Overview Geode Capital Management, LLC ("Geode") is a limited liability company organized under the laws of the State of Delaware, which was founded in 2001. Geode is a systematic asset manager providing global investment solutions across multiple asset classes. Geode Capital Holdings LLC (“GCH”) is the majority (99%) owner of beneficial ownership interests of Geode. Geode acts as adviser and sub-adviser for equity, commodity and options strategies for funds and client accounts. Geode provides discretionary portfolio management services to certain open-end investment companies (“Mutual Funds”) and exchange traded funds (“ETFs”) that are registered as such under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Geode provides investment advisory services for U.S. and non-U.S. taxable and tax-exempt clients. Such clients are primarily institutions that invest through separately managed accounts (“Separate Accounts”) and pooled investment vehicles. Geode also provides sub-advisory services to registered investment companies domiciled in Canada under the regulatory framework for National Instruments 81-102 and U.K Open- Ended Investment Company (“OEICs”), and Irish Collective Asset-management Vehicle (“ICAVs”) and Luxembourg SICAVs under the regulatory framework for Undertakings for Collective Investment in Transferable Securities (together with the Mutual Funds and ETFs, the “Funds”). The Funds and Separate Accounts advised and sub-advised by Geode are collectively referred to herein as “Client Accounts.” As of December 31, 2023, Geode had discretionary assets under management of $1,062,795,395,069. These numbers reflect total assets under management across all of Geode’s client accounts. Types of Investments The type of investments transacted by Geode will be contingent on the investment strategy employed. In general, Geode will transact in U.S. and non-U.S. common stocks, depositary receipts, real estate investment trusts, mutual funds, ETFs, index future and option contracts, commodity-related derivatives, master limited partnerships, preferred stock, convertible securities, warrants, rights and fixed-income securities. In addition, Geode uses various techniques, such as buying and selling futures contracts, options contracts, and swaps, to increase or decrease exposure to changing security prices or other factors that affect security values and conducts foreign currency transactions on a spot or forward basis. Strategies Geode’s primary service is the design, implementation and management of portfolios that

employ equity index investment strategies. Indexing is an investment strategy that seeks to track the performance of a specified market benchmark, or “index.” An index is a group of securities whose aggregate performance is used as a standard to measure the investment performance of a particular market. Some indexes represent entire markets, such as the U.S. stock market. Other indexes cover market segments, such as large-capitalization stocks. For equity index strategies, Geode’s portfolio managers generally employ full index replication techniques. At times, portfolios may be optimized to closely match the portfolio risk characteristics with those of the benchmark. This approach balances the risk of having slight mis- weightings relative to the benchmark against limiting transaction costs associated with trading a vast number of small positions. Optimization employs statistical sampling techniques to attempt to match the investment characteristics of a particular index and a portfolio by taking into account factors like market capitalization, industry and sector exposures, dividend yield, P/E ratio, P/B ratio, and earnings growth, as examples. Generally, Geode’s portfolio managers manage the weightings of the securities in the portfolio GEODE CAPITAL MANAGEMENT, LLC 5 within established tolerances. Separate Account clients may require investment limitations on Geode’s investment selection process through customized guidelines. Geode also offers options-based strategies that seek to capture returns through the systematic buying and/or selling of volatility within the listed options market. The strategies search for mispriced volatility across a variety of portfolio constructs seeking attractive risk adjusted returns over a full investment cycle. Geode seeks to systematically capture these opportunities through a disciplined, risk-controlled investment process and continuous research. Additionally, Geode offers both index and active commodity strategies. The index strategy seeks to provide investors with broad-based commodity market exposure. The active strategy seeks to outperform the benchmark by capturing long-term premiums in the commodity markets. Geode provides investment advice for strategies based on numerous indexes, including customized (non- proprietary) indexes and indexes from the following providers:
• S&P
• MSCI
• Russell
• Dow Jones
• FTSE
• NASDAQ
• Solactive
• TOPIX
• CBOE
• Bloomberg Geode may, from time to time, add or discontinue certain index or investment strategies.