Introduction to Putnam Putnam Investment Management, LLC ("PIM") has been registered with the Securities and Exchange Commission as an investment adviser since 1971. 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, PIM, a 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. PIM primarily manages Putnam’s open-end and closed-end registered investment companies (the “Putnam Funds”) and Putnam 529 for America,SM 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 (“Retail SMA”) clients through managed account programs sponsored by broker-dealers and other financial intermediaries (“Program Sponsors”). PIM also sub-advises registered investment companies sponsored by other financial firms. PIM is also investment adviser to a range of actively-managed exchange-traded funds. PIM is affiliated, through common ownership by Putnam Investments, with: ♦ 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, ♦ 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 also sub-advises some Putnam Funds, and ♦ Putnam Investments Limited (“PIL”), a registered investment adviser that manages assets for non-U.S. institutional clients, sub advises some PAC and PIM client portfolios (including certain Putnam Funds), and promotes Putnam products and services in Europe, the Middle East and Africa and some other non-U.S. countries. 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. 5 Putnam Investment Management, LLC Services of Other Affiliates 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 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, PIM has $92,886,867,398 in discretionary net assets under management1 and no non-discretionary assets under management. PIM manages the Putnam Funds in accordance with their written investment objectives, strategies and guidelines, as disclosed in their SEC registration statements. The investment program of a Putnam Fund cannot be tailored to the individual needs of any particular investor. Investment in a Putnam Fund does not create an advisory client relationship between the investor and Putnam. Therefore, investors should consult their financial representatives and consider whether a Putnam Fund meets their investment objectives and risk tolerance prior to investing. PIM manages other discretionary advisory clients’ 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 relationship, the client authorizes PIM to supervise, manage and direct the investment of the assets of the portfolio without prior consultation with the client. With respect to its alternative investments business, which provides investment solutions across equity and credit in both open-ended and drawdown structures, PIM uses the trade name “37 Capital.” Model Portfolios PIM also provides non-discretionary investment management services through wrap fee programs such as Unified Managed Account (UMA) programs or other programs, where PIM generally provides ongoing investment recommendations through one or more “model” portfolios, and the program sponsor, rather than PIM, makes investment decisions and executes trades on behalf of its underlying clients. The sponsor decides in its discretion whether to make any changes to the model that PIM recommends and is also solely responsible for determining the suitability of the strategy and investments for each client that participates. All management and support of underlying client accounts, such as investment allocation, implementation of any agreed-on client customizations, or tax management, is also the responsibility of the sponsor or any 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 Investment Management, LLC overlay manager selected by the sponsor. When PIM does not provide continuous investment advice or effect transactions for client accounts in model provider programs, their assets are not counted as assets under management in the information above in this item. To the extent that this brochure is delivered to program clients with whom PIM has no advisory relationship, or in other circumstances where it is not legally required to be delivered, it is provided for informational purposes only. PIM also serves as a model provider in the Morgan Stanley Smith Barney LLC Select UMA® program. Although PIM’s role is limited to providing a model portfolio, we could be deemed to have an advisory relationship with the sponsor’s clients due to the structure of the program. As a result, we arrange for the sponsor to deliver this brochure to program clients who have selected a PIM model. Such clients should refer to the Sponsor’s Wrap Fee Program Brochure and Appendix A to this document for additional information about the program and PIM’s services. PIM also offers multi-asset allocation model portfolios, made up of mutual funds and ETFs, which may be selected by registered investment advisers and other third-party financial intermediaries for use in managing their clients’ investment portfolios. Putnam currently offers four such model portfolios with allocations designed for different investment objectives. Putnam’s multi-asset allocation model portfolios are created using a quantitative, factor-based approach that analyzes historical fund returns,

with additional elements of qualitative judgment, with the goal of constructing a risk- and cost- efficient portfolio. PIM makes these portfolios available on a “model only” basis through third-party intermediaries and investment platforms. PIM does not manage the model portfolios directly for underlying investors and is not responsible for determining the suitability of any such portfolio for a given investor. These multi-asset allocation model portfolios generally consist of a mix of actively-managed Putnam mutual funds and non-Putnam passive ETFs. Putnam will consider only Putnam funds for inclusion within the active mutual fund allocation for a fund model. We do not seek or purport to review or consider third party mutual funds available in the marketplace for this purpose, and investors interested in constructing a model portfolio offering active funds from other providers should consult with an independent financial intermediary about other investment options. PIM earns additional fees from the underlying Putnam mutual funds when a model portfolio includes a higher percentage of Putnam funds, and also earns differing levels of management fees from different Putnam funds; as a result, we face a conflict of interest in our decisions on how to construct the portfolios. Although we seek to mitigate these conflicts by maintaining controls around the models and by requiring that Putnam funds included in a model portfolio pass certain quantitative screens, there can be no assurance that these controls will resolve the conflict. Retail SMAs PIM provides investment advisory services to Retail SMAs in a “single contract” or a “dual contract” capacity, where the clients (“Dual Contract Clients”) contract separately with the Program Sponsor or a designated broker for brokerage and other services and with PIM for portfolio management services (“Dual Contract Programs”). In single contract programs, PIM contracts with the Program Sponsor to provide portfolio management services to the Program Sponsor’s clients. In Dual Contract Programs, PIM provides its advisory services pursuant to an advisory agreement directly with the Dual Contract Client. Clients may select PIM to provide investment advisory services for their account (or a portion thereof) for a specified strategy. Clients are encouraged to consult their own financial advisors and legal and tax professionals on an initial and continuous basis in connection with suitability of the strategy and selecting and engaging the services of an investment adviser for the particular strategy and participating in a managed account program. In Retail SMA accounts, the Program Sponsor or designated broker is responsible for ascertaining the financial circumstances, investment objectives, and investment restrictions applicable to each client through information provided by the client. PIM is entitled to rely on such information provided by Program Sponsor. The client may select PIM from among the investment advisers that the Program Sponsor or designated broker presents to the client. In 7 Putnam Investment Management, LLC the course of providing services to Retail SMA accounts advised by a financial advisor, PIM generally relies on information or directions communicated by the financial advisor acting with apparent authority on behalf of its client. PIM reserves the right, in its sole discretion, to reject for any reason any SMA Program participant referred to it. PIM is responsible only for managing the Retail SMA in accordance with the selected investment strategy and any “reasonable restrictions” imposed by the client. The execution of a particular strategy in a Retail SMA may differ from the execution of the same or a similar strategy for a fund or institutional client due to the need to adhere to “reasonable restrictions” imposed by the client and agreed to by PIM. Accordingly, the performance of a strategy available through a Retail SMA may differ from the performance of the same or a similar strategy that is executed for a Putnam Fund or institutional client. PIM seeks to commence management of an account as soon as practicable after review of the account documentation in good form, acceptance of its appointment as adviser and contribution of assets to the client’s account. The time required to commence management varies depending on the time required to complete these steps, the efficiency of the Program Sponsor and/or other third parties, and the time required to establish an appropriate portfolio. The timing required to fully invest an account depends on multiple factors, including the particular strategy and guidelines; market conditions; availability of desirable securities; the amount of cash versus legacy securities used to fund a new account; and if legacy securities are used, the characteristics of such legacy securities, among others. With respect to Retail SMA accounts, PIM has entered into, and expects to enter into additional, arrangements with service providers to provide administrative and operational functions, such as accounting, reconciliation, trade generation, trade settlement, recordkeeping and reporting (“SMA Service Providers”). SMA Service Providers include Vestmark, Inc. (“Vestmark”) and Franklin Templeton Private Portfolio Group, LLC (“FTPPG”), an affiliated service provider. Fees paid pursuant to these arrangements are typically paid for by PIM and not Retail SMA clients. Vestmark, through its subsidiary Vestmark Advisory Solutions, Inc., a registered investment adviser, will provide discretionary sub-advisory services to Retail SMA accounts for the purpose of generating trades for implementing position changes directed by PIM, enforcing draft tolerances and implementing maintenance trades. Index Products From time-to-time PIM engages in other business activities related to its core investment business, including licensing of intellectual property with respect to, for example, the development of methodologies for compiling and calculating a benchmark index. We license or sell our intellectual property rights in these methodologies to third parties who use these methodologies to create and issue investment products that are based on such indices and/or correlated to the underlying components of such indices. In connection with such indices, we may retain third parties as calculation agents and/or license the third parties’ underlying intellectual property, to the extent used in constructing our indices. 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. 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 8 Putnam Investment Management, LLC 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, except in the limited case of the model portfolios discussed above, investment funds (such as our managed funds and 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, PIM provides a specific service. PIM does not provide tax, legal, or accounting advice, and clients should note that, unless otherwise specifically agreed or disclosed in writing, PIM will not take tax considerations into account in managing a client’s portfolio. In addition, for sub-advised clients, 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. 9 Putnam Investment Management, LLC