Established in 2001, SSGA Funds Management, Inc. (“SSGA FM” or the “Adviser”) is a global leader in asset management that sophisticated institutions worldwide rely on for their investment needs. The Adviser is registered with the United States (“U.S.”) Securities and Exchange Commission (“SEC”) as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and is an indirect wholly‐owned subsidiary of State Street Corporation (“State Street”), a publicly traded financial holding company. SSGA FM is also registered as a commodity trading adviser (“CTA”) and commodity pool operator (“CPO”) with the U.S Commodity Futures Trading Commission (the “CFTC”) and is a member of the National Futures Association (the “NFA”) in such capacities under the Commodity Exchange Act. SSGA FM and certain other affiliates of State Street make up State Street Global Advisors, the investment management arm of State Street (“State Street Global Advisors”). As of December 31, 2023, SSGA FM had $ 1,014,331,002,469 in regulatory assets under management on a discretionary basis. SSGA FM’s investment advisory clients consist primarily of U.S. investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”), including mutual funds offered through variable annuity products, and certain pooled investment vehicles exempt from registration under the 1940 Act (each a “Fund,” and collectively, the “Funds”), for which SSGA FM is either the named investment adviser or sub‐adviser. SSGA FM works with its clients to provide customized solutions to their investment management needs, which may include customized indexes, model portfolios, and screened portfolios. Clients may impose restrictions on investing in certain securities or types of securities. Pursuant to certain advisory agreements between the Funds and SSGA FM, SSGA FM is authorized to engage one or more sub‐advisers for the performance of any of the services contemplated to be rendered by SSGA FM. SSGA FM also serves as sub‐adviser to various Funds sponsored by unaffiliated third parties, including Funds offered through variable annuity products. SSGA FM provides ETF model portfolio services on a non‐discretionary basis to investment advisers and other financial institutions that use such information provided by SSGA FM for use in or with various financial products offered to their clients. We also advise private limited partnerships, collective investment vehicles and other private funds that are sponsored by SSGA FM, or for which SSGA FM has been engaged to act as investment manager. These entities invest primarily in real estate, publicly-traded or privately-placed equity securities, debt securities, fixed income securities and currencies. In addition, SSGA FM provides a range of investment management services with respect to certain alternatives investment management strategies (“Alternatives”). Alternatives may include direct investment in private placement equity or debt securities (“Private Equity”) and real estate and/or real estate‐related instruments (“Real Estate”). Alternatives also include investments in hedge fund strategies that SSGA FM directly manages, including global fixed income. In addition, Alternatives include investments in pooled investment vehicles employing hedge fund strategies that are managed by third party investment advisers. In addition, SSGA FM provides investment management services with respect to investments in futures, options on futures and swaps or other derivatives instruments. SSGA FM may receive services from certain affiliated entities. SSGA FM may use the services of appropriate personnel of one or more of the other affiliated entities for client solicitation, investment advice, portfolio

execution and trading, and client servicing, except to the extent contractually restricted by the client or not permitted under applicable law. Arrangements among these affiliates could include dual employee or delegation arrangements or formal sub‐advisory or servicing agreements. SSGA FM and its non-U.S. adviser affiliates may enter into an agreement whereby shared personnel may provide advisory resources and trading support in connection with SSGA FM’s services to certain of its clients. If so, such shared personnel will be subject to SSGA FM’s supervision and will be considered “associated persons” of the Adviser as that term is defined in the Advisers Act. The following is a non-exhaustive list of services that SSGA FM may provide to clients:
•Investment Selection — For the substantial majority of SSGA FM’s clients, SSGA FM has full investment discretion for each client that it manages and executes its investment selection decisions in accordance with each client’s investment objectives and policies, applicable legal and regulatory requirements, and the oversight of any client’s Board of Trustees or Directors (the “Board”). Additionally, we combine proprietary global research capabilities with intellectual capital in an effort to improve investment factor efficiencies and to solve investment problems for clients.

• Trading — SSGA FM, as part of its investment management services, provides trading services to its clients pursuant to which it sends orders for execution of client purchases and sales transactions to third-party broker-dealers and other trading venues.
• Operations — Investment operations is organized by function on a regional basis. The functional teams include client administration (including shareholder services) and portfolio services. The Strategic Partner Oversight team is responsible for oversight of functions provided by Investment Management Services (“IMS”) and Global Exchange, which includes portfolio administration, corporate actions, reconciliations, performance measurement and trade administration, and index and benchmark services.
• Securities Lending Program — SSGA FM as investment manager provides oversight of the Securities Lending program for its clients. Oversight of the program includes 1) monitoring of the affiliated lending agent’s implementation of the program’s relevant policies and procedures, 2) assistance in evaluation of program performance, 3) coordination of independent third party advisors and consultants related to the program, and 4) evaluation and recommendations for improvements to the program for Board consideration, if applicable.
• Compliance — SSGA FM has committed substantial resources to establishing a compliance program and dedicates human capital to ensure that compliance requirements are satisfied. SSGA FM has a number of employees who devote a substantial portion of their time supporting its clients’ compliance with applicable law and regulations. This program involves testing and/or oversight of the clients’ service providers and operations, including, as applicable, fund accounting, custody, transfer agency services, portfolio management, investment operations, sales, distribution, and shareholder servicing.
• Risk Management — The Risk Management Group is comprised of investment, model, counterparty, liquidity, operational risk management, and Chief Operating Officer Risk teams, and as such takes on a variety of roles with regards to monitoring, supporting and managing business risks taken through the organization. The Risk Management Group seeks to protect its clients from unintended risks by providing an independent assessment framework to evaluate risk exposures and process controls across asset classes.