Towers Watson Investment Management Limited (referred to herein as “TWIM”) is a wholly-owned subsidiary of Towers Watson Global Limited, which is a subsidiary of Towers Watson Global Holdings Limited, with the ultimate parent being Willis Towers Watson PLC. Willis Towers Watson PLC is a public company traded on the New York Stock Exchange and the NASDAQ Stock Market (NYSE, NASDAQ:WLTW). In the line of ownership between Towers Watson Investment Management Limited and Willis Towers Watson PLC, multiple other entities are wholly-owned subsidiaries of each other, including Watson Wyatt International Inc. and Willis North America Inc. TWIM was incorporated in 2005 (previously named Oxford Investment Management Limited and later Oxford Investment Partners Limited) in order to provide professional, dedicated investment advisory consulting services to our clients, which are currently pooled-investment vehicles. TWIM provides investment management services to several pooled-investment vehicles. Certain pooled- investment vehicles managed by TWIM are organized as sub-funds (“Sub-Funds”) of Towers Watson Investment Management Ireland 1 plc, an investment company with variable capital established as an umbrella fund with segregated liability between Sub-Funds. Different Sub-Funds may be created from time to time, with the prior approval of the Central Bank of Ireland. In order to achieve its investment objective, each Sub-Fund, generally through a sub-fund (a “Master Sub-Fund”) of Towers Watson Investment Management Master Trust Ireland (, a “Master Fund”), primarily invests in a range of underlying portfolio funds and/or managed accounts (together, the “Portfolio Funds”) or trades directly pursuant to a delegation of investment authority from TWIM to one or more sub-investment managers (“Sub-Investment Managers”). Carne Global Fund Managers (Ireland) ltd (the “Manager”), serves as the Manager of the Umbrella Funds and the Master Funds but has delegated all of its investment management functions to TWIM. Each Sub-Fund and Master Sub-Fund is domiciled in Ireland. In addition, Towers Watson Investment Services, Inc. (“TWIS”), an affiliate of TWIM, will serves as manager to a group trust (the “Group Trust”) which is comprised of separate investment funds (the “Group Trust Funds”) that provide a variety of investment approaches as outlined in each Group Trust Fund’s declaration of trust. TWIS has delegated certain investment management functions with regard to certain Group Trust Funds to TWIM pursuant a sub-advisory agreement. TWIM provides sub-advisory services to the Group Trust Funds identified in the sub-advisory agreement between TWIM and TWIS. TWIM provides non-discretionary investment management authority with respect to the Group Trust Funds covered by the sub-advisory agreement. TWIM has tailored its advisory services to the individual needs and specified investment objectives and strategies of the Group Trust Funds, as set forth in the Group Trust’s declaration of trust and each Group Trust Fund’s declarations of trust. There is no limit

or restriction on the investment styles or strategies that may be adopted by the Group Trust Funds, the Portfolio Funds or the Sub-Investment Managers. The Group Trust Funds, Umbrella Funds, Sub-Funds and Master Sub-Funds are collectively referred to herein as the “Funds,” and each, a “Fund.” Investors are encouraged to review the offering documents related to each Fund (“Offering Documents”) in their entirety. TWIM provides advice to the Funds based on specific investment objectives and strategies. TWIM tailors its advisory services to the individual needs and specified investment objectives and strategies of each Fund, as set forth in each Fund’s offering documents and/or investment management agreement. Notwithstanding the foregoing, TWIM neither tailors its advisory services to the needs of individual investors in any Funds it advises or sub-advises nor accepts individual investor-imposed investment restrictions with respect to any Funds it advises or sub-advises. An investment in a Fund does not, in and of itself, create a client-adviser relationship between any underlying investor and TWIM. It should be noted that TWIM also provides investment advice to certain pooled-investment vehicles that are not offered in the U.S. at this time. This Brochure will primarily discuss TWIM’s operations as they relate to Funds offered in the U.S. As of December 31, 2022, TWIM had $24.8 billion of regulatory assets under management (“RAUM”) on a discretionary basis. These figures include pooled-investment vehicles not currently offered in the U.S. but do not include investment advisory assets under management by any parent companies or investment adviser affiliates of TWIM. TWIM manages assets of the Group Trust on a non-discretionary basis. TWIM does not participate in wrap fee programs. WTW believes that sustainable investment is central to successful long-term investment outcomes for our clients. Therefore, WTW considers the financial impact of environmental, social, and governance (“ESG”) factors across its investment process. In formulating its investment advice, WTW seeks to analyze and understand the ESG factors in order to properly assess the risk and return of the investment under consideration. In analyzing the risk/reward profile of an investment, WTW evaluates the impact of ESG risks and, as with any other risks, seeks to ensure that the expected return for every investment is commensurate with those risks. The relevance of ESG factors will vary by asset class, sector, and strategy, and the use of ESG factors will depend in part on any regulatory, operational, or account considerations. Further, WTW’s use of ESG factors might differ from how others use such factors. WTW generally prefers engagement over exclusion within WTW-affiliate managed funds but acknowledges that an exclusionary approach may be necessary when engagement is unlikely to be effective or where certain business practices are incompatible with sustainable investment. Therefore, certain exclusion criteria are applied across asset classes. Additional information regarding ESG and related exclusions is available within the offering documents.