Advisory Business A. General Description of the Advisory Firm ILIM manages assets on behalf of a diverse range of institutional clients including pension plans, Investment Advisers, Insurance companies, corporations and charitable foundations, across a broad range of asset classes. Irish Life Investment Managers Limited (“ILIM”), previously the asset management division of Irish Life Assurance (established in 1939), is an Irish domiciled company, incorporated in 1997. ILIM is an investment firm authorised by the Central Bank of Ireland under the European Union (Markets in Financial Instruments) Regulations 2017 – S.I. No. 375/2017 (“MiFID II”). ILIM is registered with the Securities Exchange Commission (SEC) as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). ILIM has also been granted the International Adviser Exemption from registration in the Canadian Provinces of Ontario and Manitoba. This exemption enables ILIM to provide advisory services to clients in these provinces in accordance with the applicable securities legislation of Ontario and Manitoba. Since July 2013, ILIM is part of the Great-West Lifeco (“GWL”) group of companies – global leaders in financial services. GWL is a member of the Power Financial Corporation Group of Companies (“Power Group”) and is also the parent company of, inter alia, Canada Life Assurance Company, Irish Life, and Great-West Life Financial (US). In addition to its base in Ireland, Great- West Lifeco has operations in Canada, the United States (“U.S”), the United Kingdom, Ireland and Germany. B. Description of Advisory Services ILIM offers a range of indexed strategies which are designed to track specified market indices and active quantitative strategies which are designed to meet specific objectives. These services are available through separately managed accounts, sub advised client portfolios or collective investment vehicles managed by ILIM. ILIM’s investment philosophy is that by delivering structured investment processes, we aim to manage risk and deliver the desired outcomes to clients. (i) Indexing We offer a wide range of indexed strategies across regional and global markets and across asset classes including both Market and Non-Market Capitalization Indexation and can deliver to client- specific index or mandate requirements. Indexing is an investment strategy for tracking the performance of a specified industry benchmark, or ’index’. An index is an unmanaged group of securities whose aggregate performance is used as a standard to measure the investment performance of a particular strategy. There are many types of indexes. Some represent entire markets, such as the U.S. stock market or the U.S. bond market while other indexes cover market segments, such as small–capitalization stocks or short-term bonds. At ILIM we utilize both replication

and optimization processes for Indexation – the choice of which is determined by a range of factors including, but not limited to, the investment universe, the size of mandate and costs. (ii) Quantitative Strategies We offer a range of active quantitative strategies across regional and global markets including:
• alpha strategies which seek to generate stable outperformance over the benchmark; and
• risk management strategies which are designed specifically to help investors manage the risk of absolute loss of capital over time (“Cumulative Drawdown”). These strategies include low volatility equity strategies and tactical asset allocation strategies. ILIM’s Quantitative investment capabilities were established in 1996. ILIM’s Multi-Asset Team is responsible for the research, development and management of ILIM’s quantitative strategies. The Multi-Asset Team is comprised of a team of highly qualified and experienced portfolio managers with cross asset expertise with a shared investment philosophy and strong quantitative and technological skills. Our quantitative strategies employ proprietary quantitative multi factor models which have been designed over years of research and experience in factor investing. These strategies are designed around a quantitative process that seeks, to assess a number of factors when selecting securities including, but not limited to, an assessment of a security’s relative return potential, valuation, growth prospects, and risk profile to deliver to specific objectives for clients. C. Tailored Advisory Services Clients may require bespoke solutions to enable them to meet their specific investment objectives. To the extent a client retains ILIM to provide investment management services for a separately managed or sub advised portfolio, our capabilities allow for a high degree of customization and the client may impose specific investment restrictions on that account with respect to investing in securities or certain types of securities. Limitations on Services As an asset manager, ILIM provides a specific service. ILIM does not provide tax, legal, or accounting advice and clients should note that, unless otherwise specifically agreed or disclosed in writing, ILIM will not take tax considerations into account in managing a client’s portfolio. For segregated and sub-advised portfolios, we do not advise on or take any action in any legal proceedings, 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. D. Wrap Fee Programs ILIM does not participate in any wrap-fee programs. E. Assets Under Management ILIM manages $118,718,180,095 bn (€91.6.bn) in assets as at December 31st, 2023, on a discretionary basis.