Putnam Investment Management LLC

Item 5: Fees and Compensation
      Putnam’s management fees are set forth in the client’s investment management agreement. Putnam generally
      charges management fees to its discretionary account clients in accordance with its standard fee schedules in
      effect when the management agreement is signed. Management fees are negotiated with some clients, so fees
      vary from the standard schedules. Other investment advisers may charge higher or lower fees for comparable
      services than Putnam charges.

      Generally, PIM’s fund clients pay management fees to PIM out of fund assets. For separate account clients,
      fees are billed to the client and are payable quarterly in arrears. Putnam does not require prepayment of
      management fees.

      Putnam must comply with SEC rules about “custody” of client assets (which can include automatic billing
      arrangements). Clients other than registered investment companies who prefer that Putnam deduct fees
      directly from their account will be required to make specific arrangements with a qualified custodian and to
      provide Putnam with additional information (including confirmation that the custodian provides the client with
      required account statements).

      Except with respect to the Putnam Funds, fees, minimum account sizes, and fee breakpoints may be negotiated
      or modified in Putnam’s discretion based on factors such as asset class, pre-existing fee schedules, account
      size and overall size of the client relationship, , the client’s status as a “founder” or early investor in a given
      strategy or pooled vehicle, portfolio complexity and customization requests (such as specific investment
      restrictions requested by the client that cause the account to differ from similar accounts managed at Putnam),
      service requirements (such as non-standard reporting and information requests), the country or market in
      which a client is located, affiliate status, or other factors. Putnam sometimes also chooses to waive all or a
      portion of negotiated fees for a period.

      While we act as a fiduciary in managing client assets, not all our business decisions are fiduciary decisions.
      Subject to applicable law and any contractual commitments, we may choose to charge different fees or
      otherwise offer different levels of service to different clients for the same fee, depending on our own business
      needs and market demands.

      Putnam Fund Fees

      PIM's fees under its investment management agreements with respect to the Putnam Funds (and, where
      required by SEC rules, other registered investment company clients) are shown in the funds’ registration
      statements, on file with the SEC.

      First, a separate account client arranges for custody, recordkeeping and other service providers for its
      portfolio on its own (and pays for these services separately). In contrast, Putnam Funds hire their own
      service providers and pay the related operating costs. Depending on the fund and account documentation,
      in some cases, Putnam bears some or all of these expenses. For details, please refer to the specific funds
      or portfolio’s offering documents.

      In addition, the management fees on a fund may also differ from the fees for similar separate accounts
      depending, for example, on the specific services provided and Putnam’s related costs.

      SMA Programs

      With respect to Accounts for which PIM serves as a sub-adviser through an SMA Program, the timing of fee
      payments will be negotiated with each client or the SMA Program sponsor. See the SMA Program Brochure,
      which is available upon request, for more information regarding fees and compensation with respect to SMA
      Programs.

7   Putnam Investment Management,

      Performance Fees

      Some Putnam clients, including some investment funds, pay performance-based fees. For more information
      on these fees, please read Item 6 of this brochure.

      Non-Discretionary Advice

      In addition to discretionary asset management, Putnam may sometimes agree to provide non-discretionary
      advice for a specific client portfolio in a particular asset class. Putnam does not act as general investment
      counsel for these accounts, but instead makes specific, security-level recommendations for the client to
      implement in its discretion. The fees for these services, or for any additional services such as unusual reporting
      needs or other client-specific requirements, are determined on a case-by-case basis.

      Account Termination

      The terms and conditions of PIM’s services are specified in the investment management agreement between
      PIM and the client. The management agreement generally allows either the client or PIM to terminate it at any
      time on written notice (typically, of not less than 60 days).

      Other Third-Party Fees and Expenses

      In addition to the fees described above, clients of the Putnam Advisers typically bear other costs associated with
      their accounts or portfolio investments. Depending on the type of investment account, vehicle or product
      that a client is invested in these costs and expenses may include, but are not limited to: (i) custodial charges,
      brokerage fees/costs, commissions, other transaction costs and related costs, certain consulting fees, auditing
      fees, and transfer agency fees, (ii) interest expenses, (iii) taxes, duties and other governmental charges
      (including regulatory, licensing and filing expenses and fees, costs and expenses for preparation therefor), (iv)
      transfer and registration fees or similar expenses, (v) costs associated with foreign exchange transactions, (vi)
      other portfolio expenses (including, without limitation, research, risk modelling and software expenses), (vii)
...

Item 7: Types of Clients
       PIM primarily manages the Putnam Funds. PIM also sub-advises other financial firms’ registered investment
       companies and offers its advisory services to a wide variety of other institutional clients. Effective January 1,
       2025, PIM also provides investment advisory services to individuals through its affiliate FTPPG, as described in
       FAV’s SMA Program Brochure, which is available upon request. PIM generally requires an institutional separate
       account, at or shortly after commencement, to have, depending on the product, minimum assets ranging from
       $25 million to $100 million. Exceptions to account minimums may be made in some cases.