Introduction BNY Mellon Investment Adviser, Inc. (“BNYMIA”) (the “Firm” or “We” or “Us”) is a US- registered investment adviser organized under the laws of State of New York. We are a wholly owned subsidiary of MBC Investments Corporation, which in turn is a wholly owned subsidiary of The Bank of New York Mellon Corporation (“BNY Mellon”). BNYMIA was originally formed in 1951 as The Dreyfus Corporation, a pioneer of the US mutual fund industry. Effective June 3, 2019, The Dreyfus Corporation changed its name to BNY Mellon Investment Adviser, Inc. As of the date of this Brochure, all of our clients consist of affiliated, US-registered mutual funds - The BNY Mellon Family of Funds and The BNY Mellon Funds Trust - and certain affiliated private placement funds as described below under Equity Fund Management. This Brochure does not apply to the advisory services provided to affiliated U.S.-registered mutual funds since the SEC does not require delivery of a Brochure to such funds. We may from time to time offer investment advisory services to pooled investment vehicles other than U.S.-registered mutual funds. Such pooled investment vehicles (each a “pooled vehicle”) would each have a stated investment objective and a set of uniform investment policies and guidelines we would be required to follow. For this reason, unlike separate accounts, pooled vehicle guidelines cannot be tailored for, nor selectively applied to, individual underlying participants, but are meant to apply in common across all pooled vehicle participants. We offer investment advisory services to non-U.S. clients and may be subject to the laws and regulations of the relevant jurisdictions. Assets Under Management As of the date of this Brochure we managed $339.70 billion on a discretionary basis; no assets were managed on a non-discretionary basis. Of this amount, $330.48 billion is attributable to affiliated, US-registered mutual funds and $9.22 billion to our Equity Fund Management business. Equity Fund Management In addition to the investment advisory services we provide to affiliated mutual

funds, we serve as manager (or in a similar capacity) to certain equity-strategy pooled investment vehicles (the “Funds”). The Funds are organized as one of a variety of corporate forms, including limited partnerships, limited liability companies, trusts and group trusts. The Funds are not registered under the Investment Company Act of 1940, as amended ("Investment Company Act”), and certain of the Funds are not offered or available to US investors. We provide investment advisory and fund operation services to the Funds, either through a management agreement or pursuant to a Fund’s operating document. In addition, we carry out the key activities of risk management, fund administration and governance, as well as the ongoing oversight of service providers. With respect to certain of the Funds, to maintain the Fund’s legal structure and retain the ability to perform certain administrative functions, we hold a nominal ownership position in the Fund. With respect to such nominal ownership, we collect no dividends and receive no voting rights. As agent of the Funds, we have entered into an advisory agreement with Walter Scott & Partners Limited (“Walter Scott” or the “Investment Manager”), an affiliated investment adviser, and have delegated to Walter Scott the discretion to make all investment decisions for the Funds’ portfolios and to perform certain other tasks for the Funds, subject to our overall supervision. Walter Scott carries out the day-to-day portfolio management and determines the amount of capital committed to each investment for the Funds. The Funds are offered only to sophisticated and institutional investors. Each of the Funds has an investment objective and a set of investment policies and/or guidelines that it must follow. For this reason, we cannot tailor the investment advisory services we provide to the Funds to meet individual investor needs. In addition, we cannot impose individual investment restrictions on the investment strategies for underlying investors in the Funds. The Funds employ a ‘long only’ equity investment strategy with regional focuses, including international, US and global.