JHIUS is an indirect, wholly-owned subsidiary of Janus Henderson Group plc (“Janus Henderson Group”). Janus Henderson Group is a publicly-traded company (NYSE:JHG) conducting business as Janus Henderson Investors. Janus Henderson Group is responsible for the strategic direction of its subsidiaries. More information about certain financial industry affiliations of JHIUS is described in Item 10 – Other Financial Industry Activities and Affiliations. Janus Henderson Investors’ mission is to help clients define and achieve superior financial outcomes through differentiated insights, disciplined investments, and world-class service. This means being ever mindful of the futures of the millions of lives that our thinking and our investments help shape. Janus Henderson Investors provides access to some of the industry’s most talented and innovative thinkers, spanning equities, fixed income, multi-asset and alternatives, globally. Janus Henderson Investors believes its clients benefit from: 1. Differentiated Insights
• A deep-rooted research culture, which underpins the long-standing track record of investing.
• Insights from company meetings combined with proprietary analysis results in original views that shape investment positioning.
• 340+ investment professionals worldwide share ideas to differentiate between the winners and losers. 2. Disciplined Investments
• Setting clearly defined objectives to deliver long-term risk-adjusted returns.
• Staying true to their investment style through all market conditions. 3. World Class Service
• Combining global reach with the responsiveness, tailored solutions, and personal touch of a local partner.
• Understanding the challenges of clients and our clients’ clients, enabling us to blend best ideas and capabilities to define tailored outcomes.
• Contributing to clients’ understanding and decision-making through published insights, at events, and in debate on the future of investing. JHIUS, through its predecessors, has provided investment management services since 1969 and has been registered with the SEC since 1978. Over the last several years, JHIUS has expanded its business to become a more diversified manager with increased investment product offerings and distribution capabilities. As of December 31, 2023, JHIUS had approximately $239,345,489,058 in regulatory assets under management on a discretionary basis and $0 in regulatory assets under management on a non-discretionary basis. JHIUS has offices in Denver, Colorado; Newport Beach, California; Darien, Connecticut; Chicago, Illinois; Boston, Massachusetts; and New York City, New York. Janus Henderson Group has a broader global footprint with additional offices in Amsterdam, Brisbane, Copenhagen, Dubai, Edinburgh, Frankfurt, Geneva, Hong Kong, London, Luxembourg, Madrid, Melbourne, Milan, Paris, Singapore, Sydney, Tokyo and Zurich. In addition to offering its own proprietary investment strategies, JHIUS offers investment strategies through other affiliates within the Janus Henderson Group, including using participating affiliate arrangements, as described in greater detail under Item 10 – Other Financial Industry Activities and Affiliations. JHIUS provides investment management services, as an investment adviser or sub-adviser, to U.S. and non-U.S. institutional and individual clients and investors through the following types of products:
• U.S. mutual funds and exchange-traded funds (“ETFs”), registered under the Investment Company Act of 1940, as amended (the “1940 Act”) (“U.S. Investment Companies”),
• non-U.S. domiciled mutual funds, trusts or similar entities (“non-U.S. Investment Companies”),
• private funds, including hedge funds, offered pursuant to Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), and excluded from the investment company definition under either Section 3(c)(1) or 3(c)(7) of the 1940 Act (“Private Funds”),
• individual and institutional separate accounts (“Separate Accounts”),
• separately-managed account wrap programs offered by unaffiliated investment advisers or broker-dealers,
• collective investment trusts, and
• other proprietary accounts. In this Brochure, we refer to the funds in the Janus Investment Fund trust as the “Sponsored Funds.” When JHIUS serves as investment adviser, it enters into a written investment management agreement with each of its advisory clients. Investors in U.S. Investment Companies and non-U.S. Investment Companies (together, “Investment Companies”), Private Funds and other pooled investment vehicles do not generally enter into investment management agreements with JHIUS and are not considered JHIUS’s advisory clients. With respect to any Sponsored Fund, this Brochure is qualified in its entirety by the Sponsored Fund’s prospectus, statement of additional information or similar disclosure and governing documents (collectively, the “offering documents”). Janus Henderson Direct Advice Portfolios JHIUS offers individual retail clients a discretionary investment advice service (the “Direct Advice Portfolios Program”) that maintains a target allocation among one or more Sponsored Funds (a “Managed Allocation Recommendation”) based on a client’s responses to an investor due diligence questionnaire (the “Investor Questionnaire”). The Investor Questionnaire asks clients a series of questions to identify their investment objective, risk tolerance and time horizon. In addition to completing the Investor Questionnaire, clients will separately be asked about their initial investment amount. The Direct Advice Portfolios Program does not consider a client’s income and expenses, assets and debts, marital status, tax status, sophistication or any other financial or non- financial factors beyond those specifically identified above or reflected in the Investor Questionnaire. As set out in Item 7 – Types of Clients, the Direct Advice Portfolios Program is available to eligible retail direct shareholders with certain tax-deferred or tax-advantaged accounts (e.g., IRA and Coverdell accounts) held directly with the Sponsored Funds’ transfer agent, Janus Henderson Services US LLC (the “Transfer Agent”). To enroll in the Direct Advice Portfolios Program, clients must establish or have established an eligible account with the Transfer Agent (a “Direct Advice Portfolios Program Account”) and must agree to the terms of the Direct Advice Portfolios Program Agreement, including acknowledgment of receipt of the Form ADV Part 2A, Part 2B and Part 3, relevant offering documents, and other program materials; consent to electronic signatures; and consent to electronic delivery of certain Direct Advice Portfolios Program communications and notices through the Secure Messaging System, by email, by click-through acknowledgement or otherwise. The Transfer Agent will provide custodial, administrative, recordkeeping and reporting services for the Direct Advice Portfolios Program Accounts. Clients may enroll in the Direct Advice Portfolios Program over the phone by first contacting the Transfer Agent who will conduct an initial screening and then transfer eligible potential clients to the licensed employees of JHIUS (the “Advisory Representatives”) providing investment advice as part of the Direct Advice Portfolios Program and Direct Advice Investments Programs. Clients may also be able to enroll in the Direct Advice Portfolios Program online at janushenderson.com. Clients must complete the Investor Questionnaire at the time of their enrollment in the Direct Advice Portfolios Program. For those clients who have enrolled over the phone, the Advisory Representative will walk the client through the Investor Questionnaire and enter their responses to the Investor Questionnaire on their behalf. During this interaction, the Advisory Representative may discuss the features of the Direct Advice Portfolios Program and the assumptions underlying the Managed Allocation Recommendation with the client and assist with any implementation needs. However, the Managed Allocation Recommendation is responsive only to the client’s answers to the Investor Questionnaire; the Advisory Representative does not formulate any advice or recommendations to the client independently of the Investor Questionnaire. Clients are responsible for providing accurate and complete information to JHIUS, including in their Investor Questionnaire, and for promptly notifying JHIUS of any changes to information previously provided, providing updated responses to their Investor Questionnaire or changing their elections. Depending on the changes, JHIUS may make a different Managed Allocation Recommendation for the client, which will result in trading activity in the client’s Direct Advice Portfolios Program Account. If a client does not update their Investor Questionnaire Information, we may continue to manage the client’s Direct Advice Portfolios Program Account according to the most recent information provided by the client. For example, if the client indicated in their most recent Investor Questionnaire that their time horizon for the Direct Advice Portfolios Program Account is 15 years and the client does not update that information the following year, we will maintain their Direct Advice Portfolios Program Account in the portfolio recommended to them consistent with a 15-year time horizon. Even though the client’s time horizon may change with the ordinary passage of time, we will not adjust the client’s time horizon or the associated portfolio used to manage their Direct Advice Portfolios Program Account year-over-year unless the client updates their time horizon within their Investor Questionnaire responses. The client’s answers to the Investor Questionnaire are considered solely for purposes of the Direct Advice Portfolios Program and will not be considered in connection with other accounts or services that may be offered by JHIUS or its affiliates. Similarly, any information clients provide to JHIUS or its affiliates that is not reflected in the Investor Questionnaire will not be considered as part of the Direct Advice Portfolios Program (e.g., if clients provide information relevant to their time horizon to the Advisory Representatives, this will have no impact on the client’s recommended portfolio absent an accompanying update to their Investor Questionnaire). JHIUS and/or its affiliates shall not bear any responsibility for investment management decisions or other actions taken on the basis of any incomplete, misleading, or incorrect information provided by clients or because of a client’s failure to promptly update the information when changes occur. For this reason, clients are required to revisit their Investor Questionnaire inputs and elections at least annually. We reserve the right to terminate the client’s Direct Advice Portfolios Program Account for failing to confirm current information and/or to provide updated information. The Direct Advice Portfolios Program is designed to provide clients with a Managed Allocation Recommendation based on their responses to the Investor Questionnaire and the results produced by a proprietary investment advice model described in Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Each Direct Advice Portfolios Program Account will generally be assigned to one of six model portfolios that JHIUS determines best aligns with their time horizon and risk tolerance with an equity allocation ranging from approximately 0% to 100%; although, clients may subject to certain limitations select another model portfolio which presents greater or lesser risk at their discretion and different from the advice of JHIUS . As further explained in Item 16 – Investment Discretion, JHIUS may in its discretion allow clients to impose certain restrictions on the management of their account where JHIUS deems those restrictions reasonable and where they do not prevent JHIUS from meeting its fiduciary duty to the client in the context of the Direct Advice Portfolios Program. The equity allocation resulting from the Investor Questionnaire and/or otherwise agreed to by the client will be considered as part of the client’s investment objective. Due to the systematic nature of the advice model, clients with similar investment time horizons and risk tolerances are typically provided the same Managed Allocation Recommendation. As discussed in Item 13 – Review of Accounts and Item 16 – Investment Discretion, by entering into the Direct Advice Portfolios Program Agreement, the client authorizes JHIUS to provide discretionary investment management services by determining the appropriate fund allocations for the client’s Direct Advice Portfolios Program Account and investing them in a selection of participating Sponsored Funds that coincide with the model portfolio recommended by JHIUS or otherwise instructed by the client. Generally, at the time of the agreement or promptly thereafter, JHIUS will buy and sell shares of the participating Sponsored Funds in the Direct Advice Portfolios Program Account to align with the allocation of the model portfolio to which the client has been assigned or which the client has otherwise instructed. Thereafter, JHIUS continuously monitors the relevant model portfolios and periodically rebalances the associated Direct Advice Portfolios Program Accounts to maintain alignment with its current fund allocations, subject to rebalancing parameters and de minimis thresholds (e.g., no exchanges of less than a defined dollar or percentage threshold) that JHIUS establishes from time to time. JHIUS can change its rebalancing methodology and de minimis thresholds at its discretion without notice to the client. JHIUS may periodically revise or adjust the fund allocations for each model portfolio consistent with the overall asset allocation methodology described in Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss. Any capital gains and dividends will be automatically reinvested. As noted above, the Direct Advice Portfolios Program is not a complete investment program as it does not consider a client’s outside assets, income, debt, and a number of other financial and non-financial considerations. It is also not designed for and may be inappropriate for short-term investors. The Direct Advice Portfolios Program consists solely of asset allocation and trading services among certain Sponsored Funds participating in the Direct Advice Portfolios Program (i.e., a subset of Sponsored Funds comprising the model portfolio to which an investor is assigned). JHIUS will not evaluate Janus Henderson- sponsored funds other than the Sponsored Funds and will not evaluate share classes of the Sponsored Funds other than the Sponsored Funds’ Class D shares. JHIUS will also not evaluate third-party funds for inclusion in the Direct Advice Portfolios Program even if they have characteristics similar or superior to, or fees and expenses that are lower than, the Sponsored Funds. The Direct Advice Portfolios Program does not include recommendations to invest in individual securities, ETFs, third-party mutual funds or other non-Janus Henderson securities. The Direct Advice Portfolios Program is not required to include any particular Sponsored Fund. At its discretion, JHIUS may remove funds from or add funds to the recommended model portfolios. The Sponsored Funds within the specific model portfolio will be identified during the account opening process and in periodic account statements. Not all Sponsored Funds being used in the Direct Advice Portfolios Program may be included in any specific model portfolio or Direct Advice Portfolios Program Account. As part of the Direct Advice Portfolios Program Agreement, clients agree to fund their Direct Advice Portfolios Program Account with at least $10,000 in cash or Sponsored Funds (amount subject to waiver or change at JHIUS’s discretion). JHIUS, in its sole discretion, may refuse or terminate any client’s participation in the Direct Advice Portfolios Program for any reason, including but not limited to failure to meet the initial funding requirements generally within 60 days of the initial Direct Advice Portfolios Program Account opening. JHIUS will generally only invest funds received in the Direct Advice Portfolios Program Account upon full receipt of the investment minimum. JHIUS makes no representation as to how quickly Direct Advice Portfolios Program Accounts, either via initial or ongoing funding, will be invested. Client assets may not be fully invested and will be subject to market risk between investment, redemption and reinvestment dates, including, but not limited to, cases in which JHIUS is required to sell one fund and purchase another fund. Contributions to the Direct Advice Portfolios Program Account must be made by check, wire transfer, Automated Clearing House (ACH) or other methods determined by JHIUS and the Transfer Agent. If the market value of a Direct Advice Portfolios Program Account falls below the defined investment minimum as a result of withdrawals as opposed to market movement, JHIUS may require the client to deposit additional cash to bring the Direct Advice Portfolios Program Account up to the required minimum. JHIUS reserves the right to terminate the Program Account if it is not brought up to the required minimum. Transactions involving Direct Advice Portfolios Program Accounts may be conducted by

telephone with the assistance of an Advisory Representative. Certain transactions, such as additional contributions, may also be performed online. Daily cutoff times for submitting requests for deposits or withdrawals in the Direct Advice Portfolios Program Accounts and their anticipated processing times are disclosed in the relevant Sponsored Funds’ offering documents. Daily cutoff times for submitting requests may be earlier than market close. JHIUS reserves the right to change the daily cutoff times at any time in its sole discretion. Depending on the nature of the request, requests for withdrawals may take up to 7 calendar days. JHIUS reserves the right to temporarily suspend redemptions and postpone payment of redemption proceeds during periods of market stress, consistent with the terms set forth in the relevant Sponsored Funds’ offering documents. Clients may request that a check be sent to the address of record. Depending on the type of Direct Advice Portfolios Program Account and the exact dollar amount a client wishes to withdraw, more information may be necessary before the withdrawal can occur. Clients should contact an Advisory Representative by phone. As noted above, clients participating in the Direct Advice Portfolios Program agree to use electronic signatures and accept electronic delivery (as available) of any communications associated with the client’s Direct Advice Portfolios Program Account, including, but not limited to, the Direct Advice Portfolios Program Agreement, the Form ADV Part 2A, Part 2B and Part 3, transaction confirmations, statements, agreements, disclosure documents, prospectuses, annual and semiannual reports, account communications, proxies, and other materials, including all applicable future updates of these documents. Clients may print or save a copy of any of the account communications for as long as they are available on their online account. Clients have the right to request in writing, free of charge, a paper copy of certain documents required to be delivered under the Internal Revenue Code as described in the IRA Agreement as well as Form ADVs and Forms CRS. Such requests do not waive or invalidate a client’s consent to electronic distribution. Internet access is required to enroll in the Direct Advice Portfolios Program and to access all Direct Advice Portfolios Program related documents. Clients are required to maintain an accurate and up-to-date email address with JHIUS and the Transfer Agent for the Direct Advice Portfolios Program and to ensure that they have the ability to read, download, print, and retain documents they receive. In the event of failed electronic delivery to the client’s email, JHIUS may post account communications in the Secure Messaging Center or mail the client’s account communications to them in paper form to the client’s address of record until they successfully update their email address. JHIUS reserves the right to terminate a client’s Direct Advice Portfolios Program Account if the client does not maintain an accurate and up-to-date email address for the Direct Advice Portfolios Program. To the extent clients enroll in the Direct Advice Portfolios Program digitally by electronic means (such as clicks, e- signatures or other online means), the Direct Advice Portfolios Program Agreements are legally binding and are considered to have been “signed” by the client with the same effect as a physical signature. Electronic records of the Direct Advice Portfolios Program Agreements that are made online will also be considered to be “in writing.” Clients agree not to dispute the validity or enforceability of any of the Direct Advice Portfolios Program Agreements entered into electronically by the client (or by anyone using client’s authentication devices, such as a password or PIN). Any notice required to be given to JHIUS by the client (other than as otherwise specified herein) in relation to the Direct Advice Portfolios Program will be delivered electronically through the JHIUS and Transfer Agent’s website or another website designated by JHIUS. Notice given by the client may also be sent by U.S. mail, certified or registered, or overnight courier, postage prepaid with return receipt requested, and addressed to Janus Henderson Investors US LLC, P.O. Box 219109, Kansas City, MO 64121-9109 or to another address specified by JHIUS in writing. The client may terminate the advisory relationship by contacting an Advisory Representative by phone and communicating their intention to withdraw from the Direct Advice Portfolios Program. Such termination and withdrawal, however, will only be effective upon written confirmation from JHIUS. JHIUS may terminate the advisory relationship at any time by written notice to the client. JHIUS may terminate or suspend our advisory services for a client’s Direct Advice Portfolios Program Account and/or place other restrictions on a client’s Direct Advice Portfolios Program Account for any reason at our sole discretion. Reasons for termination by JHIUS include, but are not limited to, a client not providing updated Investor Questionnaire responses, a client’s Program Account balance falling below the minimum account maintenance level of $10,000 (subject to change at our discretion); failure to maintain a valid email address; or revocation of consent to electronic delivery of all Direct Advice Portfolios Program Account related communications, excluding those noted above which can be delivered in hard copy upon request. Before terminating a Program Account, JHIUS will generally provide clients with a minimum of 10 business days’ notice. Certain instances may arise, however, where we may need to suspend investment including, without limitation, if clients reside outside the U.S. or otherwise fail to comply with applicable law, rule, or regulation or any other applicable requirement of the Direct Advice Portfolios Program, including electronic delivery. In such instances, JHIUS will attempt to contact the client with further instructions. If the advisory relationship is terminated for any reason, the client’s accounts which were previously within the Direct Advice Portfolios Program will remain open; however, they will no longer be investment advisory accounts managed by JHIUS, and JHIUS will no longer have or exercise investment discretion over them. Upon termination, the client’s accounts will include the same Sponsored Funds in the same proportions and amounts prior to termination of the advisory relationship. The owner registration (including mailing address) and any beneficiaries on the accounts will likewise remain unchanged. Any accounts created in connection with the enrollment in the Direct Advice Portfolios Program and any transactions in those accounts or other accounts held with the Transfer Agent will be subject to all other surviving terms and conditions, including but not limited to those set out in the Direct Advice Portfolios Program Agreement and the offering documents for each Sponsored Fund held by the client. Termination will not affect: (a) the validity of any action we have previously taken, (b) any liabilities or obligations for transactions initiated before termination, or (c) our or our affiliates’ right to retain compensation from the Sponsored Funds held in the Direct Advice Portfolios Program Account, or any fees for services rendered that the client or the client’s Direct Advice Portfolios Program Account may have agreed to pay. We will have no obligation to take any action with regard to assets in a client’s IRA or Coverdell account (i.e., a former Direct Advice Portfolios Program Account) after the termination of the Direct Advice Portfolios Program Agreement except as directed by the client. During periods of market volatility or high demand, clients’ ability to effect transaction and our ability to execute client transactions may be impacted due to system delays or outages, which could result in losses. High call volumes during such periods may also result in delays in reaching a representative or in the execution of transactions. JHIUS and its affiliates do not provide any tax advice. Although a client’s actions to enroll in the Direct Advice Portfolios Program may raise tax or other legal implications, clients acknowledge that JHIUS bears no responsibility for their decision-making. Clients are responsible for any tax implications and/or tax obligations arising as a result of their use of the Direct Advice Portfolios Program. Clients are strongly encouraged to seek the advice of their accountant or attorney for tax or legal questions related to their participation in the Direct Advice Portfolios Program. Janus Henderson Direct Advice Investments JHIUS offers individual retail clients a non-discretionary investment advice service (the “Direct Advice Investments Program”) that provides a point-in-time investment recommendation consisting of a single Sponsored Fund (the “PIT Investment Recommendation”) based on a client’s responses to the Investor Questionnaire. The Investor Questionnaire asks clients a series of questions to identify their investment objective, risk tolerance and time horizon. In addition to completing the Investor Questionnaire, clients will separately be asked about their initial investment amount. The Direct Advice Investments Program does not consider a client’s income and expenses, assets and debts, marital status, tax status, sophistication or any other financial or non-financial factors beyond those specifically identified above or reflected in the Investor Questionnaire. As set out in Item 7 – Types of Clients, the Direct Advice Investments Program is available to eligible retail direct shareholders with certain tax-deferred or tax-advantaged accounts (e.g., IRA and Coverdell accounts) held directly with the Transfer Agent. To enroll in the Direct Advice Investments Program, clients must establish or have established an eligible account with the Transfer Agent and must agree to the terms of the Direct Advice Investments Program Agreement, including acknowledgment of receipt of the Form ADV Part 2A, Part 2B and Part 3, relevant offering documents, and other program materials; consent to electronic signatures; and consent to electronic delivery of all Direct Advice Investments Program communications and notices through the Secure Messaging System, by email, by clickthrough acknowledgement or otherwise. Clients may enroll in the Direct Advice Investments Program over the phone by first contacting the Transfer Agent who will conduct an initial screening and then transfer eligible potential clients to the Advisory Representatives. Clients may also be able to enroll in the Direct Advice Investments Program online at janushenderson.com. Clients must complete the Investor Questionnaire at the time of their enrollment in the Direct Advice Investments Program. For those clients who have enrolled over the phone, the Advisory Representative will walk the client through the Investor Questionnaire and enter their responses to the Investor Questionnaire on their behalf. During this interaction, the Advisory Representative may discuss the features of the Direct Advice Investments Program and the assumptions underlying the PIT Investment Recommendation with the client and assist with any implementation needs. However, the PIT Investment Recommendation is responsive only to the client’s answers to the Investor Questionnaire; the Advisory Representative does not formulate any advice or recommendations to the client independently of the Investor Questionnaire. Clients are responsible for providing accurate and complete information to JHIUS, including in their Investor Questionnaire, for providing updated responses to their Investor Questionnaire in order to obtain a new PIT Investment Recommendation or for changing their program elections. The client’s answers to the Investor Questionnaire are considered solely for purposes of the Direct Advice Investments Program and will not be considered in connection with other accounts or services that may be offered by JHIUS or its affiliates. Similarly, any information clients provide to JHIUS or its affiliates that is not reflected in the Investor Questionnaire will not be considered as part of the Direct Advice Investments Program (e.g., if clients provide information relevant to their time horizon to the Advisory Representatives, this will have no impact on the client’s recommended portfolio absent an accompanying update to their Investor Questionnaire). JHIUS and/or its affiliates shall not bear any responsibility for investment management decisions or other actions taken on the basis of any incomplete, misleading, or incorrect information provided by clients. The Direct Advice Investments Program is designed to provide clients with a PIT Investment Recommendation. The PIT Investment Recommendation will be one of three Janus Henderson allocation funds which invest in a portfolio of Sponsored Funds and seek to meet a specific risk-return profile: Janus Henderson Global Allocation Fund – Conservative, Janus Henderson Global Allocation Fund – Moderate and Janus Henderson Global Allocation Fund – Growth. Due to the systematic nature of the advice model, clients with similar investment time horizons and risk tolerances are typically provided the same PIT Investment Recommendation. In addition, due to the design and objectives of the Sponsored Funds, none of the Sponsored Funds eligible may be fully aligned to an individual client’s investment objective, time horizon and risk tolerance. JHIUS will not evaluate Janus Henderson-sponsored funds other than the Sponsored Funds and will not evaluate share classes of the Sponsored Funds other than the Sponsored Funds’ Class D shares. JHIUS will also not evaluate third-party funds for inclusion in the Direct Advice Investments Program even if they have characteristics similar or superior to, or fees and expenses that are lower than, the Sponsored Funds. The Direct Advice Investments Program does not include recommendations to invest in individual securities, ETFs, third-party mutual funds or other non-Janus Henderson securities. The Direct Advice Investments Program is not required to include any particular Sponsored Fund. While they are intended to be correlated, the performance and risk of a PIT Investment Recommendation may materially differ from the performance and risk of a Managed Allocation Recommendation due to differences in methodology, objectives and other factors. Any clients who would prefer a portfolio which may better align with their investment time horizon and risk tolerance should consider the separate Direct Advice Portfolios Program described above. The Direct Advice Investments Program only provides point-in-time investment advice and is not an ongoing investment advisory relationship. A PIT Investment Recommendation delivered over the phone by an Advisory Representative expires at the end of that particular conversation. To the extent available, a PIT Investment Recommendation delivered through the Janus Henderson Investors website expires at the end of that particular online session. The client is solely responsible for implementing the PIT Investment Recommendation, and clients have no obligation to accept any recommendations provided by JHIUS through the Direct Advice Investments Program. While clients may instruct the Advisory Representatives to implement the PIT Investment Recommendation or another investment decision on their behalf, the Advisory Representatives are not exercising any investment discretion when acting at the client’s direction to implement the PIT Investment Recommendation. JHIUS is not authorized to make decisions regarding clients’ accounts or investments and will not monitor or manage any of the client’s accounts opened to implement the PIT Investment Recommendation, whether at JHIUS or elsewhere. Since PIT Investment Recommendations expire at the end of an online session or a phone call with an Advisory Representative, such recommendations do not account for any changes to the client’s investment goals, risk tolerance, or time horizon, and JHIUS is not responsible for any decision to implement the recommendation after it has expired. To the extent clients enroll in the Direct Advice Investments Program digitally by electronic means (such as clicks, e-signatures or other online means), the Direct Advice Investments Program Agreements are legally binding and are considered to have been “signed” by the client with the same effect as a physical signature. Electronic records of the Direct Advice Investments Program Agreements that are made online will also be considered to be “in writing.” Clients agree not to dispute the validity or enforceability of any of the Direct Advice Investments Program Agreements entered into electronically by the client (or by anyone using client’s authentication devices, such as a password or PIN). JHIUS and its affiliates do not provide any tax advice. Although a client’s actions to implement a PIT Investment Recommendation may raise tax or other legal implications, clients acknowledge that JHIUS bears no responsibility for their decision-making. Clients are responsible for any tax implications and/or tax obligations arising as a result of the client’s implementation of the PIT Investment Recommendation. Clients are strongly encouraged to seek the advice of their accountant or attorney for tax or legal questions related to their implementation of the recommendation.