VIL, an Arizona limited liability company, is wholly-owned by Voya Funds Services, LLC (“VFS”). VFS is wholly-owned by
Voya Capital, LLC, which in turn is a wholly-owned subsidiary of Voya Investment Management LLC ("Voya IM LLC"), which
in turn is a wholly owned subsidiary of VIM Holdings LLC, a Delaware limited liability company. Voya Financial, Inc., a
publicly traded company, holds a 76% economic stake in VIM Holdings LLC through its subsidiary Voya Holdings Inc. As of
July 25, 2022, Allianz SE, a stock corporation organized and existing under the laws of the European Union and the Federal
Republic of Germany, holds an indirect 24% economic stake in VIM Holdings LLC as a result of a transaction combining Voya
IM LLC with the assets and teams comprising specified transferred strategies formerly managed by Allianz Global Investors
U.S. LLC.
VIL is registered with the SEC as an investment adviser. It serves as an investment adviser for certain registered investment
companies, consisting of open- and closed-end registered investment companies (each a “Fund” and collectively, the “Funds”).
The predecessor of VIL, ING Pilgrim Investments, Inc. began business as an investment adviser on December 27, 1994. On
February 23, 2001, the name of the investment adviser changed from “Pilgrim Investments, Inc.” to “ING Pilgrim Investments,
LLC.” On February 26, 2002, the name of the investment adviser was changed from “ING Pilgrim Investments, LLC” to “ING
Investments, LLC.” On May 1, 2014, the name of VIL was changed from “ING Investments, LLC” to “Voya Investments, LLC.”
The overwhelming majority of assets managed by VIL are discretionary in nature, although from time to time non-discretionary
mandates will be accepted. As of December 31, 2023, VIL managed $57,786,360,253 in discretionary assets and $0 in non-
discretionary assets.
INVESTMENT AUTHORITY
For the majority
of its clients, VIL’s primary role is to function as a Manager-of-Managers. As such, while retaining overall
investment oversight, VIL generally hires other registered investment advisers (the “Sub-Advisers”) to perform the day-to-day
asset management services in a sub-advisory capacity. VIL then oversees the provision of these sub-advisory services. Under this
structure, trading on behalf of the clients is substantially executed by the Sub-Advisers, subject to VIL’s oversight, although in
certain circumstances VIL will itself exercise direct authority over purchases and sales for all or a portion of a Fund. As a
Manager-of Managers, VIL provides numerous services to its clients, including, among other services: developing investment
programs for certain clients’ portfolios; researching, negotiating with, selecting and removing the Sub- Advisers of such clients
(subject to approval of such client’s board of directors/trustees); monitoring the Sub-Advisers’ performance and adherence to their
investment policies and/or procedures; monitoring the Sub-Advisers’ compliance with legal and regulatory requirements; and
facilitating the contract renewal process with such client’s board of directors/trustees.
In addition, even where VIL currently acts as Manager-of-Managers, should the need arise, VIL can act in a traditional asset
management role. With respect to certain Voya funds that are managed by multiple Sub-Advisers (the “Multi-Managed Funds”),
in addition to allocating Fund assets to such Sub-Advisers, VIL will, from time to time, manage a portion of the Funds’ assets to
seek to manage the Funds’ overall exposure to achieve the Funds’ desired risk/return profile and to effect the Funds’ investment
strategies. Under certain circumstances, VIL will also directly invest in futures and exchange-traded funds to implement its
investment process for the Multi-Managed Funds.
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