Chartwell Investment Partners LLC (“Chartwell”), is an SEC registered investment adviser and wholly owned subsidiary of Carillon Tower Advisers, Inc., doing business as Raymond James Investment Management (“RJIM”). RJIM is the asset management subsidiary of Raymond James Financial, Inc. (NYSE: RJF), a publicly held and leading diversified financial services company based in St. Petersburg, Florida. As of December 31, 2023, Chartwell managed a total of $11.4 billion in assets on both a discretionary and non-discretionary basis. Under RJIM’s affiliate model, Chartwell continues to focus on achieving the objectives of our new and long-term clients operating under the Chartwell Investment Partners brand. Chartwell’s structural history includes: a limited partnership founded in April 1997; reformation into a Pennsylvania corporation upon acquisition by TriState Capital Holdings, Inc. in March 2014 and modification into a limited liability company made strictly for tax purposes only effective July 2015. Chartwell’s advisory services consist of selecting investments for institutional, sub-advisory and private clients while considering the client’s needs, including total return objectives, risk tolerance, other assets and obligations of the client, legal investment laws and other investment restrictions applicable to the client. Chartwell offers investment advice concerning a wide range of investment styles but predominantly advises clients regarding investments in U.S. securities. Chartwell will ordinarily apply one of several varied investment strategies to manage a portfolio of equity securities and/or fixed income securities. For individual investors, Chartwell may allocate assets among several varied investment strategies and investment vehicles, including equity and fixed income securities, exchange traded funds and mutual funds, including affiliated funds sub-advised by Chartwell, collective investment trusts or collective fund trusts. Chartwell also participates in wrap fee programs by providing discretionary and non-discretionary investment management services to the clients of these programs. This is an advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Such clients may select Chartwell from a number of investment managers based on analysis, performed by the relevant program sponsor, of client’s goals and objectives and the compatibility with Chartwell’s investment philosophy. Generally, we manage wrap fee client accounts in the same manner as other client accounts investing pursuant to the same or similar investment strategy. Clients may impose reasonable restrictions on Chartwell’s management of account assets. To the extent there are differences in client accounts, such differences would relate to the broker- dealer through which Chartwell places orders for execution. See Item 12 below, for a description of Chartwell’s practices in placing orders for execution for firm clients. While Chartwell primarily offers investment management services, we generally do not enter into securities lending arrangements for our clients. Under typical securities lending arrangements, a manager loans a security held in a client’s portfolio to a broker-dealer in exchange for

collateral. The client may earn potentially enhanced returns from these arrangements by collecting finance charges on the loan or by investing the collateral. Such returns are generally shared between the client and the securities lending agent, and the risk associated with the investment of collateral is generally borne by the client. On occasion, if instructed by a client, we may enter into securities lending transactions although Chartwell does not manage the investment of collateral in connection with such arrangements. In these instances, we will have entered into a Master Securities Loan Agreement with a counterparty and the transaction must meet all the requirements under the agreement. Some clients have established separate securities lending arrangements with their custodian. If a client has entered into these arrangements, the client and its custodian are responsible for adhering to the requirements of such arrangements, including ensuring that the securities or other assets in the Account are available for any securities lending transactions. For Accounts that we actively manage, we execute transactions based on a number of factors, including market conditions and best execution, and generally do not consider factors relating to a client’s securities lending arrangements, such as whether the Client’s custodian may need to recall securities on loan to settle the sales transactions. As part of its fiduciary duty to its clients and as a matter of best business practices, Chartwell has adopted policies and procedures for disaster recovery and for continuing business in the event of an emergency, a disaster or pandemic. These policies are designed for Chartwell to continue providing services to clients in as short a period of time as possible. Chartwell’s policies are, to the extent practicable, designed to address those specific types of disasters that the firm might reasonably face given its business and location. Chartwell management realizes that the rapidly changing nature of technology demands that a comprehensive security policy be developed and implemented to secure the confidentiality, security, integrity and accessibility of Chartwell’s client information systems. Further, management recognizes that in order to determine the appropriate type and scope of controls to deploy as part of the information security program, Chartwell must assess risks to its client information and systems, identifying reasonably foreseeable internal and external threats that could result in unauthorized disclosure, misuse, alteration, or destruction of client information or client information systems and evaluate the adequacy of policies, procedures, information security systems, and other practices intended to control the risks identified. To ensure that information security risks are understood, and appropriate security systems are maintained, Chartwell management has adopted an Information Security Policy. The primary purposes of Chartwell’s Information Security Policy are to ensure that Chartwell management:
• Understands the risks and threats to which information systems are exposed
• Evaluates the potential exposures to such risks/threats
• Implements appropriate information security systems and administrative, technical and physical security controls to mitigate such risks, threats and exposures, tests the effectiveness of information security systems and controls, and responds timely to various type of cyber incidents.