Firm overview Allspring Investments was incorporated in the State of California in 1981 and converted to a Delaware limited liability company in 2021. It has been registered as an investment adviser with the SEC since April of 1984. Allspring Investments is a direct wholly-owned subsidiary of Allspring Global Investments Holdings, LLC (“Allspring Global Investments Holdings”), a holding company indirectly owned by Allspring Group Holdings, LLC (“Allspring Group Holdings”). Allspring Group Holdings is owned by certain private funds managed by GTCR LLC (“GTCR”) and Reverence Capital Partners, L.P. (“Reverence Capital Partners”), as well as certain others described below. Allspring Investments has offices located throughout the United States. Certain employees of the Allspring Global Investments1 group of companies (collectively, “Allspring”) indirectly own non-voting equity interests in Allspring Group Holdings, the indirect parent of Allspring Investments and the other Allspring Global Investments group of companies. Such Allspring employees hold less than 25% of the fully diluted equity interests of Allspring Group Holdings. In addition, Wells Fargo & Company (“Wells Fargo”) owns a passive non- voting equity interest of less than 9.9% of the fully diluted equity interests of Allspring Group Holdings, through an indirect wholly-owned subsidiary known as Wells Fargo Central Pacific Holdings, Inc. Founded in 1980, GTCR is a leading private equity firm that pioneered The Leaders Strategy™—finding and partnering with management leaders in core domains to identify, acquire and build market-leading companies through organic growth and strategic acquisitions. GTCR is focused on investing in transformative growth in companies in the Business & Consumer Services, Financial Services & Technology, Healthcare and Technology, Media & Telecommunications sectors. Since its inception, GTCR has invested more than $25 billion in over 270 companies, and the firm currently manages more than $35 billion in equity capital. GTCR is based in Chicago with offices in New York and West Palm Beach. Reverence Capital Partners is a private investment firm focused on two complementary and synergistic strategies: (i) financial services-focused private equity and (ii) opportunistic, structured credit. In financial services, Reverence Capital Partners is a thematic investor in leading global, middle-market businesses through control and influence- oriented investments in 5 sectors: (1) Depositories and Non-Bank Finance Companies, (2) Asset and Wealth Management, (3) Insurance, (4) Capital Markets and (5) Financial Technology/Payments and Services. The firm was founded in 2013 by Milton Berlinski, Peter Aberg and Alex Chulack, who collectively bring over 100 years of advisory and investing experience across a wide range of financial services sectors. Prior to November 1, 2021, Allspring was indirectly, wholly-owned by Wells Fargo. Given the large scale and complexity of the divestiture of Allspring from Wells Fargo to new ownership, some technology infrastructure, operational processes and Allspring employees have temporarily remained at Wells Fargo to manage critical processes and systems that transition over time, under a Transition Services Agreement (“TSA”) between Allspring and Wells Fargo. Additionally, Wells Fargo continues to serve as an important client and, subject to applicable 1 Allspring Global Investments is the trade name for the asset management companies of Allspring Global Investments Holdings, LLC, that includes Allspring Investments; Allspring Funds Management, LLC (“Allspring Funds Management”), Allspring Global Investments (UK) Limited (“Allspring UK”), Allspring Funds Distributor, LLC (“Allspring Funds Distributor”), Allspring Global Investments Luxembourg S.A. (“Allspring Luxembourg”), Allspring Global Investments (Singapore) Pte. Ltd.; Allspring Global Investments (Hong Kong) Limited (“Allspring Hong Kong”) and Allspring Global Investments (Japan) Limited (“Allspring Japan”). Associated with Allspring, but not part of the Allspring trade name/GIPS firm, is Galliard Capital Management, LLC (“Galliard”), which is a direct wholly owned subsidiary of Allspring Global Investment Holdings. fiduciary duties and other considerations, Wells Fargo remains an important distribution partner with respect to Allspring products in a manner similar to their role prior to the divestiture. Types of advisory services Allspring Investments provides investment management services to mutual funds, private funds, offshore funds, collective investment trusts (“CITs”), pooled vehicles and client accounts. Allspring Investments’ clients include institutional clients such as corporations, endowments, foundations, pension plans, healthcare organizations, educational organizations, public agencies, multi-employer plans, sovereign organizations, insurance companies, other investment advisers and high net worth individuals, as well as retail clients with separately managed accounts. Allspring Investments’ investment management services are offered on both a discretionary and non-discretionary basis. When Allspring Investments offers investment management services on a discretionary basis, the client relies on Allspring Investments to formulate and, in most cases, to implement the investment decisions consistent with parameters and information that the client provides in advance. Allspring Investments will tailor its investment management services to the individual needs of its clients, including by incorporating client specific restrictions, as necessary. However, Allspring Investments will not accommodate investment restrictions that are unduly burdensome, including any requested restrictions on underlying securities held in a fund/commingled vehicle in which the client invests. Allspring Investments reserves the right to decline, accept, or terminate client accounts with such restrictions. Investment restrictions requested by a client might cause the performance of their account to differ from that of the portfolio recommended by Allspring Investments, possibly producing less-favorable overall results. Allspring Investments also provides

non-discretionary investment management services that include providing securities ranking information and model portfolios to other investment advisers, including one affiliated investment adviser. As explained in Item 8 below, Allspring Investments’ non-discretionary services are used by other investment advisers to provide advisory services to their clients. Where Allspring Investments is the investment adviser or sub-advisor to a pooled investment vehicle (e.g., mutual fund or private fund), investments will not be tailored to the individualized needs of any particular investor in the pooled investment vehicle. Investors may not impose restrictions on investing in certain securities or certain types of securities but rather will be subject to the investment guidelines as described in the vehicle’s prospectus or other offering document. Allspring Investments utilizes proprietary and vended investment allocation systems in conjunction with the securities selection services provided by its portfolio managers to create and maintain actively managed investment portfolios intended to meet the requirements of its clients’ investment needs. For certain retail account clients, Allspring Investments utilizes a systematic portfolio construction tool overseen by its portfolio managers that produces customized portfolios targeting specific outcomes, risk management and tax management. Allspring Investments offers a variety of equity, multi-asset, derivative, and fixed income investment strategies and these investment strategies (collectively) invest in a wide variety of financial instruments. In circumstances where a client is willing to accept greater risk in pursuit of potential higher total return, Allspring Investments also uses certain types of techniques, including buying securities on margin, trading derivatives, and selling securities short. Wrap fee programs Allspring Investments provides investment sub-advisory services on a discretionary and non-discretionary basis to separately managed account programs (referred to as "wrap fee programs" or "SMA programs") for which its affiliate, Allspring Funds Management, provides investment advisory services. The wrap fee programs are sponsored by third- party broker dealers or investment advisers (“Sponsors”). With respect to a traditional wrap fee program, the Sponsor offers clients the ability to have their separately managed accounts managed by one or more participating investment advisers, such as Allspring Funds Management. For a single unified or wrap fee that is paid by the wrap program client and typically includes investment management, brokerage, custody and other program services, Sponsors will select and monitor the services of the participating investment advisers, define client investment objectives and risk tolerances, evaluate performance, and maintain required records relating to the client’s account. Allspring Investments typically receives a portion of the compensation paid by the Sponsor to Allspring Funds Management for its investment sub-advisory services provided to the wrap fee program, which fee is based on the amount of client assets invested in strategies serviced by Allspring Investments. Allspring Investments shares discretionary investment authority with Allspring Funds Management over the wrap fee program participants’ accounts, apart from most model delivery programs. Generally, where Allspring Investments has discretion, Allspring Investments considers and manages the account according to the program participant’s individual needs and guidelines, which are provided by the Sponsor. With respect to certain wrap fee programs, Allspring Investments provides model portfolios on a non-discretionary basis to Allspring Funds Management; and depending on the program, Allspring Funds Management or its outsourced provider either implement the model portfolio for program participant accounts according to account guidelines – which are provided by the Sponsor – or communicate the model portfolio to the Sponsor to implement for the account(s). In both instances, Allspring Investments typically provides the model portfolio to Allspring Funds Management on a non-discretionary basis. When Allspring Investments is providing investment advice to Allspring Funds Management on a non-discretionary basis, it does not consider the program participant to be a client of Allspring Investments and does not include the assets as part of the reported Regulatory Assets Under Management. Pursuant to an agreement, Allspring Funds Management relies on Allspring Investments to provide trading and/or other support services related to these programs. In instances where Allspring Investments is providing overlay services via strategy or account optimization, Allspring Investments is considered to have discretion. Unlike Allspring Investments’ institutional clients, Allspring Investments does not communicate directly with wrap fee program participants unless the program participant has an agreement directly with Allspring Funds Management as the participant’s investment adviser, and Allspring Investments serves as a sub-adviser for the participant’s account. Wrap fee program accounts may not be managed identically to institutional accounts, so purchases that are implemented for institutional accounts will not always be reflected or fully reflected in wrap accounts that follow the same or a substantially similar strategy. For instance, there are scenarios in which managed account clients will not have the opportunity to participate or fully participate in certain transactions due to various circumstances (e.g., timing, relationships, volume limitations and availability) that are applicable to institutional clients. To the extent that a Sponsor of a wrap fee program provides Allspring Investments’ Form ADV Part 2A to SMA program clients with whom Allspring Investments has no advisory relationship, or when it is not legally required to be delivered, it is provided for informational purposes only. Current assets under management As of December 31, 2023, Allspring Investments had $ 429,010,617,291 in regulatory assets under management on a discretionary basis and $ 13,822,876 in regulatory assets under management on a non-discretionary basis.