Legal & General Investment Management America Inc

Item 5 – Fees and Compensation

A. How we are compensated for Advisory Services

We determine a client’s management fees based primarily on the client’s chosen investment strategy,
factoring in any unique servicing arrangements or facts and circumstances for that particular client.
Clients are primarily subject to a fee expressed as a percentage of the total value of the assets we
manage (a “Management Fee”), generally determined at the end of each month or quarter, as well as
annual minimum fee amounts. We offer customized fee arrangements, such as Management Fees based
on total notional exposure (rather than net asset value) for accounts that engage in derivatives trading.
Management Fees for Private Credit or Real Estate Equity strategies in certain cases are calculated on
an investor’s committed capital.

Certain Index Plus offerings are also subject to a performance-based fee (a “Performance Fee”) when
these funds or accounts outperform the applicable index on terms set forth in the offering document or
IMA for that product. Performance Fees are typically only charged on the portion of the return that
outperformed the applicable index (the “Excess Return”) over one year, or from the date of the last
Performance Fee to the time of a withdrawal (each, the “Performance Period”). Performance Fees will
not be charged if the product underperforms compared to the applicable index during the Performance
Period, and the client will generally receive a credit for loss carry-forward applied to the Performance Fee
of the next Performance Period. However, because the Performance Fee is determined based upon the
product outperforming the applicable index for any Performance Period, it is possible that we will receive
a Performance Fee even if there is negative investment performance for the product over the
Performance Period.

In a few limited cases we have agreed to performance-based compensation for SMA clients in strategies
other than Index Plus.

Our fees for managing SMAs are agreed with clients and determined through good faith negotiations and
are then set forth in the client’s IMA. Clients who invest in an LGIMA Fund pursuant to their IMA may pay
us a single Management Fee and have fees waived at the fund level. With respect to LGIMA Funds, the
applicable Management Fee, Performance Fee and expenses are set forth in the LGIMA Fund’s offering
documents, operating agreement or other governing documents. In certain cases, we may manage an
SMA with a similar investment mandate to a LGIMA Fund, in which case fees charged to such account
are not necessarily identical to those of the similar LGIMA Fund.

L&G – Asset Management, America            71 South Wacker Drive, Suite 800 | Chicago, IL 60606 | am.landg.us.com

March 2026 - Form ADV Part 2A Brochure                                                                          7

Our current Management Fee rate ranges for each strategy are as follows (expressed as basis points of
assets under management or, in the case of certain derivatives overlay accounts, gross notional
exposure):

       •   Active Fixed Income: 0 – 70
       •   LDI and Fixed Income Solutions: 0 – 40
       •   Equity Solutions: 0 – 50
       •   Private Credit: 0 – 50
       •   Real Estate Equity: 0 – 500

For Index Plus strategies, performance fees are negotiable and vary by each fund’s offering document
or IMA and may be up to 25% of the Excess Return.

Fees are subject to negotiation on a case-by-case basis and vary by client. Clients in LGIMA Funds may
agree to different fees than are stated in the fund’s offering documents via side letters. Fee arrangements
are based on a variety of factors to ensure the Management Fee is reasonable and commensurate with
the services received by a client, including but not limited to: expected risk and performance of the
investment strategy; the complexity of the mandate and estimated resources needed to provide related
services; and the investor’s total investment size across the Firm and with affiliates; the total investment
size of accounts that are aggregated because their investors are affiliated, use the same consultant or
OCIO, or otherwise share group bargaining power. We have entered into arrangements or agreements
with certain investors granting them preferential fee terms, including limits on aggregate fees charged. In
addition, we charge reduced or no fees to our affiliates.

Due to the foregoing, similarly-situated clients at times will pay different fees for comparable advisory
services. We are generally not obligated to disclose fee arrangements to other clients or obtain their
approval before entering into any special fee arrangement. However, we will not enter into a special fee
arrangement that could have a material adverse effect on other clients of the Firm. To ensure that this
conflict is appropriately mitigated, we have a Pricing Committee comprised of certain executive officers
to ensure all opportunities are fairly and competitively priced.

B. Payment of Fees

Fees are generally payable monthly or quarterly in arrears, pursuant to the terms of the IMA, side letter,
offering document or other fee agreement, as applicable. SMA clients are billed outside of their accounts.
Investors in LGIMA Funds may have their fees deducted from their accounts at the fund level or billed
outside of the LGIMA Fund in certain circumstances. Where an SMA invests in an LGIMA Fund, the client
and the Firm may agree that aggregate fees will be charged at the SMA level only, or vice versa.

In instances where we utilize affiliates for all or a portion of a mandate via a participating affiliate
agreement, we share with the affiliate a portion of the fee that the client pays to us. Similarly, in instances
where one of our affiliates sub-delegates the management of assets to us, we will receive the portion of
the fees applicable to our services from our affiliate, rather than directly from the client.

C. Expenses that Clients Pay
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Item 7 – Types of Clients

A. Clients

As discussed in Item 4 “Advisory Business” above, we offer our services to (1) institutional clients through
separately manged accounts, (2) the LGIMA Funds and other single-investor or commingled investment
vehicles for which we serve as investment adviser or sub-adviser, (3) third party registered investment
companies, and (4) other affiliated and unaffiliated investment advisers, including OCIOs.

Our clients include, but are not limited to: U.S. and non-U.S. affiliated and unaffiliated public and private
pension plans and pension funds, certain of which are subject to ERISA; other employee benefit plans;
insurance companies; Taft-Hartley plans; registered investment companies; sovereign wealth funds;
corporations, including healthcare organizations; trusts; banks; charitable organizations; foundations;
endowments; and other business entities.

We maintain relationships with OCIOs and third-party consultants who recommend us to their clients. We
do not compensate any OCIO or consultant for such recommendations. However, clients of such OCIOs
or consultants may be aggregated for purposes of fee rate negotiations, as they share group bargaining
power. We have a Pricing Committee that reviews all such pricing decisions and associated conflicts of
interest.

L&G – Asset Management, America            71 South Wacker Drive, Suite 800 | Chicago, IL 60606 | am.landg.us.com

March 2026 - Form ADV Part 2A Brochure                                                                        10

B. ERISA Clients

We provide investment management services to clients that are employee benefit plans covered by
ERISA. For ERISA clients, the Firm is usually a “covered service provider” to the plan for purposes of
ERISA Section 408(b)(2). We provide services to ERISA plans both as a registered investment adviser
under the Advisers Act and as a fiduciary within the meaning of ERISA Section 3(21). When providing
discretionary investment management services to ERISA plans, we also serve as an investment manager
as defined in ERISA Section 3(38). In addition to providing services to ERISA SMA clients, we may serve
as an ERISA fiduciary to plans whose assets we manage through certain LGIMA Funds whose assets
are treated as plan assets under ERISA.

C. Registered Investment Companies

We serve as sub-adviser for a variety of U.S. registered investment companies advised by unaffiliated
investment advisers (collectively, “Sub-Advised Mutual Funds”). We are not involved in the operation or
distribution of these Sub-Advised Mutual Funds and our responsibility is limited to the portion of such
funds for which we serve as sub-adviser. Further information regarding our role in the Sub-Advised
Mutual Funds can be found in the relevant disclosure documents and registration statements thereof.

D. Private Funds

We offer, and may offer in the future, Private Funds with a variety of strategies, including but not limited
to, Passive Index, Index Plus, active fixed income, private credit and real estate equity. Our Private Funds
are generally organized as US limited liability companies or limited partnerships and are exempt from
registration as investment companies in reliance on Section 3(c)(7) of the Company Act and from
registration as a commodity pool under CFTC Rule 4.13(a)(3) or CFTC 4.7. For the Private Funds, each
U.S. investor must, among other things, be an “accredited investor” as defined in Regulation D under the
U.S. Securities Act of 1933, as amended (the “Securities Act”), and a “qualified purchaser” under Section
2(a)(51) of the Company Act; and each non-U.S. investor must not be a “U.S. person” as defined in
Regulation S under the Securities Act. For the avoidance of doubt, in the absence of a separate advisory
relationship with the Firm, an investor in a Private Fund is not an advisory client of the Firm. Investment
advice is provided directly to the LGIMA Funds and not individually to the LGIMA Fund investors.

Interests in our Private Funds are sold in reliance on Rule 506 under Regulation D of the Securities Act.
Each Private Fund is managed in accordance with its investment objective and generally not customized
to the individual needs of any particular investor in the relevant Private Fund unless established as a
single investor fund. Investors should carefully review the relevant Private Fund’s offering materials,
such as the private placement memorandum, prospectus or similar offering document for complete
disclosures relating to the strategy, investment guidelines and unique risks of the product.

E. Other Pooled Investment Vehicles

We act as sub-adviser to a number of different types of U.S. and non-U.S. pooled investment vehicles,
including collective investment trust funds, which are bank-maintained trusts available only to certain U.S.
tax-exempt employee benefit plans, that are exempt from registration as investment companies in
reliance on Section 3(c)(11) of the Company Act. We also provide investment advice as a sub-adviser to
collective investment schemes in the United Kingdom, Luxembourg, and Ireland which are managed by
our affiliates, some of which are Undertakings for Collective Investments in Transferable Securities
(“UCITS”), SICAVs or ICAVs. These products are generally only open to non-U.S. investors.

L&G – Asset Management, America            71 South Wacker Drive, Suite 800 | Chicago, IL 60606 | am.landg.us.com

March 2026 - Form ADV Part 2A Brochure                                                                         11

F. Requirements for Opening and Maintaining Accounts

Certain products impose investor eligibility requirements, as noted above and as outline in each product’s
subscription documentation. In addition, SMAs are subject to minimum investment amounts depending
on the strategy to be employed. The minimum amount necessary to open an SMA varies by investment
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