A. Description of the Advisory Firm LGIM America is a Delaware corporation with its principal place of business in Chicago, Illinois. LGIM America has been in business since January 2009. LGIM America is registered with the SEC as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), the U.S. Commodity Futures Trading Commission (“CFTC”) as a Commodity Trade Advisor and Commodity Pool operator, the Ontario Securities Commission (“OSC”) and the Quebec Authorité des Marchés Financiers (“AMF”) in Canada as a Portfolio Manager, and is a member of the U.S. National Futures Association (“NFA”). With respect to its management of client funds deemed to be “plan assets” under the U.S. Employee Retirement Income Security Act of 1974, as amended (“ERISA”), LGIM America relies on the U.S. Department of Labor’s Qualified Professional Asset Manager exemption or other statutory or administrative prohibited transaction exemptions to avoid engaging in non-exempt prohibited transactions in those assets under ERISA and the U.S. Internal Revenue Code of 1986, as amended. LGIM America is a wholly-owned subsidiary of Legal & General Investment Management United States Holdings, Inc. (“US Holdings”), which itself is a wholly owned subsidiary of Legal & General Investment Management Holdings, Limited (“LGIM(H)”). LGIM(H) is a financial services holding company wholly-owned by Legal & General Group PLC, (“Legal & General”), a publicly-traded company in the United Kingdom (“U.K.”). LGIM America is an affiliate of Legal & General Investment Management Ltd. ("LGIM"), a London-based adviser authorized and regulated by the U.K. Financial Conduct Authority (“FCA”), and LGIM International Ltd. (“LGIMI”), a London-based adviser authorized and regulated by the FCA and registered with the SEC. B. Types of Advisory Services We provide investment management services on a fully discretionary basis to our clients and on a non-discretionary basis to certain of our affiliates. We do not offer non-discretionary investment advisory services generally or to clients that are not affiliates of our firm. Currently, LGIM America only provides services to institutional investors. 1. Investment Strategies Offered Currently we offer six primary investment strategy types: active fixed income (“AFI”), liability-driven investing (“LDI”), multi-asset, passive index-tracking (“Passive Index”), index-tracking that implements certain additional trading strategies selected by LGIM America (“Index Plus”); and private credit, real estate debt, and real estate equity (collectively, “Real Assets"). The foregoing strategies are described in detail below. In addition, we periodically offer certain strategies that are fully implemented for clients through delegation to LGIMI, including emerging market debt, global high yield and transition services. Please see Item 8 of this Brochure for more information about certain of LGIM America’s strategies. Further information on strategies delegated to an affiliate which are not included in this Brochure is available upon request. AFI Offerings: Currently deployed AFI strategies include the following, although this list may change without notice: Absolute Return, Absolute Return Plus, Buy and Maintain, Cash Flow Matched Bond, Enhanced Cash, High Yield, Liability Aware Long Duration US Credit, Long Duration Government / Credit, Long Duration US Corporate, Long Duration US Credit, Long Duration US Credit / US Long Government, Long Duration US Credit Plus, US Corporate, US Credit, US Credit Plus, US Intermediate Credit, US Intermediate Government, US Long Government, US Long Treasury, US Treasury 1-10 Year TIPS, US Treasury 15+ STRIPS, US Treasury 20+ STRIPS and US Treasury STRIPS Custom. LGIM America 2 LDI Offerings: We offer custom solutions through LDI management services, which includes custom liability benchmarking, derivatives management, Treasury management, completion management, funded ratio monitoring, and pension endgame portfolios. Multi-Asset Offerings: We offer the following multi-asset strategies: policy allocation management, including cash equitization, factor exposure, volatility management and tactical asset allocation, equity hedging and structuring, such as broad index overlay and replication, tactical hedging, tail risk protection and cross asset exposure, alternatives replacement, as well as Retirement Income. We do this by using derivatives (exchange traded, over the counter, and centrally cleared), physical investments (including cash), or a mix thereof. Passive Index Offerings: We offer Passive Index investment strategies that track market indices designed by Standard & Poor’s, MSCI, FTSE Russell, Bloomberg Barclays, Solactive, EDHEC Risk Institute Scientific Beta, or LGIM, our affiliate. Offerings include tracking to customized indexes created to meet a client’s specific needs. Index Plus Offerings: We offer Index Plus strategies which attempt to earn returns that slightly exceed market indices designed by Standard & Poor’s, MSCI, FTSE Russell, Bloomberg Barclays, Solactive, or our affiliate, LGIM. The Index Plus strategies will primarily seek exposure to the market indices by investing the assets of these strategies in publicly traded, U.S. and non-U.S. equity securities that are primarily components of such indices, while secondarily employing, on an opportunistic basis, other selected trading strategies, including event driven trading, risk inefficiency trading, rebalance prediction-based trading and synthetic asymmetries-based trading. See Item 8 for more details about this strategy. Real Assets Offerings: We offer Real Assets strategies across investment-grade corporate and structured credit, infrastructure debt investments, commercial mortgage loans, real estate debt, and real estate equity. . Global mandates for all the foregoing, with the exception of real estate equity, are sub-delegated to our affiliate, LGIMI. Administrative services for our Real Assets Offerings

are provided by our affiliates. 2. Investment Products Offered We offer the foregoing strategies: (i) through separately-managed accounts (“SMAs”); (ii) as an adviser to “Private Funds”, which are U.S. investment funds exempt from registration as investment companies in reliance on Section 3(c)(7) of the U.S. Investment Company Act of 1940, as amended (the “Company Act”); (iii) as advisor or sub- adviser to “CITs”, which are collective investment trust funds exempt from registration as investment companies in reliance on Section 3(c)(11) of the Company Act; (iv) as investment adviser of SEC registered investment companies (the “LGIMA Mutual Funds”); (v) as sub-adviser to SEC registered investment companies for which unaffiliated third parties serve as investment advisers (the “Sub-Advised Mutual Funds”); and (vi) as sub-adviser to other investment advisers in connection with their services to institutional clients, funds, and Outsourced Chief Investment Officer (“OCIO”) platforms. The Private Funds, the CITs and the LGIMA Mutual Funds are collectively referred to herein as the “LGIMA Funds.” The various product offerings described above are collectively referred to as the “LGIMA Products.” Certain LGIMA Products are described in more detail below. Private Funds: Only qualified purchasers may invest in the private funds. A list of the Private Funds, and their primary services providers, is available in LGIM America’s ADV Part 1A. CITs: Reliance Trust Company is the trustee, transfer agent, and adviser of the CITs, which are bank-maintained trusts available to certain tax-exempt employee benefit plans. Citibank, N.A. is the CITs’ custodian and securities lending agent, and Citi Fund Services Ohio, Inc. is the CITs’ fund accountant and administrator. Mutual Fund: The LGIMA Mutual Fund is operated by SEI Investments Management Corporation (“SEI”) and its affiliated entities. In addition, LGIM America sub-advises certain multi-manager mutual funds for which SEI and GuideStone Capital Management, LLC serve as investment advisers. LGIM America is not involved in the operation LGIM America 3 or distribution of these Sub-Advised Mutual Funds and its responsibility is limited to the portion of such funds for which it serves as sub-adviser. Please see the respective LGIMA Fund’s offering materials, such as the private placement memorandum, prospectus, statement of additional information or similar offering documents (the “Offering Document”) for complete disclosures relating to such products. The foregoing information is provided for informational purposes only and not as a solicitation, and is merely intended to address required disclosures about our business practices and the conflicts associated with managing multiple types of investment products. No reference within this Brochure should be viewed as an offer to sell or an offer to buy an interest in any LGIMA Product. C. Client Tailored Services and Client Imposed Restrictions The LGIMA Products have varying business terms, including, but not limited to, differences in fees charged, withdrawal rights, voting rights, investment objectives and guidelines, investment portfolios, investment minimums, investment qualification standards, and dividend payments. Certain LGIMA Products, particularly the SMAs and single-investor LGIMA Funds, are tailored to the needs of their investors in that they are subject to investment restrictions, limitations, and/or guidelines that LGIM America has agreed to with the investor. The investment objective and appropriate level of risk of each LGIMA Product, as well as any applicable investment limitation, restriction, guideline or benchmark, are generally set forth in that LGIMA Product’s Offering Document and/or investment management agreement or sub- advisory agreement (the “IMA”). In certain instances, SMA clients direct LGIM America, via their IMA, to invest all or a portion of their separately-managed account into one or more LGIMA Funds, such that the SMA’s strategy is implemented partially or wholly through LGIM America’s commingled funds. D. Participation in Wrap Fee Program We do not participate in or offer Wrap Fee programs. E. Assets Under Management As of December 31, 2023, we manage approximately $214 billion on a discretionary basis and approximately $1 billion on a non-discretionary basis. Please note that the methodology that this Brochure uses to present LGIM America’s assets under management differs from the methodology that the SEC requires to calculate “regulatory assets under management” (“RAUM”). For purposes of LGIM America’s Form ADV Part 1, RAUM is calculated on a gross basis (without deduction of any outstanding indebtedness or other accrued but unpaid liabilities) and double counts investments by one investment product into another (e.g., internal fund-of-funds structures). In contrast, we calculate the net assets under management disclosed in this Brochure to prevent double counting. All assets under management presented in this Brochure are comprised of December 31, 2023 net asset values. F. Participating Affiliate Arrangements In some cases, LGIM America utilizes non-U.S. advisory affiliates, or such affiliates’ personnel, to perform services through various shared services, personnel sharing and “participating affiliate” arrangements. In participating affiliate arrangements, certain personnel of certain of LGIM America’s non-U.S. advisory affiliates act as “associated persons” in providing such services pursuant to a participating affiliate agreement between LGIM America and such non-U.S. advisory affiliate, and in that capacity are subject to LGIM America supervision and oversight. We, each participating affiliate, and any such personnel, will act according to a series of SEC no-action relief letters mandating that our participating affiliates remain subject to the supervision of LGIM America and the SEC with respect to activities engaged in pursuant to the participating affiliate agreement. LGIM America 4