Separately Managed Accounts

Disclosure:

BNY Mellon Investment Management is one of the world's leading investment management organizations, encompassing BNY Mellon's affiliated investment management firms and global distribution companies. BNY Mellon is the corporate brand of The Bank of New York Mellon Corporation and may also be used as a generic term to reference the corporation as a whole or its various subsidiaries generally. BNY Mellon Securities Corporation (“BNYMSC”) and Newton Investment Management North America LLC (“Newton North America”) are the investment managers of record with respect to the BNY Mellon SMA strategies described above. Additionally, Newton North America and Walter Scott & Partners Limited (“Walter Scott”) provide certain investment advisory services to BNYMSC in instances where BNYMSC is the investment manager of record. BNYMSC, Newton North America and Walter Scott are registered investment advisers and BNY Mellon Investment Management companies.

"Newton" and/or the "Newton Investment Management" brand refers to the following group of affiliated companies: Newton Investment Management Limited (NIM) and Newton Investment Management North America LLC (NIMNA). NIM is incorporated in the United Kingdom (Registered in England no. 1371973) and is authorized and regulated by the Financial Conduct Authority in the conduct of investment business. Both Newton firms are registered with the Securities and Exchange Commission (SEC) in the United States of America as an investment adviser under the Investment Advisers Act of 1940. Newton is a subsidiary of The Bank of New York Mellon Corporation. Newton's investment advisory businesses are described in their Form ADVs, Part 1 and 2, which can be obtained from the SEC.gov website or obtained upon request.

Fayez Sarofim & Co. (“Sarofim”) is an SEC-registered investment adviser and a wholly owned subsidiary of The Sarofim Group, Inc. Sarofim, among other services, provides advisory services for equity portfolios under various agreements related to wrap-fee programs, and is introduced to wrap-fee program sponsors primarily through the efforts of BNYMSC under the terms of a solicitation agreement between Sarofim and BNYMSC. With respect to such wrap-fee programs, BNYMSC acts as the account administrator and serves as the liaison between Sarofim and the program sponsors and the program sponsors’ clients, and receives in consequence a portion of the fee charged by the program sponsor for its account administration services. BNYMSC plays a similar role with respect to the UMA programs for which Sarofim provides investment management or supervisory services. For such UMA programs, BNYMSC functions on behalf of Sarofim as the primary administrative contact with program sponsors and acts as account administrator, and receives in consequence a portion of the fee charged by the program sponsor for providing such services. In addition to such administrative services, BNYMSC provides certain promotional and marketing services on behalf of Sarofim.

Sarofim is an independent firm, and not affiliated with BNYMSC or BNY Mellon.

Not all strategies listed may be available at all participating firms.

MARK-210218-2021-08-25