Royce & Associates LP

Item 5. Fees and Compensation
Investment Company and Collective Investment Trust Accounts
Royce is generally entitled to receive fees that are payable as of the end of each month or quarter, as applicable, for the
investment advisory services it provides to U.S. registered management investment companies, collective investment
trusts, and a non-U.S. investment company under compensation formulas ranging from 0.5% up to 1.5% per year of their
respective average net assets. For two of the closed-end U.S. registered management investment companies, these fees
are subject to upward or downward adjustments of up to 0.5% per year based on the investment performance of such
investment companies relative to the investment record of a specific equity index.

Royce also serves as sub-investment manager to various non-U.S. investment companies for which an affiliated entity
serves as investment manager. Such affiliated investment manager: (i) receives an advisory fee as of the end of each
month or quarter, as applicable, from the relevant non-U.S. investment company based on such non-U.S. investment
company’s net assets and the applicable per annum fee rate; and (ii) allocates a portion of such advisory fee to Royce
as a subadvisory fee in accordance with the terms of the Sub-Adviser Agreement between such affiliated investment
manager and Royce.

Royce typically bills investment company and collective investment trust accounts on a monthly or quarterly basis in
arrears, consistent with each fund’s investment advisory agreement.

Limited Liability Company and Institutional Separate Accounts
These privately offered accounts usually compensate Royce for its investment advisory services at the end of each
month or quarter and the compensation may be payable in advance or in arrears. The amount of the compensation is
generally based on the market value of each account’s net assets at the end of the month or quarter. The investment
advisory agreements for accounts that compensate Royce in advance on a quarterly basis may be terminated through
written notice to Royce in accordance with the terms of such agreements. If Royce stops managing the relevant
account before the end of a calendar quarter, Royce will refund a prorated portion of the advisory fee for the period
in which it was not managing the account. Royce does not have a basic investment advisory fee schedule for its
privately offered accounts; its investment advisory fees for such accounts are generally negotiable and set forth in the
applicable investment advisory agreement.

Non-Discretionary Model Portfolio Delivery Arrangements
As noted above under “Item 4 − Advisory Business,” Royce provides model portfolios to certain investment advisers
or other financial services providers. When doing so, Royce is compensated through a contractually agreed-upon
fee schedule. The fee schedules and arrangements with these firms vary depending on several factors. These
factors include, but are not limited to, the amount of assets under advisement, client servicing requirements,
client type, and the investment strategy for which investment management or advisory services are provided.

Retail Separately Managed Accounts for Which Royce Serves as Subadviser to Franklin Templeton Private Portfolio
Group. For a description of the fees paid in connection with various types of retail separately managed accounts for
which Royce serves as subadviser to FTPPG, including those paid to Royce, please see “Item 5 – Fees and
Compensation” of the Combined Brochure.

Other Fees and Expenses
Accounts for which Royce provides investment advisory services, including SMA programs in which Royce participates
as subadviser to FTPPG and managed accounts, pooled investment vehicles, and/or other financial products for which
Royce provides non-discretionary model portfolios to certain investment advisers or other financial services providers,
may be subject to other fees and expenses in addition to the investment advisory or subadvisory fees referenced above.
Such fees and expenses may include (without limitation):
    •   investment advisory, custody fees, administration fees, and all other fees charged by service providers providing
        services related to such an account that are levied by the relevant investment adviser, financial service provider,
        custodian, administrator, or other service providers for such account, including fees for security transfers and
        wire transfers;
    •   legal, tax, bookkeeping, and accounting expenses, including expenses for preparation of annual audited financial
        statements, tax return preparation, routine tax and legal advice, and legal costs and expenses associated with
        indemnity, litigation, claims, and settlements;
    •   brokerage commissions, mark-ups, mark-downs, and other commission equivalents as well as spreads and/or
        transaction costs related to transactions effected for such accounts (please also see the section entitled
        “Brokerage Practices” in this Advisory Brochure for more information regarding these practices);
    •   insurance and fidelity bonding premiums (which premiums may cover numerous accounts, in which case
        participating accounts may be responsible for a share of such premiums);
    •   professional fees;
    •   SEC fees, transfer taxes, other governmental charges based on securities transactions, or other taxes (other than
        income taxes);
    •   acquired fund fees and expenses (e.g., investment advisory fees and other expenses of any pooled investment
        vehicle in which a client account invests);
    •   expenses related to the preparation and distribution of reports and notices to investors;

    •   fees and expenses related to the organization, offering of interests, and/or registration of such account;
    •   vendor charges and out-of-pocket expenses charged in connection with SMA programs; and
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Item 7. Types of Clients
As of September 30, 2025, Royce offered investment advisory services to U.S. registered investment companies, non-
U.S. investment companies, three collective investment trusts, a series of a privately offered limited liability company,
and two institutional separate accounts managed for charitable organizations. Generally, Royce has not accepted
institutional separate accounts with assets of less than $10 million.

Through its subadvisory relationship with FTPPG, Royce also provides discretionary or non-discretionary investment
advisory services through participation in SMA programs. For a description of the clients for these products, please
see “Item 7 – Types of Clients” of the Combined Brochure.

Royce also provides model portfolios to certain investment advisers or other financial services providers. Because
Royce does not have investment discretion or trading discretion in connection with the relevant non-discretionary
model portfolio delivery arrangements, Royce does not consider itself to have an investment advisory relationship
with the clients of the relevant investment advisers or other financial services providers.

Item 8. Method of Analysis, Investment Strategies and Risk of Loss
Method of Analysis for All Royce Client Accounts
Royce uses various methods primarily rooted in the valuation of each stock and an evaluation of each company in
managing client accounts. Royce’s security selection process puts primary emphasis on the quality of a company’s
balance sheet and other measures of a company’s financial condition and profitability, such as the history and/or
potential for improvement in cash flow generation, internal rates of return, and sustainable earnings. Royce may also
consider other factors, such as a company’s unrecognized asset values, its future growth prospects, or its turnaround
potential following an earnings disappointment or other business difficulties. As part of its investment research
process, Royce may meet with management of companies in which it has invested or in which Royce is considering an
investment. These meetings may be organized by Royce directly or by a third party, such as an investment research
provider. Depending on the venue and context, other parties, often including other investment firms, may be present
in these meetings. While having multiple points of view present can make the meeting more valuable to participants
and more efficient for the companies involved, Royce also recognizes the need in those circumstances to take steps
to protect the confidentiality of its investment deliberations and decisions. Royce’s policies and procedures prohibit
Royce’s officers, Board members, and employees from disclosing any non-public information relating to Royce or its
securities transactions, or plans regarding future securities transactions, to any person outside Royce. These policies
and procedures also include specific requirements for managing information transmission risks associated with sharing
office space on the same floor with certain affiliated investment advisers.

For certain client accounts, or segments within client accounts, Royce may also select some portfolio securities using
a proprietary investment model, which employs quantitative factors similar to those used by Royce in its other
accounts to take long positions and to determine when to sell the long positions. These proprietary investment models
are refined/adjusted from time to time.

Environmental, social, and governance (“ESG”) factors may have a material impact on the business risk and financial
performance of portfolio companies held by Royce client accounts. Royce seeks to ensure, to the extent applicable,
that material ESG factors are incorporated as inputs to the investment analysis of such portfolio companies. Royce
defines material ESG factors as those that it believes may impact a portfolio company’s cash flows, balance sheet,

reputation, and/ or enterprise value. Each investment strategy used in connection with Royce client accounts, other
than the Royce ETF (which does not integrate an assessment of ESG risks and opportunities as an input to its
investment process), has its own customized ESG due diligence framework that focuses on the ESG factors Royce
investment staff members believe to be most material to their respective investment processes. Materiality is the core
principle of Royce’s approach to ESG integration, as particular factors may or may not be meaningful to different
business models, industries, and regions. No assurance can be given that ESG factors will, in fact, contribute to the
long-term investment performance of any particular portfolio company or that Royce’s assessment of material ESG
factors in respect of any particular portfolio company will be correct.

Evaluation of what Royce believes to be material ESG risks is only one component of Royce’s assessment of a potential
investment by a Royce client account and, as with its consideration of other factors and risks, may not be a
determinative factor in any instruction or recommendation to purchase, sell, or hold a security. In addition, where
such material ESG factors are considered, the importance given to such ESG factors may vary across Royce investment
staff members and accounts to which they are assigned and across different types of investments, sectors, industries,
regions, and issuers. The ESG factors considered, and the importance placed upon each of those factors, may or may
not change over time. Royce will not assess every investment by a Royce client account for ESG factors and when it
does, not every ESG factor may be identified or evaluated. The assessment of ESG-related risk(s) for a portfolio
company by Royce investment staff members also may vary across the various accounts to which they are assigned,
even if such accounts employ identical or substantially similar ESG integration approaches. Royce investment staff
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