This disclosure document describes investment advisory services offered by Threadneedle International Limited (“TINTL”). TINTL is a subsidiary of TAM UK International Holdings Limited (“UK HoldCo”), an English registered company owned by Ameriprise Financial, Inc. (“Ameriprise”), the ultimate parent company. The UK HoldCo and all its subsidiaries, including TINTL, are referred to herein as “the Group” All investment management within the Group is performed by either TINTL or Threadneedle Asset Management Limited (“TAML”). The investment management capabilities of TINTL and TAML are integrated, and they share the same staff, systems, infrastructure and controls, as well as portfolio research and analysis. Information about the Threadneedle Investments group of Companies. The Group was founded in 1994 and has retained strong links with its former parent company Zurich Financial Services Group, managing a significant number of portfolios on Zurich’s behalf. In 2003, the Group became the international asset management arm of American Express Company, which then, in 2005, spun off its asset and wealth management business into Ameriprise Financial, a new U.S. publicly listed company. The Group now benefits from the strength of being part of a wide asset management group. In 2015, the Group along with our U.S. based affiliate, Columbia Management Investment Advisers, LLC, (“CMIA” or “Columbia”) launched a new global brand called Columbia Threadneedle Investments. The new brand combines the capabilities, reach and resources of the Threadneedle and Columbia group of companies, offering clients access to the best of both firms through one single brand, Columbia Threadneedle Investments. On November 8, 2021, the Group’s parent, Ameriprise Financial Inc., completed the acquisition of BMO Financial Group’s (“BMO”) EMEA asset management business. On July 4, 2022, these businesses were renamed and updated to incorporate the Columbia Threadneedle name to become part of the Columbia Threadneedle Investments brand. In 2021, the most senior company for the Threadneedle group transitioned from the Luxembourg incorporated Threadneedle Asset Management Holdings Sarl (“Sarl”) to the English incorporated TAM UK International Holdings Limited (“UK HoldCo”). UK HoldCo is directly owned by Ameriprise Financial Inc. The Threadneedle group business is consolidated and overseen at the UK HoldCo level. The Group provides a full range of investment products in equities, fixed income, real estate, infrastructure and alternative investments and has a global product range that uses a wide range of product strategies (UK OEICS, Luxembourg SICAVs, UK Life structures and segregated accounts). Distribution is to a well- diversified base of retail and institutional investors globally. Information about TINTL TINTL was incorporated in the United Kingdom in August 1988 and has been a part of the Group since November 1999. The Group acquired TINTL (then called Kemper Investment Management Company Ltd) as a consequence of the creation of Scudder Kemper Investments, Inc. within the Zurich Group. In addition to being an SEC-registered investment adviser, TINTL is authorised and regulated by the Financial Conduct Authority (FCA) in the UK for the provision of investment management activities, and as such all investment management services, including those provided to U.S. clients, must also comply with the FCA rules. TINTL is registered as a Commodity Trading Advisor (“CTA”) with the U.S. Commodity Futures Trading Commission (“CFTC”). In addition, TINTL holds an International Adviser Exemption (“IAE”) in Ontario, Canada, and utilizes an instrument of relief for provision of certain financial services to wholesale clients in Australia with the Australian Securities and Investments Commission (“ASIC”). TINTL also has a representative office in Colombia under the supervision of the Colombian SFC. General Services of the Group The Group, headquartered in London, has evolved from an in-house investment manager for an insurance parent to a provider of global investment products to both retail and institutional clients. Growth has been achieved through diversification of products and investment in distribution capability. The Group’s product range initially concentrated on the equities market. However, this has expanded to cover all global equity markets, a comprehensive range of fixed income products, including commodities, cash, real estate and an infrastructure offering. The Group has steadily established a global presence by expanding its distribution network to encompass Europe, North America, Latin America, Asia, Australia and the Middle East and has a presence in 19 countries. The Group’s operating platform underpins a range of products and distribution channels. A significant portion of the operational infrastructure is outsourced and is overseen by a dedicated team based in the Group’s UK and Luxembourg offices. Under the Group’s risk management framework, risk control is embedded into the investment process, and overseen by an independent Risk department. The Group also has separate Internal Audit and Legal & Compliance functions that oversee all aspects of its activities. Securities Investment Management The Group’s portfolio investment management process is supported by a single shared investment platform, a teamwork-based approach which considers the macroeconomic environment, together with incorporating thematic research and cross border ideas. Formal meetings bring together investment professionals from across asset classes to share the best ideas and knowledge. Equities are the largest single asset class for the Group with the global offering includes UK, European, U.S., Global, Asia, Japanese and Emerging Market Equities. The Group’s fixed income expertise is provided across the credit spectrum with emerging markets, high yield, governments, investment grade, money markets, commodities and as set backed securities forming the pillars of the fixed income business. The Group’s managed funds form a major component of the securities investment management business based around the asset allocation process. The managed funds utilize market specific expertise in equities, fixed income and property. Advisory Services offered by TINTL TINTL provides discretionary and non-discretionary investment management services (including continuous advice to clients on the investment of portfolios, trading, cash management and record keeping) to U.S. and non-U.S. registered investment companies and other U.S. and non-U.S. institutional client accounts. In addition to the arrangements described in “Global Asset Management”, below, our U.S. clients currently receive discretionary investment advisory services from TINTL through sub-advisory agreements with CMIA. These sub-advisory services previously included TINTL acting as sub-adviser for certain mutual funds operated and managed by CMIA. These arrangements ended on 14 December 2020, although TINTL continues to provide sub-advisory services in respect of a client of CMIA. U.S. clients are also able to receive investment advisory services from TINTL directly rather than pursuant to this sub-advisory arrangement. The discretionary advisory services we offer are available to prospective advisory clients. These clients can

negotiate an investment management agreement with us, which incorporates investment restrictions and guidelines developed in consultation with clients. These restrictions and guidelines customarily impose limitations on the types of securities that may be purchased and also generally limit the percentage of account assets that may be invested in certain types of securities. Clients may also choose to restrict investment in specific securities or groups of securities for social, environmental or other reasons. As of December 31, 2023, the amount of client assets managed (reported as Regulatory Assets Under Management) on a discretionary basis was $358,110,000. TINTL participates in wrap fee programs commonly referred to as “Model Delivery Programs” in which we provide investment advice to the program sponsor and/or another investment adviser, commonly referred to as an “overlay manager,” who exercises discretion over their client accounts in the program. Global Asset Management As we seek to enhance our investment capabilities and the support services provided to our clients, we may utilize services from and provide services to some of our U.S. affiliates (“U.S. Advisory Affiliates”) and non- U.S. affiliates (“Non-U.S. Advisory Affiliates”). For example, we engage certain of our Advisory Affiliates in other countries around the world to provide a variety of services. In addition, we may provide Advisory Affiliates (jointly or in coordination with us) services relating to client relations, investment monitoring, account administration, investment research and discretionary investment management (including portfolio management, trading and risk management) to certain of our clients and accounts managed by those Advisory Affiliates, including certain Funds and separately managed accounts. In addition, our Advisory Affiliates provide similar services to us for accounts we manage. In some circumstances, an Advisory Affiliate may delegate responsibility for providing those services to another Advisory Affiliate. Under personnel-sharing and other arrangements, our personnel may act on behalf of one of our Advisory Affiliates for the purpose of providing some of those services for clients of that Advisory Affiliate, such as funds and/or separately managed accounts, and some of our Advisory Affiliates’ personnel may act on behalf of our clients, including funds and separately managed accounts. Certain of our employees and officers are also officers of certain Advisory Affiliates, and employees and officers of our Advisory Affiliates are also officers of TINTL. To the extent that we engage one or more of our Advisory Affiliates to provide services, we remain responsible for and oversee the services provided by such Advisory Affiliates(s) to or on behalf of our clients. We believe that harnessing the collective expertise of our firm and our Advisory Affiliates benefits our clients. In this regard, we have certain portfolio management, trading, research, distribution and client servicing teams at both our firm and certain of our Advisory Affiliates (through subadvisory, delegation or other intercompany arrangements) operating jointly to provide a better client experience. These joint teams use expanded and shared capabilities, including the sharing of research and other information by investment personnel (e.g. portfolio managers, analysts and traders) relating to economic perspectives, market analysis and equity and fixed income securities analysis. The joint teams also have expanded capabilities to provide services in various local or regional markets. To facilitate the collaborative approach noted above, we have entered into subadvisory agreements and “participating affiliate” arrangements with Columbia Management Investment Advisers, LLC (“CMIA”), which is a SEC-registered investment adviser, a CFTC-registered Commodity Pool Operator, a CTA and a wholly- owned investment advisory subsidiary of Ameriprise Financial, Inc. As part of the participating affiliate arrangement, certain employees of TINTL serve as “associated persons” of CMIA when providing certain of these services to CMIA clients, including placing orders for trade execution, and in this capacity, are subject to CMIA’s oversight and supervision. In addition, TINTL may provide certain investment-related support services to Advisory Affiliates and their clients. These affiliates may also provide certain similar services to other TINTL and its clients. Such support services include, but are not limited to, traditional “middle office” and utility functions, such as trade processing, valuation, proxy voting administration, and client and regulatory reporting. Potential Conflicts of Interest Except in circumstances where an Advisory Affiliate is performing investment management, trading services, back or middle office services, or legal or compliance support for our accounts or we are providing similar services or support for an Advisory Affiliate’s accounts, we do not otherwise share trade information with our Advisory Affiliates. Similarly, we do not coordinate or allocate trading activities with the accounts of an Advisory Affiliate unless such affiliate is providing trading services for our accounts, or we are providing trading services for the Advisory Affiliate’s accounts. As a result, it is possible that we and our Advisory Affiliates may trade in the same instruments at the same time, in the same or opposite direction or in different sequence. Additionally, in circumstances where trading services are being provided on a coordinated basis for our accounts and the accounts of one or more Advisory Affiliates in accordance with applicable law, it is possible that the allocation opportunities available to our accounts may be decreased, especially for less actively traded securities, or orders may take longer to execute. As further detailed below under “Methods of Analysis, Investment Strategies and Risk of Loss”, we maintain an internal centralised research function for both equity and fixed-income strategies. Investment research we generate is shared with certain of our Advisory Affiliates at the same time that research is distributed internally. In connection with the sharing of relevant investment research among our Advisory Affiliates, and in providing services described above under, “Global Asset Management”, investment personnel may have access to nonpublic holdings information of clients our and certain of Advisory Affiliates’ clients. Portfolio managers of those Advisory Affiliates may decide to act on such research before our own portfolio managers do. The sharing of this information may also lead us and certain of our Advisory Affiliates to place orders in the same securities at the same or different times, if we and those Advisory Affiliates do not have a collaborative arrangement in place for the relevant client accounts. We have adopted policies and compliance controls that seek to ensure that our clients are treated fairly and equitably with respect to trading and sharing of information among Advisory Affiliates. More information about how we identify, mitigate and manage conflicts of interest can be found throughout this Brochure, and in particular, under “Our Approach to Conflicts of Interest” and “Other Conflicts of Interest”..