A. Description of the Advisory Firm LGIMI is a United Kingdom-based investment management company. LGIMI is registered with the SEC and authorised and regulated by the FCA in the UK. With respect to its management of client funds deemed to be “plan assets” under the U.S. Employee Retirement Income Security Act of 1974, as amended (“ERISA”), LGIMI relies on the U.S. Department of Labor’s Qualified Professional Asset Manager exemption or other statutory or administrative prohibited transaction exemptions to avoid engaging in non-exempt prohibited transactions in those assets under ERISA and the U.S. Internal Revenue Code of 1986, as amended. LGIMI is a wholly owned subsidiary of Legal & General Investment Management (Holdings) Ltd (“LGIM(H)”), a company incorporated under the laws of England and Wales. LGIM(H) is a wholly owned subsidiary of Legal & General Group Plc (“Legal & General”), a publicly traded company in the UK. LGIMI is an affiliate of Legal & General Investment Management America, Inc. (“LGIMA”), a Chicago-based adviser regulated by the SEC, Legal & General Investment Management Ltd ("LGIM"), a London based adviser authorised and regulated by the FCA, LGIM Singapore PTE. Ltd (“LGIM Singapore”), an adviser registered with the Monetary Authority of Singapore and Legal & General Investment Management Asia Limited (“LGIM Asia”), an adviser registered with the Hong Kong Securities and Futures Commission, In this Brochure, we use the terms “Client” to refer to the U.S. clients for whom we manage assets as an adviser or sub-adviser. B. Types of Advisory Services Under an affiliate sub-advisory relationship with LGIMA, we provide investment management services as a sub-adviser to certain LGIMA clients. These Clients are Legal & General funds and companies. These include separately managed portfolio accounts (“SMA”s) and serviced portfolios of insurance companies and private funds. Our strategies include the following:
• Index tracking investment strategies

("Index Strategies"):
• High Yield active fixed income strategies (“HY Strategies”):
• Emerging Market Debt strategies (“EM Strategies”): and
• Private Credit investment strategies across investment-grade Corporate Credit and Infrastructure Debt investments (“Private Credit Strategies”) LGIMI and LGIMA may delegate discretionary or non-discretionary advisory services to each other via sub-advisory agreements between them. We may use the services of our affiliates, LGIM and LGIM Asia, to assist us in this, under the terms of a Participating Affiliate Agreement (“PAA”) based on guidance in no-action letters issued by the SEC Staff. We are the sub-adviser of a private fund that is organised as a Delaware limited liability company which is exempted from the definition of “Investment Company” under Section 3(c)7 of the U.S. Investment Company Act of 1940 (“1940 Act”). The private fund is L&G Global High Yield Fund LLC. 6 | LGIM International Ltd C. Client Tailored Services and Client Imposed Restrictions LGIMI offerings are tailored to the needs of their investors in that they are subject to investment restrictions, limitations, and/or guidelines that LGIMA has agreed to with the particular investor These are set forth in an investment management agreement (“IMA”) between LGIMI and LGIMA. Under the IMA, where assets are sub-advised we assume discretionary responsibility for the day-to-day management and investment of all securities, cash and other investment instruments agreed upon with the Client. Based upon this, we define the asset mix that we believe is most likely to achieve the investment objectives, select investments, execute transactions, and generally manage the Client’s assets. D. Participation in Wrap Fee Programmes We do not participate in any Wrap Fee programmes. E. Assets Under Management As of December 31, 2023, we manage approximately USD 983,473,282 on a discretionary basis and no assets on a non-discretionary basis.