A. Description of the Firms Impax Asset Management Limited (“IAM”) and Impax Asset Management (AIFM) Limited (“AIFM,” each a “Firm, and, collectively, the “Firms”) are UK investment management companies authorized and regulated by the U.K. Financial Conduct Authority (“FCA”). Both Firms are also U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) registered investment advisers, which does not imply a certain level of skill or training. IAM and AIFM started operations in 1998 and 2014, respectively, and each is wholly owned by, and is a principal operating subsidiary of, Impax Asset Management Group plc (“Impax”), which is listed on the AIM market of the London Stock Exchange. IAM and AIFM operate as integrated advisers. Certain IAM employees are dual hatted with AIFM, meaning the employees provide investment advisory services on behalf of both Firms. Consequently, conflicts of interest can arise in the allocation of investment opportunities and the potential sharing of material non-public information. The Firms have adopted policies and procedures to address or mitigate those conflicts. Impax Asset Management LLC (“Impax LLC”) is a U.S. is a register investment adviser and an affiliate of IAM and AIFM. In performing advisory services, the Firms utilize the talents of investment professionals employed by Impax LLC to assist with management of certain investment strategies or products. In keeping with applicable regulatory guidance, Impax LLC has entered into an agreement with the Firms pursuant to which Impax LLC is considered a "Participating Affiliate" of the Firms, as that term is used in certain no-action positions taken by the staff of the Commission. These arrangements allow the Firms to use the resources and professional expertise of Impax LLC to render portfolio management services to clients of the Firms. The Firms are specialist asset managers focused on investing in the transition to a more sustainable global economy. The Firms invest in companies and assets that are well positioned to benefit from the shift to a more sustainable global economy. The Firms offer a well-rounded suite of investment solutions to publicly and privately offered pooled investment vehicles, professional clients and institutional investors in accordance with the requirements of client specific investment agreements. Additional detail regarding the types of clients to which each Firm provides investment management services are disclosed in each Firm’s Form ADV Part 1A. As of September 30, 2023, the Firms had discretionary Regulatory Assets under Management of $40 billion as follows:
• Impax Asset Management Limited: o Discretionary: $35 billion o Non-Discretionary: $1.5 billion o Total: $ 37 billion
• Impax Asset Management (AIFM) Limited: o Discretionary: $3 billion B. Types of Advisory Services for IAM Separately Managed Accounts IAM provides ongoing investment services to the separately managed accounts of various institutional clients based on the investment goals, objectives, time horizon and risk tolerance of each client. IAM has entered into investment agreements with each of its clients. Pooled Investment Vehicles IAM provides investment services to non- affiliated pooled investment vehicles. IAM provides discretionary investment services to its clients according to the investment objectives described in the applicable investment management agreement and not individually to the investors in such pooled investment vehicles. Sub-Advisory Services IAM also acts as sub-adviser to additional types of clients, also based on the investment goals, objectives, time horizon and risk tolerance of its clients, which include:
• Affiliated and non-affiliated open-ended investment companies registered under the Investment Company Act;
• Nonaffiliated non-US funds registered under the securities laws of offshore jurisdictions, including Undertakings for Collective Investments in Transferable Securities (also known as UCITS);
• US collective investment trusts and other investment trusts; and
• Separate Accounts. Wrap Fee Programs Additionally, IAM manages certain “wrap fee” accounts of one or more wrap fee program(s) (“Wrap Fee Program”) sponsored by unaffiliated brokers or other financial institutions (“Program Sponsor”) where the wrap fee client selects IAM as the investment adviser for the client’s Wrap Fee Program account. The Program Sponsor monitors and evaluates IAM’s performance and provides custodial services for the client’s assets, all for a single fee paid by the client to the Program Sponsor. IAM’s fees and services for managing the wrap accounts are set forth in IAM’s agreement with the Program Sponsor. As compensation, IAM receives a portion of the fee the Program Sponsor charges the wrap fee client. IAM’s role as an investment adviser participating in Wrap Fee Programs is substantially similar to its role in managing other separately managed accounts in that IAM manages each account in accordance with the model portfolio utilized by the investment strategy chosen by the client or Program Sponsor, subject to client-imposed guidelines. Due to such client-imposed guidelines, it is not always

possible to manage wrap fee accounts identically to other Wrap Fee Program accounts or separately managed accounts that IAM also manages. IAM anticipates that the majority of transactions for the Wrap Fee Program accounts will be executed through the Program Sponsors. Nevertheless, IAM has the ability to “step-out” orders if it believes that it is in the best interest of applicable clients. Model Portfolios IAM also provides model portfolios to unaffiliated brokers or other financial institutions (“Model Program Sponsors”) or the overlay managers appointed by the Model Program Sponsors (each a “Model Recipient”), which they use to construct portfolios on behalf of institutional clients. In these circumstances, IAM does not have discretion to execute trades. IAM is generally only responsible for providing the updated model portfolio to the Model Recipient on a periodic basis and is compensated based on a percentage of the total assets of the accounts managed by the Model Recipients or applicable to the model. The Model Recipients are responsible for effecting the trades recommended to achieve the model portfolio. Please refer to Item 12 for additional information regarding the model portfolio arrangements and how IAM communicates model portfolio holdings under different circumstances and trading processes. C. Types of Advisory Services for AIFM Pooled Investment Vehicles AIFM serves as the investment manager to the Private Equity Funds (defined below), other private funds and an investment trust that invests in listed equities. AIFM provides discretionary investment services to its clients according to the investment objectives described in the applicable investment management agreement and not individually to the investors in such pooled investment vehicles. D. Other Considerations Regarding AIFM’s Private Equity Funds Side Letters AIFM and/or a fund has and is expected to at any time enter into other written agreements (“Side Letters”) with one or more investors, with respect to the listed or private equity strategies. These Side Letters do and are expected to entitle an investor to make an investment in a fund on terms other than those in the governing documents. Any such terms, including with respect to: (i) opting out of particular investments, (ii) reporting obligations of the fund or the Firm, (iii) transfers to affiliates, (iv) co-investment opportunities, (v) withdrawals due to adverse tax or regulatory events, (vi) consent rights to certain governing document amendments, (vii) certain fee structures, or (viii) any other matters described in the governing documents, are expected to be more favourable than those offered to any other investors. Furthermore, subject to the provisions of the applicable governing documents, the Firm and/or the fund are expected to permit certain business associates of the Firm and/or its affiliates to invest directly or indirectly in the fund or a parallel vehicle on terms which are expected to be more favourable than those offered to the other investors, including with respect to the payment of management fees and carried interest. If the Firm and/or the fund enter into a Side Letter entitling an investor to opt out of a particular investment or, with the consent of the Firm, to withdraw from the fund, any election to opt out or withdraw by such investor may increase any other investor’s pro rata interest in that particular investment (in the case of an opt-out) or all future investments (in the case of a withdrawal). Co-Investments in the Private Equity Funds AIFM is generally authorized to offer co-investment opportunities to investors other than a fund client, even in situations where the fund client is not fully invested in the applicable investment opportunity, if, in the opinion of the Firm, the amount invested by the fund client is sufficient for its purposes, or such co-investment may, among other potential considerations, (i) encourage reciprocal investment offers to the fund client, (ii) enhance the investment opportunity, (iii) improve the economics of the investment in which the fund client participates, (iv) resolve regulatory matters in the country of investment, or (v) allow the fund client to participate in transactions, which if entered into without co-investors, would actually or potentially over time exceed the limits set forth in the fund client’s risk management guidelines or the Firm’s sense of prudence or the portfolio construction plan. Decisions to seek and accept a co-investor will be made in the best interests of the applicable fund client. Co-investors may, however, demand a significant level of control over the joint investment and may not, in all cases, have the same economic interests or objectives as the fund client, even if the Firm has not offered special terms to a co-investor. The Firm’s policy is generally to allocate all costs and expenses (including abort costs) relating to a co-investment opportunity proportionately to the co-investing parties, including the fund client. However, there are circumstances where, for commercial or other reasons, such allocation is not possible and such costs and expenses are allocated entirely to the fund.