Janus Henderson Investors US LLC

Fees and Compensation
JHIUS does not currently charge a separate advisory fee for either the Active Advice or the Snapshot Advice
Programs. If the client chooses to participate in the Active Advice Program or implement the Snapshot Investment
Recommendation, JHIUS and its affiliates will be compensated through the investment management fees and
other expenses associated with the Sponsored Fund(s) in which the client invests, all of which will be reflected in
their expense ratios. The Sponsored Funds’ management fee is calculated daily and paid monthly. The advisory
agreement between the Sponsored Funds and JHIUS details the investment management fee and other expenses
that the Sponsored Funds must pay. As a result, fees are not negotiable.

JHIUS will only use and recommend the Class D shares of the Sponsored Funds. No other share classes are
included as part of the Active Advice or Snapshot Advice Programs. The Class D shares generally bear an
investment management fee and other fund expenses, including a custodial fee and administrative service fee,
but not any sales charge or load. The administrative service fee is used to pay the Transfer Agent for the provision
of shareholder services including, but not limited to, recordkeeping, accounting, answering inquiries regarding
accounts, transaction processing, transaction confirmations, and the mailing of prospectuses and shareholder
reports. While they may bear higher fees, including sales charges or loads, other share classes in the Sponsored
Funds may be available for purchase outside the Active Advice and Snapshot Advice Programs through other
brokers or agents that are unaffiliated with JHIUS.

The details of a participating Sponsored Funds’ fees and expenses, including the applicable investment
management fee rate, can be found in each fund’s offering documents, copies of which are made available to
Active Advice and Snapshot Advice Program clients on or about the time of the initial Managed Allocation

Recommendation or Snapshot Investment Recommendation. The offering documents show the cost of investing
in Class D shares of the fund, including the returns of the funds net of their expenses. The Active Advice and
Snapshot Advice Program clients do not receive any separate invoice or account statement with separately
itemized or billed expenses.

All fees disclosed in the Sponsored Fund offering documents are subject to change, including as a result of lapses
or rescissions of any applicable fee or expense waivers. To the extent that investment management fees decline
or other fees change, the client and other fund shareholders will receive notice of those changes through updates
to prospectuses and shareholder reports. To the extent that investment management fees increase, the client and
other fund shareholders will receive notice of those changes through updates to prospectuses and shareholder
reports and may be solicited for approval of those changes through a proxy statement as required by applicable
law. JHIUS may also separately provide notice of fees and changes in fees to Active Advice Program clients,
including as a result of the introduction of a new Sponsored Fund into the program. By continuing to participate in
the Active Advice Program following receipt of such notices, clients are understood as having consented to any
changes in the disclosed fees or expenses, including any increases which do not result in fees or expenses beyond
the “Approved Management/Advisory Fee Rate”.

JHIUS has an incentive to structure the program to only include its own Sponsored Funds. JHIUS also has an
incentive to select Sponsored Funds and structure and recommend portfolios of Sponsored Funds in such a way
that results in the maximum fee or overall benefit to JHIUS and/or its affiliates. Further, while the Investment
Consultants do not directly receive compensation for the sale of the Sponsored Funds, including any asset-based
sales charges or ongoing service fees, they similarly have an incentive to provide advice in such a way that results
in the maximum fee or overall benefit to JHIUS and/or its affiliates since the management fees and other expenses
associated with the Sponsored Funds help fund the profit pools which are used to pay fixed and variable
compensation. JHIUS believes the objective or quantitative nature of the models used in the portfolio construction
process, which do not consider management fees of the underlying funds other than in considering net returns,
helps to mitigate any potential conflicts of interest. JHIUS has also adopted other policies, procedures and controls
to help mitigate these potential conflicts of interest, including disclosure to clients in this Brochure.

Performance-Based Fees and Side-by-Side Management
While JHIUS does accept performance-based fees for certain accounts, including some of the Sponsored Funds,
JHIUS does not currently charge any separate management fees to clients in the Active Advice and Snapshot
Advice Programs, including any performance-based management fees. The Investment Consultants only provide
advice to clients in the Active Advice and Snapshot Advice Programs and therefore do not face any separate
conflicts of interest arising from different compensation arrangements between clients.

Types of Clients
The Active Advice and Snapshot Advice Programs are currently designed for, intended for and available to
individuals, including high net-worth individuals, looking for investment advice with respect to certain tax-deferred
or tax-advantaged accounts (e.g., IRA and Roth IRA accounts). The Active Advice and Snapshot Advice Programs
are currently not available to other types of investors, such as charitable organizations, government entities, or
corporations or other businesses.4 To participate in either the Active Advice or Snapshot Advice Programs, clients
must have or be willing to establish an eligible account with the Transfer Agent. Clients generally must also have
or be willing to invest a minimum of $10,000 in the Class D shares of the Sponsored Funds. JHIUS may waive or
change these thresholds and eligibility requirements in its sole discretion.

The Active Advice and Snapshot Advice Programs may be inappropriate for ultra-high net-worth individuals who
may be able to implement or replicate the advice provided at lower cost or with greater flexibility using other
methods. The Active Advice and Snapshot Advice Programs may also be inappropriate for individuals who want
comprehensive financial planning advice. JHIUS provides access to interactive, self-service tools and calculators
to educate and assist users in making financial decisions at janushenderson.com. The use of such tools and
calculators are subject to any associated disclosures, disclaimers, licenses and agreements. While Active Advice
and Snapshot Advice Programs clients may use those tools and calculators, any information from, outputs of or
recommendations from such tools and calculators are not considered financial planning advice being provided by
JHIUS or through the Active Advice and Snapshot Advice Programs.

 For additional information regarding other types of accounts and services offered by JHIUS, please refer to the
separate JHIUS Form ADV Part 2A Brochure which covers its general investment advisory business.

Methods of Analysis, Investment Strategies and Risk of Loss
In the Snapshot Advice Program, JHIUS recommends a single Sponsored Fund which generally corresponds to
the client’s objectives, risk tolerance and time horizon as identified through their Investor Questionnaire. The
Snapshot Investment Recommendation will be one of three Janus Henderson allocation funds which invest in a
portfolio of Sponsored Funds and/or third-party funds and seek to meet a specific risk-return profile: Janus
Henderson Global Allocation Fund – Conservative, Janus Henderson Global Allocation Fund – Moderate and
Janus Henderson Global Allocation Fund – Growth.

In the Active Advice Program, JHIUS provides a target asset allocation among one or more Sponsored Funds
selected by JHIUS for inclusion in the program, based on the client’s objectives, risk tolerance and time horizon
as identified through their Investor Questionnaire. These Managed Allocation Recommendations represent a
series of portfolios with distinct risk and return profiles depending on the types of Sponsored Funds, including the
ratio of equity to fixed income funds, within the portfolio. These portfolios range from the most aggressive portfolios
(e.g., portfolios that include 100% in equity fund exposure) for those investors with longer time horizons and greater
risk tolerance to the most conservative portfolios (e.g., portfolios that include 0% in equity fund exposure) for those
investors with near-term liquidity needs.

The Managed Allocation Recommendations are generated through a proprietary investment model developed and
maintained by the Janus Henderson Multi-Asset team within the Solutions Group (the “Model”). Underlying the
Model is long-term strategic asset allocation process (“SAA”). The SAA process creates the foundations of a
diversified portfolio, identifies secular opportunities and risks, and aligns the risk and return expectations with the
longer-term objectives.

Layering onto the SAA, the tactical asset allocation (“TAA”) process adds flexibility and responsiveness. The TAA
process involves identification of the main decision-making frameworks and the associated macroeconomic and
market indicators, characterization of the current overarching regime that defines inter-asset class relationships
and broad valuation levels, and definition of several top-level themes that are driving asset class behavior and a
set of investment views driven by each theme.

The SAA and TAA processes define the broad market exposures to be taken. The team then translates the SAA
and TAA results into the actual individual Sponsored Fund positions which are represented in the Model, using a
proprietary fund optimization solution. In general, all Sponsored Funds with D Share Classes other than allocation
funds may potentially be considered for inclusion. The Model, including its target allocations under different
circumstances, is reviewed and adjusted from time to time in line with changes to the SAA and TAA. The changes
to the Model may include adjusting eligible Sponsored Funds as well as weights among those funds, which could
include addition or removal of asset classes or sub-classes where appropriate. Any changes to the Model will be
made effective as to clients in the Active Advice Program but not clients in the Snapshot Advice Program who
would need to seek another Snapshot Investment Recommendation.

While the application of the Model results in tailored investment advice, it is only tailored to the investment
objective, risk tolerance and time horizon yielded by the Investor Questionnaire. It does not provide fully bespoke
or personalized investment advice to clients (e.g., considering non-financial assets or financial assets held with
other institutions or in other account types) and does not incorporate any tax considerations or reflect any tax
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