Advisory business Voya AAM is wholly owned by Voya Investment Management Alternative Assets LLC (“Voya IMAAM”). Voya IMAAM is a wholly owned subsidiary of Voya Investment Management LLC (“Voya IM LLC”), a registered investment adviser, which in turn is a wholly owned subsidiary of VIM Holdings LLC, a Delaware limited liability company. Voya Financial, Inc., a publicly traded company, holds a 76% economic stake in VIM Holdings LLC through its subsidiary Voya Holdings Inc. As of July 25, 2022, Allianz SE, a stock corporation organized and existing under the laws of the European Union and the Federal Republic of Germany, holds an indirect 24% economic stake in VIM Holdings LLC as a result of a transaction combining Voya IM LLC with the assets and teams comprising specified transferred strategies formerly managed by Allianz Global Investors U.S. LLC.
Voya AAM began business as an investment adviser on December 5th, 1995. Voya AAM serves as general partner or managing member to several private investment partnerships or limited liability companies and as the investment manager or sub-adviser of several offshore funds, collateralized debt obligations or other investment vehicles. From time to time, Voya AAM also manages individually managed accounts and will tailor its advisory services to the individual needs of such clients. Such individually managed account clients can impose reasonable investment restrictions on their accounts. Some or all of the funds or vehicles advised by Voya AAM are included in multi-strategy or similar discretionary asset allocation structures. The types of financial instruments that can be used are outlined in an agreement entered into between Voya AAM and the client or other applicable offering documentation.
Voya AAM generally has the responsibility to monitor investment restrictions. Clients should be aware that their restrictions can limit Voya AAM’s ability to act and as a result, their performance will sometimes differ from and potentially be less successful than that of other accounts which do not impose any restrictions. Voya AAM shall not

be bound by any amendment to the investment restrictions unless and until the client and Voya AAM have agreed in writing on such amendment.
Assets under management As of December 31, 2023, Voya AAM managed $24,718,687,253 in client assets on a discretionary basis and did not manage any client assets on a non-discretionary basis.
Investment authority Subject to any written guidelines which the client provides or other specialized arrangements, Voya AAM typically has complete discretion and authority to manage client accounts. Voya AAM, as the client’s agent, generally has the authority to act without prior consultation pursuant to the client agreement, which is more fully described in Item 16. Accordingly, Voya AAM is generally authorized to perform various functions, at the client’s expense, without further approval from a client, except as required by law, including to: (a) make all investment decisions; (b) buy, sell and otherwise trade in securities; (c) issue instructions to the custodian for operational matters of the account for such items as tender offers and reorganizations; (d) select brokers or dealers to execute securities transactions; and (e) vote proxies and make similar decisions, except that as a general matter, a fund’s or account’s custodian rather than Voya AAM is responsible for filing class action claims. Voya AAM generally does not commence or pursue litigation on behalf of clients. With respect to many clients, Voya AAM enters into swaps and other derivatives and executes ancillary documents on their behalf. In certain instances, Voya AAM enters into non-discretionary arrangements with its clients where Voya AAM obtains client approval prior to execution of a trade or provides the client with investment recommendations which the client, in its sole discretion, can implement.
Trading support and outsourcing Voya AAM and/or its affiliates provide administrative, trading, marketing and other support services for affiliated entities, where the entities are responsible for making portfolio management decisions.