A. Describe your advisory firm, including how long you have been in business. Identify your principal owner(s). Notes: (1) For purposes of this item, your principal owners include the persons you list as owning 25% or more of your firm on Schedule A of Part 1A of Form ADV (Ownership Codes C, D or E). (2) If you are a publicly held company without a 25% shareholder, simply disclose that you are publicly held. (3) If an individual or company owns 25% or more of your firm through subsidiaries, you must identify the individual or parent company and intermediate subsidiaries. If you are an SEC-registered adviser, you must identify intermediate subsidiaries that are publicly held, but not other intermediate subsidiaries. If you are a state-registered adviser, you must identify all intermediate subsidiaries. JNAM is an indirect, wholly owned subsidiary of Jackson Financial Inc. (“JFI”), a leading provider of retirement products for industry professionals and their clients. JFI and its subsidiaries, Jackson National Life Insurance Company (“Jackson”) and Jackson National Life Insurance Company of New York (“Jackson NY”), offer variable, fixed and fixed index annuities designed for tax-efficient growth and distribution of retirement income for retail customers, as well as products for institutional investors. Since January 2001, JNAM has served as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (“Advisers Act”). JNAM’s investment management services primarily involve advising mutual funds sponsored by affiliated entities and advising proprietary Interval Funds. JNAM has engaged the services of other investment advisers (each a “Sub-Adviser,” and collectively, “Sub-Advisers”) to manage the investment activities of certain of the separate investment portfolios (series) of the JNL Series Trust, the JNL Investors Series Trust, the Jackson Credit Opportunities Fund and the Jackson Real Assets Fund (each a “Fund,” and collectively, “Funds”). The Funds are registered as investment companies pursuant to the Investment Company Act and the Securities Act of 1933, as amended (“Securities Act”). JNAM may recommend the replacement of a Fund’s Sub- Adviser with another Sub-Adviser. JNAM serves as the investment adviser to certain mutual funds operating as “Fund of Funds” that invest in a specified selection of underlying mutual funds or exchange traded funds (each an “ETF,” and collectively, “ETFs”). While JNAM may select certain ETFs as investments for the “Fund of ETF Funds,” the Sub-Adviser conducts trading and portfolio reviews of those ETF selections. JNAM also serves as investment adviser to certain mutual funds (“Feeder Funds”) that invest in specified unaffiliated funds (“Master Funds”) in what is known as a Master Feeder fund structure. In addition, JNAM serves as the investment adviser to certain Multi-Manager Funds, which are comprised of underlying Sleeves managed by Sub-Advisers or JNAM. JNAM is responsible for managing the Multi-Manager Funds, in accordance with their asset allocation limits. JNAM also serves as the investment adviser to the Interval Funds. JNAM currently does not have retail or private investment advisory clients. Likewise, JNAM does not have third-party advisory clients and does not provide investment advisory services to “government entities.” The JNL Series Trust Funds underlie certain Variable Contracts (variable products) sponsored by Jackson and Jackson NY, and are primarily sold to their separate accounts, which are registered as investment companies under the Investment Company Act

and Securities Act, and through which those variable products are offered. Certain JNL Series Trust Funds are also sold to participants in non-qualified retirement plans of Jackson and its affiliates. In limited situations, JNAM may assist in a “transition,” moving portfolio management from one Sub-Adviser to another Sub-Adviser. During transitions, JNAM personnel may provide instructions to a transition manager and the Fund’s custodian. JNAM personnel are authorized by the Funds’ Board of Trustees (“Board”) to provide such instructions. B. Describe the types of advisory services you offer. If you hold yourself out as 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. As authorized by the United States Securities and Exchange Commission (“SEC”), JNAM is a “Manager of Managers,” which means it is primarily responsible for supervising, reviewing, and monitoring the implementation by the Sub-Advisers of the investment objectives of the Funds, and recommending changes in the Sub-Advisers’ investment strategies or methods, from time to time, if deemed necessary or advisable by JNAM. JNAM currently does not have any private, retail or government entity advisory clients. JNAM serves as the investment adviser to the Funds. With regard to the limited number of Funds that are Funds of Funds or Feeder Funds, that are further described in response to Item 7. JNAM may play a greater investment advisory role in the selection of affiliated Funds and the recommendations of Master Funds. Please refer to the prospectuses for the Funds for detailed information about the Funds and the Sub-Advisers. C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. JNAM’s only investment advisory clients are the Funds. Each Fund has its own investment objective and principal investment strategies. D. If you participate in wrap fee programs by providing portfolio management 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. E. If you manage client assets, disclose the amount of client assets you manage on a 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. Note: Your method for computing the amount of “client assets you manage” can be different from the method for computing “assets under management” required for Item 5.F in Part 1A. However, if you choose to use a different method to compute “client assets you manage,” you must keep documentation describing the method you use. The amount you disclose may be rounded to the nearest $100,000. Your “as of” date must not be more than 90 days before the date you last updated your brochure in response to this Item 4.E. As of March 31, 2024, JNAM had $257,484,747,292 in assets under management. More information on JNAM’s assets under management is included in JNAM’s Form ADV Part 1A – Item 5.F.