John Hancock Variable Trust Advisers is a limited liability company founded in 1997 and is an indirect principally owned subsidiary of Manulife Financial Corporation (“MFC”), a diversified international management and holding company with interests in companies that are active in, among other things, financial services and insurance. MFC is a publicly traded company based in Toronto, Canada that trades as ‘MFC’ on the Toronto Stock Exchange, New York Stock Exchange (the “NYSE”), and the Philippine Stock Exchange, and under '945' in Hong Kong. John Hancock Variable Trust Advisers provides discretionary investment advisory services as a “manager of managers” to the John Hancock Variable Insurance Trust (“JHVIT” or the “Trust”), a no-load, registered open-end investment company that serves as the underlying investment medium for variable annuity and variable life contracts issued by John Hancock Life Insurance Company (U.S.A.) and affiliated entities as well as several nonaffiliated insurance companies (each series of JHVIT is referred to herein as a “JHVIT fund” or a “Fund”). Pursuant to the terms of investment advisory agreements with the Trust, John Hancock Variable Trust Advisers administers the business affairs of the Trust, negotiates and contracts with affiliated and unaffiliated sub-advisers (“Sub-Advisers”) that provide investment advisory services to individual portfolios of the Trust, and supervises the activities of the Sub-Advisers on behalf of the Trust, as further described herein. John Hancock Variable Trust Advisers is also responsible for performing or paying for various services provided to the Trust, including providing office space and all necessary office facilities and equipment to perform its duties under the investment advisory agreements and any personnel necessary for the oversight and/or conduct of the investment operations of the Trust. John Hancock Variable Trust Advisers also agrees to permit individuals who are directors, officers, or employees of John Hancock Variable Trust Advisers to serve (if duly elected or appointed) as Trustees and President of the Trust without remuneration from or other direct cost to the Trust. In addition, John Hancock Variable Trust Advisers allows the Trust to use the recognizable and valuable brand name, “John Hancock”. The advisory agreement between a Trust and John Hancock Variable Trust Advisers may be terminated at any time, without the payment of a penalty, by the Board of Trustees of the Trust (the “Board”), by a vote of the majority of the outstanding voting securities of the Trust, or, with respect to any portfolio, by the Board or by the vote of a majority of the outstanding voting securities of the series of shares of such portfolio, on sixty days written notice to John Hancock Variable Trust Advisers, or by John Hancock Variable Trust Advisers, on sixty days written notice to the Trust. An advisory agreement will automatically terminate, without payment of any penalty, in the event of its assignment (as defined in the Investment Company Act of 1940, as amended (“1940 Act”)). Description of Investment Advisory Services The Investment Oversight team of John Hancock Variable Trust Advisers employs highly experienced and well-credentialed professionals. Key advisory responsibilities include researching new investment products, asset classes, and investment managers, and monitoring the performance of investment managers on an ongoing basis. As a manager of managers, John Hancock Variable Trust Advisers administers the business and affairs of the Trust, including the investment portfolios of the Funds, and retains, supervises, and compensates Sub-Advisers to manage the assets of the investment portfolios of the Funds. In its role as manager-of-managers, John Hancock Variable Trust Advisers has supervisory responsibility for managing the investment and reinvestment of the Funds’ portfolio assets through proactive oversight and monitoring of the Sub-Advisers and the Funds. John Hancock Variable Trust Advisers is responsible for developing overall investment strategies for the Funds and overseeing and implementing the Funds’ continuous investment programs and provides a variety of advisory oversight and investment research services. John Hancock Variable Trust Advisers also provides management and transition services associated with certain fund events (e.g., strategy, portfolio manager or subadviser changes) and coordinates and oversees services provided under other agreements. John Hancock Variable Trust Advisers has ultimate responsibility to oversee a Sub-Adviser and recommend to the Board its hiring, termination, and replacement. In this capacity, John Hancock Variable Trust Advisers among other things: (i) monitors on a daily basis the compliance of the Sub-Adviser with the investment objectives and related policies of the Fund; (ii) monitors significant changes that may impact the Sub-Adviser’s overall business and regularly performs due diligence reviews of the Sub-Adviser; (iii) reviews the performance, and monitors the liquidity, of the Sub-Adviser; and (iv) reports regularly on such performance to the Board. John Hancock Variable Trust Advisers employs a team of investment professionals who provide these ongoing research and monitoring services. Pursuant to an order from the SEC, John Hancock Variable Trust Advisers, subject to Board approval, is permitted to appoint a new Sub-Adviser for a Fund, or change the terms of a sub- advisory agreement, without obtaining shareholder approval. The SEC order does not, however, permit John Hancock Variable Trust Advisers to appoint a Sub-Adviser that is an affiliate of John Hancock Variable Trust Advisers or of the relevant JHVIT fund (other than by reason of serving as Sub-Adviser), or to increase the sub- advisory fee of an affiliated Sub-Adviser without shareholder approval. The John Hancock Variable Trust Advisers team of professionals is responsible for the selection of Sub-Advisers and monitoring Sub-Adviser performance. The team closely monitors each sub- advised portfolio on a daily, monthly, quarterly and annual basis. Team members periodically meeting with each Sub-Adviser to perform due diligence on the advisory services provided by the Sub-Adviser, as well as the business and compliance operations of the Sub-Adviser. John Hancock Variable Trust Advisers recommends to the Board the continuation or termination of the sub-advisory agreements at least annually. The process for selecting new Sub-Advisers involves the use of screening models with and in- depth data analysis as well as the industry knowledge of the members of the investment team. A rigorous five-step process is used in selecting Sub-Adviser candidates: (i) initial screening by investment style; (ii) firm review to identify managers who demonstrate the potential to produce above average results; (iii) quantitative analysis of performance; (iv) qualitative analysis of the investment team, philosophy, process and risk management practices through in-person interviews; and (v) final selection, based on management review of the investment team’s findings and the capacity of the Sub-Adviser and the liquidity of the new fund. New Sub-Advisers are also reviewed by the Manulife Global Investment Product Committee. Sub-Advisers that are selected by John Hancock Variable Trust Advisers are generally required to adhere to pre-established value propositions. In monitoring the Sub-Advisers, John Hancock Variable Trust Advisers generally focuses on longer-term performance rather than short-term performance metrics. Although a Sub-Adviser’s performance record is one of several factors used to determine whether a Sub-Adviser should be retained or replaced, additional oversight may be considered if: (i) value proposition criteria are violated; (ii) performance is not aligned with the performance blueprint; (iii) the Sub-Adviser experiences major organizational changes such as resignations or a change in ownership; or (iv) the fund’s risk profile is outside of expectations. During a full review of a Sub-Adviser, John Hancock Variable Trust Advisers focuses on identifying and assessing the issue that has caused the full review to be undertaken. If John Hancock Variable Trust Advisers determines that the Sub-Adviser can no longer deliver its value proposition to the JHVIT fund and its shareholders, a recommendation will be made to the Board to replace the Sub-Adviser. Further information regarding John Hancock Variable Trust Advisers’ screening, supervision, and review of Sub-Advisers is described in Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. In the event of the replacement of a Sub-Adviser or the merger of one or more JHVIT funds, John Hancock Variable Trust Advisers manages the transition or merger transaction of the relevant Fund’s portfolio investments to the new Sub-Adviser in an effort to minimize transaction costs and avoid other implicit costs. This involves the development of strategic plans to execute all fund events (e.g., fund launches, mergers, and liquidations), taking into consideration downstream impacts on services provided to the Funds by global business units, in coordination with legal, compliance, tax, product, operations, and other business units of John Hancock Variable Trust Advisers or its affiliates, and with the fund’s Sub-Adviser(s). The Trust has established “Funds of Funds” which invest in a number of other underlying funds and may invest in certain other types of investments. John Hancock Variable Trust Advisers is responsible for oversight of the Funds of Funds, including the monitoring of the asset allocation strategies and processes employed by the Sub-Advisers of such funds. John Hancock Variable Trust Advisers and its Trade Oversight Committee also oversee rebalancing of the funds' assets, and have adopted procedures to help minimize any negative impact of rebalancings on the underlying funds. John Hancock Variable Trust Advisers also has the authority, with Board approval, to manage a Funds of Funds directly and, in that case, would be responsible for implementing asset allocation strategies, including by rebalancing the Funds of Funds’ underlying funds to maintain target allocations. It is not the current practice of John Hancock Variable Trust Advisers to exercise this authority in the normal course of business. Certain Fund of Funds warrant focused monitoring by John Hancock Variable Trust Advisers, which includes evaluating the Sub-Adviser's asset class mix and manager mix decisions, determining the effectiveness of the optimization process, and monitoring cash flows and trading efficiencies. John Hancock Variable Trust Advisers develops and provides detailed reports for the Board of the Trust on a regular basis. These reports include performance and liquidity data, due diligence information and compliance, risk, derivatives and other reports, based on John Hancock Variable Trust Advisers’ ongoing portfolio and Sub-Adviser monitoring activities. John Hancock Variable Trust Advisers also prepares ad hoc reports and consults with Investment and Compliance Committees established by the Boards to monitor Sub-Adviser performance and assists these committees in the preparation of performance reports to the full Board. John Hancock Variable Trust Advisers also oversees the John Hancock family of funds inter-fund lending program, and the management by Sub-Advisers of overnight cash held by the Funds. John Hancock Variable Trust Advisers has a committee governance structure that provides oversight of certain of the services John Hancock Variable Trust Advisers provides to the Funds. The services overseen by the John Hancock Variable Trust Advisers committees include investment, operational, legal, compliance, risk oversight, disclosure oversight and proxy voting. Each of the John Hancock Variable Trust Advisers Committees is listed below. 1. Risk and Investment Operations (“RIO”) Committee 2. Trade Oversight Committee 3. Complex Securities Committee 4. Multi-Manager and Multi-Style Funds Investment Oversight Committee 5. Service Provider Oversight Committee 6. Disclosure Review Committee 7. Proxy Voting Committee 8. Liquidity Risk Management Committee 9. Investment Risk Oversight Committee 10. Accounting Policies Committee 11. Ethics Oversight

Committee 12. Investment Oversight Committee 13. Derivatives Risk Management Committee 14. Pricing Committee Compliance Support and Oversight John Hancock Variable Trust Advisers also provides the John Hancock Funds with ongoing compliance support and oversight through programs designed to ensure that there are adequate procedures in place to deter, detect, correct, and report on control weaknesses that could potentially result in a violation of Federal securities laws. This program is administered pursuant to the requirements of Rule 206(4)-7 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and is managed by John Hancock Variable Trust Advisers’ duly appointed Chief Compliance Officer (“CCO”). The role of the CCO and the Compliance Office (“CCO’s Office”) is to: (a) develop and monitor a compliance program for John Hancock Variable Trust Advisers based on an on-going review of risk and current legal and regulatory developments; (b) oversee and manage compliance issues; (c) ensure that John Hancock Variable Trust Advisers complies with applicable legal and regulatory requirements; and (d) ensure that the John Hancock Variable Trust Advisers employees comply with internal policies and procedures. These responsibilities include: designing and overseeing the appropriate implementation of policies and procedures to reasonably assure compliance with applicable federal securities laws and regulations; providing employee training on certain key policies such as Code of Ethics, Insider Trading, Gifts and Entertainment and the Whistleblower Policy; managing and/or participating in investigations into regulatory and compliance issues; and responding to requests for information from regulatory authorities. In carrying out this role, the CCO’s Office has developed a compliance oversight program designed to reasonably ensure that the requirements imposed by federal securities laws are implemented effectively throughout John Hancock Variable Trust Advisers and by its third-party service providers, including the Sub-Advisers to the Funds. The Compliance Program involves four main components: (1) development and maintenance of policies and procedures; (2) risk assessments; (3) policy review and evaluation and (4) Sub-Adviser and service provider oversight (“Service Provider Oversight”). Development and Maintenance of Policies and Procedures The CCO’s Office, in conjunction with John Hancock Variable Trust Advisers’ business units, has developed policies and procedures that address the regulatory risks that are associated with John Hancock Variable Trust Advisers’ operation. In addition, these policies include procedures that address the manner in which the CCO’s office will oversee the compliance and internal control programs implemented by the Sub-Advisers and service providers. These policies and procedures are evaluated on at least an annual basis by the CCO’s Office, in conjunction with John Hancock Variable Trust Advisers’ business units, with all material changes requiring CCO’s Office and Board of Directors approval. The CCO’s Office, in conjunction with John Hancock Variable Trust Advisers’ business units, develops compliance policies as new regulations become effective and continually evaluates and amends existing policies as necessary. Risk Assessment The risk assessment process is a key component of the Compliance Program as it provides an indication of the potential risk associated with each compliance policy and procedure. The risk assessment process is designed to evaluate the effectiveness of the underlying processes supporting the compliance policies. In conjunction with each John Hancock Investment Management business unit, the CCO’s Office conducts an assessment of the organization’s risk. It is a comprehensive process that starts with a baseline assessment established by the business units and the CCO’s Office. The risk assessment process leverages Risk Control Self- Assessments performed by the Operational Risk Team over key business areas and also considers various internal/external emerging risk factors; including but not limited to, organizational changes, new product initiatives, and SEC enforcement actions, risk alerts and exam priorities. The CCO’s Office may make adjustments to the baseline risk assessments as a result of all the information gathered. Policy Review and Evaluation After assessing the risk environment, the CCO’s Office then focuses on testing the compliance program’s effectiveness. This is conducted through a series of tests that are centered on the operational and control environment that supports the Compliance Policies. In conducting the testing, the CCO’s Office, in conjunction with John Hancock Variable Trust Advisers’ business units, prepares detailed test scripts which are designed to test the key activities/controls of each process. Once these test scripts are prepared, the CCO’s Office, working with John Hancock Variable Trust Advisers’ business units, conducts testing on the effectiveness of the control environment. At the conclusion of the testing, the CCO’s Office prepares reports for Senior Management which summarize the results of the process. Sub-Adviser and Service Provider Oversight The CCO’s Office has established a standardized approach for assessing all Sub-Adviser compliance programs. For prospective Sub-Advisers and prior to any onsite due diligence meeting, each Sub-Adviser is asked to provide a response to a preliminary questionnaire which is then utilized by the CCO’s Office as the initial step in fulfilling its oversight responsibilities. These narratives are reviewed for adequacy, comprehensiveness and completeness. The CCO’s Office also requires that each Sub-Adviser complete a due diligence questionnaire and provide additional documentation (e.g. Compliance Manuals, Code of Ethics, etc.) on the firm’s processes, controls, and policies in place to address the requirements of the 1940 Act, the Advisers Act, and other federal securities laws. Responses to these questions are then reviewed by the CCO’s Office to assist in determining the adequacy of the Sub-Advisers’ compliance programs. The responses and requested documents are reviewed before the meeting in order to establish a preliminary understanding of the internal controls in place. In addition, Sub-Adviser evaluation by the CCO’s Office includes onsite and virtual due diligence meetings. A typical onsite meeting with a Sub-Adviser includes sessions with representatives from Legal, Compliance, Trading, Operations, Fund Management and the Chief Compliance Officer. The results of onsite meetings are documented and then reviewed with senior management of John Hancock Variable Trust Advisers and the Funds’ Board of Trustees. If the CCO’s Office is not satisfied with the Sub-Advisers’ compliance program, the Sub- Adviser will not be approved to sub- advise a John Hancock Fund. The CCO’s Office utilizes a similar approach for the ongoing oversight of its Sub- Advisers once they are approved to sub-advise a John Hancock Fund. The CCO’s Office continues to conduct on-site due diligence meetings on a prescribed schedule. In addition, the CCO’s Office monitors the compliance programs of the Sub-Advisers on an ongoing basis by requiring the completion of quarterly, annual and periodic compliance questionnaires, quarterly certifications concerning adherence to prospectus guidelines and disclosures as well as annual certification of the Sub- Advisers’ Code of Ethics. Further, the CCO’s Office oversees the monitoring of the investment activities of the Sub- Advisers on a daily post trade basis to ensure that each portfolio investment is in compliance with prospectus guidelines and other regulatory requirements. Service Provider Oversight is similar to the oversight performed for Sub-Advisers, but incorporates additional techniques based upon information which is generally available. The goal of the oversight performed by the Global Wealth and Asset Management’s Vendor Management department is to ensure that the Funds’ service providers have satisfactory operational controls and that the service providers are fulfilling their fiduciary and contractual obligations. The Global Wealth and Asset Management Vendor Management Group (“Vendor Management”) maintains a framework that includes, but is not limited to, the following processes: 1. Due diligence questionnaires – The due diligence questionnaires are used to gather current information on topics such as financial viability, results of regulatory reviews, business continuity programs, information security, business code of conduct issues and a number of other topics, to gain a better understanding of each provider’s overall control environment and risk monitoring process.
2. On-site/Virtual due diligence visits of the service provider – This allows the CCO’s Office, Fund Administration, Vendor Management and subject matter experts from the various business units to discuss and make observations as to the adequacy of the internal operational control environment and provides a forum to discuss the results of independent assurance tests and operational and performance issues. The forum also provides the service provider with an opportunity to present future key initiatives.
3. Independent attestation report reviews – Vendor Management reviews the results of these reports to confirm that the controls are adequate, complete, and operating as intended. These reports may be in the form of SOC-1 Reports, Agreed-Upon Procedures or other similar reports. For those service providers that provide these reports, Vendor Management obtains copies, and performs a detailed review to assess the adequacy, scope and completeness of the testing. Vendor Management, in conjunction with the business owners, evaluates the implications of the results of the testing to form a basis for determining the effectiveness of the internal control environment.
4. Monthly operational report reviews – Vendor Management obtains and reviews monthly operational management reports that are prepared by the custodians and shared with the management of John Hancock. The purpose of reviewing these reports is to ensure that operational processes are performing as intended, confirm Key Performance Indicators (KPI) are reported accurately, and identify areas which require further discussion or explanation from the service provider.
5. Service Provider Scorecards/Performance Evaluations – A tool used for key service providers to ensure that the services being provided to John Hancock continue to meet expectations. Vendor Management facilitates the scorecard process by obtaining feedback from the business owners on a regular basis and providing that feedback to the vendor in a formal performance scorecard.
John Hancock Variable Trust Advisers is advised by internal and external legal counsel in connection with general investment company governance, exemptive applications and SEC no- action letters drafted and filed on its behalf, dissolutions of subsidiaries, and mergers and acquisitions. Legal counsel services are provided to John Hancock Variable Trust Advisers in connection with the investment advisory services John Hancock Variable Trust Advisers provides to the funds related to new and existing products, acquisitions of mutual fund assets, determinations of fee breakpoints and valuations. John Hancock Variable Trust Advisers also receives legal counsel related to proxy materials, tax reporting and communications, and preparation of 15(c) material for review by the Board of Trustees. John Hancock Variable Trust Advisers provides services to the Trust related both to any litigation against JHVIT or the JHVIT funds and litigation that JHVIT or the JHVIT funds may initiate. John Hancock Variable Trust Advisers regularly monitors class actions related to securities held by the JHVIT funds and provides support for the JHVIT funds to join such class actions where appropriate. Assets Under Management As of December 31, 2023, John Hancock Variable Trust Advisers managed approximately $65,090,895,426 of assets on a discretionary basis including fund of funds in the Trust. As of December 31, 2023, John Hancock Variable Trust Advisers did not provide continuous and regular supervisory or management services on a non-discretionary basis.