Identify your principal owner(s). Winston Capital Management, L.L.C. (“Winston”), a Virginia limited liability company, has been registered as an investment adviser with the U.S. Securities & Exchange Commission (“SEC”) since 1997. Winston was formed in, and has provided investment advisory services since 1997. Winston provides discretionary investment advisory services to clients that operate as private investment funds. The private investment funds consist of: (i) the “Winston Funds” (as detailed below); and (ii) other private investment funds that have been customized based on the preferences of an investor or a group of investors (the “Customized Funds”). Specifically, the Winston Funds consist of: o Winston Growth Fund Limited Partnership, a Virginia limited partnership (the “Growth Fund”); o Winston Hedged Equity Fund, Ltd., an offshore private investment company formed under the laws of the British Virgin Islands (the “Hedged Equity Fund”); o Winston Global Fund, L.P., a Delaware limited partnership (the “Global Fund”); o Winston Global Fund, Ltd., an offshore private investment company formed under the laws of the British Virgin Islands (the “Global Fund Offshore”) o Winston Asia Fund, L.P., a Delaware limited partnership (the “Asia Fund”); and o Winston Asia Fund, Ltd., an offshore private investment company formed under the laws of the British Virgin Islands (the “Asia Fund Offshore” which, together with the Growth Fund, the Hedged Equity Fund, the Global Fund, the Global Fund Offshore and the Asia Fund, are the “Winston Funds”). The Winston Funds operate as master-feeder structures. Substantially all of the assets of the Hedged Equity Fund are invested in the Growth Fund; substantially all of the assets of the Global Fund Offshore are invested in the Global Fund; and substantially all of the assets of the Asia Fund Offshore are invested in the Asia Fund. Winston also provides non-discretionary investment advisory services to accounts established for the benefit of policyholders of Axcelus Financial Life Insurance Company formerly Lombard International Life Assurance Company, and prior to that, Philadelphia Life Assurance Company, and prior to that, American Guardian Life Assurance Company (“Axcelus” or the “Axcelus Accounts”). Further, under the terms of the agreements with Axcelus, Winston may recommend that the assets in the Axcelus Accounts be invested in the Winston Funds and related entities. Each of the Winston Funds, the Customized Funds, and the Axcelus Accounts are sometimes hereinafter referred to individually as an "Advisory Client" and collectively as the "Advisory Clients". Winston is principally owned by Winston Partners Group LLC. Winston Partners Group LLC is principally owned by an entity that is ultimately controlled by Jonathan D. Scanlon. specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. Winston invests the assets of the Winston Funds in pooled investment vehicles managed by other investment managers selected by Winston (the “Managers”). Such pooled investment vehicles include private investment partnerships or other investment vehicles which may include separately managed accounts (the “Portfolio Funds”). The investment objective of the Winston Funds is to seek long-term capital growth, while reducing downside risks through the use of a multi-manager investment approach that specializes primarily in classic long/short hedged equity strategies. Winston considers a number of factors in selecting Managers and Portfolio Funds, including a Manager's organizational depth, business stability, investment philosophy, research process, portfolio management skill, use of fundamental analysis, use of leverage, trading acumen, and prior performance. Winston attempts to select Managers and Portfolio Funds which offer a variety of different skills in an effort to balance the portfolio of the Winston Fund and to provide for preservation of capital while maximizing opportunities for growth. In addition, capital of any of the Winston Funds may, from time to time, be invested directly by

Winston in securities, money market funds or mutual funds, which investments must be consistent with the general investment objectives of the respective Winston Fund. There are no fixed restrictions on Winston’s ability to invest capital of the Winston Funds with one or more Managers, or Managers with a particular strategy or style or who invest in similar types of securities, industries or markets. However, the Growth Fund, the Global Fund and the Asia Fund may generally not invest more than 15% of their capital (in terms of market value computed at the time of investment) with a single Manager. Further, the Portfolio Funds are not limited or restricted in their investment activities. From time to time, the Winston Funds will (indirectly through their investments in Portfolio Funds), to the extent permitted by the U.S. Financial Industry Regulatory Authority, Inc. (“FINRA”), participate in the purchase of equity securities that are part of an initial public offering (referred to as “new issues”). The profits and losses with respect to new issues will be allocated to investors in the Winston Funds according to their pro rata ownership of the respective Winston Fund. However, at no time will restricted persons be allocated more than 10% of the new issue income regardless of their respective ownership in a Winston Fund. Further, to the extent that covered investors of a particular company in the aggregate exceed 25% of a particular Winston Fund, IPO profits and losses may not be allocated to such Winston Fund. The Customized Funds generally achieve their investment strategies through their direct investments in other Winston Funds and may, from time to time, make other direct investments outside the Winston Funds. As noted above, Winston does not have discretionary authority over the Axcelus Accounts. In providing advisory services to the Axcelus Accounts, Axcelus has the ultimate investment discretion. individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. Winston provides investment advisory services to the Winston Funds based upon the criteria set forth in the offering documents. The investment strategies, including investment restrictions (which are not absolute), are set forth in detail in the respective offering documents. Individual investors in the Winston Funds do not have the ability to impose restrictions on Winston’s investments in certain securities or types of securities. Winston has the right on behalf of each of the Winston Funds to hire and dismiss Managers and Portfolio Funds on a fully discretionary basis. Winston has and may, from time to time, enter into letter agreements or other similar agreements (collectively, “Side Letters”) with one or more Winston Fund investors that provide such investors with additional and/or different rights or terms than those set forth in the Winston Funds’ offering documents. Such agreements may, among other things, be based on the size of the investor’s investment in the Winston Fund or affiliated investment entity, an agreement by an investor to maintain such investment in the Winston Fund for a significant period of time, or other similar commitment by an investor to the Winston Fund. With respect to the Customized Funds, the advisory services are based on the preferences of an investor or a group of investors. As previously noted, the Customized Funds generally achieve their investment strategies through their direct investments in the Winston Funds, but have and may make direct investments in Portfolio Funds. In addition, the Customized Funds have different terms (including but not limited to investment minimums, fees, liquidity and/or transparency) than the Winston Funds. In providing advisory services to the Axcelus Accounts, Axcelus has the ultimate investment discretion. services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Not applicable. discretionary basis and the amount of client assets you manage on a non- discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2023, Winston had approximately $1,068,307,871 on a discretionary basis and $3,316,837 on a non-discretionary basis in regulatory assets under management.