Background Loomis, Sayles & Company, L.P. (“Loomis Sayles”) has been providing investment management services since 1926, when it was established by founders Robert H. Loomis and Ralph T. Sayles. Loomis Sayles provides investment advisory or subadvisory services to institutional clients through its separate account management services. In addition, Loomis Sayles provides investment advisory or subadvisory services to a variety of investment funds (which may include, but are not limited to, U.S. and offshore mutual funds, hedge funds, collateralized fixed income pools, collective investment trusts, New Hampshire investment trusts and other public or private investment companies). Loomis Sayles also provides investment advisory services in connection with certain “wrap programs.” Finally, Loomis Sayles provides non-discretionary investment advisory and subadvisory services to certain clients pursuant to which it provides such clients with its model portfolios and updates thereto, and the clients will execute trades based on the model if they deem it appropriate to do so. As of December 31, 2023, Loomis Sayles’ total assets under management were approximately $335.0 billion, including approximately $22 billion managed on a non-discretionary basis and $39 billion for which its wholly-owned subsidiary, Loomis Sayles Trust Company, LLC, serves as trustee. Loomis Sayles’ Parent and Affiliated Companies Loomis Sayles is a subsidiary of Natixis Investment Managers, LLC which, following a modification in corporate structure that took place in January 2024, is a direct subsidiary of Natixis Investment Managers (“Natixis IM”), an international asset management group based in Paris, France, that is part of the Global Financial Services division of Groupe BPCE. Natixis IM is wholly owned by Natixis, a French investment banking and financial services firm. Natixis is wholly owned by BPCE, France’s second largest banking group. The modification in corporate structure mentioned above was the merger of Natixis Investment Managers, LLC into Natixis Investment Managers U.S. Holdings, LLC and the subsequent name change of the holding company to “Natixis Investment Managers, LLC.” The internal reorganization did not change the ultimate parent of Loomis Sayles or the identity and responsibilities of, or services provided by, either Loomis Sayles’s or Natixis Investment Managers, LLC’s personnel. Advisory Services Separate Account Clients Loomis Sayles provides a wide array of fixed income and equity investment management services through separate accounts. Investment advice is furnished on either a discretionary basis, where the client authorizes Loomis Sayles to make all investment decisions for the account, or a non-discretionary basis, where Loomis Sayles makes recommendations to the client but all investment decisions are made by the client. All separate account advisory services are provided under the terms of an advisory agreement between Loomis Sayles and the client. The advisory agreement generally permits either the client or Loomis Sayles to terminate the agreement at any time upon written notice to the other party. In most cases, advance notice is required. Loomis Sayles permits customization of an account’s guidelines to meet the particular needs of clients, as long as the firm believes such customization will not unduly hamper its ability to execute the strategy. Generally, clients establish their own investment guidelines and restrictions for their accounts, although Loomis Sayles maintains standard guidelines for a number of strategies that may be used without modification by clients. Affiliated and Other Funds In addition to the separate account services described above, Loomis Sayles provides advisory or subadvisory services to mutual funds sponsored by Loomis Sayles or its affiliates. Information concerning these funds, including a description of the services provided and advisory fees, is generally contained in each fund’s prospectus. As mentioned above, Loomis Sayles also provides advisory or subadvisory services to other investment funds that are established by Loomis Sayles or its affiliates or in which Loomis Sayles, its affiliates or their personnel may have an ownership or management interest. Such investment funds may include, but are not limited to, hedge funds, collateralized fixed income pools, collective investment trusts, New Hampshire investment trusts and other types of pooled vehicles. Additional information concerning these funds is generally included in the relevant offering documents. Loomis Sayles also provides advisory or subadvisory services to otherwise unaffiliated mutual funds and investment funds. Wrap Fee Program/Model Delivery Programs Loomis Sayles offers discretionary investment advice to “wrap fee” programs, also known as separately managed account programs, and platforms sponsored by investment advisers, broker- dealers and other financial service firms (“Program Sponsors”), either directly to the Program Sponsor (“Single Contract SMA”) or the Program Sponsor’s clients (“Participants”) (“Dual Contract SMA”) depending on the program (collectively referred to as “SMA Programs”). Loomis Sayles also provides discretionary and non-discretionary investment advice to Program Sponsors and/or overlay managers through model investment portfolios (“Discretionary Model Program” and “Non- Discretionary Model Program,” respectively, and collectively referred to as the “Model Program”). Loomis Sayles’ SMA Program and Model Program are collectively referred to as the “Managed Account Programs”. Loomis Sayles does not act as a “sponsor” as that term is defined in Investment Company Act Rule 3a-4 with respect to the services it provides to Managed Account Programs. Depending on the Managed Account Program, services provided by the Program Sponsor to the Participants typically include manager selection, custodial services, periodic monitoring of investment managers, performance reporting and trade execution (often without a transaction- specific commission or charge), and investment advisory services, provided by one or more investment managers such as Loomis Sayles, all generally for a bundled (or “wrap”) fee paid to the Program Sponsor. Generally, Program Sponsors are primarily responsible for contact with Participants. Program Sponsors are also responsible for reviewing their Participants’ financial circumstances and investment objectives, and determining the suitability of a Loomis Sayles’ strategy and the Managed Account Program for their Participants, as well as any investment restrictions applicable to a Participant’s account, based on information provided by the Participant. Loomis Sayles is entitled to rely on such information provided to it by the Program Sponsors. In a Single Contract SMA program, Loomis Sayles enters into an investment subadvisory agreement with a Program Sponsor under which Loomis Sayles has investment discretion to manage Participant assets in an approved strategy. The Participant may select Loomis Sayles from among the investment advisers that the Program Sponsor presents to the Participant. In the Dual Contract SMA program, Loomis Sayles enters into an investment advisory agreement directly with the Participant, and has discretion in accordance with that agreement, and the Participant also enters into an agreement directly with the Program Sponsor. In certain Dual Contract Programs, Loomis Sayles may also enter into an agreement with the Program Sponsor as to Loomis Sayles’ activities and responsibilities in the Dual Contract arrangement involving that Program Sponsor. In a Model Program, Loomis Sayles provides model portfolio advice through an agreement with Program Sponsors and/or an overlay manager (typically another investment manager applying investment advice to the Program assets). Loomis Sayles monitors and updates the model portfolios on an ongoing basis and will periodically deliver such updates to the Program Sponsor or overlay manager. Loomis Sayles has sole discretion for determining the appropriateness, diversification or suitability of securities selected for the model portfolios. Program Sponsors or an overlay manager will provide Participants the services described in the Program Sponsor’s or overlay manager’s agreement with such Participants, including selection of the investment strategies based on information provided by the Participant. Loomis Sayles does not provide customized investment advice or recommendations to Model Program Participants. No model portfolio is customized or in any way tailored by Loomis Sayles to reflect the personal financial circumstances or investment objectives of any Participant. There are two types of Model Programs. In the Non-Discretionary Model Program, the Program Sponsor retains investment and brokerage discretion and is responsible for investment decisions and performing many other services and functions typically handled by Loomis Sayles in a traditional institutional account relationship. In the Discretionary Model Program, Loomis Sayles forwards investment advice to the overlay manager designated by the Program Sponsor, who agrees to implement the advice in client accounts taking into account any client imposed restrictions accepted by the overlay manager. As in the Non-Discretionary Model Program, Loomis Sayles does not have brokerage discretion in the Discretionary Model Program and thus has no authority to place orders for the execution of transactions. However, in order to assist the Program Sponsor in implementing the recommendations of the model portfolio, Loomis Sayles in certain instances will place orders to buy or sell securities on the Program Sponsor’s behalf. In the Non-Discretionary Model Program, Loomis Sayles does not consider itself to have an advisory relationship with clients of the Program Sponsor or overlay manager. If Loomis Sayles’ Form ADV Part 2A is delivered to Program Sponsor’s model-based clients with whom Loomis Sayles does not have an advisory relationship, or where it is not legally required to be delivered, it is provided for informational purposes only. Details of each Managed Account Program are set forth in the Program Sponsor’s documents relating to the particular Managed Account Program. Depending upon the level of the wrap fee charged by a Program Sponsor, the amount of portfolio activity in a Participant’s account, the value of the custodial and other services that are provided under a wrap fee program and other factors, a Participant should consider that the cost for a Managed Account Program may be more or less than if a Participant were to purchase the investment advisory services and the investment products separately. Participants should also understand that Loomis Sayles will not negotiate brokerage commissions with the Sponsor with respect to transactions effected for a Participant’s account, since those brokerage commissions are normally included in the wrap fee. The Sponsor may charge higher commissions, or may provide less advantageous execution of transactions, than if Loomis Sayles selected the broker or dealer to execute the transactions or negotiated the commissions. Participants are encouraged to consult their own financial advisors and legal and tax professionals on an initial and continuous basis in connection with selecting and engaging the services of an investment manager for a particular strategy and participating in a Managed Account Program. In the course of providing services to Managed Account Program accounts advised by a financial advisor, Loomis Sayles generally relies on information or directions communicated by the financial advisor acting with apparent authority on behalf of its client. Loomis Sayles reserves the right, in its sole discretion, to reject for any reason any SMA Program Participant referred to it. Not all Loomis Sayles’ strategies are available through Managed Account Programs, and not all Program Sponsors offer all of Loomis Sayles’ strategies available through Managed Account Programs. Further, the manner in which Loomis Sayles executes a strategy through a Managed Account Program may differ from how a similar institutional strategy is executed, for example, because of the need to adhere to the restrictions imposed by the Program Sponsor or due to the use of affiliated commingled vehicles rather than individual securities. Depending on the strategy, Loomis Sayles invests in a variety of securities and other investments, and employs different investment techniques. There may be differences between the recommendations provided by Loomis Sayles and recommendations or decisions made by Loomis Sayles for its institutional client accounts resulting from, among other things, differences in cash availability, availability of securities, investment restrictions, account sizes, the use of American Depositary Receipts (“ADRs”) rather than foreign securities generally, and other factors. Likewise, the performance of Loomis Sayles’ institutional client accounts and that of Participants pursuing a similar investment strategy will differ for these and other reasons. Loomis Sayles may use professional services of other third parties, including its affiliates, in servicing the Managed Account Programs. Subject to applicable law and fiduciary obligations, Loomis Sayles will make reasonably available to Program Sponsors and Participants certain staff knowledgeable about the services being provided by Loomis Sayles. Unlike most of Loomis Sayles’ other client accounts, Participant accounts generally do not generate brokerage commissions that Loomis Sayles may use to pay for research and research services (i.e., soft dollars). In addition, certain Participants have entered into arrangements with broker-dealers whereby the Participant pays a fee to such broker-dealers, and in return, these broker dealers provide the Participant with certain investment consulting services, and the ability to trade with the broker- dealers free of commission charges. Loomis Sayles is not required to trade with the Participant’s broker-dealer, and Loomis Sayles may decide to not trade with the broker-dealer if it believes it can get better execution with the broker-dealer being used for similarly managed accounts. In such instances, the Participant will pay a commission on such transactions. As described in Allocation of Investments or Trading Opportunities section of this ADV, when placing buy or sell orders for client accounts, Loomis Sayles (like many large asset managers) may aggregate orders for its institutional clients that participate in a given investment strategy. In these instances, because the order will be placed on an aggregated basis, Loomis Sayles selects a broker-dealer to execute the order based on its assessment of the selected broker-dealer’s ability to achieve best execution for the order in the aggregate. Loomis Sayles believes that order aggregation, on balance and over time, is likely to produce the fairest and most appropriate results for its clients (although in any particular transaction viewed in isolation, a particular client or clients might have been advantaged if their orders were not aggregated with those of our other institutional clients). In addition, best execution is not simply a function of executing a trade at the lowest possible commission, but rather, it also includes, among other things: the price at which the security is purchased or sold; the execution capability of the broker-dealer (including its overall competitiveness, financial soundness and reputation); the order size and depth of the market; the quantity and quality of the research provided by the broker-dealer; the broker-dealer’s market making activities; the broker-dealer’s willingness to enter into difficult transactions and commit their own capital; and the trading networks (ETNs, dark pools, etc.) provided by the broker-dealer. The Loomis Trading Desks take all of these factors into consideration when selecting broker-dealers to execute aggregated orders, in pursuit of the overall goal of best execution. While Managed Account Program clients do not pay soft dollars, they do benefit from the research and research services that are used by Loomis Sayles to assist it in its investment decision-making process, including the research and research services acquired with commissions generated by other Loomis Sayles client accounts. Unless Loomis Sayles specifically agrees otherwise with a Managed Account Program client, trading and model delivery will occur after the portfolio adjustments have been implemented for Loomis Sayles’ other discretionary client accounts in the same Investment Product. In such instances, the Participants may trade at prices that are lower or higher than Loomis Sayles’ other client accounts. Trading or model delivery may occur concurrently with the trading of Loomis Sayles’ other client accounts if Loomis Sayles specifically agrees to such terms. Where the concurrent model delivery results in the Program Sponsor executing Participants’ transactions, such

transactions may compete with similar transactions that are directed by Loomis Sayles for its non-Program client accounts in the same or similar Investment Products at the same time, thereby possibly adversely affecting the price, amount or other terms of the trade execution for some or all of the accounts. Any effect of substantially contemporaneous market activities is likely to be most pronounced when the supply or liquidity of the security is limited. Clients of the Program Sponsor should refer to their particular documentation for additional information regarding transactions for their account. Non-Advisory Services Back Office Services Loomis Sayles and its affiliates may provide services, including legal and compliance, risk management, finance, trade support and sales and marketing to various affiliates. Conflicts of interest may arise in connection with an employee's knowledge arising from such services, including holdings and trades. Such conflicts are addressed in Loomis Sayles’ Conflicts of Interest Policies and Procedures and will be mitigated by the use of personal trade oversight as well as information barriers between those who provide such services and investment decision makers at Loomis Sayles. Loomis-Sponsored Indexes Loomis Sayles designs, sponsors and publishes one or more indexes (each, a “Loomis Index”) for use in portfolio benchmarking and portfolio management. These Loomis Indexes are rules-based and maintained by an unaffiliated third party. There is no guarantee that strategies based on any of these indexes will be successful or profitable. Indexes are unmanaged and do not permit direct investment. Loomis Sayles does not issue, sponsor, endorse, market, offer, review or otherwise express any opinion regarding any fund, strategy or other investment product based on, linked to or otherwise related to any Loomis index (each, an “Index Product”). Loomis Sayles is not acting as an investment adviser or fiduciary with respect to any Loomis Index and makes no representation regarding the advisability of investment in any Index Product. Loomis Sayles does not guarantee that any Index Product will accurately track any Loomis Index, or that any Index Product will provide positive investment returns. Educational Services From time to time, Loomis Sayles may provide clients with educational services related to our investment process, investment risk management practices or other investment-related topics. In some instances, certain clients may be invited to participate in more in-depth educational programs and training in which the client may work closely with our investment professionals over an extended period of time to gain a greater understanding of our research process, idea generation and trading practices. In these cases, Loomis Sayles has taken measures to protect the confidential information of our other clients. Recipients of these educational services are restricted from access to client specific information and must agree to confidentiality terms that restrict the use of any confidential information discussed. All clients participating in such educational programs are also subject to our Code of Ethics, Insider Trading and other relevant policies and procedures. Clients participating in extended educational programs may receive entertainment in conjunction with the educational program. In these cases, Loomis Sayles will take the appropriate steps to ensure compliance with regulatory restrictions placed upon us on providing gifts and entertainment to clients. Loomis Sayles expects that participants in extended educational programs are also aware of, and in compliance with, any company and/or regulatory restrictions placed upon them with respect to the receipt of gifts and entertainment. Conflicts of Interest Various parts of this ADV discuss potential conflicts of interest that arise from our business. Conflicts of interest arise as a result of having competing interests in the outcome of a situation. By favoring itself, a related party or another client, Loomis Sayles may fail to act in the best interest of a client. When assessing a potential conflict of interest, Loomis Sayles considers whether it: (1) is likely to make a financial gain, or avoid financial loss, at the expense of the client; (2) has an interest, that is separate and distinct from that of the Client, in the outcome of the service provided to the Client or of a transaction carried out on behalf of the Client; (3) has a financial or other incentive to favor the interest of one client or group of clients over the interests of another client or groups of clients; or (4) receives or will receive, from a person other than the client an inducement in relation to the service provided to the client, in the form of higher fees. We disclose these conflicts due to the fiduciary relationship we have with our investment advisory clients. When acting as a fiduciary, Loomis Sayles owes its investment advisory clients a duty of loyalty. This includes the duty to address, or at minimum disclose, conflicts of interest that may exist between different clients; between the firm and clients; or between our employees and our clients. Where potential conflicts arise from our fiduciary activities, we will take steps to mitigate, or at least disclose, them. Conflicts arising from fiduciary activities that we cannot avoid (or choose not to avoid) are mitigated through written policies that we believe protect the interests of our clients as a whole. Loomis Sayles has adopted numerous policies and procedures that include principles and guidelines for identifying, managing, recording and, where relevant, disclosing existing or potential conflicts and protecting the interests of its clients. Pursuant to these policies and procedures, Loomis Sayles and each of its employees are responsible for (1) identifying actual or potential conflicts of interest (defined below) and reporting them to the Chief Compliance Officer, (2) discussing any questions or concerns about possible conflicts with the Chief Compliance Officer, and (3) managing and mitigating conflicts fairly and in accordance with applicable policies and procedures. By complying with these rules, using robust compliance practices, we believe that we handle these conflicts appropriately. Loomis Sayles has reviewed its business to identify potential conflicts of interest and to establish appropriate policies and procedures to manage those conflicts. Recognizing that it is impossible to anticipate all potential conflicts, the list below provides examples of the identified permanent conflicts of which the firm’s staff is aware, along with a brief explanation of the firm’s arrangements for mitigating and managing the risk of such conflicts:
• Sales and Marketing - Employees may use inaccurate and/or misleading materials to attract new clients to or retain existing clients with Loomis Sayles. To manage this potential conflict, Loomis Sayles has implemented Advertising and Marketing Policies and Procedures that are designed to reasonably ensure that all communications to clients, prospective clients and consultants comply with the regulatory requirements applicable to such communications. These procedures set forth the general standards and specific legal requirements that govern the firm’s sales and marketing efforts, and they provide for the legal review of all such communications before they are used with prospective and existing clients of Loomis Sayles. In addition, Loomis Sayles uses an automated review system to process materials for quality control and review by the Loomis Sayles Legal and Compliance Department.
• Affiliated Trading – Loomis Sayles’ traders could favor Natixis broker-dealers in a way that may not be in the best interest of Loomis Sayles’ clients. To manage this potential conflict, as a policy matter, the Loomis Sayles traders are prohibited from trading with the firm’s affiliated broker-dealers.
• Soft Dollars - Loomis Sayles may use clients’ commissions to offset costs that Loomis Sayles would otherwise incur directly such as research, computers, travel expenses, etc. To manage this potential conflict, Loomis Sayles’ soft dollar policies and procedures require all soft dollar services to be Section 28(e) eligible, and the Chief Compliance Officer formally approves all new third-party soft dollar services.
• Errors – Loomis Sayles corrects trading errors and investment guideline violations affecting client accounts in a fair and timely manner, and in such a way that the client will not suffer a loss. Ultimately, however, we decide whether an incident is an error that requires compensation. Also, in certain circumstances, correcting an error may require the firm to take ownership of securities in its own error account, and the disposition of those securities may create a gain in the firm’s error account. To manage potential conflicts concerning such errors, we have implemented trade error and investment guideline breach policies and procedures, and the resolution of all such errors has to be approved by the Chief Compliance Officer or designee thereof.
• Relationships with Broker-Dealers - Traders could have relationships with broker-dealers that may provide an incentive to trade with such broker-dealers in a manner that is not in our clients’ best interest. To manage this potential conflict, Loomis Sayles has implemented an annual certification requirement whereby traders must disclose any and all personal or familial relationships with broker-dealers which could present the trader or Loomis Sayles with a conflict of interest. In addition, traders are required to acknowledge that they have read, understand and have complied with Loomis Sayles’ policies and procedures with respect to gifts and business entertainment.
• Gifts and Entertainment - Frequent or inappropriate gifts to Loomis Sayles employees from, or lavish entertainment of employees by, or employee affiliations with, vendors, service providers or intermediaries (among others) could prompt questions as to whether recommendations are based on such relationships rather than on the interests of the client. To manage this potential conflict, Loomis Sayles’ Gifts and Entertainment Policies and Procedures govern personal conduct issues such as these, and require certain reporting by employees that is intended to help the Loomis Sayles Legal and Compliance Department identify matters that could give rise to a conflict.
• Allocation of Investment Opportunities - Portfolio managers may attempt to allocate investments in a manner that does not treat all clients fairly and equitably. To manage this potential conflict, Loomis Sayles has implemented Trade Aggregation and Allocation Policies and Procedures, pursuant to which, Loomis Sayles’ policy is to allocate purchase and sale opportunities among its clients’ accounts in a fair and equitable manner over time. The Loomis Sayles Legal and Compliance Department utilizes various oversight capabilities to monitor allocations that have the highest degree of risk such as those of the firm’s hedge funds.
• Side-By-Side Management - The performance fees paid by the hedge funds may cause their investment teams to give preferential treatment to such funds in terms of the allocation of investment opportunities, or may cause the hedge funds to front-run the trading activities of the long-only accounts. To manage this potential conflict, Loomis Sayles’ policies and procedures identify and address the potential conflicts of interest (e.g., aggregation and allocation of orders, cross trading, pricing of securities, front running, etc.) when managing hedge funds side-by-side with long-only accounts. The Legal and Compliance Department utilizes several daily automated exception reports to oversee the hedge funds’ compliance with such policies and procedures. Finally, external auditors are engaged periodically to conduct an internal audit on the fixed income trade aggregation and allocation processes, with a specific focus on determining whether the hedge funds, other performance fee accounts, and high profile funds are receiving preferential treatment with respect to investment opportunities or front running long-only accounts. They also audit for compliance with trade aggregation and allocation policies and procedures.
• Cross Trading - Loomis Sayles may cross securities among client accounts in a manner which is not in the best interest of all accounts involved. As a policy matter, Loomis Sayles will not knowingly or intentionally effect transactions between client accounts, and the Loomis Sayles Legal and Compliance Department has implemented various automated reports to prevent or detect the crossing of securities among client accounts. Any exceptions to this policy must receive the prior approval of the Loomis Sayles Legal and Compliance Department.
• Allocating Fund Brokerage Based Upon Fund Sales - Loomis traders may direct client transactions to broker-dealers for purposes of rewarding them for selling shares of the Loomis/Natixis funds, and such transactions may not achieve best execution. To manage this potential conflict, Loomis Sayles’ policies and procedures prohibit its traders from directing transactions to broker-dealers in reciprocation for said broker-dealers’ efforts to sell shares of the funds to their clients. Furthermore, as a procedural matter, the Loomis Sayles traders are not provided with broker-dealers’ funds sales activities.
• Personal Trading - Loomis Sayles’ employees may conduct their personal dealings in a manner that is not in the best interests of the clients of Loomis Sayles. To manage this potential conflict, Loomis Sayles has implemented a Code of Ethics (“Code”) which contains restrictions that are designed to avoid apparent and actual conflicts of interest with clients and inadvertent violations of the securities laws as they relate to personal trading. Loomis Sayles employees agree in writing to abide by the Code as a condition of employment. Under the Code, employees carrying out personal securities transactions must generally ensure that they are not (1) benefiting from their personal investments at the expense of any Loomis Sayles client or (2) taking advantage of or “trading on” knowledge of the market impact of client transactions, and the Loomis Sayles Legal and Compliance Department utilizes various automated systems to monitor compliance with the Code.
• Outside Business Interests - Loomis Sayles’ employees may engage in outside activities that conflict with the best interests of Loomis Sayles and/or its clients. To manage this potential conflict, the Code provides that no employees of Loomis Sayles may serve on the board of directors of any publicly traded company. Additionally, no employee of Loomis Sayles may accept any other service, employment, engagement, connection, association, or affiliation in or with any enterprise, business or otherwise absent prior written approval by the supervisor of said employee and the Loomis Sayles Chief Compliance Officer, or a designee thereof.
• Securities Valuation. The fees we charge our own clients and the performance of our products are based upon the value of our clients’ portfolios. Loomis Sayles has the authority to determine the value of securities that are difficult to price (i.e., those that require a fair valuation determination), and in such cases there is an incentive to select a higher price for those securities, when a lower price would be more reasonable. To mitigate that potential conflict, our Securities Pricing Policies and Procedures require our pricing personnel to follow specific steps when determining the fair value of a security, and portfolio managers that own the security in client accounts are not permitted to vote on the fair valuation of the security. Finally, the pricing staff personnel are overseen by our Pricing Committee that is chaired by the firm’s Chief Compliance Officer. Depending on circumstances, Loomis Sayles may use a number of administrative and organizational arrangements to mitigate any actual or potential conflicts, including: (1) functional independence and separate supervision of relevant employees whose main functions involve carrying out activities or providing services for clients whose interests may conflict, or otherwise representing interests that may conflict. For example, with limited exceptions due to the complexities of the various workflows within the fixed income trading room, the permissioning provided in the firm’s trading and settlements systems is such that only portfolio managers/portfolio specialists can create a trade order; only traders can execute a trade order; and only the operations staff can settle executed trades. These access controls and the separate oversight thereof deter portfolio managers, traders and operations staff from correcting or hiding their errors; and (2) periodic training of employees on potential conflicts of interests and the firm’s mechanisms to mitigate such conflicts.