Collection and Use of Client Information AMG Funds LLC and its affiliated businesses, AMG Distributors, Inc. and The AMG Funds Complex, (collectively, “AMG Funds” or “We”) collect only relevant information about our clients that the law allows or requires us to have in order to conduct our business and properly service our accounts. We collect financial and other nonpublic personal information about our clients from the following sources: Directly provided by our clients from investment management contracts and other forms; and Information provided to us by authorized parties acting on behalf of our clients such as accountants, attorneys and investment consultants. Keeping Information Secure AMG Funds maintains physical, electronic and procedural safeguards and procedures to protect your financial and other nonpublic personal information, and AMG Funds continuously strives to improve these safeguards and procedures. Limiting Access to Information All of AMG Funds’ employees are aware of the importance of maintaining and respecting customer privacy and of the importance of confidentiality. Violations of AMG Funds’ privacy policies may result in disciplinary action. Accuracy of Information AMG Funds strives to keep accurate client information records, and AMG Funds takes steps to correct errors as they are found. If there are any inaccuracies in your account statements or in any other communications from AMG Funds, please contact us immediately and the necessary corrections will be made. Use of Personal and Financial Information by Us and Third Parties Information about AMG Funds’ clients that is in the firm’s possession is shared with non-affiliated third parties only to the extent necessary for AMG Funds to provide the services for which our clients have hired us, and then only to the extent permitted by law. AMG Funds typically does not share nonpublic client information with unaffiliated third parties other than as necessary to carry out the actual performance of the investment management services it has been hired to provide. Thus, for example, AMG Funds will share nonpublic client information with brokers and custodian banks in order to buy and sell securities and record those purchases and sales accurately. AMG Funds may also use such information in the account intake process, which typically includes conducting anti-money laundering screening. As a general rule, AMG Funds does not engage in joint marketing arrangements with unaffiliated third parties that involve the sharing of nonpublic information regarding AMG Funds’ clients, nor does it sell client information to unaffiliated third parties for their own marketing purposes. Any exceptions to these practices are made only with the permission of the particular client for the sharing of information with identified third parties or as otherwise required by law. As an affiliate of Affiliated Managers Group, Inc. (AMG), AMG Funds also shares with AMG (and certain authorized AMG Affiliates, as applicable) information about AMG Funds’ experiences or transactions with customers or their accounts. AMG and the AMG Affiliates abide by a “No Share” policy whereby this information is not shared with unaffiliated third parties. In certain situations where information is being shared with an AMG Affiliate, AMG Funds has either a “Limited Authorization Form” in place or confidentiality agreements to cover any access to information and limits the sharing of information to that which is referenced in these agreements. Maintaining Customer Privacy in Business Relationships AMG Funds does not share client information with anyone who does not agree to keep such information confidential. If you believe AMG Funds has shared your information inappropriately or if you have questions concerning our policy, please contact AMG Funds’ Compliance Department at (203) 299-3500, or write to: AMG Funds LLC 680 Washington Blvd Suite 500 Stamford, CT 06901 Attn: Compliance Department Privacy Policy Concerning Other Persons During the routine course of business, AMG Funds may also obtain nonpublic personal information from persons other than customers. AMG Funds’ policy is to protect such nonpublic personal information by employing physical, electronic and information destruction safeguards. AMG Funds limits access to such nonpublic personal information, including social security numbers, to only those individuals who need such information to execute their employment duties or to comply with applicable law or regulation. Any other use, access or distribution of nonpublic personal information obtained by AMG Funds is prohibited. Privacy Notice (Non-U.S.) Effective Date: January 3, 2025 Background This privacy notice (“Non-U.S. Privacy Notice”) describes how Affiliated Managers Group, Inc. (“AMG,” “we,” “our,” or “us”) collects and uses personal data covered by the European Union’s General Data Protection Regulation 2016/679 (the “EU GDPR”) and the EU GDPR as it forms part of the law of England, Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 as amended by Schedule 1 to the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (the “UK GDPR”) (“Personal Data”). AMG is committed to protecting the privacy of the individuals whose Personal Data it processes, and this Non-U.S. Privacy Notice describes how AMG will collect, use, and otherwise process such Personal Data. Personal Data may be collected or received by AMG or by our global capital formation team (each an “AMG Company” and, together with AMG, the “AMG Group”) through any of the additional entities listed below: Affiliated Managers Group (Asia) Limited (“AMG Asia”) Affiliated Managers Group Korea LLC (“AMG Korea”) Affiliated Managers Group Limited (“AMG UK”) AMG Distributors, Inc. (“AMG Distributors”) AMG Funds LLC (“AMG Funds”) AMG Limited (DIFC Representative Office) (“AMG Dubai”) References to AMG throughout this Non-U.S. Privacy Notice should be understood to reference the AMG entity that collected, or was provided with, your Personal Data. 1. Collection and Use of Personal Data Who we collect Personal Data about AMG may collect Personal Data of current or prospective clients of our Affiliates, through marketing and distribution activities. Where clients are businesses, we may collect Personal Data about the employees or representatives of those businesses for these purposes. We may also collect relevant Personal Data of employees of Affiliates, and from visitors to our website. How we use and share Personal Data We may collect, store and use Personal Data in order to conduct our business and provide support to the business activities of our Affiliates. Due to the global nature of our business, we may share Personal Data among the AMG Group and with our Affiliates. Personal Data of Affiliates’ clients may be shared among the entities in the AMG Group, in connection with marketing activities, or to support strategic business opportunities for our Affiliates. Similarly, Personal Data may be shared with third parties who provide professional services to us, such as technology companies who support our computer systems, or to our external auditors or other professional consultants. We may process Personal Data or make disclosures to third parties or government agencies as required by law, for example, in support of our anti-money laundering (“AML”) controls. As part of our commitment to confidentiality, we do not share confidential information of employees or partners at our Affiliates, or potential Affiliates, with other Affiliates. How we collect Personal Data AMG may collect Personal Data from general business and marketing activities with Affiliate clients, as part of investment due diligence processes, or from our Affiliates (including in investment agreements). AMG may also collect Personal Data from authorised third parties acting on behalf of our Affiliates, such as accountants, attorneys and consultants. The Personal Data we collect The Personal Data we may collect directly from Affiliates’ clients is generally limited to contact information. From time to time, we may also collect incidental health or family information for relationship management purposes. The types of Personal Data we collect (directly or indirectly) from Affiliates or their authorised agents may include contact information, financial information and, in certain cases, health information and background check information. The types of Personal Data we may receive when you visit the AMG website may include contact information and professional or employment-related information. For example, when you use the “Contact AMG” page to submit an enquiry or to join our shareholder distribution list, we collect Personal Data, including your name, email address, telephone number, and company name. We also automatically collect certain internet or other electronic network activity information related to your use of the website, such as IP address, web browser, operating system, internet service provider, the pages visited, time and date of visit, and geolocation information. Please see Section 3 below for more detail. You may be requested to provide some or all of the Personal Data referred to above. If you fail to provide this Personal Data when requested, and it is necessary for AMG to comply with its legal or contractual obligations, we may not be able to manage our relationship with you. In all other cases, the provision of Personal Data is voluntary. Our lawful bases for using Personal Data We may collect and process Personal Data for our legitimate interests or the legitimate interests of our Affiliates, and third parties to whom we transfer your Personal Data (provided that such legitimate interests are not overridden by your interests or your fundamental rights and freedoms). Our legitimate interests for processing Personal Data include: enabling collaboration within the AMG Group and with our Affiliates; ensuring business continuity within the AMG Group and with our Affiliates; improving the quality of the services of the AMG Group and of our Affiliates; performing investment related due diligence in connection with potential new investments; ensuring that the AMG Group and our Affiliates comply with applicable laws; enabling the AMG Group and our Affiliates to exercise and defend legal claims; and ensuring the AMG Group and our Affiliates comply with requests from governmental, quasi-governmental and judicial bodies and regulators for information relating to its business. AMG may also receive and process Personal Data in connection with the performance of a contract, or in order to take steps before entering into that contract, to comply with our legal obligations, or for the establishment, exercise or defence of legal claims. 2. International Transfers of Personal Data The sharing of Personal Data may require the transfer of the data by AMG Companies in the European Economic Area (“EEA”) or the United Kingdom (“UK”) outside the EEA and the UK, including to AMG Companies in the United States and the Dubai International Finance Centre, as well as Affiliates in the Channel Islands, the United States, Canada and Hong Kong, and to third party service providers in Switzerland, the United States, Hong Kong, Japan and the Dubai International Finance Centre. Of these countries, currently only the laws of the Channel Islands, Japan and Switzerland have been deemed by the European Commission and the Information Commissioner’s Office in the United Kingdom (“ICO”) to provide for an adequate level of protection of Personal Data (and the ICO’s adequacy finding about Japan is applicable to private sector organisations only). Nevertheless, AMG provides appropriate safeguards when transferring Personal Data outside the EEA or the UK, specifically on the basis of contracts with the recipients that include standard data protection clauses adopted by the European Commission (which can be found here) or the ICO (which can be found here), as appropriate, or by relying on one or more transfer derogations under the EU GDPR and the UK GDPR. You may obtain a copy of our standard data protection contracts by writing to AMG using the contact details provided in Section 7 below. 3. Cookies We and our service providers use cookies and other online tracking mechanisms to track information about your use of our website. Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website, while others allow us to track your activities while using our website. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. We use third-party web analytics services (such as those of Google Analytics) and other technologies on our website to collect and analyse usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognise or respond to browser-initiated DNT signals. 4. Keeping Information Secure and Limiting Access AMG has a formal information security program, designed to develop and maintain privacy and data security practices to protect company assets and sensitive third-party information (including Personal Data). We seek to protect against anticipated threats or hazards to the security or integrity of such information, and against unauthorised access to, or use of, Personal Data that creates a substantial risk of financial loss, identity theft, fraud or reputational harm. Our information security protocols comprise internal and external resources designed to identify, protect, detect, resolve, and recover from various threats and attacks of malicious actors. We have documented strategies, policies and procedures in place to protect employee, business, and client data (including Personal Data) in the event of an emergency or natural disaster. We also have a documented incident response plan, with defined roles and responsibilities that address notification obligations and procedures in the event of a data breach. 5. Retention of Personal Data The length of time that we may hold Personal Data will vary, depending on the purpose for which we are using it and any applicable legal obligations in the relevant various jurisdictions. We periodically review the Personal Data that we hold to verify whether it is still required. We will not retain your Personal Data for longer than is necessary for the purposes set out above and we will destroy it, or erase it from our systems, when it is no longer required for those purposes, provided that we may retain your Personal Data in order to comply with applicable laws, rules and regulations. 6. Your Rights Depending on your residence, you may have various rights under data protection laws regarding the processing of your Personal Data, including: The right of access – Upon request, you may be entitled to access a copy of your Personal Data held by us and to be provided with information in relation to that Personal Data. The right to rectification – Upon request, you may be entitled to have inaccurate Personal Data amended or erased, and to have incomplete Personal Data completed. We encourage you to contact us if you believe there are any inaccuracies in any communications to you, so that we may promptly make any necessary corrections. The right to erasure (‘right to be forgotten’) – You have the right to request that we delete your Personal Data, such as where we no longer require your information or no longer have a lawful basis for processing it. However, there are circumstances where we may not be able to respond to your request, such as another overriding regulatory or legal obligation (such as AML obligations). The right to restrict processing – In certain circumstances, you may request that processing of your Personal Data be restricted. For example, where the accuracy is contested, you may request a restriction until we verify the data. The right to object – In certain circumstances, you have the right to object to us processing your Personal Data (such as where our processing is on the basis of our legitimate interests and/or where we process for direct marketing purposes). In these circumstances, we will terminate: (a) all processing for direct marketing purposes; and (b) processing on the basis of our legitimate interests if we cannot demonstrate that there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or that the processing is undertaken for the establishment, exercise or defence of legal claims. The right to portability – Where we are processing your Personal Data on the basis of consent or a contract with you, and we are carrying out the processing by automated means, you have the right to request a copy of your Personal Data in a machine-readable format and/or for us to transfer your Personal Data to another data controller. You may exercise these rights by submitting a request via email or in writing using the AMG contact details provided in Section 7 below. You also have the right to lodge a complaint with us (using the AMG contact details provided in Section 7), and with a supervisory authority such as the ICO using the following details: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://ico.org.uk 7. Contact Information If you have any questions concerning this notice, please contact Leena Kerai (AMG Data Protection Specialist) at +44 20 7290 6817, via email at dataprivacy@amg.com, or in writing at Affiliated Managers Group Limited, 35 Park Lane, London W1K 1RB.