OUR NON-INVESTMENT COMPANY ADVISORY BUSINESS 5 | P a g e Investments’ website (https://www.pgim.com/investments/sirg). The reports are also provided to affiliated and unaffiliated third-party sponsors of managed account wrap platforms and mutual fund non-discretionary wrap programs, described in more detail below. SIRG’s manager evaluation philosophy is based on the proposition that skill exists among active managers. Over time and through experience, SIRG’s approach to the evaluation of managers has identified major attributes or characteristics that are associated with competitive, ongoing investment performance. Identified attributes are both quantitative and qualitative and are gauged using a variety of tools and techniques. The following is a description of SIRG’s manager evaluation process. Organizational Infrastructure SIRG believes that organizational infrastructure as it pertains to investment management is: 1) an assessment of whether the structure of the organization and investment team is optimally designed to develop quality asset forecasts, and 2) an evaluation of the mechanics of how a security name makes its way into the final portfolio and whether its sizing accurately reflects the manager’s conviction in that name. SIRG typically evaluates the structure and design of the firm to determine if it is optimal given the investment strategy and seeks to identify any impediments that would prevent or delay ideas from making their way into the final portfolio. Investment Professionals SIRG observes that organizations who focus on investment talent and talent management generally have an edge over their peers in generating investment performance. Assessing the talent within an investment organization involves quantitative measures as well as subjective judgments. One measure is the experience of the investment team. A premium is placed on significant relevant investment experience, in the asset class and the style implemented. Experience alone, however, is not an indication of talent. Judgments around team members’ passion, critical thinking, and intellectual diversity provide insights into their ability to add value. Further, understanding how a firm approaches the hiring process, trains and motivates its employees, manages underperformers, and promotes an entrepreneurial spirit, can provide further indications of an ability to develop effective high-performance teams. SIRG typically evaluates an investment team’s career histories, both in terms of experience level and quality of previous positions, the firm’s approach to hiring/firing investment professionals, the key attributes that the manager looks for in an individual if they are considering adding people to the investment team, and the characteristics of professionals that have left the firm. EVALUATION OF MANAGER CANDIDATES 6 | P a g e Asset Forecasting SIRG believes asset prices reflect three broad tenets: fundamental valuation, investor behavior, and macroeconomic positioning (top-down views). In essence, an assessment of a manager’s asset forecasting methodology measures its ability to create a sustainable, competitive advantage through either a unique source of information, additional resources devoted to research, and/or processing information differently from other investors. Managers possessing these traits could be able to identify assets the market has mispriced, providing them with an alpha-generating advantage. Portfolio Construction and Risk Management Managers use the process of portfolio construction to design portfolios that seek to optimize risk adjusted performance and ensure that holdings are deliberate, scaled, and consistent with investment themes. SIRG looks to determine the risk consciousness of the manager, how the portfolio was constructed, and how the manager's views are reflected within the portfolio. Performance Analysis SIRG seeks to develop a multi-dimensional view of performance results to draw appropriate conclusions regarding the skills brought to bear by the portfolio management team and process governing a given portfolio. SIRG examines performance, utilizing a variety of metrics and analytical tools. SIRG typically measures and analyzes: returns, risk, efficiency, consistency, symmetry, and attribution. Performance measurement is contextual, that is, relative to like managers and benchmarks. Performance measurement is, in all instances possible, based on rolling observations rather than a single period “snap shot”. The advice SIRG provides regarding principles of performance measurement is based upon the theory that investors should: (i) measure the performance of their investments by looking at whether their total performance is on track to meet their specific objectives; and (ii) measure the performance of their managers versus comparable strategies and benchmarks. In doing so, SIRG evaluates managers regularly to assess whether they continue to meet expectations. Quarterly quantitative analysis typically covers performance, risk-adjusted performance, consistency and investment style. SIRG also monitors for and responds to events that have impacted past performance or could impact future performance. Events considered potentially detrimental to historical or future performance include, but are not limited to: significant organizational changes, portfolio manager changes, or changes to the investment management team. SIRG also monitors for historical underperformance and seeks to identify the causes of such underperformance (for example, poor security selection or style drift). SIRG will implement an increased level of scrutiny on managers evidencing such factors and seek to further understand the potential impact on portfolio performance. 7 | P a g e When practicable, SIRG conducts field office visits at a manager’s location (“Field Visits”) from time to time that could offer an additional perspective from which to evaluate a firm. Field Visits are designed to, among other things, to verify information received through questionnaires and other sources. Upon completion of its manager evaluation, SIRG typically presents a report of its findings and recommendations to one or more of the internal and/or external business/investment committees that utilize SIRG’s services. Each committee reviews SIRG’s research and recommendations, explores any questions or concerns that arise, and then determines whether to accept the addition, termination, reaffirmation, or suspension of a manager with respect to a particular product or program. PGIM Investments’ non-investment company clients are comprised of unaffiliated wrap program sponsors; the investment committees of Prudential's variable annuity, variable life, and retirement businesses; and the general account of The Prudential Insurance Company of America (“PICA”). An unaffiliated financial institution has engaged PGIM Investments to provide non-discretionary manager and fund research services directly to one of the unaffiliated financial institution’s clients, Pruco Securities LLC (“Pruco”), an affiliate of PGIM Investments. These services are prepared using the various methodologies described in Item 4 of this Brochure. The information provided by SIRG to the unaffiliated financial institution is used by Pruco to implement and administer the following wrap fee program:  The Pruco Unified Managed Account (“UMA”) Platform is designed to give investors the ability to select mutual funds, Separately Managed Accounts (“SMAs”), model portfolios, and ETFs covering a wide range of asset classes. Pruco typically offers no-load classes of PGIM Investments’ proprietary mutual funds and certain no-load and load-waived classes of unaffiliated mutual funds, as well as SMAs, model portfolios, and non-proprietary ETFs. SIRG provides quantitative research (such as peer relative performance and manager tenure) that is used by the unaffiliated financial institution and the institution’s client, Pruco, to supplement the factors Pruco considers when adding and removing investment options from the Pruco UMA investment platform. Although SIRG’s research plays a role in Pruco’s review process, Pruco (not SIRG) ultimately decides the investment options on the Pruco UMA investment platform. The unaffiliated financial institution is responsible for its contractual arrangements with its own clients. PGIM Investments does not contract with the unaffiliated financial institution’s clients. Nothing in the arrangement between PGIM Investments and the unaffiliated financial institution is designed to create or imply any contractual, services or advisory relationship between PGIM Investments and any of the institution’s clients. DESCRIPTION OF CLIENTS SERVICES PROVIDED TO AN UNAFFILIATED FINANCIAL INSTITUTION REGARDING WRAP FEE PROGRAMS 8 | P a g e PGIM Investments, through SIRG, provides manager research and recommendations to various investment committees (each, a “Committee”) of our affiliated insurance companies, including PICA. The services SIRG provides are prepared using the various methodologies described in Item 4 of this Brochure. SIRG provides these services on a non-discretionary basis and as inputs for the respective Committee’s consideration. Each Committee (and not SIRG) makes a final determination on which manager or strategy to utilize in the particular product or service. The products or services overseen by the respective Committees include:  Individual and/or group variable life insurance or variable annuity contracts;  Services to retirement plans;  Third-party variable insurance trusts (“VITs”) offered through group variable annuities sold to retirement plans and individual retirement accounts (“IRAs”); and  IRA platforms. PGIM Investments, through SIRG, also provides the following services regarding VITs to the Group Life Insurance and Individual Annuities Committees: (i) monitoring fund performance, style, and market cap consistency, and (ii) monitoring firm stability and composition of the applicable VIT portfolio management team. PGIM Model Portfolios: PGIM Investments, through SIRG, creates, maintains and makes available

PGIM Model Portfolios to Third-Party Advisors. In creating the PGIM Model Portfolios, PGIM Investments works with certain affiliates, including PGIM Quantitative Solutions LLC (“PQS”), which may provide asset allocation input and performance tracking services to PGIM Investments. The PGIM Model Portfolios are made available on Third-Party Platforms for Third-Party Advisors to use, at their discretion, with such Third-Party Advisors’ own clients. The PGIM Model Portfolios are designed and balanced such that the risk profiles approximate those of the respective benchmarks chosen, or the desired outcomes, for the PGIM Model Portfolio. PQS serves as a resource to SIRG with respect to setting the allocations to each asset class. The SIRG team members responsible for PGIM Model Portfolios will incorporate research, quantitative analysis, and capital market assumptions from PQS in the foundation and ongoing management of PGIM Model Portfolios. For additional information about PQS’s asset allocation and portfolio construction services and their associated risks, please review PQS’s SERVICES PROVIDED TO THE INVESTMENT COMMITTEES OF AFFILIATED INSURANCE COMPANIES REGARDING MANAGER SELECTION SERVICES MADE AVAILABLE ON THIRD-PARTY PLATFORMS AND PROVIDED TO THIRD-PARTY ADVISORS RELATED TO MODEL PORTFOLIOS 9 | P a g e Form ADV Part 2 Brochure. SIRG is responsible for the selection of and weightings to each of the underlying mutual funds and ETFs. Each PGIM Model Portfolio is built using specific investment strategies and each is designed consistent with a specific risk tolerance level or desired outcome. SIRG could primarily use PGIM Funds and PGIM ETFs in the PGIM Model Portfolios unless there is no PGIM Fund or PGIM ETF consistent with the desired asset allocation or investment strategy for the PGIM Model Portfolio or in SIRG’s discretion a different mutual fund or ETF is preferred. As a result, PGIM Model Portfolios typically include PGIM Funds and PGIM ETFs notwithstanding the fact that there could be a similar fund with lower costs or better performance. The PGIM Model Portfolios will also include an allocation to cash. The PGIM Model Portfolios will seek to incorporate and follow any model specific constraint(s) imposed upon them by the Third-Party Platform(s) with respect to investment limitations including, fund/ETF usage or allocation constraints. SIRG selects mutual funds and ETFs for inclusion in the PGIM Model Portfolios using a risk-based approach, selecting mutual funds and ETFs that reflect the intended investment exposure and forward performance expectations. As noted above, SIRG will generally select PGIM Funds and PGIM ETFs when constructing a PGIM Model Portfolio. In so doing, SIRG will generally recommend the PGIM Fund/ETF with the lowest expense ratio available to investors on the Third-Party Platform, in addition to non-proprietary money market and index funds and ETFs as determined appropriate by SIRG. In connection with each fund selection within a PGIM Model Portfolio, SIRG analyzes and reviews, among other things, the investment performance, return expectations, investment style and structure, fees, and risk exposure of the mutual funds and ETFs. SIRG could also use fundamental analysis to monitor/assess each fund based on market outlook and fund management fundamentals seeking to optimize the selection of each mutual fund and ETF for inclusion in a PGIM Model Portfolio. SIRG maintains the PGIM Model Portfolios in alignment with established allocations, which may be adjusted from time to time. SIRG will adjust the underlying mutual funds and ETFs in the PGIM Model Portfolios in accordance with PGIM Investments’ policies and processes. Once constructed, the PGIM Model Portfolios are provided to an unaffiliated Third-Party Platform Provider, which in turn makes the PGIM Model Portfolios available to Third-Party Advisors on Third-Party Platform(s). The Third-Party Advisors access the PGIM Model Portfolios through the Third-Party Platform and use them to provide investment advice to their clients. Certain affiliates, including Pruco, are Third-Party Advisors for certain Model Portfolio platforms. In offering the PGIM Model Portfolios, neither PGIM Investments nor its investment advisory affiliates are providing advisory services to, or managing assets for or on behalf of, any Third- Party Advisors or any Third-Party Advisor’s clients. PGIM Investments and its investment advisory affiliates also do not manage any assets through the Third-Party Platform(s) except that PGIM Investments and its investment advisory affiliates could serve as the investment adviser or, in the case of PQS, the investment subadviser to the underlying mutual funds or ETFs in the PGIM Model Portfolios. PGIM Investments and its investment advisory affiliates do 10 | P a g e not have trading authority over any client account of any Third-Party Advisor. The PGIM Model Portfolios are not tailored to meet the needs of the Third-Party Advisor’s clients. Each Third-Party Advisor, and not PGIM Investments or its investment advisory affiliates, is responsible for determining whether the applicable PGIM Model Portfolio is suitable and appropriate for such Third-Party Advisor’s clients. Accordingly, the PGIM Model Portfolios do not take into account broader investment objectives, risk tolerance, or financial circumstances that could be relevant to any Third-Party Advisor’s clients and each Third-Party Advisor is responsible for ensuring that its clients’ current investment objectives, risk tolerance, and financial circumstances are considered before such client invests based on a PGIM Model Portfolio or rebalances per changes in a PGIM Model Portfolio. Evaluations of Other Model Portfolio Providers: PGIM Investments, through SIRG, also performs research services on model portfolios created and maintained by an unaffiliated asset manager for an affiliate. In providing these research services to the affiliate, PGIM Investments is not providing advisory services to, or managing assets for or on behalf of, any of the affiliate’s clients. PGIM Investments, through SIRG, has entered into a research arrangement with PGIM Custom Harvest LLC (“PGIM Custom Harvest”), an affiliate of PGIM Investments, which is a SEC-registered investment adviser that creates and manages specialized portfolios that invest in ETFs to maximize after-tax returns using capital loss harvesting strategies. The research arrangement allows PGIM Custom Harvest to supplement its own research and analysis by leveraging SIRG’s expertise with respect to the identification, selection, and monitoring of ETF providers. Under the research arrangement, SIRG provides PGIM Custom Harvest with information and research concerning ETFs identified by PGIM Custom Harvest that could be considered and used by PGIM Custom Harvest in selecting ETFs used in managing client accounts. PGIM Custom Harvest retains sole and exclusive responsibility for its management of its client accounts, including all decisions regarding the purchase, holding, and sale of ETF shares by PGIM Custom Harvest in connection with such management. RESEARCH SERVICES PROVIDED TO OTHER AFFILIATES 11 | P a g e PGIM Investments receives the following sources of fees for our non-investment company advisory business:  We receive fees and/or cost reimbursements for the research and recommendation services provided to our affiliated insurance companies.  For the recommendations relating to the PGIM Model Portfolios, we receive a management fee for managing the assets of the underlying PGIM mutual funds and PGIM ETFs, if any, that are included in a PGIM Model Portfolio, which is disclosed in the prospectus and SAI of each PGIM Fund and PGIM ETF. For the services PQS provides to PGIM Investments related to the PGIM Model Portfolios, PQS receives a fee from PGIM Investments out of its revenues. Additionally, to the extent PQS is a subadviser to any mutual fund or ETF included in a PGIM Model Portfolio, PQS receives a subadvisory fee for the services it provides on behalf of the mutual fund/ETF. PGIM Investments does not directly charge a fee to any Third-Party Advisors or the clients of any Third-Party Advisors for accessing the PGIM Model Portfolios on the Third-Party Platform(s). PGIM Investments also pays installation, maintenance, technology, or other fees to the Platform Provider(s) for making PGIM Model Portfolios available on the Third-Party Platform. Fees are calculated and billed in accordance with the agreement in place between PGIM Investments and the Platform Provider.  Each underlying PGIM mutual fund and PGIM ETF, if any, included in a PGIM Model Portfolio incurs advisory, administrative, and/or custodial fees, as well as other fees and expenses that it pays out of its own assets. As a result, such fees and expenses are borne by the clients of the Third-Party Advisor as shareholders of the applicable mutual fund or ETF. More information about the fees and expenses associated with underlying funds and ETFs included in a PGIM Model Portfolio is found in such fund’s or ETF’s prospectus and SAI. For the Model Portfolio platform(s) in which Pruco Securities is a Third-Party Advisor, Pruco Securities has agreed to waive its platform fee for its clients for which a PGIM Model Portfolio is used in an amount equal to or greater than the management fees of the PGIM Funds and/or PGIM ETFs included in the PGIM Model Portfolio(s) used for such client. Clients of Pruco Securities should refer to Pruco’s Form ADV for more detailed information on Pruco Securities’ fees and any waiver of such fees for its clients invested in PGIM Model Portfolios. Clients of other Third-Party Advisors should also refer to the Third-Party Advisor’s Form ADV for information on additional fees charged by the Third- Party Advisor. Conflicts of interest or potential conflicts of interest commonly refer to activities or relationships in which the interests of PGIM Investments or its affiliates compete with the interests of PGIM Investments’ clients. Like other investment advisers, PGIM Investments is subject to various