The Firm Vontobel Asset Management, Inc. (“VAMUS”, “we”, “our”) is a global investment management firm headquartered in New York City, NY. We have provided global asset management services to investors since 1984, and we are an SEC- registered investment adviser. VAMUS is part of Vontobel (defined below), a global financial services group of companies with Swiss roots. VAMUS and its affiliates are subsidiaries of Vontobel Holding AG (“Vontobel”), a Swiss holding company in Zurich, Switzerland. We are also a related company to Bank Vontobel AG, one of Switzerland’s foremost private banks for over 90 years. Vontobel Holding AG shares are listed on the SIX Swiss Exchange. Discretionary Advisory Services We offer fundamental analysis-based discretionary investment management, advisory, and sub- advisory services to a broad array of institutional and intermediary clients, respectively. We also provide investment advisory services to separate accounts; certain affiliated open-end investment companies (“Registered Funds”) and non-affiliated investment companies registered under the Investment Company Act of 1940, as amended (“Investment Company Act”); collective investment trusts; a series of open-ended variable capital foreign-registered funds managed by our affiliate Vontobel Asset Management S.A. (“VAMSA”), each a “VAMSA Fund” and collectively referred to herein as the “VAMSA Funds”); non-U.S. pooled investment vehicles; and other pooled investment vehicles not required to be registered under the Investment Company Act (“Private Funds”). The above-mentioned pooled vehicles together are thereafter referred to as “Commingled Funds”. We strive to invest all of our clients’ assets in a similar manner within each investment strategy so as to ensure that all portfolios benefit from the best investment ideas of the firm and to limit the dispersion of returns among client portfolios. Each investment strategy offered by our firm is defined by its own portfolio construction and investment guidelines developed by us. Within the bounds of a given investment strategy or strategies, a client may customize its investments through the use of investment guidelines, restrictions, and limitations (“guidelines”). These client-driven guidelines are drafted during the course of contract negotiations and become an integral part of the final investment management agreement between us and our clients (“Investment Management Agreement”). We reserve the right to reject investment guidelines that we determine, in our judgement, to be unduly restrictive in light of strategy and portfolio objectives. Non-discretionary Advisory Services We also provide asset model portfolios to related investment advisers, third party firms (“sponsors”), and institutional investors on a non- discretionary basis subject to negotiated fees. Recommendations made on a non-discretionary basis are substantially the same to the advice provided to our clients on a discretionary basis. It is at the investment advisers’, sponsors or institutional investors’ sole discretion as to whether or not and to what extent they will implement the model portfolios, or each recommendation made by us for their respective clients and accounts. VAMUS does not enter into a direct relationship with clients of affiliated investment advisers or sponsors. We do not provide administrative, trading, portfolio accounting or account- specific performance reporting services to the clients of affiliated investment advisors or sponsors. Trade recommendations and model changes are provided to the third-party concurrently or approximately at the same time as investment instructions are delivered for our other discretionary client accounts. This process is administered in accordance with the third- party’s procedures, and they are solely responsible for adjusting their model program accounts to conform to model portfolio changes. As such, responsibility for pursuing best execution for their participating accounts resides

with them. It should be noted that VAMUS also has model portfolio arrangements which follow a different process from what’s noted herein. For these arrangements, VAMUS provides the model changes and trade recommendations at the end of the business day or weekly per our agreement with the client and after we have begun to implement recommendations for discretionary client accounts. There may be a positive and or negative performance divergence as a result of such timing differences. Types of Investments Our advisory services encompass several types of asset classes across our various strategies including equity, fixed income, and multi-asset. The types of investments in which we offer investment advice are limited to: exchange listed securities, privately placed securities, real estate investment trust (“REITs”), exchange traded funds (“ETFs”), exchange traded notes (“ETNs”), 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 over-the-counter instruments. We may also recommend that clients invest in the Private Funds, certain other pooled investment vehicles, open- or closed-end mutual funds, separate account programs, individual securities or other assets. 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 are investment advisers registered with non-U.S. regulators; and some are exempt from registration with other U.S federal and state. 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 a client’s investment management agreement, 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 Investment Advisers Act of 1940 (“Advisers Act”), as VAMUS’ 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, ERISA and its prohibited transaction exemptions, U.S. federal securities laws and regulations. Please refer to Item 10. Other Financial Industry Activities and Affiliations for information related to the Participating Affiliate Arrangement with select affiliates. This practice of utilizing affiliates is designed to make Vontobel’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. No additional fees are charged for our affiliates’ services except as set forth in a client’s investment management agreement, or a fund’s governing documents, private placement memorandum, offering memorandum, and/or similar documents, and as allowed by applicable law and regulation. Regulatory Assets Under Management As of December 31st, 2023, VAMUS had $ 28,023,416,512 total regulatory assets under management calculated on a gross basis; $27,645,170,923 of which was discretionary and $378,245,589 non-discretionary.