Russell Investment Management, LLC (“RIM”) is part of Russell Investments (defined below), a global investment solutions company. Headquartered in Seattle, Washington, Russell Investments operates globally with other offices in various financial centers around the globe. RIM and its affiliates are indirect wholly-owned subsidiaries of Russell Investments Group, Ltd., a Cayman domiciled company (“Russell Investments” or “RI”). The limited partners of certain private equity funds affiliated with TA Associates Management, L.P. indirectly hold a majority ownership interest, and the limited partners of certain private equity funds affiliated with Reverence Capital Partners, L.P. indirectly hold a minority ownership interest in Russell Investments. Hamilton Lane Advisors LLC, a private markets firm, along with current and former management of Russell Investments also hold minority positions in Russell Investments. References to “we”, “us”, and “our” refer to RIM unless the context otherwise requires. We provide investment advisory services to series portfolios of open-end investment companies (each, a “Fund”) registered under the Investment Company Act of 1940, as amended (“Investment Company Act”), including investment advice to the Funds of Russell Investment Company (“RIC”) and Russell Investment Funds (“RIF” and collectively, the “RIC/RIF” Funds). We also provide discretionary and non-discretionary investment advisory services to non-affiliated U.S. and non- U.S. funds and other pooled vehicles not required to be registered under the Investment Company Act (“Private Funds”), and to institutional, high net worth, and retail clients. Our investment advisory services include investment management and licensing or provision of model securities portfolios. The sections below provide a summary of each of these services. Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information regarding our investment strategies. RIM has been a registered investment adviser since May 21, 1982. RIM is also a registered commodity pool operator (“CPO”) with the Commodity Futures Trading Commission (“CFTC”) and is a member of the National Futures Association (“NFA”). As of December 31, 2023, RIM had $52,358,801,511 in discretionary regulatory assets under management and $121,781,545 in non- discretionary assets under management. INVESTMENT MANAGEMENT SERVICES Our investment management services and strategies are designed to help Funds and clients meet their market exposure, risk management, and return objectives. We blend our core capabilities including capital markets insights, asset allocation, manager research, portfolio implementation and factor exposures to design, construct and manage portfolios. Portfolios are often invested using a “multi-style multi-manager” open-architecture approach. Other than for the RIC/RIF Funds, we provide investment management services based on investment guidelines and restrictions that are developed in accordance with the mandate selected by the client. Each Fund managed or otherwise advised by us is managed in accordance with the investment guidelines and restrictions of the Fund. Depending on the investment strategy or strategies a client or a client’s financial intermediary wishes to pursue, a client’s contractual relationship may be with RIM and one or more of its affiliates. Asset Allocation Russell Investment Management, LLC / Form ADV Part 2A / 6 Our asset allocation process incorporates information about the potential implications of changes in capital markets with client specific information that includes a client’s goals, return objectives, spending policy, ability to tolerate risk and liquidity needs. We help clients to, among other things:  Develop investment objectives;  Define and control risk for their specific requirements;  Diversify their investment portfolio;  Meet cash flow needs; and  Conduct scenario analysis on asset allocations of portfolios as well as evaluate alternative portfolios. Once a strategic asset allocation is determined, an investable portfolio is constructed by identifying the specific investment strategies and/or money managers that will be used in the portfolio. Third-Party Money Manager Selection Multi-manager portfolio assets are managed by us and two or more third-party money managers pursuant to a multi-style (e.g., growth, value, market-oriented, defensive, and/or dynamic) and multi-manager approach. RIM may change a money manager asset allocation at any time, including not allocating assets to one or more money manager strategies. Such changes may be made without notice to clients. Our money manager research services include evaluating and recommending third-party money managers according to designated investment objectives, outcomes, styles and strategies. A money manager may have:  A discretionary asset management assignment where it is allocated a portion of a portfolio’s assets to manage directly, selects the individual instruments for that portfolio and also purchases and sells individual instruments for the portfolios assigned to them;  A non-discretionary assignment where it provides a model portfolio to us representing its investment recommendations, based upon which we apply our own investment advice, and through an affiliate, purchase and sell individual instruments for the portfolio; or  Both a discretionary and non-discretionary assignment. RIM does not separately evaluate the investment merits of a money manager’s individual security selections or recommendations. Portfolio Management and Construction In moving from a strategic asset allocation to an implementable portfolio, the portfolio is developed using our proprietary strategies (discussed below) and active strategies from selected third-party money managers. In addition to utilizing discretionary third-party money managers to manage client portfolios, we construct certain portfolios by combining non-discretionary money manager models in a Russell Investment Management, LLC / Form ADV Part 2A / 7 centralized portfolio (“Enhanced Portfolio Implementation” or “EPI”). Under EPI, we hire money managers to provide lists of recommended investments and the weightings of such investments. For example, a portfolio may utilize strategies from multiple non-discretionary money managers. We implement the portfolio by aggregating the model portfolios of each manager and of RI and may adjust the combined aggregated model in order to vary certain exposures, to adhere to any portfolio level guidelines and other restrictions, and for transaction cost management. We generally allocate portfolio assets to two or more money manager strategies; however, RIM or its affiliates also may directly manage all or some portion of a portfolio’s assets (“direct investment”) for a variety of purposes. In such a scenario, Russell Investments may retain more of its advisory fee as it pays less in fees to money managers. Our direct investment of portfolios can include the implementation of certain quantitative analysis and/or rules-based processes to assess a portfolio’s characteristics or fundamental strategies; investing in securities and instruments which provide desired exposures (such as volatility, momentum, value, growth, quality, capitalization size, industry, sector, region, currency, commodity, credit or mortgage exposure, country risk, yield curve positioning, or interest rates); modifying the portfolio’s overall investment strategy or risk/return characteristics relative to investments made by one or more money managers; and enhanced funding, cash management, currency overlay or other direct investment management techniques (collectively, “Proprietary Strategies”). We may also use strategies based on indices. We, or our affiliates, may also directly manage portions of a portfolio during transitions between money managers. Alternative Asset Advisory Services Our alternative investment management services include advising and providing due diligence services on infrastructure and real estate. Infrastructure assets are broadly defined to be real assets that provide essential or commercial services to the public. Examples of infrastructure assets include transportation systems, communication networks, sewage, water, and electric systems. Our real estate investment management activities include investing in U.S. and non-U.S. real

estate investment trusts (“REITs”) and other REIT-like entities that own interests in real estate or real estate loans. We also provide investment advice on investing in equity securities of other types of real estate-related companies. MODEL PORTFOLIOS We offer a range of model strategies and managed account solutions to registered investment advisers, and broker-dealers, which typically include the RIC Funds. The model strategies include strategic asset allocation, tax-managed asset allocation, income models, and active/passive asset allocation strategies. We offer Separately Managed Account Model (“SMA Model”) services, which are multi-style portfolio products where we license or provide model securities portfolios to registered investment advisers and other financial intermediaries. These SMA Models combine the investment strategies of two or more third-party money managers into a model portfolio intended to expose investors to various investment strategies whereby the sponsor of the participating program maintains full investment authority over model execution for their clients. Our SMA model services are not a RIM-sponsored wrap program. Financial intermediaries use the models to create separate account portfolios for their clients. Russell Investment Management, LLC / Form ADV Part 2A / 8 We also offer other types of asset allocation model strategies for Unified Managed Account (“UMA”) programs of other financial intermediaries. UMAs are professionally managed investment accounts that can include multiple types of investments, including mutual funds, stocks, bonds and exchange traded funds (“ETFs”), all in a single account. We also act as a portfolio strategist for certain tax-aware UMA models that are offered to financial intermediaries by a third-party turnkey asset management platform (“TAMP”). These tax-aware UMA models incorporate RIC Funds and our SMA Model solutions. The operational trading aspects and portfolio overlay management are implemented by the TAMP provider. Personalized Managed Accounts and Direct Investing We offer customized portfolio management services and investment strategies to high net worth and retail investors through third-party financial intermediaries, including under our Personalized Managed Accounts (“PMA”) offering. Under this product, we may partner with external service providers to offer diversified, single or multi-asset managed account solutions with individually tailored portfolios inclusive of considerations for overlays and any client-imposed restrictions. Excluding allocations to pooled investment vehicles, if any, each client’s account is managed separately from other client accounts, allowing for a personalized experience to deliver unique investment outcomes. Services offered on the platform are designed to meet clients’ individual goals, circumstances and preferences that are determined by the client’s third-party financial intermediary, such as (but not limited to), market exposure, risk management, tax management, environmental, social and governance considerations, and return objectives. Clients may impose restrictions on investments in securities or types of securities, as well as set additional investment guidelines. Wrap Fee Programs We provide discretionary investment advisory services to wrap fee program clients, sponsored by a third-party investment adviser, broker-dealer, or other financial services firms (“Sponsor”). In this capacity, we provide asset allocation and security selection services with respect to mutual funds and/or ETFs. We generally select mutual funds and/or ETFs from the funds available within a Sponsor’s wrap fee program, which limits the breadth of instruments which may be purchased or sold. These typically include RIC Funds; however, we may be restricted by the financial intermediary in the selection of funds. When a RIC/RIF Fund is selected as an investment, Russell Investments earns compensation. Clients of such wrap fee programs are generally considered investment advisory clients of both RIM and the third-party financial intermediary sponsoring the wrap fee program and we receive a portion of the wrap fee for our services. See Item 5 – Fees and Compensation for additional information. In most wrap fee programs, the Sponsor is responsible for establishing the financial circumstances, investment objectives, and investment restrictions applicable to each client, often through a client profile and discussions between the client and the Sponsor’s personnel. The client’s wrap fee program agreement with the Sponsor generally sets forth the services to be provided to the client by or on behalf of the Sponsor. Wrap program clients should review the Sponsor’s wrap program brochure for further details about the relevant program. We are not responsible for, and do not attempt to determine, whether a particular third-party wrap fee program is suitable or advisable for program participants. Russell Investment Management, LLC / Form ADV Part 2A / 9 TYPES OF INVESTMENTS Our advisory services encompass all types of investments and asset classes, including equity, fixed income, multi-asset, alternatives, and derivatives. Types of investments in which we offer investment advice include, but are not limited to: exchange listed securities, privately placed securities, Private Funds, Funds, in affiliated and/or third-party funds (“Fund of Funds”), Real Estate Investments Trusts (“REITS”), Exchange Traded Funds (“ETFs”), Exchange Traded Notes (“ETNs”), master limited partnerships (“MLPs”), securities traded over-the-counter, foreign issues, depository receipts, warrants; corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual fund shares, U.S. and non-U.S. sovereign government securities, commodities, listed futures and options contracts. Other types of investments may include foreign currency (“FX”) instruments, including forwards, spots, and swaps, centrally cleared swaps and other bilateral OTC instruments. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, for more detail on the types of instruments used in implementing our strategies. SERVICES OF AFFILIATES We utilize our affiliates to offer certain services to clients, some of these affiliates also are investment advisers or broker-dealers registered with the SEC, the Financial Industry Regulatory Authority (“FINRA”), and some are registered or are exempt from registration with other federal, state or non-U.S. regulatory authorities. We may use the services or personnel of one or more of our affiliates for investment advice, portfolio execution and trading, and client servicing in their local or regional markets or their areas of special expertise, except to the extent restricted by the client pursuant to its investment management agreement or other type of advisory agreement (“IMA”), or inconsistent with applicable law. Arrangements among affiliates take a variety of forms, including dual employee, delegation, participating affiliate, sub-advisory, sub-agency or other formal or informal servicing arrangements. Certain of those affiliates’ employees are deemed “associated persons” within the meaning of Section 202(a)(17) of the Advisers Act, as Russell Investments’ affiliates may, through such employees, contribute to our investment advisory and investment research process. These arrangements comply with applicable law and regulation including, but not limited to, Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and its prohibited transaction exemptions, U.S. federal securities laws and regulations, and the regulations of applicable self- regulatory organizations such as FINRA, the NFA and the Municipal Securities Rulemaking Board (“MSRB”). This practice of utilizing affiliates is designed to make Russell Investment’s global capabilities available to our clients in as seamless a manner as practical within a varying global regulatory framework. In these circumstances, we remain fully responsible for the portfolio from a legal and contractual perspective. If provided in the client’s IMA, a fund’s governing documents and/or private placement memorandum or offering memorandum (both and similar documents referred to as the “OM”), we will charge additional fees for such services as permitted by applicable law and regulation. Russell Investment Management, LLC / Form ADV Part 2A / 10