A. The Firm Ninety One North America, Inc. (“Ninety One NA”), a Delaware corporation whose principal office and place of business is in New York, NY, is registered with the SEC and a wholly-owned subsidiary of Ninety One International Limited (“Ninety One International”). Ninety One International is a company organized under the laws of England and Wales. Ninety One NA is an indirect wholly-owned subsidiary of Ninety One Plc, a company formed under the laws of England and Wales and listed on the London Stock Exchange and Johannesburg Stock Exchange. Ninety One Plc is affiliated with Ninety One Limited (“Ninety One Ltd,” and together with Ninety One Plc, “Ninety One”), a company incorporated in South Africa and listed on the Johannesburg Stock Exchange as a secondary listing. Ninety One Plc and Ninety One Ltd are part of a dual listed companies structure with linked companies. Ninety One Plc and Ninety One Ltd are separate legal entities and listings, but are bound together by contractual agreements and legal mechanisms. Ninety One Ltd, a limited company organized under the laws of South Africa, owns 100% of Ninety One SA (Pty) Ltd (“Ninety One SA”), whose principal office is located in Cape Town, South Africa and is regulated by the South African Financial Sector Conduct Authority (“FSCA”). Ninety One NA is also an affiliate of Ninety One UK Ltd (“Ninety One UK”), an investment adviser registered with the Financial Conduct Authority (“FCA”), as well as registered with the SEC. Ninety One NA entered into a dual-hatting agreement (“Dual-Hatting Agreement”) with Ninety One UK, Ninety One SA, Ninety One Hong Kong Limited (“Ninety One HK”), and Ninety One Singapore Pte. Limited (“Ninety One Singapore,” and together with Ninety One UK, Ninety One SA, Ninety One HK, the “Dual- Hatting Affiliates”). Pursuant to this agreement, certain employees of the Dual-Hatting Affiliates (“Dual- Hatted Employees”) are permitted to provide discretionary investment advice and portfolio management services to Ninety One NA’s clients. These employees are deemed Ninety One NA’s “associated persons” as defined under the Investment Advisers Act of 1940, as amended (“Advisers Act”) and, in this capacity, are subject to the oversight of Ninety One NA and its Chief Compliance Officer (“CCO”). The Dual-Hatting Agreement is based on no-action letters of the staff of the SEC that permit an SEC-registered investment adviser to rely on and use the resources of advisory affiliates, subject to the supervision of the SEC- registered investment adviser. In connection with their provision of services to Ninety One NA, the Dual- Hatting Affiliates have each appointed Ninety One NA as its agent for service of process within the jurisdiction of the United States. Ninety One NA is an investment adviser to Funds (as defined below) and certain separate accounts (“Separate Accounts”), each as more fully described below. Ninety One NA is also an investment adviser to funds (the “Registered Funds”) registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Complete information concerning the Registered Funds, including advisory fees, minimum account requirements (if any) and termination provisions, is disclosed in each Registered Fund’s prospectus and/or statement of additional information (the “Prospectus”). Ninety One NA is also a sub-adviser to certain non-US separate accounts (the “Sub-advised Separate Account(s)”) and sub-funds of (i) Ninety One Global Strategy Fund (“GSF”) and Ninety One Global Alternative Fund 1 (“GAF”), each a société d'investissement à capital variable Investment Fund under Luxembourg Law, (ii) Ninety One Funds Series iv, an open-ended investment company with variable capital, incorporated in England and Wales and registered with the FCA (“OEIC”), (iii) a cell of the Ninety One Premier Funds PCC Limited (“GSY”) and (iv) a South African unit trust (“UT,” and together with the GSF, the GAF, the OEIC, the GSY, the “Sub-Funds”), as certain of Ninety One NA’s investment personnel provide investment advisory functions to such Sub-Funds (and together with the Sub-advised Separate Accounts, the “Sub-Advised Clients”). In each case, Ninety One NA has been appointed by Ninety One UK as a sub- adviser to the Sub-Advised Clients. As of the date of the brochure, no U.S. investors comprise the Sub- Advised Clients. Complete information concerning the Sub-Funds, including advisory fees, minimum account requirements (if any) and termination provisions, is disclosed in the prospectus, product annex, Key Investor Information Document or similar fund disclosure of each Sub-Fund. For the purpose of the brochure, Ninety One’s direct or indirect subsidiaries are each deemed to be an affiliate (“Ninety One NA Affiliate”). Ninety One NA also markets to non-U.S. institutional clients and distributes through financial intermediaries non-U.S. pooled investment vehicles on behalf of Ninety One UK and other Ninety One NA Affiliates. As of March 31, 2023, Ninety One NA had US $31,668,833,621 in regulatory assets under management calculated on a gross basis, all managed on a discretionary basis. B. The Services Discretionary Services Ninety One NA manages Separate Accounts for institutional investors. Ninety One NA tailors its advisory services to these investors as they typically impose restrictions or limitations on how Ninety One NA manages their accounts according to their investment strategies. The restrictions or limitations generally appear either in the client’s investment management agreement (“IMA”) or in the investment guidelines adopted for the account. Ninety One NA manages the Sub-advised Separate Accounts in accordance with the restrictions or limitations in the IMA originally entered into between Ninety One NA Affiliate and such client. Ninety One NA is also the investment adviser and managing member (the “Managing Member”) for certain U.S. private investment funds

(each, a “Fund,” and together, the “Funds”) and the Funds are offered to institutional investors (“Fund Investors”). In addition, Ninety One NA serves as the investment adviser to Registered Funds that are part of The Advisors’ Inner Circle Fund III, a Delaware business trust registered as an investment company under the Investment Company Act. Finally, Ninety One NA also serves as a sub-adviser to the Sub-Funds. For the purpose of the brochure (except for Item 11, Code of Ethics, Participation or Interest in Client Transaction and Personal Account Dealing), the term “Clients” is defined as the Funds, the Registered Funds, the Separate Accounts and the Discretionary SMAs (as defined below) to distinguish those from the Sub-Advised Clients or Model Delivery Programs (as defined below). Model Delivery Programs Ninety One NA provides discretionary and non-discretionary services to clients through unified managed account programs (“Model Delivery Programs”) by delivering model portfolios (“Model Portfolios”). Ninety One NA provides the Model Portfolios to investment advisers, program sponsors or overlay managers (“Model Delivery Manager”) to construct portfolios and to provide investment advisory and asset allocation services to their clients. When Ninety One NA provides the Model Portfolios to a Model Delivery Manager that delegates investment discretion over its clients’ accounts to Ninety One NA, then that firm’s clients are also Ninety One NA’s clients (“Discretionary SMAs”). Although Ninety One NA has discretion to select investments for client portfolios with respect to Discretionary SMAs, Ninety One NA is not responsible for trade execution and does not perform brokerage, custody, or any other administrative function. When Ninety One NA provides the Model Portfolios on a non-discretionary basis to a Model Delivery Manager that determines when and if to use the Model Portfolios in whole or in part, these accounts are clients of the Model Delivery Manager and not clients of Ninety One NA (“Non-discretionary SMAs”). In these arrangements, Ninety One NA’s services are limited to the creation and maintenance of the Model Portfolios. For Non-discretionary SMAs, Ninety One NA generally does not know the identity of the underlying clients, does not act as a fiduciary to such underlying clients, does not have access to such underlying clients’ account information, does not trade or vote proxies for such underlying clients participating in a Model Delivery Program, and does not perform brokerage, custody, or any other administrative function for either a Model Delivery Program or its underlying clients. Ninety One NA does not provide advice regarding the selection of the Model Portfolios for Non-discretionary SMAs, and such decisions will be made by the participant in consultation with the Model Delivery Manager. In providing services to the Model Delivery Programs, Ninety One NA generally uses the same sources of information and investment/research personnel as Ninety One NA uses to manage its other Clients with similar investment objectives, subject only to differences resulting from such Model Delivery Manager’s investment guidelines or cash or other needs of the applicable Model Delivery Program. For certain Model Portfolios, the recommendations at times will reflect recommendations that Ninety One NA is also providing to its other Clients. Ninety One NA amends and updates the Model Portfolios when a model change occurs and provides this information through a portal or similar uploading system to the Model Delivery Manager. Notwithstanding services provided to the Discretionary SMAs, Ninety One NA does not have direct contact with the clients of any Model Delivery Manager. Please see Item 12, Brokerage Practices for more information about the communication and delivery of recommendations to a Model Delivery Program. Investment Strategies of Discretionary and Non-Discretionary Services Ninety One NA investments are directed by specific processes developed by each of Ninety One NA’s specialist investment teams. In addition to research analysts, each team has portfolio managers who have authority to manage portfolios within pre-agreed risk parameters. Within this structure, the process used to allocate assets varies by strategy and investment team. With the assistance of the Head of Investment Risk, the Co-Chief Investment Officers oversee each Strategy. On behalf of some Clients and across some Strategies, Ninety One NA trades certain swaps, futures and derivatives under the jurisdiction of the Commodity Futures Trading Commission. Ninety One NA relies on an exemption from commodity pool operator and commodity trading advisor registrations in respect of such trading. Ninety One NA provides discretionary investment management services to its Clients under the following investment strategies (“Strategies”):
• 4Factor - International Equity - Global Dynamic Equity - Emerging Markets Equity - Global Core Equity - European Equity - China A Shares
• Emerging Market Fixed Income - Emerging Market Sovereign & Currency - Emerging Markets Local Currency Dynamic Debt - Emerging Markets Hard Currency - Emerging Markets Blended Debt - Africa Fixed Income Opportunities - Emerging Market Corporate - Emerging Markets Investment Grade Corporate Debt - Emerging Markets High Yield Corporate Debt
• Alternative Credit - Multi-Sector Credit
• Quality - Global Franchise - International Franchise
• Multi-Asset - Thematic Equity - Global Environment Ninety One NA provides discretionary and non-discretionary investment management services under the following Strategies:
• Quality - Global Franchise ADR SMA - International Franchise ADR SMA Please refer to the Investment Strategies section in Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for additional information related to our investment strategies.