligible. In all cases, Harris does not charge a fee for non-discretionary services; however, the private wealth client assumes all costs associated with effecting trades and custody of assets, and assumes the cost of the total expense ratio of the share class of the Oakmark mutual fund or third-party mutual fund in which they have invested. Harris does not possess or exercise discretionary authority over non-discretionary assets held in any private wealth client account and Harris is not authorized in any way to manage such client account or to make any decisions to buy, sell, or hold any investments in such client account. If a private wealth client elects to follow any Harris Associates L.P. Page 6 of 28 recommendations received from Harris, the client makes the decision to buy, hold or sell the investment. Harris does not monitor these assets, although the client understands and acknowledges that Harris may voluntarily review the client’s account, and recommend certain securities based on the client’s investment goals. However, the purchase or selling of said securities is solely at the discretion of the private wealth client. As of December 31, 2023, Harris advised approximately $25,931,275 on a non-discretionary basis for the accounts described above. Nothing herein, will restrict or waive any remedies which the client may have pursuant to applicable federal and state laws or regulations. Investment Guidelines and Restrictions Harris may agree to certain investment guidelines or restrictions requested by a client and will endeavor to abide by such guidelines or restrictions. Clients who impose investment guidelines or restrictions should be aware that any guidelines or restrictions placed on an account may affect the account’s performance, which can result in performance that is better or worse relative to other similar client accounts. Occasionally, a client will request guidelines or restrictions that require we avoid investments based on common socially responsible investment (“SRI”) themes (e.g., alcohol, tobacco or gambling). These requests are considered on an account-by-account basis. To the extent that a client has SRI guidelines or restrictions but does not provide Harris with a list of prohibited securities or issuers, Harris will use a third-party service provider to identify the securities or issuers that will be deemed restricted. Absent a client’s list of prohibited securities or issuers, Harris’ interpretation of which securities to restrict will control.