Introduction to Putnam Putnam Investments Limited ("PIL") has been registered with the Securities and Exchange Commission as an investment adviser since 2002. On January 1, 2024, a subsidiary of Franklin Resources, Inc. (“Franklin Resources”) acquired Putnam U.S. Holdings I, LLC, which does business as Putnam Investments (“Putnam” or “Putnam Investments”) in a stock and cash transaction (the “Transaction”). As a result of the Transaction, PIL, an indirect wholly-owned subsidiary of Putnam, became an indirect, wholly-owned subsidiary of Franklin Resources. Putnam, whose history reaches back to 1937, is an active asset manager providing investment advice across all asset classes to individuals and institutions worldwide through separately managed accounts and pooled investment funds. Based in Boston, Putnam also has offices in Europe, Asia and Australia. Franklin Resources is a holding company with subsidiaries that operate under the Franklin Templeton® and/or subsidiary brand names. Franklin Resources is a global investment management organization, and the various distinct brand names it offers investment services and products under include, but are not limited to, Alcentra®, Benefit Street Partners®, Brandywine Global Investment Management®, Clarion Partners®, ClearBridge Investments®, Fiduciary Trust International™, Franklin®, Franklin Bissett®, Franklin Mutual Series®, K2®, Legg Mason®, Lexington Partners®, Martin Currie®, O’Shaughnessy® Asset Management, Royce® Investment Partners, Templeton®, and Western Asset Management Company®. Franklin Resources, through current and predecessor subsidiaries, has been engaged in the investment management and related services business for over 75 years. Franklin Resources’ common stock is traded on the New York Stock Exchange under the ticker symbol “BEN” and is included in the Standard & Poor’s 500 Index. PIL primarily manages assets for non-U.S. institutional clients. In addition, PIL sub-advises client portfolios of other Putnam advisers, and promotes Putnam products and services in Europe, the Middle East and Africa and some other non-U.S. countries. PIL is affiliated, through common ownership by Putnam Holdings, with: ♦ Putnam Investment Management, LLC (“PIM”), a registered investment adviser that manages Putnam’s open-end and closed-end registered investment companies, including open-end mutual funds, exchange-traded funds (“ETFs”), and closed-end funds (the “Putnam Funds”) and Putnam 529 for AmericaSM, a Section 529 college savings plan. PIM also provides “model only” recommendations to the account sponsors for various wrap programs’ separately managed account offerings, and offers certain standalone model portfolios. Additionally, PIM provides investment advisory services to retail separately managed account clients through managed account programs sponsored by broker-dealers and other financial intermediaries. PIM also sub-advises registered investment companies sponsored by other financial firms. ♦ Putnam Fiduciary Trust Company, LLC (“PFTC”), a New Hampshire non-depository trust company that manages assets through collective investment trusts and separate accounts, and also provides trustee and custodial services pursuant to its banking and fiduciary powers, and ♦ The Putnam Advisory Company, LLC (“PAC”), a registered investment adviser that manages assets for institutional and international clients. PAC also manages various pooled investment funds, such as limited liability companies, limited partnerships, and non-U.S. funds, and sub-advises some Putnam Funds. These four Putnam management companies generally market their services together (depending on the type of client involved) under the Putnam brand, and share a common platform of trading, compliance, risk systems, and policies and procedures. They are sometimes called “Putnam,” the “Putnam Advisers,” or simply “We” in this brochure. Services of Other Affiliates 5 Putnam Investments Limited Franklin Templeton operates its investment management business through the Putnam Advisers, as well as through multiple affiliates of the Putnam Advisers, some of which are investment advisers registered with the SEC, some of which are registered with non-U.S. regulatory authorities, and some of which are registered with multiple regulatory authorities. A Putnam Adviser uses the services of appropriate personnel of one or more of its affiliates for investment advice, portfolio execution and trading, and/or client servicing in their local or regional markets or in their areas of special expertise, except to the extent restricted by the client under its investment management agreement, or if inconsistent with applicable law. Arrangements among affiliates take a variety of forms, including delegation arrangements, formal sub- advisory arrangements, and servicing agreements. Certain employees and officers of Franklin Resources and its subsidiaries who engage in investment advisory services may also be appointed to serve as officers and/or authorized persons of a Putnam Adviser and, in that capacity, may provide investment research, investment recommendations and other services to a Putnam Adviser from time to time. In each of these circumstances, the Putnam Adviser remains fully responsible for the account from a legal and contractual perspective. No additional fees are charged for the affiliates’ services except as disclosed in the investment management agreement. Please see Item 10 (“Other Financial Industry Activities and Affiliations”) for more details. Investment Management Services Putnam offers professional, active investment management across a broad range of asset classes, including traditional long-only

equity, fixed income, multi-asset income, alternative, and multi-asset class strategies. Putnam manages client assets based on the individual needs of the client, which are stated in the written objectives and guidelines of the client’s account. In a typical discretionary separate account relationship (that is, an investment portfolio pursuing a particular investment strategy, established in the client’s name at its custodian), the client authorizes PIL to supervise, manage and direct the investment of the assets of the portfolio without prior consultation with the client. For non-discretionary accounts, which are less common, PIL must consult with the client prior to implementing any investment decisions. PIL is primarily a discretionary asset manager and does not routinely provide general investment advice or planning services to its clients. As of December 31, 2023, PIL has $2,782,815,069 in discretionary net assets under management and $193,502,936 in non-discretionary net assets under management.1 In addition to separate accounts, PIL also manages or sub-advises. pooled investment funds. Like separate accounts, investment funds are managed in accordance with written investment objectives, strategies and guidelines. However, a fund is a pooled vehicle, and its investment program cannot be tailored to the individual needs of any particular investor. Investment in a fund does not create an advisory client relationship between the investor and Putnam. Therefore, investors should consult their consultant or financial representative and consider whether a fund meets their investment objectives and risk tolerance prior to investing. Investors in pooled funds receive an offering memorandum, prospectus, or similar document that describes the fund, including its risks, fees, and the qualifications needed to invest. Some investment funds may be offered on a private placement or other limited basis and may not be available to, or appropriate for, all prospective investors. Sales and Marketing Activities In order to promote our products and services, Putnam engages in sales and marketing activities, including responding to client requests for proposals (RFPs) and presenting or making available information on our investment capabilities and pooled fund products, as well as sharing education materials, market commentary, white papers, investment and portfolio analysis tools and models, and other resources. Clients and prospective clients should be aware that Putnam will not be considered an investment advice fiduciary in connection with selling and distributing our products and services, including under the Employee Retirement Income Security Act of 1974 or any similar law. When we discuss a possible investment with Putnam with a prospective or current client, we do not undertake to provide impartial investment advice, or to give advice in a fiduciary capacity in connection with any related investment decision or transaction. 1 Regulatory assets under management reported in Item 5 of Form ADV Part 1 are required to be calculated gross of fees and other liabilities, so they will differ from the net asset numbers stated in this brochure or in other sources. 6 Putnam Investments Limited This is because providing such advice could involve an inherent conflict of interest, since Putnam earns fees, such as the management fees discussed in Item 5 of this brochure, when clients invest with us. We earn our fees in connection with selecting portfolio investments for our clients within a specific investment discipline or fund strategy; in contrast, we do not provide advice, and do not earn fees for providing advice, on the selection of investment advisers (such as Putnam and its competitors) or investment funds (such as for evaluating our managed funds versus those offered by other asset managers). We offer and sell only our own products and services and do so on an arm’s length basis. While Putnam aims to provide accurate information and comply with applicable law in all our sales and marketing activities, clients and prospects who want professional guidance on whether or not to hire Putnam, or whether or not to invest in a particular Putnam offering, should seek independent advice. Limitations on Services As an asset manager, PIL provides a specific service. PIL does not provide tax, legal, or accounting advice, and clients should note that, unless otherwise specifically agreed or disclosed in writing, PIL will not take tax considerations into account in managing a client’s portfolio. In addition, for clients other than our managed funds, we do not advise on or take any action in any legal proceedings on their behalf, including bankruptcies or class actions, involving securities or other investments held or formerly held in a client’s account or the issuers of those securities, except where specifically agreed with the client in writing. For Putnam-sponsored pooled investment funds, Putnam manages portfolio cash as part of its overall investment services. Cash arrangements for other clients, such as separate accounts or sub-advised clients, vary depending on the client’s preferences and the account documents. Where the short-term investment fund (STIF) or similar vehicle offered by a client’s custodian is used for residual cash investment (for example, where a client directs that all cash be swept daily to the STIF), clients should note that the STIF involve additional credit, market and other risks beyond the securities managed directly by Putnam. Clients interested in greater detail about their custodian’s STIF should contact their custodian for more information. 7 Putnam Investments Limited