Jackson National Asset Management LLC

ITEM 5 – FEES AND COMPENSATION
A. Describe how you are compensated for your advisory services. Provide your fee schedule. Disclose whether
the fees are negotiable.

JNAM receives a management or advisory fee, as well as an administrative fee from each applicable Fund. JNAM
pays the Sub-Advisers’ fees out of the fees it receives. The fees are computed separately for each Fund, and fees
are accrued daily and paid monthly (in the subsequent month payable in arrears).

Upon the termination of a Sub-Adviser, fees are paid through termination date. The fees for each Fund vary,
please refer to the Funds’ prospectuses for the fees paid by each Fund. The fees are stated as an annual
percentage of the value of the net assets of the Fund. JNAM negotiates its fee with the Funds’ Board.

B. Describe whether you deduct fees from clients’ assets or bill clients for fees incurred. If clients may select
either method, disclose this fact. Explain how often you bill clients or deduct your fees.

See Item 5.A. with regard to the accrual and payment of JNAM’s fees.

C. Describe any other types of fees or expenses clients may pay in connection with your advisory services, such
as custodian fees or mutual fund expenses. Disclose that clients will incur brokerage and other transaction
costs, and direct clients to the section(s) of your brochure that discuss brokerage.

In addition to the fees that JNAM receives (out of which it pays the Funds’ Sub-Advisers, custodian, transfer
agent and other administrative services), a Fund’s expenses include brokerage and other transaction costs of
buying and selling portfolio holdings. (See the section entitled “Brokerage Practices,” for information about
brokerage and transactions costs). A Fund’s expenses may also include registration fees, taxes, nonrecurring or
extraordinary expenses, the Funds’ trustees, legal fees, Rule 12b-1 fees, applicable license fees, the Funds’ Chief
Compliance Officer, the cost of short sales, and borrowing.

D. If your clients either may or must pay your fees in advance, disclose this fact. Explain how a client may
obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period.
Explain how you will determine the amount of the refund.

Not applicable.

E. If you or any of your supervised persons accepts compensation for the sale of securities or other investment
products, including asset-based sales charges or service fees from the sale of mutual funds, disclose this fact
and respond to Items 5.E.1, 5.E.2, 5.E.3 and 5.E.4.

1. Explain that this practice presents a conflict of interest and gives you or your supervised persons an incentive to
recommend investment products based on the compensation received, rather than on a client’s needs. Describe
generally how you address conflicts that arise, including your procedures for disclosing the conflicts to clients. If you
primarily recommend mutual funds, disclose whether you will recommend “no-load” funds.

Not applicable.

2. Explain that clients have the option to purchase investment products that you recommend through other
brokers or agents that are not affiliated with you.

Not applicable.

3. If more than 50% of your revenue from advisory clients results from commissions and other compensation
for the sale of investment products you recommend to your clients, including asset-based distribution fees

from the sale of mutual funds, disclose that commissions provide your primary or, if applicable, your exclusive
compensation.

Not applicable.

4. If you charge advisory fees in addition to commissions or markups, disclose whether you reduce your
advisory fees to offset the commissions or markups.

Not applicable.

ITEM 7 – TYPES OF CLIENTS
Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts,
investment companies, or pension plans. If you have any requirements for opening or maintaining an account,
such as a minimum account size, disclose the requirements.

JNAM’s advisory clients include the investment companies that underlie the Jackson and Jackson NY separate
accounts, through which they offer their variable products and certain Jackson sponsored “Non-Qualified
Retirement Plans,” as well as certain affiliated Funds of Funds, Feeder Funds, Funds of ETF Funds, Multi-Manger
Funds and Interval Funds. JNAM does not have any private, third-party or government entity clients.

JNAM typically does not offer advice with respect to the purchase and/or sale of specific securities or other
investment products but is responsible for supervising and monitoring the investment advisory services provided
by the Sub-Advisers with respect to the separate investment portfolios of the Funds. JNAM does not have a
traditional portfolio management department and does not operate a traditional trading desk.