Cullen Capital Management, LLC. (the “Adviser” or “CCM”) is an investment adviser registered under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and does business as Schafer Cullen Capital Management, Inc. S c h a f e r C u l l e n C a p i t a l M a n a g e m e n t , I n c . ( SCCM), an affiliated investment adviser, began operating in 1983 and contributed its advisory contracts to CCM in 2021. SCCM, which remains in existence for tax purposes, owns non-voting units of CCM. CCM was incorporated in 2000 to manage mutual funds using the same value investment philosophy as SCCM. The Adviser provides investment advisory services to individuals, pension and profit sharing plans, trusts, charitable organizations, corporations, mutual funds, UCITS, exchange-traded funds (“ETFs”) and two private funds, Schafer Cullen Global Small Cap Value LP and Schafer Cullen Emerging Markets Small Cap LP (each, a “Hedge Fund” and collectively, the “Hedge Funds”). As of February 29, 2024, CCM, together with its affiliates managed $8,987,685,172 on a discretionary basis in client assets. Ownership The Adviser is currently controlled by James P. Cullen, who owns 75.001% of its voting securities. Investment Decisions When managing on a discretionary basis, the Adviser makes specific investment decisions for clients without their approval regarding the securities to be bought or sold for accounts, the amount of securities to be bought or sold, the broker-dealer through or with whom transactions are to be effected, and/or the commission rates, if any, at which transactions are to be effected. In determining an investment to be bought or sold for a client’s account, the Adviser adheres to any investment objectives and guidelines established by the client (in consultation with the Adviser, where appropriate). Investment objectives and guidelines typically relate to matters such as the type of return the client expects (i.e.

income, capital appreciation, or both), the desired rate of return, the degree of risk which the client is willing to assume, and the types of securities which the client wishes to include or exclude from its portfolio. Investment decisions for clients will be made with a view to achieving their respective investment objectives after consideration of factors such as the client’s current holdings, availability of cash for investment and the size of the client’s investments generally. In some cases, a particular investment may be bought or sold for one or more but fewer than all clients, or may be bought or sold in different amounts and at different times for more than one but fewer than all clients. Similarly, a particular investment may be bought for one or more clients when such investment is being sold for one or more other clients. In addition, purchases or sales of the same investment may be made for two or more clients on the same date. In such cases, the Adviser will allocate such transactions among clients in a manner deemed by the Adviser to be equitable to each. When advising on a non-discretionary basis, the Adviser only provides its model portfolio and related updates as applicable to the party responsible for trading the account or fund. The account’s responsible party (and not the Adviser) ultimately determines the number of shares, commissions, and broker-dealer(s) to affect securities bought or sold for client accounts (each such circumstance, “Model Delivery”). The main focus of the Adviser's investment process is on identifying investments that, in the Adviser's opinion, are undervalued in the marketplace. In seeking to identify such investments, the Adviser utilizes a combination of external research and its own fundamental and technical analysis as performed by its in-house investment research staff. The Adviser manages client accounts according to a variety of value-based strategies, as described in Item 8 below.