DWS Investment Management Americas, Inc. (“DIMA”) is a registered investment adviser with the Securities and Exchange Commission and has offered its products and services to clients, across a range of asset classes and investing styles since its formation in 1984, although various predecessors have been registered with the Securities and Exchange Commission (“SEC”) since 1940. DIMA was part of the asset management division of Deutsche Bank AG, a publicly listed banking corporation organized under the laws of Germany. Deutsche Bank AG reorganized the asset management division into a separate financial services firm, DWS Group GmbH & Co. KGaA (“DWS KGaA”), a German partnership limited by shares. DWS KGaA is now a separate publicly listed financial services firm but remains an indirect majority-owned subsidiary of Deutsche Bank AG. On April 2, 2018, DIMA became an indirect subsidiary of DWS KGaA. DIMA is part of the global investment management business of DWS KGaA and its affiliates (“DWS”). This brochure, including any brochure supplement, is intended for DIMA’s direct advisory clients. Investors in any DIMA-advised fund should rely on the fund’s prospectus or offering materials, and may therefore refer to this brochure, or any brochure supplement, for informational purposes only. DIMA provides discretionary and non-discretionary investment advisory services to institutions, individuals and both private funds and registered investment companies. DIMA provides services to U.S. and non-U.S. clients. DIMA delivers certain model portfolios on a nondiscretionary basis to affiliated and unaffiliated wrap/separately managed account program sponsors who are themselves investment advisers (each such program sponsor, a “Sponsor,” and collectively, the “Sponsors”). Sponsors use non-discretionary model portfolios to assist in developing their own investment recommendations and managing their client accounts. DIMA may also execute securities transactions for affiliated Sponsors and such transactions will be treated as any other orders for purposes of DIMA’s order execution policies as set forth in Item 12, Brokerage Practices. DIMA also delivers certain model portfolios on a discretionary basis to clients of third party Sponsors where Sponsor has determined such program is appropriate. DIMA’s advisory services are tailored according to investment policies and guidelines that are either pre- established by their client or established at the inception of the adviser-client relationship (as amended from time to time) in cooperation with the client. These policies and guidelines, which may include client imposed restrictions on investing in certain securities or types of securities, assist DIMA in making investment decisions for the client, as well as cover matters such as the degree of risk that the client wishes to assume, and the types and amounts of securities to make up the portfolio. Private commingled funds and registered investment companies managed by DIMA are not tailored to address the specific investment objectives or circumstances of any individual investor. DIMA offers a wide degree of advisory services to clients, with capabilities of tailoring investment strategies to meet the individual needs of clients. To leverage the global capabilities of DWS, DIMA may bring together investment professionals throughout the platform to discuss and debate geographic markets, industry sectors, asset classes and investment styles. The outcome of these discussions and debates provide directional guidance to inform individual portfolio managers in implementing an investment strategy, including through the use of lead portfolios. DIMA offers advisory services focused on helping insurance companies, a segment of large institutional investors, customize their investment program to their unique objectives, needs and constraints. The ultimate goal is to partner with the insurance company client in developing customized investment policies and guidelines that serve as the basis for how DIMA manages their portfolio. Advisory services are performed in partnership with the client and include matters such as: asset liability management; liquidity planning; portfolio risk analyses; and strategic asset allocation that considers regulatory constraints, investment income goals and tax considerations. These services are performed at the overall client level and accordingly may include a variety of asset classes. However, insurance company clients are largely invested in fixed income and public equities. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 5 Wrap Products DIMA may, from time to time, provide investment advisory services for its municipal bond strategies through “wrap fee” programs. In traditional wrap fee programs, a client selects an investment adviser and/or broker- dealer (a “Wrap Sponsor”), which provides a bundle of services for a single fee. For example, for a wrap fee program in which DIMA participates, the Wrap Sponsor’s bundle of services would typically include the payment of DIMA’s investment advisory fee, ongoing monitoring and evaluation of DIMA’s performance, provision of periodic market commentaries prepared by DIMA, execution of the client’s portfolio transactions, and/or custodial services for the client’s assets. In some wrap fee programs, so-called “dual contract” programs, the client enters into both an investment management agreement with DIMA and a program agreement with the Wrap Sponsor. In a dual contract program, the investment management fee may not be included in the Wrap Sponsor’s bundled fee and, in those cases, the client pays the investment management fee directly to DIMA. The services provided by DIMA to wrap fee program accounts may differ from the services provided to its institutional separate accounts and funds, which do not participate in wrap fee programs. The municipal bond investment strategy DIMA uses in managing wrap fee program accounts is similar to the strategy offered to its other clients, but may involve fewer securities holdings due to smaller account sizes, and less ability for customization. In addition, DIMA typically will rely on the Wrap Sponsor to provide client portfolio reporting. In certain cases there may be limitations on the ability of DIMA in the ordinary course to communicate directly, on its own initiative, with wrap program clients, without going through the Wrap Sponsor. Also, DIMA may use Wrap Sponsor-gathered information to assess the suitability of its investment style to the individual needs and financial situation of a wrap account client. Accordingly, when participating in wrap account programs, the Wrap Sponsor is typically responsible for determining the suitability of the program, including DIMA and DIMA’s investment strategy, for the client. In certain programs, Wrap Sponsors may limit the information that is available to DIMA about the client, the client’s other investments or risk tolerance, and other information that would be relevant to determining whether the investment strategy or certain specific investments would be suitable for the client. In wrap account programs, DIMA has discretion to select broker-dealers, subject to its duty to seek best execution. Due to the nature of the municipal bond asset class, DIMA generally will execute transactions at financial institutions other than the Wrap Sponsor in its municipal bond strategy wrap accounts. Such transactions ordinarily occur at net prices, meaning that the broker-dealer’s charge for the trade is built into the security’s purchase or sale price and is ultimately borne by the client in addition to any charges for execution otherwise included in the Wrap Sponsor’s overall fee. Each client should evaluate whether particular wrap programs are suitable for his or her needs, including the fees charged and services provided. Depending upon the level of the wrap fee charged by a Wrap Sponsor, the amount of portfolio activity in a client’s account, the value of the custodial and other services that are provided under a wrap arrangement and other factors, a wrap fee client should consider whether the wrap fee would exceed the aggregate cost of such services if they were to be provided separately. Similarly, a non-wrap fee program client paying separate fees should consider whether the fees charged by different parties for custody, advisory services, portfolio management services, securities execution and other services would exceed the aggregate cost of such services if they were provided in a wrap fee arrangement. Some broker-dealers serving as custodian charge fees for settling transactions executed through other broker-dealers. Assets Under Management As of December 31, 2018, DIMA had discretionary assets under management of $176,864,146,306 USD and non-discretionary assets under management of $1,558,056,020 USD. Investment Capabilities Products listed below may be managed by DIMA either directly or through sub-advisory relationships with affiliated and non-affiliated entities. See Item 10 for information regarding certain DIMA arrangements with affiliates related to its advisory business. DIMA’s policies and practices can vary by strategy and/or product type. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 6 Principal investment strategies and products currently offered by DIMA include: Alternatives Fixed Income Equity Asset Allocation (Alternatives) Canada Fixed Income Emerging Markets Equity Commodities Commodities with Fixed Income ESG Fixed Income ESG Equity Commodity Securities Emerging Markets Fixed Income Equity Index Global Sector Gold Fixed Income Multi Product World Dividend Equity Private Equity Global Fixed Income European Specific Equity Global U.S. Real Estate Equity Global Government Bond Index Global Sector Communications Global Real Estate Equity Global Inflation Protected Securities Growth Equity Global Small Cap Equity Global Infrastructure Global Short Duration International Equity Direct Real Assets Core Fixed-Income Latin America Equity Liquidity Management Core Intermediate Insurance Managed Equity U.S. Cash Prime Core Plus Fixed-Income Healthcare U.S. Cash Government Core Short Duration U.S. Large Cap Growth U.S. Cash Municipals U.S. Corporate Investment Grade U.S. Large Cap Value U.S. Cash Municipals State-Specific U.S. Floating Rate Debt Market Neutral Multi-Asset U.S. Government U.S. Mid Cap Growth Global High Yield U.S. Municipals Long Term U.S. Municipals U.S. High Yield U.S. Mid Cap Value Liability Driven Investing U.S. Mortgage Backed U.S. Small Cap Growth Strategic Asset Allocation U.S. Municipals High Yield U.S. Small Cap Value U.S. Municipals State Specific U.S. Municipals Short Term U.S. Technology U.S. Syndicated Loans U.S. Municipals Intermediate Active CROCI Non-U.S. Strategies/Other Arrangements DIMA offers a variety of non-U.S. strategies through its sub-advisory relationships with advisory affiliates located outside the United States. Apart from furnishing investment advice to clients, DIMA also provides various investment advisory, consulting, trading, administrative, and research support services to its affiliates, pursuant to intercompany agreements. DIMA may offer, and may negotiate fees with respect to its investment advisory, trading, administrative, and research support services to certain third-party banks, trust companies, insurance companies and other fiduciaries, and may also render investment advice to specific accounts of these banks, trust companies, and other fiduciaries that contract with DIMA. From time to time, DIMA may also provide certain other services such as investment company administrative services and executing broker evaluations and selections. In order to provide financial services in Australia, DIMA relies on an exemption from the requirement to hold an Australian financial services license under the Corporations Act 2001 (Cth). DIMA is regulated by the SEC under U.S. laws, which differ from Australian laws. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 7 Environmental, Social and Governance Issues DIMA portfolio management may incorporate considerations of environmental, social, and governance issues (“ESG”) into both investment decisions and proxy voting decisions where the financial performance of a company in which DIMA invests on behalf of clients could be impacted, but also where the investment raises purely ethical concerns. Companies or states that contravene internationally accepted ethical principles, and in which DIMA is considering an investment, will be subject to heightened scrutiny. DIMA may also consider reputational impact to its parent or affiliates, or its clients, and, in making investment decisions, DIMA may further consider how prospective clients might view these issues. Determinations regarding socially responsible investing are complex and should be made on a case-by-case basis, in accordance with investment mandates, and must always be made in the best interest of clients. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 8 please register to get more info

Fee schedules, account minimums and payment arrangements DIMA’s general policy is to assess client fees according to the current fee schedule of the investment strategy in which they are invested. Actual fees, minimum fees and minimum accounts size may vary depending on the circumstances of a particular client (e.g., whether a client is an institutional client or an individual), additional or differing levels of servicing, or as otherwise agreed with specific clients. Fixed Income: 12 basis points - 50 basis points Equities: 25 basis points -100 basis points For a mandate with multiple managed portfolios there is a per portfolio charge of up to $25,000 in addition to the fees quoted. This fee covers the additional administrative, operational and reporting costs associated with multiple portfolios. For equity model portfolio arrangements, the fees are generally within the range of 25 basis points to 100 basis points. Fees are generally based on the combined market value of all securities and cash on the accounting date and are payable quarterly or monthly either in advance or in arrears based on the quarter or month end value, as applicable, and as also dictated by the client’s investment management agreement (IMA). DIMA may also enter into performance based fee arrangements with eligible clients. Fees are negotiable, and DIMA may also charge a lower fee depending on the entirety of its, DWS’ or Deutsche Bank's relationship with a particular client, or for any other reason, in DIMA’s discretion. Certain separately managed account clients may also be charged a flat fee for administrative and/or account services performed by DIMA, in addition to any applicable management and performance fees. Such flat fee will vary by client and is subject to negotiation. DIMA does not debit management fees directly from the client account; we render invoices in accordance with fee schedules. Typically DIMA does not impose multiple advisory fees when an advisory client’s assets are invested in an affiliated investment vehicle. Specifically, client holdings of investment companies advised or sub-advised by DIMA and held in a separately managed account are excluded from the basis of DIMA’s fee computation. However, when deemed legally permissible, DIMA may charge multiple advisory fees to certain clients such as hedge funds of funds and separately managed accounts investing in Collateralized Loan Obligation Funds (“CLO”), hedge funds or other investment funds managed by DIMA or its affiliates. DIMA does not bill clients custodian charges. Clients will incur additional fees and expenses relating to third-party services, including, but not limited to administration, custodian, transfer agent, and other similar fees. In addition to paying advisory fees, clients will pay brokerage commissions, mark-ups, mark-downs and/or other commission equivalents related to transactions in their advisory accounts. See Item 12 for a discussion on Brokerage Practices. Termination arrangements An advisory relationship with a client is generally terminable at will by either party. Certain agreements may require a notice period before the termination becomes effective. In addition, some agreements (e.g., in the case of CLO advisory agreements) may require certain events to occur prior to the termination of the investment advisory relationship. Furthermore, certain agreements may also stipulate that DIMA may not resign as investment adviser until a successor has been appointed. In the event of termination, investment advisory fees are prorated to the date of termination and, to the extent they have been paid for periods beyond the date of termination; the fees are refunded to the client. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 9 Registered Investment Companies/Unregistered Commingled Vehicles DIMA acts as investment adviser to certain registered investment companies (the “DWS Funds”). The management fees paid by the DWS Funds are subject to negotiation with the Board of Trustees/Directors of each DWS Fund and the approval of the respective shareholders. DIMA’s current investment management fees range up to 1.75% of aggregate net assets on an annual basis depending on the nature of the DWS Fund, the advisory fee structure, and the size of the DWS Fund's assets. DIMA may have arrangements with certain registered investment companies whereby the base annual investment management fee is subject to upward or downward adjustment on the basis of the investment performance of one or more classes of the DWS Fund's shares as compared with the performance of a market index. As of the date of this Brochure, no DWS Funds pay DIMA a performance-based fee. DIMA may act as an investment adviser to unregistered U.S. and non-U.S. pooled investment vehicles. With respect to such unregistered pooled investment vehicles advised by DIMA, please refer to the applicable Offering Memorandum (“OM”), subscription agreement and/or other governing document that sets forth the applicable fees and expenses. Collateral Management of Structured Securities The fee arrangements for CLOs generally are described in the offering circular for each CLO. The fees are calculated as well as performance fees based on the total portfolio collateral and may include both senior and subordinated components. Compensation of DIMA and Supervised Persons Compensation of sales staff varies by types of products offered. In some areas, supervised individuals do not earn commissions; rather they receive a set annual “base” pay, along with an annual bonus that is determined on a variety of factors including profitability of the bank, profitability of the division, and contributions of that individual to the successes of the division. While DIMA does not receive asset-based sales charges or service fees from the sale of mutual funds, certain of its supervised persons, through their association with an affiliated broker-dealer, may from time to time receive compensation for the sale of DIMA-advised mutual funds. Such personnel may market the DWS Funds to financial intermediaries, including financial advisors, who in turn may recommend that their clients purchase these products. The DWS incentive program (the “Plan”) combines a monthly and quarterly incentive component with an annual out-performance award potential, based on achieving certain sales and other performance metrics. Under the Plan, DIMA’s wholesalers will receive a monetary monthly incentive based on the amount of sales generated from their marketing of the DWS Funds, and that incentive will differ depending on the product tier of the DWS Fund. Each DWS Fund is assigned to one of two product tiers taking into consideration, among other things, the following criteria, where applicable: _ The DWS Fund’s consistency with DWS branding and long-term strategy; _ The DWS Fund’s competitive performance; _ The DWS Fund’s Morningstar rating; _ The length of time the DWS Fund’s Portfolio Managers have managed the DWS Fund/strategy; _ Market size for the DWS Fund tier; _ The DWS Fund’s size, including sales and redemptions of the DWS Fund’s shares. This information and other factors are presented to a senior management committee comprised of representatives from various groups within DIMA, who review on a regular basis the DWS Funds assigned to each product tier described above, and may make changes to those assignments periodically. No one factor, whether positive or negative, determines a DWS Fund’s placement in a given product tier; all these factors together are considered, and the designation of DWS Funds in a particular tier represents management’s judgment based on the above criteria. In addition, management may consider a DWS Fund’s profile over the course of several review periods before making a change to its tier assignment. These tier assignments will be posted quarterly to the DWS Funds’ Web site at https://fundsus.dws.com/EN/wholesaler-compensation.jsp , approximately one month after the end of each quarter. DWS Wholesalers receive the highest compensation for Tier 1 DWS Funds and successively less for Tier 2. The level of compensation among these product tiers may differ significantly. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 10 The prospect of receiving or the receipt of, additional compensation by a DWS Wholesaler under the Plan may provide an incentive to favor marketing DWS Funds in higher payout tiers over DWS Funds in lower payout tiers. The Plan, however, will not change the price that investors pay for shares of a fund. The DWS Compliance Department monitors DWS Wholesaler sales and other activity in an effort to detect unusual activity in the context of the compensation structure under the Plan. Disclosure regarding the Plan appears in the Statement of Additional Information for DWS Funds and investors may wish to take the Plan and the product tier of the fund into account when considering purchasing a fund or evaluating any recommendations relating to fund shares. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 11 please register to get more info

Management DIMA may charge performance based fees, and DIMA may manage accounts using similar investment strategies that charge either performance-based fees or asset based fees, or a combination of both. DIMA will not determine allocations based upon whether an account has performance-based or other incentive fee arrangements; however, allocations among such accounts and asset based fee paying-only accounts could be viewed as a potential conflict of interest. For example, DIMA may have an incentive to allocate attractive investments to performance-fee accounts over accounts not subject to a performance fee. Performance-based fees may also create an incentive to utilize riskier investments. In addition, due to the method of calculating the performance fees, such fees may be affected by the timing of dispositions and other factors within DIMA’s control. The performance fees are computed based on realized and appraised appreciation, and calculations based on appraised value may be higher or lower than the true value of the performance fees due to DIMA. DIMA has implemented policies and procedures reasonably designed to provide fair and equitable treatment of similarly situated clients. Under these policies and procedures, and consistent with its fiduciary obligations, DIMA will allocate investment opportunities among client accounts based upon a number of factors that may include, but are not limited to: _ Investment objectives and guidelines; _ Risk tolerance _ Availability of other investment opportunities; and _ Available cash for investment DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 12 please register to get more info

DIMA may provide investment advice to many client types including: banks, corporations, governments (U.S. federal and state entities), international public authorities, foundations, endowments, financial institutions, insurance firms, individuals, trusts, registered investment companies, including mutual funds, pension plans, pooled investment vehicles, non-U.S. funds and private investment funds, issuers of collateralized bond and loan obligations and other structured products in the U.S. and abroad. The requirements for opening any account will vary depending on the type of product and type of client. In addition, DIMA may from time to time provide investment advice to individual retail investors through either a traditional “single contract” wrap fee structure or through dual contract wrap accounts, each sponsored by unaffiliated investment advisers, banks or broker-dealers. DIMA may also manage separate account clients through a third-party “manager of managers” program, under which the third party investment adviser hires or recommends DIMA to its own advisory clients. The minimum account size for a traditional wrap account under a single contract program is generally $250,000. The minimum account size for a wrap account under a dual contract or “manager of managers” program is generally $1,000,000. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 13 please register to get more info

Risk of Loss DIMA offers a wide range of investment products and opportunities. Portfolio management teams typically invest in securities that appear to offer the best potential to meet client needs, which may include any number of factors such as: yield, value, growth, income, etc. In making their buy and sell decisions, a manager can weigh any number of factors against each other ranging from economic outlook, possible interest rate movements, supply, demand, analyst research and price. Portfolio management periodically reviews accounts allocations and may adjust them based on current or anticipated market conditions or to manage risk consistent with the account's overall investment strategy. In the course of adjusting these positions, a client would pay transaction costs when the strategy buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs, affect performance, and may mean higher taxes, if you are investing in a taxable account. Within each investment strategy there is a team that manages and specializes in the particular asset category being employed. The team may use a variety of quantitative and qualitative techniques in trying to meet a client’s investment goals. Irrespective of what strategy clients select, investing in securities involves varying risks, principally the risk of loss. Additional risks include, but are not limited to, asset allocation risk, stock market risk, credit risk, interest rate risk, liquidity risk, foreign investment risk, and derivative risk. DIMA may use research that is "bottom up" or focuses on individual companies that it believes have a history of above-average growth, strong competitive positioning, attractive prices relative to potential growth, sound financial strength and effective management, among other factors. Additionally DIMA may use research that is "top down" or considers the economic outlook for various industries as a key indicator while looking for investments that may benefit from changes in the overall business environment. DIMA may also utilize its own individual research and the research it receives from a variety of sources, including other DWS companies and third party research providers when selecting securities. A general description of each strategy and basic investment risks are represented below and in the appendix. Alternatives

Strategy: Asset Allocation (Alternatives) Strategy Description: The strategy is designed to provide access to a diversified portfolio of alternative investment strategies. The strategy invests predominantly in a combination of affiliate funds. Investment strategies may fall into the following categories: absolute return, real return and non-traditional, in addition to employing a blend of alternative investment strategies to help enhance diversification. To maintain the desired allocations, the strategy will be rebalanced periodically.
ASSOCIATED MATERIAL RISKS: (SEE, “ASSOCIATED MATERIAL RISKS” BELOW FOR FURTHER DEFINITIONS.)
Active trading risk Dividend-paying stock risk Prepayment and extension risk Asset allocation risk Derivatives risk Pricing risk Borrowing risk ETF risk Short sale risk Conflict of interest risk Focus risk Security selection risk Counterparty risk Foreign investment risk Small company risk Commodities-related investments risk Interest rate strategies risk Senior loans risk Credit risk Interest rate risk Stock market risk Currency strategies risk Liquidity risk Tax status risk Multi-manager approach risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 14 Strategy: Commodities Strategy Description: The strategy seeks to provide the benefits of commodities investing with higher returns and lower volatility than otherwise investing in a passive commodity index. This strategy seeks to identify and exploit pricing inefficiencies among listed commodities through tactical positions in individual commodities. Active trading risk Commodities-related investments risk Derivatives risk Security selection risk Foreign investment risk Non-diversification risk Counterparty risk Inflation-indexed bond risk Liquidity risk Pricing risk Securities lending risk Tax status risk Strategy: Commodities with Fixed Income Strategy Description: The strategy invests in commodity-related securities and commodity-linked derivative instruments backed by a portfolio of fixed income instruments. The investment team seeks to use an active management strategy to improve return potential and decrease risk potential.
ASSOCIATED MATERIAL RISKS:
Commodities-related investments risk Derivatives risk Foreign investment risk Credit risk Interest rate risk Liquidity risk Counterparty risk Inflation-indexed bond risk Securities lending risk Concentration risk Subsidiary risk Prepayment and extension risk Tax status risk Pricing risk Emerging Markets risk Senior loans risk Operational and Technology risk Security selection risk Strategy: Commodity Securities Strategy Description: The strategy seeks to invest in equity issuers providing a broad exposure to the global commodity universe through exchange-traded commodities, commodity companies and commodity-related securities.
ASSOCIATED MATERIAL RISKS:
Commodities-related investments risk Derivatives risk Security selection risk Stock market risk Foreign investment risk Non-diversification risk Counterparty risk Liquidity risk Pricing risk IPO risk Securities lending risk Tax status risk Active Trading risk Strategy: Global Sector Gold Strategy Description: The strategy invests the majority of its assets in gold coin and bullion as well as the stocks of global companies engaged in activities related to precious metals. In choosing securities, the investment team seeks companies that mine high-quality metals, use solid fabrication techniques, have strong management teams and maintain a compelling level of un-mined reserves. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 15 Stock market risk Small company risk Foreign investment risk Medium-sized company risk Emerging markets risk Pricing risk Non-diversification risk Security selection risk Securities lending risk Growth investing risk IPO risk Liquidity risk Restricted Securities risk Tax status risk Credit risk Interest rate risk Prepayment and extension risk Active trading risk Concentration risk – gold related investments

Strategy: Private Equity Strategy Description: The strategy seeks to combine rigorous due diligence, management and risk analytics processes to offer a broad range of private equity investment products including primary funds, secondary funds, and co-investments for institutional and high net worth investors worldwide.
ASSOCIATED MATERIAL RISKS:
Borrowing risk Concentration risk Conflict of interest risk Counterparty risk Credit risk Emerging markets risk Focus risk Foreign investment risk Fund of funds risk Interest rate risk Investment style risk IPO risk Liquidity risk Non-diversification risk Pricing risk Regional focus risk Stock market risk Tax risk Prepayment and extension risk Active trading risk Strategy: U.S. Real Estate Equity Strategy Description: The strategy looks to invest in real estate securities that portfolio management believes will provide superior returns over the long term, particularly in companies with the potential for stock price appreciation and a record of paying dividends. In particular, the strategy will invest in different types of domestic (U.S.) Real Estate Investment Trusts ("REITS") and Real Estate Operating Companies ("REOC").
ASSOCIATED MATERIAL RISKS:
Stock market risk Non-diversification risk Credit risk Securities lending risk Liquidity risk Concentration risk – real estate securities Counterparty risk Active trading risk Pricing risk Interest rate risk Operational and Technology risk Security selection risk Strategy: Global Real Estate Equity Strategy Description: The strategy seeking current return, mainly invests in the equity securities of real estate investment trusts ("REITS"), and real estate operating companies ("REOC") listed on recognized stock exchanges around the world, including the U.S. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 16 Stock market risk Foreign investment risk Currency risk Pricing risk Security selection risk Securities lending risk Concentration risk – real estate securities Active trading risk Emerging Market risk Small Company risk Credit risk Interest rate risk Counterparty risk Liquidity risk Operational and Technology risk Strategy: Global Infrastructure Strategy Description: The strategy primarily invests in both U.S. and non-U.S. infrastructure securities that have derived their gross income or net profits from ownership, management, construction, operation, utilization or financing of infrastructure assets. These assets can include physical assets, structures, and networks that provide necessary services and operations to society. The strategy can invest in both equity and fixed income securities.
ASSOCIATED MATERIAL RISKS:
Stock market risk Security selection risk Foreign investment risk Non-diversification risk Small company risk Credit risk Derivatives risk Emerging Markets risk Medium sized Company risk Interest rate risk Liquidity risk Counterparty risk Pricing risk Securities lending risk Operational and Technology risk Concentration risk – infrastructure- related companies Currency risk Liquidity Management

Strategy: ESG Liquidity/ESG US Cash Prime
ASSOCIATED MATERIAL RISKS:
Money market fund risk ESG investing risk Interest rate risk Credit risk Pricing risk Liquidity and transaction risk Security selection risk Municipal securities risk Repurchase agreement risk Counterparty risk Prepayment and extension risk Foreign investment risk Risks of holding cash Market risk Fees and gates risk Concentration risk Operational and Technology risk Strategy: U.S. Cash Prime Strategy Description: The strategy seeks a high level of current income consistent with liquidity and the preservation of capital. The strategy invests in high quality, short-term, U.S. dollar denominated money market instruments paying a fixed, variable or floating interest rate. Money market risk Interest rate risk Credit risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 17 Security selection risk Repurchase agreement risk Counterparty risk Prepayment and extension risk Concentration risk Liquidity and transaction risk Market risk Municipal Securities risk Fees and Gates risk Foreign investment risk Risk of Holding cash Operational and Technology risk Strategy: U.S. Cash Government Strategy Description: The strategy seeks a high level of current income consistent with liquidity and the preservation of capital. The strategy invests in high quality, short-term, U.S. dollar denominated money market instruments issued by the U.S. Government, its agencies or instrumentalities (or in repurchase agreements collateralized by such obligations) paying a fixed, variable or floating interest rate.
ASSOCIATED MATERIAL RISKS:
Money market risk Interest rate risk Security selection risk Repurchase agreement risk Counterparty risk Credit risk Prepayment and extension risk Liquidity and transaction risk Market risk Risk of Holding cash Operational and Technology risk

Strategy: U.S. Cash Municipals Strategy Description: The strategy seeks a high level of current income exempt from federal income taxes consistent with liquidity and the preservation of capital by investing in high quality, short-term, tax-exempt money market instruments. The strategy invests its assets in investments the income from which is excluded from federal income taxes. The strategy may invest in municipal obligations that pay interest that is subject to the federal alternative minimum tax (AMT). Money market risk Tax risk U.S. territory and Commonwealth obligations risk Municipal trust receipts risk Municipal securities risk Liquidity and transaction risk Risk of Holding cash Fees and Gates risk Counterparty risk U.S. territory and Commonwealth obligations risk Credit risk Operational and Technology risk Interest rate risk Prepayment and extension risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 18 Strategy: U.S. Cash Municipals State-Specific Strategy Description: The strategy seeks a high level of current income that is exempt from State personal income taxes and federal income taxes. The strategy invests in municipal securities whose income is free from regular federal and State personal income tax. The strategy may invest in securities whose income is subject to the federal alternative minimum tax (AMT). Money market risk Interest rate risk Credit risk Security selection risk Municipal trust receipts risk Tax risk Counterparty risk Prepayment and extension risk Liquidity risk Regulatory risk Focus risk – State municipal securities Equity

Strategy: Emerging Markets Equity Strategy Description: The strategy seeks long-term growth of capital. The strategy invests in emerging market equities (equities traded mainly in emerging markets or issued by companies that are organized in emerging markets or have more than half of their business there). The strategy typically invests in equities from the U.S. or other developed markets or but may have a portion of its assets in U.S. or emerging market debt securities when portfolio management believes the securities may perform as well as equities.
ASSOCIATED MATERIAL RISKS:
Stock market risk Foreign investment risk Emerging markets risk Regional focus risk Pricing risk Derivatives risk Security selection risk Securities lending risk Counterparty risk Credit risk Growth investing risk Interest rate risk Liquidity risk Prepayment and extension risk Active trading risk Frontier markets risk Currency risk Small company risk Medium-sized company risk Operational and Technology risk Strategy: ESG Equity Strategy Description: The strategy considers both financial return and social good. The strategy invests primarily in common stocks and other equities of U.S. and foreign companies whose corporate practices promote environmental stewardship, consumer protection, human rights and diversity. Stock market risk Foreign investment risk Emerging markets risk Security selection risk Derivatives risk Liquidity risk Pricing risk Securities lending risk Active trading risk Concentration risk-climate change companies Strategy: Equity Index Strategy Description: The strategy’s primary strategy seeks to replicate the performance of a broad market equity index. The strategy gains exposure to the largest stocks in the index in approximately the same DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 19 proportion they are represented in the index, then gaining exposure to a statistically selected sample of the smaller stocks found in the index. This process is intended to produce a portfolio whose industry weightings, market capitalizations and fundamental characteristics (price-to-book ratios, price-to-earnings ratios, debt-to- asset ratios and dividend yields) closely replicate those of the index. This approach attempts to maximize the strategy’s liquidity and returns while minimizing its costs. Stock market risk Indexing risk Derivatives risk Security lending risk Counterparty risk Liquidity risk Pricing risk Operational and Technology risk Strategy: World Dividend Equity Strategy Description: The strategy invests primarily in dividend paying stocks, providing income. The strategy will generally invest in multiple countries and will normally invest significantly in securities issued by foreign based companies. Although the strategy may include companies of any size and from any country, it will invest mainly in common stocks of established companies with developed economies.
ASSOCIATED MATERIAL RISKS:
Counterparty risk Dividend-paying stock risk Liquidity risk Regional focus risk Emerging markets risk Counterparty risk Security selection risk Foreign investment risk Pricing risk Securities lending risk Operational and Technology risk Currency risk Stock market risk Strategy: European Specific Equity Strategy Description: The strategy seeks return through long-term capital appreciation by investment in equity securities of foreign issuers. The strategy can focus on a single country or sector such as middle-market German equities or equities represented by any market cap or issuer in the European Union.
ASSOCIATED MATERIAL RISKS:
Foreign investment risk Stock market risk Security selection risk Liquidity risk Derivatives risk Securities lending risk Counterparty risk Regional Focus risk European investment risk Emerging markets risk Currency risk Pricing risk Growth Investing risk Mid- and Small-cap risk Operational and Technology risk Strategy: Global Sector Communications Strategy Description: The strategy focuses primarily on telecommunications equities. In selecting investments, the investment management team may choose companies engaged in communications research, development, manufacturing and/or the sale of communications services, technology, equipment or products. These include both traditional communications companies and companies that engage in new information- based applications. Portfolio holdings may include common stocks as well as dividend- and interest-paying securities of companies in the communications field. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 20 Stock market risk Non-diversification risk Foreign investment risk Derivatives risk Credit risk Pricing risk Security selection risk Securities lending risk Medium-sized company risk Real estate securities risk Emerging markets risk IPO risk Growth investing risk Small company risk Operational and Technology risk Counterparty risk Liquidity risk Concentration risk-communications companies Strategy: Global Small Cap Equity Strategy Description: The strategy invests primarily in common stocks and other equities of small companies throughout the world. As part of the investment process the strategy may own stocks even if they are outside the small market capitalization range. The strategy may also invest in common stocks, other equities of large companies or in debt securities, and investments in junk bonds or those below the fourth highest rating grade.
ASSOCIATED MATERIAL RISKS:
Stock market risk Small company risk Security selection risk Securities lending risk Currency risk Counterparty risk Liquidity risk Pricing risk Foreign investment risk Emerging markets risk Operational and Technology risk Growth investing risk Strategy: Growth Equity Strategy Description: This strategy is designed to capture shifts in global trends and economic developments. The strategy invests significantly in common stocks of U.S. and foreign companies. The strategy can invest in companies of any size from any country, but invests mainly in established global companies
ASSOCIATED MATERIAL RISKS:
Foreign investment risk Stock market risk Security selection risk ETF risk Pricing risk Derivatives risk Securities lending risk Currency risk Operational and Technology risk Counterparty risk Growth investing risk Interest rate risk Emerging markets risk Regional focus risk Asset allocation risk Credit risk Infrastructure related companies risk Prepayment and extension risk Strategy: International Equity Strategy Description: The strategy seeks long-term growth of capital by investing in foreign equities (equities issued by foreign-based companies and listed on foreign exchanges). In selecting stocks, portfolio management uses a combination of analytic disciplines. In particular, the team looks for industries and companies that are deemed likely to benefit from social, political and economic developments. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 21 Stock market risk Foreign investment risk Emerging markets risk Regional focus risk Pricing risk ETF risk Security selection risk Derivatives risk Securities lending risk Counterparty risk Liquidity risk Small company risk Active Trading risk Currency risk Strategy: Latin America Equity Strategy Description: The strategy seeks long term capital appreciation by investing primarily in Latin American common stocks and other Latin America-related equities, such as those issued by a company traded mainly on Latin American markets, issued or guaranteed by a Latin American government or issued by a company with more than half of its business in Latin America. Portfolio management uses quantitative and field research to identify key regional economic and industrial themes, as well as changes such as privatization, improved inflow of direct foreign investment, and the development of a business environment conducive to investment and growth.
ASSOCIATED MATERIAL RISKS:
Stock market risk Foreign investment risk Regional focus risk Emerging markets risk Non-diversification risk Growth investing risk Pricing risk Security selection risk Securities lending risk Credit risk Interest rate risk Prepayment and extension risk Counterparty risk Liquidity risk Latin America risk Active trading risk Currency risk Operational and Technology risk Frontier market risk Focus risk Strategy: Insurance Managed Equity Strategy Description: The strategy attempts to outperform the return of a broad market index on a pre-tax basis by harvesting gains and losses in the portfolio. The strategy seeks long-term capital growth by investing primarily in futures contracts and common stocks of companies whose market capitalizations fall within the normal range of the associated index.
ASSOCIATED MATERIAL RISKS:
Foreign investment risk Stock market risk Security selection risk Liquidity risk Pricing risk Derivatives risk Securities lending risk Credit risk Interest rate risk Counterparty risk Indexing risk Active trading risk Strategy: Healthcare Strategy Description: The strategy invests in common stocks of companies in the health care sector. The management team focuses on biotechnology, pharmaceutical, medical device, life science instrumentation and medical service companies with superior earnings prospects and a solid pipeline of products and services. The team uses large-cap stocks as core portfolio elements, supplemented with mid-cap and small-cap stocks with higher growth potential. This approach is used to help manage risk. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 22 Stock market risk Foreign investment risk Growth investing risk Security selection risk Small company risk Securities lending risk Counterparty risk IPO risk Pricing risk Liquidity risk Concentration risk — health care companies Operational and Technology risk Strategy: U.S. Large Cap Growth Strategy Description: The strategy seeks to achieve its investment objective by investing in large U.S. companies. The managers select stocks by thoroughly analyzing long-term economic trends to determine industries that they believe will be the strongest drivers of growth. Research is then conducted to uncover companies within those industries that offer the potential for delivering high and sustainable earnings growth.
ASSOCIATED MATERIAL RISKS:
Stock market risk Growth investing risk Security selection risk Securities lending risk Counterparty risk Liquidity risk Focus risk – limited number of securities Foreign investment risk Operational and Technology risk Strategy: U.S. Large Cap Value Strategy Description: The portfolio's managers use a contrarian value investment strategy to look for stocks from historically sound companies that are temporarily out of favor. Investments are screened based on low valuation ratios and high dividends, creating a portfolio of undervalued, large-company stocks representing many sectors and industries.
ASSOCIATED MATERIAL RISKS:
Stock market risk Security selection risk Value investing risk Focus risk Derivatives risk Counterparty risk Liquidity risk Securities lending risk Active trading risk Pricing risk Strategy: Market Neutral Strategy Description: The portfolio management team seeks to provide a long-term absolute return strategy over a long-term market cycle. The strategy invests in long and short positions of large U.S. and foreign companies and stock selection is based on a dynamic approach that evaluates stocks based on valuation, growth, quality, and sentiment characteristics. The strategy attempts to limit its volatility relative to movements in the overall stock market and provide low correlation to the broad stock market indices. Stock market risk Security selection risk Short sale risk Investment style risk Comparative risk Pricing risk Liquidity risk Securities lending risk Counterparty risk Focus risk Multi-manager approach risk Active trading risk Focus risk Multi-manager approach risk Active trading risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 23 Strategy: U.S. Mid Cap Growth Strategy Description: The portfolio management team focuses on mid-cap stocks with superior growth prospects and above-average performance potential. The portfolio management team uses an active investment process to evaluate individual growth prospects and competitive strategies. Stock market risk Medium-sized company risk Growth investing risk Security selection risk Foreign investment risk Emerging markets risk Active trading risk Strategy: U.S. Mid Cap Value Strategy Description: The strategy invests primarily in common stocks of mid-cap companies that the portfolio managers believe are undervalued but have the potential for growth. The managers screen stocks with low price-to-earnings (P/E) ratios - a common measure of how expensive a stock is. The P/E ratio is equal to a stock's market capitalization by its after-tax earnings over a 12-month period - as well as analyzing other factors, in an effort to target companies from a variety of industry sectors that are financially sound and appear to have strong potential for long-term capital appreciation and dividend growth.
ASSOCIATED MATERIAL RISKS:
Stock market risk Security selection risk Value investing risk Medium-sized company risk Focus risk Foreign investment risk Pricing risk Real estate securities risk Securities lending risk Liquidity risk Operational and Technology risk Strategy: U.S. Small Cap Growth Strategy Description: The strategy invests in assets, determined at the time of purchase, in stocks and other securities with equity characteristics of U.S. smaller capitalization companies. The strategy may also invest in other types of equity securities such as preferred stocks or convertible securities. The strategy may invest its assets in the stocks of non-U.S. companies and larger capitalization stocks given market conditions.
ASSOCIATED MATERIAL RISKS:
Stock market risk Small company risk Foreign investment risk Emerging markets risk Pricing risk Security selection risk Growth investing risk Liquidity risk Securities lending risk Active trading risk Focus risk Operational and Technology risk Strategy: U.S. Small Cap Value Strategy Description: The strategy invests in undervalued common stocks of small U.S. companies, which are companies that are similar in market value to those in the Russell 2000 Index. While the strategy typically invests in U.S. stocks, it could invest a portion of its assets in foreign securities. Stock market risk Security selection risk Value investing risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 24 Small company risk Focus risk Foreign investment risk Emerging markets risk Pricing risk Securities lending risk Active trading risk Strategy: U.S. Technology Strategy Description: The strategy invests in common stocks of companies in the technology sector. A company will generally be defined as being in the technology sector if it commits at least half its assets to, or derives at least half its revenues or net income from, that sector. Examples of industries within the technology sector are semiconductors, software, telecom equipment, computer/hardware, IT services, the Internet and health technology. The strategy may invest in companies of any size and may invest in initial public offerings. While the strategy invests mainly in U.S. stocks, it could invest in foreign securities (including emerging markets securities).
ASSOCIATED MATERIAL RISKS:
Stock market risk Small company risk Foreign investment risk Emerging markets risk Pricing risk Non-diversification risk Security selection risk Derivatives risk Securities lending risk Counterparty risk Growth investing risk IPO risk Liquidity risk Restricted Securities risk Credit risk Interest rate risk Prepayment and extension risk Active trading risk Concentration risk — technology companies Medium-sized company risk Operational and Technology risk Strategy: Active CROCI Strategy Description: The strategy follows Deutsche Bank’s registered trademark CROCI (Cash Return on Capital Invested) approach applying a proprietary equity valuation technique which aims to deliver investment strategies that offer exposure to real value, growth and long-term performance by converting accounting into economic data. The investment process includes the analysis of distortions in reported financial statements as the basis for a rules-based stock selection process. Financial data are systematically adjusted to provide a comparable platform for research and investment purposes. Based on a consistent adjustment process, the CROCI strategy amends reported financial statements by adjusting all assets for inflation, accounting for hidden liabilities, depreciating similar assets in the same manner and estimating the value of unreported assets. CROCI strategy implementation is entirely systematic, transparent and without subjectivity due to ranking of stocks according to CROCI Economic Price Earnings Ratios. Strategies are rebalanced on a regular (monthly or quarterly) basis in an equally weighted manner. Pricing risk Stock market risk Derivatives risk Active trading risk Regional Focus risk Security selection risk Securities lending risk Counterparty risk Liquidity risk CROCI® - Value and Growth investing risk Foreign investment risk Currency risk Operational and technology risk Emerging markets risk Small company risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 25 Fixed Income Strategy: Canada Fixed Income Strategy Description: The strategy seeks high total investment return consistent with preservation of capital and prudent investment management. The strategy typically invests in Canadian dollar-denominated investment grade debt securities of Canadian and non-Canadian issuers: government and government agencies, instrumentalities, provincials and municipals, corporate and asset-backed securities. Interest rate risk Credit risk Foreign investment risk Derivatives risk Security selection risk Securities lending risk Derivatives risk Liquidity risk Pricing risk Currency risk Active trading risk High-yield debt securities risk Strategy: ESG Fixed Income Strategy Description: The strategy considers both financial return and social goods. The strategy invests primarily in debt of U.S. and foreign companies whose corporate practices promote environmental stewardship, consumer protection, human rights and diversity.
ASSOCIATED MATERIAL RISKS:
Credit risk Interest rate risk Foreign investment risk Emerging markets risk Security selection risk Derivatives risk Counterparty risk Liquidity risk Securities lending risk Prepayment and extension risk Pricing risk Currency risk Active trading risk High-yield debt securities risk Strategy: Emerging Markets Fixed Income Strategy Description: The strategy seeks to provide high current income and long-term capital appreciation. The strategy typically invests in high yield bonds or "junk bonds" rated below the fourth highest credit rating and other debt securities issued by governments and corporations in emerging market countries.
ASSOCIATED MATERIAL RISKS:
Credit risk Interest rate risk Foreign investment risk Emerging markets risk Regional focus risk Derivatives risk Non-diversification risk Pricing risk Securities lending risk Security selection risk Counterparty risk Liquidity risk High-yield debt securities risk Operational and technology risk Strategy: Fixed Income Multi Product Strategy Description: The strategy seeks high current income and total return. The strategy employs numerous investment techniques including, but not limited to leverage, U.S. and non U.S. debt, fixed and floating-rate debt of both investment grade and high yield debt of varying maturities. The exact portfolio composition will vary over time as a result of market changes as well as DIMA's view of the portfolio composition that best enables the strategy to achieve its investment objectives. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 26 Interest rate risk Credit risk Foreign investment risk Derivatives risk Security selection risk Securities lending risk Strategy: Global Fixed Income Strategy Description: The strategy seeks total return by investing primarily in fixed income securities of issuers located outside the United States. The strategy will typically invest in bonds of all maturities issued by governments, agencies and corporations around the world, which may be rated below investment grade.
ASSOCIATED MATERIAL RISKS:
Credit risk Interest rate risk Securities lending risk Foreign investment risk Emerging markets risk Regional focus risk Non-diversification risk Pricing risk Derivatives risk Security selection risk Counterparty risk Liquidity risk Prepayment and extension risk Active trading risk High-yield debt securities risk Currency risk Operational and technology risk Strategy: Global Inflation Protected Securities Strategy Description: The strategy seeks to provide maximum inflated adjusted return. The strategy will typically invest in inflation indexed bonds or other fixed income investments that are linked to the rate of inflation. The strategy can include investments in both U.S. and non U.S. governments, government agencies, instrumentalities, corporations and other derivatives related to these types of securities.
ASSOCIATED MATERIAL RISKS:
Security selection risk Inflation-indexed bond risk Credit risk Interest rate risk Focus risk Interest rate strategies risk Derivatives risk Foreign investment risk Emerging markets risk Conflict of interest risk Counterparty risk Liquidity risk Pricing risk Securities lending risk Senior loans risk Commodities-related investments risk Tax status risk Stock market risk Strategy: Global Short Duration Strategy Description: The strategy seeks to maximize total return consistent with preservation of capital and prudent investment management. The strategy typically invests in investment grade debt securities of domestic (U.S.) and foreign: government agencies, instrumentalities, corporate, mortgage backed, asset backed, taxable and tax exempt municipal bonds. In keeping with a short duration strategy, investments are typically in securities that have short to intermediate maturities. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 27 Interest rate risk Credit risk Foreign investment risk Emerging markets risk Derivatives risk Security selection risk Counterparty risk Liquidity risk Prepayment and extension risk Pricing risk Securities lending risk Forward commitment risk High-yield debt securities risk Operational and technology risk Senior loans risk Focus risk Mortgage backed and other Asset backed securities risk

Strategy: Global Government Bond Index Strategy Description: The strategy seeks an investment return that approximates as closely as practicable before expenses, the performance of the J.P. Morgan Government Bond Index Global (GBI Global Index), net coupon reinvested, unhedged in USD. The strategy will typically invest directly in securities of companies included in GBI Global Index, in approximately the same proportions as they are represented in the GBI Global Index. The portfolio shall be rebalanced on a monthly basis, in line with the rebalancing of the GBI Global Index.
ASSOCIATED MATERIAL RISKS:
Interest rate risk Derivatives risk Security selection risk Credit risk Liquidity risk Securities lending risk Prepayment and extension risk Pricing risk Index risk Indexing risk Tracking Error risk Currency risk Strategy: Core Fixed-Income Strategy Description: The strategy seeks high total investment return consistent with preservation of capital and prudent investment management. The strategy typically invests in U.S. dollar-denominated investment grade debt securities of domestic (U.S.) and foreign issuers: government and government agencies, instrumentalities, corporate, mortgage backed, asset backed, and taxable municipal bonds.
ASSOCIATED MATERIAL RISKS:
Interest rate risk Credit risk Foreign investment risk Derivatives risk Security selection risk Securities lending risk Strategy: Core Intermediate Strategy Description: The strategy seeks high total investment return consistent with preservation of capital and prudent investment management. The strategy typically invests in U.S. dollar-denominated investment grade debt securities of domestic (U.S.) and foreign issuers: government and government agencies, instrumentalities, corporate, mortgage backed, asset backed, and taxable municipal bonds. In keeping with an intermediate duration strategy, investments are typically in securities that have intermediate maturities. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 28 Interest rate risk Credit risk Foreign investment risk Derivatives risk Security selection risk Securities lending risk Strategy: Core Plus Fixed-Income Strategy Description: The strategy seeks high total investment return consistent with preservation of capital and prudent investment management by investing for both current income and capital appreciation. The strategy primarily invests in U.S. dollar-denominated investment grade and debt securities of domestic (U.S.) and foreign issuers: government and government agencies, instrumentalities, corporate, mortgage backed, asset backed, and taxable municipal bonds. It also may invest in below investment-grade debt securities of domestic (U.S.) and foreign issuers: emerging-market government and government agencies, corporate, mortgage backed, asset backed, and taxable municipal bonds.
ASSOCIATED MATERIAL RISKS:
Interest rate risk Credit risk Foreign investment risk Derivatives risk Security selection risk Securities lending risk Counterparty risk Liquidity risk Pricing risk Prepayment and extension risk Active trading risk Emerging markets risk High-yield debt securities risk Operational and technology risk Market risk Mortgage backed and other Asset backed securities risk

Strategy: Core Short Duration Strategy Description: The strategy seeks high total investment return consistent with preservation of capital and prudent investment management. The strategy typically invests in U.S. dollar-denominated investment grade debt securities of domestic (U.S.) and foreign issuers: government and government agencies, instrumentalities, corporate, mortgage backed, asset backed and taxable municipal bonds. In keeping with a short duration strategy, investments are typically in securities that have short maturities.
ASSOCIATED MATERIAL RISKS:
Interest rate risk Credit risk Foreign investment risk Derivatives risk Security selection risk Securities lending risk Prepayment and extension risk Currency risk Senior loans risk High-yield debt securities risk Operational and technology risk Forward commitment risk Emerging markets risk Mortgage backed and other Asset backed securities risk Strategy: U.S. Corporate Investment Grade Strategy Description: The strategy seeks high total investment return. The strategy invests in investment grade fixed income securities of U.S. dollar-denominated corporate issuers. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 29 Interest rate risk Credit risk Derivatives risk Security selection risk Securities lending risk Counterparty risk Liquidity risk Pricing risk Prepayment and extension risk High-yield debt securities risk Active trading risk Strategy: U.S. Floating Rate Debt Strategy Description: The strategy seeks to provide high current income. The strategy typically invests in U.S. adjustable rate loans that have a senior right to payment ("Senior Loans") and other floating rate debt securities. The senior loans that make up the strategy are typically below investment grade and unsecured leading to higher yield and higher volatility and risk of default.
ASSOCIATED MATERIAL RISKS:
Credit risk Market Risk Liquidity risk Pricing risk Interest rate risk Security selection risk Borrowing risk Derivatives risk Senior loan risk Prepayment and extension risk Securities lending risk Operational and technology risk Foreign investment risk Counterparty risk Strategy: U.S. Government Strategy Description: The strategy seeks to provide current income, liquidity, and security of principal. The strategy typically invests in securities backed by the full faith and credit of the U.S. Government, including related repurchase agreements, agencies with the explicit guarantee of the U.S. Government, and U.S. Treasury securities. Depending on the implementation of the strategy and needs of a client, the strategy can include debt and mortgage backed securities, including securities that are issued by U.S. government agencies or instrumentalities, but are not backed by the full faith and credit of the U.S. Government.
ASSOCIATED MATERIAL RISKS:
Interest rate risk Derivatives risk Security selection risk Credit risk Liquidity risk Securities lending risk Prepayment and extension risk Pricing risk High-yield debt securities risk Active trading risk Strategy: Global High Yield Strategy Description: The strategy seeks a high level of current income. The strategy invests primarily in below investment grade debt or "junk" bonds that are below the fourth highest credit rating of Global fixed income securities. Credit risk Interest rate risk Foreign investment risk Emerging markets risk Security selection risk Derivatives risk Counterparty risk Liquidity risk Securities lending risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 30 Prepayment and extension risk Pricing risk High-yield debt securities risk Focus risk Operational and technology risk Stock market risk Convertible securities risk Currency risk Strategy: U.S. High Yield Strategy Description: The strategy seeks a high level of current income. The strategy invests primarily in below investment grade or below the fourth highest credit rating of United States fixed income securities. Credit risk Interest rate risk Security selection risk Derivatives risk Counterparty risk Liquidity risk Prepayment and extension risk Pricing risk Securities lending risk High-yield debt securities risk Foreign investment risk Operational and technology risk Focus risk Emerging markets risk Market risk Strategy: U.S. Mortgage Backed Strategy Description: The strategy seeks income by investing in mortgage backed securities that are issued by one of the United States Government sponsored enterprises, including but not limited to Government National Mortgage Associate (GNMA), Federal National Mortgage Association (FNMA), and Federal Home Loan Mortgage Corporation (FHLMC).
ASSOCIATED MATERIAL RISKS:
Interest rate risk Credit risk Security selection risk Securities lending risk Counterparty risk Derivatives risk Liquidity risk Pricing risk Forward commitment risk Prepayment and extension risk Active trading risk Operational and technology risk Mortgage backed securities risk Strategy: U.S. Municipals

Strategy Description: The strategy seeks a high level of income exempt from regular federal income tax. The strategy will typically invest in securities issued by municipalities across the United States and in other securities whose income is free from regular federal income tax. Interest rate risk Credit risk Focus risk Market risk (municipals) Counterparty risk Liquidity risk Prepayment and extension risk Pricing risk Municipal securities risk High-yield debt securities risk Tender option bonds risk Security selection risk Derivatives risk ETF risk Operational and technology risk Tax risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 31 Strategy: U.S. Municipals High Yield Strategy Description: The strategy seeks a high level of income exempt from regular federal income tax. The strategy will typically invest in securities issued by municipalities across the United States and in other securities whose income is free from regular federal income tax. While the strategy can invest in investment grade municipal debt, it can also invest in high yield or "junk" bonds which are those rated below the fourth credit grade. Interest rate risk Credit risk Focus risk Market risk (municipals) Counterparty risk Liquidity risk Prepayment and extension risk Pricing risk Municipal securities risk High-yield debt securities risk Tender option bonds risk Security selection risk Derivatives risk ETF risk Operational and technology risk Tax risk Strategy: U.S. Municipals Short Term Strategy Description: The strategy seeks a high level of income exempt from regular federal income tax, consistent with the preservation of capital. The strategy will typically invest in securities issued by municipalities across the United States and in other securities whose income is free from regular federal income tax. Usually the strategy is limited to investment grade municipal debt and focuses on securities with short maturities.
ASSOCIATED MATERIAL RISKS:
Municipal Securities risk Interest rate risk Liquidity risk Credit risk Tax risk Counterparty risk Prepayment and extension risk Security selection risk Focus risk When-issued and delayed delivery securities risk Pricing risk Operational and technology risk Private activity and industrial development bond risk

Strategy: U.S. Municipals Intermediate Strategy Description: The strategy seeks a high level of income exempt from regular federal income taxes and seeks to limit principal fluctuation. The strategy will typically invest in securities issued by municipalities across the United States and in other securities whose income is free from regular federal income tax. The strategy is limited to investment grade, although investments can concentrate in the fourth credit grade or lower part of the investment grade scale. As the strategy is intermediate, it will typically invest in securities that are between long and short maturities. Municipal Securities risk Interest rate risk Liquidity risk Credit risk Tax risk Inverse floating rate Securities risk Security selection risk Prepayment and extension risk Pricing risk High-yield debt securities risk Focus risk Market risk Operational and technology risk ETF risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 32 Strategy: U.S. Municipals Long Term Strategy Description: The strategy seeks a high level of income exempt from regular federal income tax, consistent with the preservation of capital. The strategy will typically invest in securities issued by municipalities across the United States and in other securities whose income is free from regular federal income tax. The strategy is limited to investment grade, although investments can concentrate in the fourth credit grade or lower part of the investment grade scale. As the strategy is long, it will typically invest in securities that have long maturities. Municipal Securities risk Interest rate risk Liquidity risk Tax risk Municipal securities risk Pricing risk Security selection risk Counterparty risk Focus risk Prepayment and extension risk ETF risk Operational and technology risk Market risk Credit risk Strategy: U.S. Municipals State Specific Strategy Description: The strategy seeks income that is exempt from single state personal and federal income taxes. The strategy will typically invest in securities issued by municipalities in a single state that are exempt from state taxes and whose income is free from regular federal income tax. While the strategy can invest in investment grade single state municipal debt, it can also invest in high yield or "junk" bonds which are those rated below the fourth credit grade.
ASSOCIATED MATERIAL RISKS:
Interest rate risk Credit risk Market risk Tax risk Non-diversification risk Security selection risk Derivatives risk Counterparty risk Liquidity risk Prepayment and extension risk Pricing risk Operational and technology risk Tender option bonds risk U.S. territory and Commonwealth obligations risk Focus risk –state municipal securities Private activity and industrial development bond risk

Strategy: U.S. Syndicated Loans Strategy Description: The strategy seeks high yielding investments through the U.S. syndicated loan market, in addition to investments in U.S. corporate debt securities that are below investment grade or "junk", below the fourth highest rating grade. Credit risk Interest rate risk Security selection risk Derivatives risk Counterparty risk Liquidity risk Prepayment and extension risk Pricing risk Securities lending risk High-yield debt securities risk Active trading risk DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 33 Strategy: Liability Driven Investing Strategy Description: The strategy provides a custom approach to strategic asset allocation that seeks to hedge the risk factors inherent in pension liabilities, while providing total return. A custom benchmark is created from a client's projected liabilities and rate of interest. The strategy then seeks to hedge the interest rate and credit risk factors inherent in pension liabilities through fixed income investments, while seeking a specific rate of return in equities. Depending on the client, it can also include alternative asset classes, including but not limited to hedge funds, private equity, real estate, and other complex products.
ASSOCIATED MATERIAL RISKS:
Interest rate risk Credit risk Liquidity risk Actuarial risk Derivatives risk Counterparty risk High-yield debt securities risk Active trading risk Strategy: Strategic Asset Allocation Strategy Description: The strategy seeks to achieve as high a total return as is consistent with its allocation to one or more asset classes over a given period. The strategy will typically invest in other investment companies that in turn, invest in fixed income, equity, and other asset classes (which may include closed end funds, open end mutual funds, or exchange traded funds) some of which may be affiliated with DIMA.
ASSOCIATED MATERIAL RISKS:
Asset allocation risk Stock market risk ETN risk Growth investing risk Currency strategies risk Foreign investment risk Credit risk Interest rate risk Market risk Inflation-indexed bond risk Infrastructure related risk ETF risk Focus risk Security selection risk Convertible securities risk Counterparty risk Securities lending risk Senior loans risk Preferred stock risk Subsidiary risk Tax status risk Commodities-related investments risk Real estate securities risk Emerging markets risk High-yield debt securities risk Pricing risk Prepayment and extension risk Operational and technology risk Associated Material Risks

Active trading risk. The strategy may trade securities actively and this may lead to high portfolio turnover rate. Asset allocation risk. Portfolio management may favor one or more types of investments or assets that underperform other investments, assets, or securities markets as a whole. Anytime portfolio management buys or sells securities in order to adjust the strategy’s asset allocation this will increase portfolio turnover and generate transaction costs. Banking Laws and Regulations. Due to Deutsche Bank AG’s majority shareholding, DWS KGaA and its subsidiaries, including DIMA, remain subject to a broad array of U.S. and certain non-U.S. banking laws and regulations. As a result of principal positions held by DWS KGaA and its and DIMA being an affiliate of Deutsche Bank AG, certain funds advised by DIMA may become subject to the banking laws and regulations that are applicable to the Deutsche Bank AG. Such laws and regulations may, among other things, impose restrictions on the types and amounts of investments that a fund may make, the types of activities in which the fund may engage and the amount of influence and control DIMA or the fund may have over the operations of DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 34 the projects. In addition, certain bank regulatory limits may apply to Deutsche Bank AG and funds advised by DIMA on an aggregate basis. Additionally, Deutsche Bank AG or its affiliates may not be permitted to extend credit to or enter into certain financing arrangements with funds advised by DIMA that are deemed to be “covered funds” due to the Volcker Rule. As a result, certain investments made by affiliates of DIMA in the ordinary course of business may limit the scope and size of the projects that a fund advised by DIMA can make or the degree of influence and control DIMA or funds advised by DIMA may have with respect to such projects. Additionally, some otherwise suitable projects may not be available to, or may be unprofitably disposed of by, funds advised by DIMA. Borrowing risk. Borrowing creates leverage. It also adds to any given strategies expenses and at times could effectively force the strategy to sell securities when it otherwise might not want to. Cash flow risk. Direct property management or ownership may rely greater on cash flows than other traditional asset classes. As such situations resulting from improvements or construction may increase debt service expenses and costs, causing delays in leasing properties. There may be delays in obtaining all necessary zoning, land use, building, occupancy, and other required governmental permits and authorizations. New or renovated properties may perform below anticipated levels, producing cash flow below expected or budged amounts.

Commodities-related investments risk. The commodities-linked derivatives instruments in which the strategy invests tend to be more volatile than many other types of securities and may subject the strategy to special risks that do not apply to all derivatives transactions. For example, the value of commodity-linked derivative instruments may be affected by changes in overall market movements, commodity index volatility, changes in interest rates, or factors affecting a particular industry or commodity, such as drought, floods, weather, livestock disease, changes in storage costs, embargoes, tariffs, policies of commodity cartels and international economic, political and regulatory developments. Concentration risk. Any strategy that concentrates in a particular segment of the market will generally be more volatile than a strategy that invests more broadly. Any market price movements, regulatory or technological changes, or economic conditions affecting gold and precious metals related investments may have a significant impact on the strategy’s performance. Concentration risk – Communications field. The strategy concentrates its investments in companies in the communications field, and will therefore be susceptible to adverse economic, business, regulatory or other occurrences affecting the communications field. Companies in the communications field can be adversely affected by, among other things, changes in government regulation, intense competition, dependency on patent protection, equipment incompatibility, changing consumer preferences, technological obsolescence, and large capital expenditures and debt burdens. Concentration risk – infrastructure-related companies. Any strategy that concentrates in a particular segment of the market will generally be more volatile than a strategy that invests more broadly. Any market price movements, regulatory or technological changes, or economic conditions affecting infrastructure-related companies may have a significant impact on the strategy’s performance. In particular, infrastructure-related companies can be affected by general or local economic conditions and political developments, changes in regulations, environmental problems, casualty losses, and changes in interest rates Concentration risk – money market. Any strategy that concentrates in a particular segment of the market will generally be more volatile than a strategy that invests more broadly. Any market price movements, regulatory or technological changes, or economic conditions affecting banks or financial institutions may have a significant impact on the strategy’s performance. In particular, banks and other financial institutions are highly dependent on short-term interest rates and can be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Concentration risk – science and technology companies. Any strategy that concentrates in a particular segment of the market will generally be more volatile than a strategy that invests more broadly. Any market price movements, regulatory or technological changes, or economic conditions affecting science and technology companies may have a significant impact on the strategy’s performance. In particular, science and technology companies are vulnerable to market saturation and rapid product obsolescence. Many science and technology companies operate under constantly changing fields and have limited business lines and limited DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 35 financial resources, making them highly vulnerable to business and economic risks. Other investment risks associated with investing in science and technology securities include abrupt or erratic market movements, management that is dependent on a limited number of people, short product cycles, changing consumer preferences, aggressive pricing of products and services, new market entrants and dependency on patent protection. Convertible securities risk. The market value of a convertible security performs like that of a regular debt security; that is, when interest rates rise, the price of a convertible security generally declines. In addition, convertible securities are subject to the risk that the issuer will not be able to pay interest or dividends when due, and their price may change based on changes in the issuer’s financial condition. Because a convertible security derives a portion of its value from the common stock into which it may be converted, market and issuer risks that apply to the underlying common stock could impact the price of the convertible security. Comparative risk. Although portfolio management attempts to achieve returns for the strategy that exceed those of 3-month U.S. Treasury Bills, investors should be aware that the strategy has higher risks than 3- month U.S. Treasury Bills because, among other differences, Treasury Bills are backed by the full faith and credit of the U.S. have a fixed rate of return, and generally are less volatile than an investment in an equity strategy. Consumer discretionary sector risk. The strategy invests a significant portion of its assets in securities issued by companies in the consumer discretionary sector in order to track an underlying index’s allocation to that sector. Companies engaged in the consumer discretionary sector are subject to fluctuations in supply and demand. These companies may also be adversely affected by changes in consumer spending as a result of world events, political and economic conditions, commodity price volatility, changes in exchange rates, imposition of import controls, increased competition, depletion of resources and labor relations. Conflict of interest risk – senior loans. Affiliates of DIMA may participate in the primary and secondary market for Senior Loans. Because of limitations imposed by applicable law, the presence of DIMA’s affiliates in the senior loan market may restrict the strategy’s ability to acquire some senior loans, or affect the timing or price of such acquisition. Counterparty risk. A financial institution or other counterparty with whom DIMA does business, or that underwrites, distributes or guarantees any investments or contracts that the strategy owns or is otherwise exposed to, may decline in financial health and become unable to honor its commitments. This could cause losses for the client or could delay the return or delivery of collateral or other assets to the client. Credit risk. The strategy’s performance could be hurt if an issuer of a debt security suffers an adverse change in financial condition that results in the issuer not making timely payments of interest or principal, a security downgrade or an inability to meet a financial obligation. Because the issuers of high-yield debt securities or junk bonds (debt securities rated below the fourth highest credit rating category) may be in uncertain financial health, the prices of their debt securities can be more vulnerable to bad economic news or even the expectation of bad news, than investment-grade debt securities. Credit risk for high-yield securities is greater than for higher-rated securities. For securities that rely on third-party guarantors to support their credit quality, the same risks may apply if the financial condition of the guarantor deteriorates or the guarantor ceases to insure securities. Because guarantors may insure many types of securities including subprime mortgage bonds and other high-risk bonds, their financial condition could deteriorate as a result of events that have little or no connection to securities within the strategy. Some securities issued by U.S. government agencies or instrumentalities are backed by the full faith and credit of the U.S. government. Other securities that are supported only by the credit of the issuing agency or instrumentality are subject to greater credit risk than securities backed by the full faith and credit of the U.S. government. This is because the U.S. government might provide financial support, but has no obligation to do so, if there is a potential or actual loss of principal or failure to make interest payments. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 36 Because of the rising U.S. government debt burden, it is possible that the U.S. government may not be able to meet its financial obligations or that securities issued by the U.S. government may experience credit downgrades. Such a credit event may also adversely impact the financial markets. Credit Risk (senior loans). A strategy purchasing senior loans faces the risk that the creditworthiness of the borrower may decline, causing the strategy’s interest in a loan to decline. In addition, a borrower may not be able to make timely payments on the interest and principal on the debt obligations it has outstanding. In the event of bankruptcy of a borrower, the strategy could experience delays or limi please register to get more info

DIMA has no disciplinary issues to report. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 52 please register to get more info

Deutsche Bank AG, a multi-national financial services company (together with its affiliates, directors, officers, and employees, the “Deutsche Bank Group”), is an indirect majority owner of DIMA and DIMA’s parent DWS KGaA (together with its affiliates, directors, officers, and employees, the “DWS Group”). The Deutsche Bank Group provides and/or engages in commercial banking, insurance, brokerage, investment banking, financial advising and broker-dealer activities, including sales and trading. DWS Group is a global asset manager providing services to institutions and individuals. Deutsche Bank AG continues to be able to exercise significant influence over DWS Group’s operations. The Deutsche Bank Group engages in businesses and has interests other than managing asset management accounts, and this can result in real, potential, or apparent conflicts of interest that prove disadvantageous to DIMA’s advisory clients. Specifically, Deutsche Bank Group entities may act in their own interest, in the interest of third parties other than DIMA’s clients, for example when Deutsche Bank Group entities other than DIMA engage in advisory, transactional, and financial activities, or acquire or divest interests in assets that DIMA may directly or indirectly purchase or sell for its clients' advisory accounts. On occasion, other entities within the Deutsche Bank Group may have engagements and responsibilities that could give rise to the appearance of a conflict with DIMA's duty of loyalty. In addition, DWS Group engages in global asset management activities, which could result in actual, potential or apparent conflicts of interest between clients of DIMA and the interests of other DWS Group affiliates and their clients. A number of factors mitigate these conflicts:

_ DIMA personnel involved in decision-making for advisory accounts are required to act in the best interests of their advisory clients. DIMA acts as a fiduciary with respect to its asset management activities and owes its clients a duty of undivided loyalty. As a fiduciary, DIMA must act solely in the best interests of the clients whose assets it manages. _ DWS Group has implemented policies, procedures and controls to be followed when actual, potential or perceived conflicts of interest, whether with respect to Deutsche Bank AG or other DWS Group businesses interests, are identified. _ DIMA employees associated with the investment process, including portfolio managers, research analysts, and traders, have no contact with employees of the Deutsche Bank Group outside of DIMA as it pertains to specific clients, business matters, or initiatives. Any exceptions to this policy must be permissible by internal procedures or approved by DWS Group’s Compliance. _ DIMA personnel generally, but not exclusively, act without knowledge of specific business goals or positions of Deutsche Bank Group. When advisory personnel have knowledge of actual or potential conflicts among advisory accounts or between advisory accounts and the Deutsche Bank Group, applicable policies require mitigation of the conflicts. A discussion about additional conflicts of interest that involve related persons is set out in Item 11 – Code of Ethics - Participation or Interest in Client Transactions and Personal Trading. Broker-dealer or Registered Representative Certain management persons of DIMA may be registered as registered representatives of DWS Distributors, Inc., a registered broker-dealer, as necessary or appropriate to perform their responsibilities. Material Relationships or Arrangements with Financial Industry As stated above, DIMA is an indirect, majority owned subsidiary of Deutsche Bank AG, a multi-national financial services company (together with its affiliates, directors, officers, and employees, the “Deutsche Bank Group”). The Deutsche Bank Group provides, and/or engages in, commercial banking, insurance, brokerage, investment banking, financial advisory, broker-dealer activities (including sales and trading), hedge funds, and real estate and private equity investing, in addition to investment management services to institutions and individuals. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 53 Since the Deutsche Bank Group is engaged in businesses and has interests other than managing asset management accounts, such other activities involve real, potential or apparent conflicts of interests, and the Deutsche Bank Group entities may act in their own interest or in the interests of third parties other than DIMA’s clients. These interests and activities include potential advisory, transactional and financial activities and other interests in securities and companies that may be directly or indirectly purchased or sold by DIMA for its clients' advisory accounts. These are considerations of which advisory clients should be aware and which may cause conflicts that could be to the disadvantage of DIMA's advisory clients. Present and future activities of the Deutsche Bank Group in addition to those described herein may also result in conflicts of interest that may be disadvantageous to DIMA's clients. DIMA may utilize, suggest or recommend other services of any of its affiliates for DIMA’s clients, which may involve revenue sharing or joint compensation, and which may create a conflict of interest. DWS has established a variety of policies, procedures and disclosures designed to address conflicts of interest arising between its employees, its vendors, and its advisory accounts and the Deutsche Bank Group's businesses. Pursuant to DWS's policies, DIMA personnel involved in decision-making for advisory accounts must act in the best interests of their advisory clients and generally (but not exclusively) without knowledge of the interests of proprietary trading and other operations of the Deutsche Bank Group and/or personnel of the Deutsche Bank Group. Where advisory personnel do know of conflicts or potential conflicts among advisory accounts or between advisory accounts and the Deutsche Bank Group and/or personnel of the Deutsche Bank Group, it is DIMA's policy to mitigate such conflicts, and generally to disclose the types of conflicts involving related persons that may arise through this Form ADV. A discussion concerning additional conflicts of interest involving related persons is set out in Item 11 – Participation or Interest in Client Transactions. DIMA acts as a fiduciary with respect to its asset management activities and owes its clients a duty of undivided loyalty. As a fiduciary, DIMA is required to act solely in the best interests of the clients whose assets it manages. On occasion, other entities within the Deutsche Bank Group may have engagements and responsibilities which could give the appearance of a conflict with DIMA's duty of loyalty. To minimize these conflicts, as a general matter, DIMA employees associated with the investment process (including portfolio managers, research analysts and traders) have no contact with employees of the Deutsche Bank Group outside of DIMA regarding specific clients, business matters or initiatives, unless permissible by internal procedures, or approved by DIMA Compliance. DIMA has entered into and may in the future enter into arrangements with affiliates and third-party service providers to perform various compliance, administrative, back-office and other services on behalf of, and relating to, client accounts. Such affiliates and service providers may be located in the U.S. or in non-U.S. jurisdictions. Accordingly, certain information about client accounts may be shared with such affiliates and third party service providers in connection with these functions. Moreover, upon client request, DIMA may share information about its clients with affiliates with whom the clients wish to enter into a business arrangement. Deutsche CIB Centre Private Limited; DBOI Global Services Private Limited, Deutsche Bank Securities Inc., and Deutsche Knowledge Services Pte, Ltd provide certain near sourced financial services to DIMA including but not limited to trade processing, client account management, FX sell off activities and conduct period end substantiation of cost related accounts. Broker-Dealers DIMA has arrangements with the following related persons that are broker-dealers: _ Deutsche Bank Securities Inc. ("DBSI"), New York, NY, is a registered broker dealer under the U.S. Securities Exchange Act of 1934 (the "Securities Exchange Act"). It is a member of the New York Stock Exchange and other principal exchanges in the United States as well as the Financial Industry Regulatory Authority (“FINRA”). DBSI also serves as distributor for certain funds of DIMA. DIMA may also utilize DBSI’s services to effect securities transactions for clients. _ DWS Distributors, Inc. is a wholly owned subsidiary of DIMA, which is registered as a broker-dealer in the U.S. It serves as the principal underwriter for the DIMA-advised mutual funds, and proprietary private funds (or private placements). DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 54 Investment Companies and Other Pooled Vehicles DIMA acts in an advisory or sub-advisory capacity to a variety of U.S. investment companies and U.S and non- U.S. pooled vehicles for which an affiliate may act as adviser, sub-adviser, manager or distributor. In connection with these funds, certain DIMA employees may serve as directors, trustees or officers. These arrangements are disclosed in each fund's prospectus or offering document in accordance with any disclosure requirements. DIMA and its affiliates will receive management or advisory fees with respect to these services. Although such fees are generally paid by the entities, the costs are ultimately borne by their investors. These fees will be in addition to any advisory fees or other fees agreed between the investors in their capacities as clients and DIMA and its affiliates for investment advisory, brokerage or other services. Investment Advisers DIMA has investment advisory affiliates around the globe, including, without limitation, in Australia, England, Germany, Hong Kong, Japan, Singapore, Switzerland and the United States. The following DIMA investment advisory affiliates are registered with the SEC as investment advisers: Deutsche Bank Securities Inc., DWS International GmbH, DWS Investments Australia Limited, DWS Investments Hong Kong Limited, RREEF America L.L.C., DWS Alternatives Global Limited, DBX Advisors LLC and DBX Strategic Advisors LLC. A number of DIMA’s non-U.S. investment advisory affiliates are not registered, including without limitation, Deutsche Bank S.A. Banco Alemão, and Deutsche Asset Management (Japan) Limited. DWS Investments Singapore Limited is an exempt reporting adviser. Apart from furnishing investment advice to clients, DIMA also provides various investment advisory, consulting, trading, administrative, and research support services to its affiliates pursuant to intercompany agreements. With respect to certain non-U.S. strategies, or otherwise as it determines, DIMA may, in its discretion, delegate all or a portion of its advisory or other functions (including placing trades on behalf of clients) to any affiliate that is registered with the SEC as an investment adviser, in the U.S. or outside the U.S., or to any Participating Affiliate, or otherwise as permitted by law. To the extent DIMA delegates its advisory or other functions to affiliates that are registered with the SEC as investment advisers, a copy of the brochure of each such affiliate is available on the SEC’s website (http://www.adviserinfo.sec.gov) and will be provided to clients or prospective clients upon request. Certain services may be performed for affiliates by DIMA employees who are also employees of such affiliates or through delegation or other arrangements. In addition, DIMA may participate in sub-advisory, co-advisory or other joint projects related to pooled investment vehicles with unaffiliated entities. Participating Affiliate Relationships As mentioned above, DIMA may utilize the advisory and/or management services of certain of its foreign affiliates (“Participating Affiliates”), as that term has been used by the Division of Investment Management of the SEC) to provide advisory and/or management services to U.S. clients, through and under the supervision and control of DIMA to its clients, with respect to foreign securities and markets. DIMA currently utilizes (or may utilize) the services of Deutsche Bank S.A. Banco Alemão as a Participating Affiliate. Commodity Pool Operator, Commodity Trader Advisor and Futures Commission Merchant DIMA is registered with the U.S. Commodity Futures Trading Commission (“CFTC”) as a commodity trading operator (“CPO”) and a commodity trading advisor (“CTA”). Certain management persons of DIMA are registered with the National Futures Association (“NFA”) as associated persons. With respect to arrangements with a related person who is registered with the CFTC as either a CPO, CTA or futures commission merchant ("FCM") including but not limited to the following: Affiliates Licenses RREEF America L.L.C. CTA / exempt CPO Deutsche Bank Securities Inc. FCM / CPO / SEC broker-dealer To the extent permitted by law and applicable regulations, DIMA may utilize the foregoing or other affiliates as FCM, CPO or CTA in connection with DIMA's purchase or sale of futures on behalf of certain of its clients, or DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 55 may delegate advisory services to an affiliate as a CTA, and such FCM, CPO or CTA affiliates may receive remuneration for such services. Banking Institutions The following banking institutions are related persons of DIMA: − DWS Trust Company ("DWS TC") is a New Hampshire trust company. DWS TC is the trustee as well as sponsor and/or investment adviser to privately offered investment funds, including various funds exempt from registration under the Investment Company Act of 1940, as amended (the “Investment Company Act”). DWS TC also provides trustee and/or custodial services to various IRAs, profit sharing plans, pension plans and other retirement plan clients of DIMA.

− Deutsche Bank AG is a publicly traded international commercial and investment banking concern listed on the Frankfurt and New York Stock Exchanges and is the indirect parent of DIMA and its affiliates. DIMA’s clients may utilize custodians unaffiliated with DIMA who may, in turn, hire affiliates of DIMA as sub-custodians in certain jurisdictions. Any of Deutsche Bank AG’s branches may be selected as a foreign subcustodian by a U.S. global custodian, acting as custodian for client accounts including an account subject to ERISA. In these circumstances, DIMA affiliates may execute certain transactions on behalf of DIMA’s clients (e.g., foreign exchange transactions, corporate actions). These circumstances may give rise to the appearance of conflicts of interest. DIMA has developed policies and procedures to monitor such circumstances. DBAG may also provide various non-financial services to DIMA.

Sponsor or Syndicator of Limited Partnerships From time to time, DIMA’s affiliates may act as placement agent, sponsor, general partner, managing member or other controlling entity in private investment vehicles in which DIMA's clients may be solicited to invest, and DIMA’s clients may also be solicited to invest in private investment vehicles for which DIMA acts as adviser or subadviser. Absent specific authority, DIMA does not exercise any discretionary authority with respect to client decisions to invest in such vehicles. Please see further discussion under the above section “Investment Companies and Other Pooled Vehicles.” Management Persons; Policies and Procedures Certain of DIMA's management persons may also hold positions with DIMA’s affiliates. In these positions, those management persons of DIMA may have certain responsibilities with respect to the business of these affiliates and the compensation of these management persons may be based, in part, upon the profitability of these affiliates. Consequently, in carrying out their roles at DIMA and these other entities, the management persons of DIMA may be subject to the same or similar potential conflicts of interest that exist between DIMA and these affiliates. DIMA has established a variety of restrictions, policies, procedures, and disclosures designed to address potential conflicts that may arise between DIMA, its management persons and its affiliates. These policies and procedures include: information barriers designed to prevent the flow of information between DIMA, personnel of DIMA and certain other affiliates; policies and procedures relating to brokerage selection, trading with affiliates or investing in products managed or sponsored by affiliates; and allocation and trade sequencing policies applicable to clients. Electronic Trading Platforms DIMA may enter into agreements with various vendors who provide platforms for DIMA to gain electronic access to various participating broker-dealers. DIMA aims to make use of electronic venues wherever possible. This means that the order will be made available on the venues (i.e. request for quote submitted) on a best effort basis to avoid market movements adversely impacting execution. DIMA determines the execution venue for order execution in respect of a particular order by taking into consideration of the followings factors:
• The instrument types mainly traded on the particular venue where the competitive prices are available
• The depth of liquidity and the relative volatility of the market
• The speed and likelihood of execution
• The creditworthiness of the counterparty on the venue DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 56
• The quality, cost, and arrangements supporting clearing and settlement DIMA has identified the brokers and execution venues on which we place significant reliance in meeting our best execution obligations on a consistent basis. There may, however, be occasions when achieving the best possible result in carrying out a client order will require executing the order outside trading venues. Electronic Communication Network (ECN) DIMA may elect to utilize Electronic Communication Networks (ECNs) to execute trades. DIMA’s affiliates may maintain an ownership interest in one or more ECNs, which creates a conflict of interest. In no case does such interest by DIMA or any U.S. affiliate currently exceed 10%. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 57 please register to get more info

Transactions, and Personal Trading DWS has created certain global policies, which apply to all of its investment management entities, including DIMA. Code of Ethics The DWS Code of Ethics (the "Code"), which DIMA has adopted, imposes restrictions on the ability of DIMA’s employees who are "Access Persons" as defined in the Investment Advisers Act of 1940, as amended (“Investment Advisers Act”) to invest in securities that may be recommended or traded in DIMA client accounts. The Code currently applies to most securities transactions (including transactions in equity or debt securities, municipal bonds, exchange-traded securities, securities indices, derivatives of securities and similar instruments) and certain mutual fund transactions (including transactions in open-end and closed end mutual funds, excluding money market funds and other mutual funds specifically designed for short-term investment). The Code applies to all securities and specified mutual fund transactions in which employees have direct or indirect beneficial interest, influence and/or control. Generally, the Code classifies employees based on whether they are investment personnel involved in the investment management and trading activity of clients' assets (including portfolio managers, research analysts and traders) and imposes the greatest level of restriction on those most centrally involved in that process. Pursuant to the Code, employees are required to pre-clear all of their personal securities transactions in securities that are not exempt from the Code. Employees must also receive prior approval before purchasing any securities in a private placement. Further, employees must receive prior approval to serve on a board of a publicly traded company or to engage in certain other outside activities that may conflict with DIMA's obligations to its clients. The hedging of long stock positions, with stock options or other equity derivatives is prohibited. Finally, employees may not purchase a security pursuant to an initial public offering. The purchase or sale of securities of certain open-end mutual funds is not subject to pre-clearance. Trading in direct obligations of the U.S. Government is not subject to the Code. The Code imposes a thirty (30) day holding period between purchases and sales, or sales and purchases in the same securities and certain mutual funds with certain exceptions (such as transactions in mutual funds subject to periodic purchase plans and other exceptions specifically granted by DIMA Compliance). The Code also imposes specific blackout period restrictions on securities that apply to certain employees. For example, Access Persons may not knowingly engage in a transaction of a security on the same day as it is known that DIMA is transacting that security for a client account, and Investment Personnel (defined as those involved in the investment decision-making and trading process) may not knowingly purchase or sell a security within five days before and after a transaction of that security in a client account if he/she manages or provides advice to that client account. All employees are subject to reporting obligations, including filing a quarterly personal securities transaction report (which provides information with regard to all securities and certain mutual fund transactions that are required to be reported, if any, effected during the previous quarter for their own accounts and any accounts over which they have direct or indirect beneficial interest, influence and/or control). Employees are also required to disclose their securities and mutual fund accounts to the Deutsche Bank Group upon hire and annually confirm the information. Additionally, employees are required to acknowledge annually that they have received and read the Code. Any employee who violates the Code may be subject to disciplinary actions, including possible dismissal. Violations are report to the Chief Compliance Officer. In addition, any securities transactions executed in violation of the Code, such as short-term trading or trading during blackout periods, may subject the employee to sanctions, ranging from warnings to trading privilege suspensions, including but not limited to, unwinding the trade and/or disgorging the profits as well as additional disciplinary action. Violations and suspected violations of criminal laws will be reported to the appropriate authorities as required by applicable laws and regulations. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 58 DIMA’s clients and/or prospective clients may obtain a copy of DWS’s Code of Ethics upon request by calling their client service representative. Gifts and Entertainment DIMA has policies and procedures in place, including the DWS Code of Ethics, which limit and prohibit DIMA employees from accepting gifts, entertainment and other things of material value that may create a conflict of interest or give the appearance of a conflict of interest. Additionally, DIMA employees may not offer gifts, entertainment or other things of material value that could be viewed as attempting to unduly influence the decision making or objectivity of any client or other business partner. In general, the policies dictate that giving and receiving of gifts or participating in entertainment cannot occur if the value and/or the frequency of the gift or entertainment is deemed excessive or extravagant. The policies impose specific restrictions and require DIMA Compliance approval of certain gifts and entertainment. In general, the policy permits employees to accept gifts having a nominal value (e.g., promotional items) which must be logged. Reporting and approval requirements and restrictions apply in the case of entertainment offered to or to be provided by DIMA. DWS’ Policy also sets forth parameters with respect to entertainment- related expenses. Additional restrictions regarding gifts and entertainment apply to DIMA employees who are registered representatives or other associates of DIMA's affiliated broker-dealers. Participation or Interest in Client Transactions DIMA is indirectly owned by Deutsche Bank AG, a multi-national financial services company and therefore is affiliated with a variety of entities of DIMA disclosed in Item 10 that provide multiple financial services in addition to the provisions of investment management services to institutional and individual investors. Such other activities as previously disclosed in Item 10, involve real, potential or apparent conflicts of interests. With respect to certain managed investment strategies, trading services including counterparty selection as well as certain “downstream” functions including, but not limited to, trade matching and settlement, investment accounting, reconciliations, corporate actions, and performance measurement may be provided through DIMA and its global affiliates. In providing these services, DIMA and its affiliated entities may have access to certain information about client accounts, including not limited to, client identifies, portfolio transactions, open order and positions. Deutsche Bank Group is a major participant in global financial markets and it acts as an investor, investment banker, investment manager, financer, advisor, market maker, trader, prime broker, lender, agent and principal in the global fixed income, currency, commodity, equity and other markets in which DIMA's advisory accounts directly and indirectly invest. As permitted by and in conformity with applicable laws and regulations, DIMA's advisory accounts will invest in, engage in transactions with, make voting decisions with respect to, or obtain services from entities for which Deutsche Bank Group performs or seeks to perform banking or other services. Additionally, it is likely that DIMA's advisory accounts will undertake transactions in securities in which Deutsche Bank Group makes a market or otherwise has direct or indirect interests. DIMA makes decisions for its clients in accordance with its fiduciary obligations as manager of its advisory accounts. As noted below, however, certain activities of Deutsche Bank Group may have a negative or detrimental effect on advisory accounts managed by DIMA. DIMA may take investment positions in securities of the same issuer that are different parts of the capital structure in which other clients or related persons within the Firm have different investment positions. There may be instances in which DIMA is purchasing or selling for its client accounts, or pursuing an outcome in the context of a workout or restructuring with respect to, securities in which Deutsche Bank Group is undertaking the same or differing strategy in other businesses or other client accounts. Prices, availability, liquidity and terms of the investments may be negatively impacted by the Firm's activities and the transactions for DIMA's clients may, as result, be less favorable. The investment results for DIMA's clients may differ from the results achieved by Deutsche Bank Group and other clients of Deutsche Bank Group. In addition, results among DIMA clients may differ. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 59 As noted, DIMA makes decisions for its clients in accordance with its fiduciary obligations as manager of its advisory accounts independent of what decisions may be made by Deutsche Bank Group. While conflicts of interest could potentially arise between decisions that are in the best interests of DIMA's advisory clients and decisions that may benefit parts of the Deutsche Bank Group, such conflicts of interest are managed by the use of information barriers that control the sharing of information among the different businesses of the Deutsche Bank Group. For a summary of the restriction of the flow of certain information between DIMA and Deutsche Bank Group, please see "Information Barriers" below. The DWS Americas Investment Risk Oversight Committee is responsible for monitoring investment performance of client accounts on a regular basis and performing an annual product review. See Item 12 for more details. The investment activities of Deutsche Bank Group may limit the investment opportunities for DIMA's client accounts. This may occur in certain regulated industries, private equity markets, emerging markets, and in certain futures and derivative transactions where restrictions may be imposed upon the aggregate amount of investment by affiliated investors. DIMA may voluntarily limit transactions for client accounts or limit the amount of voting securities purchased for client accounts, or waive voting rights for certain securities held in client accounts, which may limit positions, in order to avoid circumstances which, in the view of DIMA, would require aggregation of such client account positions with investments in Deutsche Bank Group that would approach or exceed certain ownership thresholds. DIMA may have portfolio managers who manage long/short accounts alongside long-only accounts. For example, DIMA may buy on behalf of a client account a security for which DIMA may establish a short position on behalf of another client account. The subsequent short sale may result in impairment of the price of the security held long in the client account. Conversely, DIMA may on behalf of a client account establish a short position in the same security which it may purchase on behalf of another client account. The subsequent purchase may result in an increase of the price of the underlying position in the short sale exposure. DIMA may engage in security transactions with brokers who may also sell shares of registered investment companies advised by DIMA, provided that it reasonably believes that the broker will provide best execution. However, trading with these brokers may raise the appearance of a conflict of interest. There are no quid pro quo arrangements or agreements in place with these brokers. Furthermore, DIMA has implemented policies and procedures reasonably designed to prevent its traders from considering sales of DWS Fund shares as a factor in the selection of broker-dealers to execute portfolio transactions for each DWS Fund. Information Barriers Deutsche Bank Group may come into possession of confidential, material non-public information particularly in connection with its commercial and investment banking activities. Deutsche Bank Group and DWS, have internal procedures in place intended to limit the potential flow of any such non-public information. Should DIMA come into possession of any material, non-public information, DIMA has procedures that prohibit trading activities based on such information by DIMA for its clients and by DIMA employees. DIMA may not use material, non-public information when making investment decisions for its clients. These procedures and prohibitions may preclude client accounts from purchasing or selling certain securities, which could have a detrimental effect on one or more client accounts. There may be instances in which senior management of DIMA, not involved in the investment process, may be privy to material, non-public information about transactions or securities due to discussions with senior personnel from other departments within Deutsche Bank Group. However, when in possession of material, non-public information, senior management may not participate or use that information to influence trading decisions; nor may they pass that information along to personnel within DWS involved in the investment process (e.g., portfolio managers, research analysts and traders) for use in investment activities. DIMA has developed policies and procedures to monitor such circumstances. There may also be periods during which DIMA may not initiate or recommend certain types of transactions, disseminate research or may otherwise restrict or limit its advice given to clients in certain securities issued by or related to companies that Deutsche Bank Group is performing banking or other services, or companies in which Deutsche Bank Group has a proprietary position. As a result, client accounts may be precluded from purchasing or selling certain securities, which could have a detrimental effect on one or more client accounts. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 60 Trading with an Affiliate/New Issues The only compensation received by DIMA for effecting securities transactions for clients is its advisory fees. Related persons of DIMA may receive brokerage commissions, commission equivalents, fees associated with acting as an issuer’s paying agent, spread and other fees in connection with brokerage services provided. DIMA may also receive certain non-financial soft dollar benefits, as described in “Research and Soft Dollars,” below. See Item 12 for more details. DIMA may purchase, on behalf of its clients, securities in which an affiliate of DIMA serves as lead underwriter or co-manager of an underwriting syndicate or member of an underwriting syndicate. In these cases, the purchase is generally made from a party unaffiliated with any DWS company, but DIMA’s affiliate may nevertheless benefit from such transactions, including in circumstances where the syndicate of which DIMA’s affiliate is a member is experiencing difficulty in effectuating the distribution of the new issues. While DIMA acts solely in the best interests of its clients, these circumstances may give rise to the appearance of a conflict of interest, even though the transactions are effectuated in compliance with applicable regulations (see "Agency Transactions," "Investment Companies," and "Principal Transactions" below). DIMA may have a potentially conflicting division of responsibilities to both parties to a cross transaction. Additionally, regulatory or other government requirements applicable to DIMA’s related persons may restrict DIMA from investing in or disposing of certain securities for its clients on a temporary or on-going basis. This may affect potential returns on clients' accounts, and a client not advised by DIMA may not be subject to some of these restrictions. DIMA clients may utilize custodians unaffiliated with DIMA and such custodians may, in turn, hire affiliates of DIMA as sub-custodians in certain jurisdictions. In such circumstances, DIMA affiliates may affect certain transactions on behalf of DIMA clients (e.g., foreign exchange transactions, corporate actions). These circumstances may give rise to the appearance of conflicts of interest. DIMA has developed policies and procedures to monitor such circumstances. In the event a DIMA client hires its own custodian, DIMA will work with such client to avoid conflicts of interest in connection with its custodian engaging DIMA affiliates as sub-custodians. Agency Transactions DIMA is a related person of various broker-dealers through which it may effect agency transactions. DIMA has procedures reasonably designed to ensure that agency transactions executed with these related broker- dealers acting as agent comply with applicable law and regulations. If any client portfolio transaction is executed with related broker-dealers, the broker-dealers may charge a commission in connection with these transactions; however, the commissions do not exceed the usual and customary commission that the broker- dealers would charge their own customers. As a general matter, DIMA can execute agency transactions on behalf of clients with related broker-dealers only if DIMA has determined in good faith that the client will receive best execution in the transaction, and only in compliance with applicable law and regulations, DWS's policies and procedures, and in accordance with the consent of clients to these kinds of transactions. Executing transactions with affiliates of DIMA may present conflicts of interest, including that DIMA affiliates will earn fees with regard to such transactions. See Item 12 Directed/Restricted Brokerage for a discussion of “Restricted Brokerage.” Investment Companies For registered investment company clients, agency and underwriting transactions with affiliated broker-dealers will be executed only pursuant to procedures adopted by the Boards of Trustees or Directors of such companies under Rule 17e-1 and Rule 10f-3 under the Investment Company Act. Rule 17e-1 under the Investment Company Act provides that, when purchasing or selling securities as agent, an affiliate of the registered investment company may not accept any compensation, except in that person’s role as an underwriter or broker. In addition, Rule 10f-3 under the Investment Company Act provides a limited exception to the prohibition on registered investment companies from knowingly purchasing or acquiring securities during the existence of an underwriting or selling syndicate when a principal underwriter of such security is an affiliate of the registered investment company. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 61 Principal Transactions DIMA generally does not cause its clients to enter into principal transactions with related persons. Under limited circumstances, DIMA may enter into a principal transaction provided the transaction is in accordance with Section 206(3) of the Investment Advisers Act. All such transactions must receive client consent for each transaction, are effected on arms' length terms and, with respect to commissions paid, are generally competitive with those paid to non-related broker dealers. Cross Trades DIMA may affect agency cross transactions for advisory accounts in which a DIMA affiliated broker-dealer acts as broker for both the advisory account and other party to the transaction. Such transactions may result in commissions being paid to the DIMA affiliated broker. DIMA may have a potentially conflicting division of loyalties and responsibilities to both parties in an agency cross transaction. In addition, transactions between managed accounts may result in the incurrence by such accounts of custodial fees, taxes or other related expenses. DIMA may affect cross transactions directly between advisory accounts, provided that: such transactions are consistent with the investment objectives and policies of such accounts (for mutual funds, consistent with the funds’ Rule 17a-7 procedures (procedures for transactions with affiliated persons)); are, in the view of the respective portfolio managers, favorable to both sides of transactions; and are otherwise executed in accordance with applicable laws, rules and regulation. DIMA will only consider engaging in cross transactions to the extent permitted by applicable law and will, to the extent required by law, obtain the necessary client consents. Clients may revoke their consent for agency cross transactions at any time. Portfolio Holdings Disclosure Policy As investment advisers, DIMA and each sub-adviser have a responsibility to their clients and investors not to disclose non-public portfolio holdings information unless such disclosure is consistent with relevant laws and regulations and with the fiduciary duties DIMA and each sub-adviser owe to their clients. DIMA may make non-public portfolio holdings information available to certain clients or other parties including DIMA affiliates, sub-advisers, custodians, independent registered accounting firms, a DWS Fund's officers and trustees/directors, securities lending agents, financial printers, proxy voting firms, mutual fund analysts and rating and tracking agencies or a fund's shareholders in connection with in-kind redemptions in accordance with DIMA’s portfolio holdings disclosure policy. Proprietary Account Trading and Hedging Activities In accordance with DWS policy, DIMA may invest and manage its own proprietary capital by investing in a variety of securities and other instruments that is also subject to Volcker compliance. Proprietary capital investments will include investing in certain products and strategies managed by DIMA for its clients. The market risks of these investments may be hedged, while market risks of client assets may not be so hedged. Hedging activities may include purchasing instruments or using investment strategies such as short selling, futures (or options on futures) trading or employing other derivative techniques. Portfolio management and trading of the proprietary capital as well as any associated hedging activity is undertaken in accordance with DWS policies and procedures. Proprietary capital may not perform the same as similarly managed client accounts for a variety of reasons, including, but not limited to regulatory restrictions on the type and amount of securities in which the proprietary capital may be invested, differential credit and financing terms, as well as any hedging transactions. While DIMA acts solely in the best interests of its clients, these circumstances may give rise to the appearance of a conflict of interest or could potentially disadvantage its clients. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 62 please register to get more info

Broker Dealer Selection The execution strategy and associated execution methods, including where and how to execute an order, are made based on the functional and economic merits e.g. liquidity, suitability, certainty, and settlement infrastructure of a broker or a venue. Our selection of a particular broker to execute an order is based on a number of criteria, including, but not limited to, their: Market and security familiarity Access to liquidity or willingness to commit risk to principal trade Financial stability and certainty of settlement Reliability and Integrity of maintaining confidentiality Soundness of technological infrastructure and operational capabilities In case of new Issues: The broker´s capability to provide subscription facility in the primary market Safeguards and compliance controls to protect Clients Pricing and costs for execution-only services Ability to provide transaction cost analysis (TCA) Access to Centralized Risk Book (CRB) Ability to provide analysis of speed of execution Level of control over interactions with internal and external Systematic Internalisers (SIs) Approach to double caps and new large-in-size (LIS) venues Smart order routing (SOR) logic and Algorithmic trading strategies Ability to produce customized reports, trade related performance data, performance attribution, risk reports (including breach violations and rejection) on a periodic basis Ability to provide assisted trade reporting Commission Rates DIMA’s trading desks utilize a schedule of commission rates that have been negotiated with the broker-dealers approved by DWS. The schedule delineates the commission rates negotiated with the broker-dealer by country and by types of trades. There may be limited instances in which a trade may deviate from the schedule. Best Execution

When executing orders, we will take all sufficient steps to obtain the best possible result taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order. When executing or transmitting an order to other firms for execution, we must take all sufficient steps to obtain, the best possible result on a consistent basis by taking into account following execution factors, such as:
• Price
• Costs
• Speed
• Likelihood of execution and settlement
• Size
• Nature
• Any other consideration relevant to the execution of a particular order The relative importance of these execution factors will be determined based on the following criteria:
• The characteristics of the order
• The Financial Instruments that are the subject of the order
• The characteristics of the Execution Venues to which the order can be directed
• The current market circumstances DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 63
• Specifically for Funds: the objectives, investment policy and risks of the Fund as indicated in the prospectus, articles of association or offering documents of the Fund Generally, we will regard price and cost as the important factors for Best Execution, however there may be circumstances when we may determine that other execution factors have a greater influence in achieving the best possible result. Investment and Brokerage Discretion Generally, DIMA is retained on a discretionary basis for client accounts and DIMA determines which securities should be bought or sold, the total amount to be bought or sold for the account, the broker or dealer through which the securities are executed, and the commission rates, if any, at which transactions are effected for those accounts. From time to time, a client may also retain DIMA on a non-discretionary basis, explicitly requiring that portfolio transactions be discussed in advance. Brokerage Practices Sub-Committee (“BPSC”) The Brokerage Practices Fiduciary Oversight Committee (“BPSC”), which is is directed by the DWS Americas Investment Risk Oversight Committee (“IROC” also knows as the “Delegative Person”), is the fiduciary oversight committee for brokerage practices, including broker selection, best execution and new commission sharing and soft dollar agreements for DWS in the Americas. The responsibilities of the BPSC include, but are not limited to, the following: (i) Review of:
• Best execution practices including, but not limited to broker selection, new soft dollar arrangements, approval of standard commission schedules, etc. (ii) Best execution determinations from each trading desk, including where applicable:
• Trading volume and commission by broker
• Broker rank
• Trends and market color as it related to execution
• Cross trading activity (iii) Approved brokers and counterparts as determined by Counterparty Risk

(iv) Trading errors Allocation of Investments DWS has policies and procedures, which DIMA has adopted, reasonably designed to ensure that all clients are treated fairly and equitably. Allocation of executed aggregated orders must be made to the accounts participating in the transactions on pro-rata basis or in accordance with DWSs’ Trading Allocation Methodology. Participating accounts shall receive the actual day’s execution price per broker (single or average price) and shall pay any additional commission, fees or charges on a pro-rata basis. If a purchase or sell order extends beyond a trading day, the same procedure is applied at the end of the next trading day in respect to all trades entered into during that day. New Issue Allocation When allocating Initial Public Offerings (“IPOs”), Secondary Public Offerings (“SPOs”) (collectively “new issues”) and other block trades, DWS must treat all client accounts in a fair and equitable manner. When the order has been entered by the portfolio manager into the front office system and sent to the responsible dealing desk, DWS Trading will aggregate all orders in relation to a new issue and submit an DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 64 aggregated indication of interest for DWS to the broker. Communication to the broker should only reflect actual interest of the respective fund. Participation in new issues is limited to those client accounts that meet applicable FINRA eligibility requirements. Not all client accounts or funds will be eligible for investment in new issues. Any deviations to the applicable allocation methodologies must be approved by DIMA Compliance. Research and Soft Dollar Benefits DIMA is generally responsible for placing orders for the purchase and sale of portfolio securities, including the allocation of brokerage. In placing orders for the purchase and sale of securities for a client or fund, it is the policy of DIMA to seek best execution, taking into account the commission rate and a variety of other factors, including the quality of the execution. DIMA seeks to evaluate the overall reasonableness of brokerage commissions with commissions charged on comparable transactions. DIMA is permitted by Section 28(e) of the Securities Exchange Act of 1934, as amended (such Act, the “1934 Act” and such Section, the “Sec. 28(e) Safe Harbor”) when placing securities transactions for an account, to cause the account to pay brokerage commissions in excess of that which another broker-dealer might charge for executing the same transaction in order to obtain research and brokerage services if DIMA determines that such commissions are reasonable in relation to the overall services provided. DIMA may from time to time, execute portfolio transactions with broker-dealers that provide research and brokerage services to DIMA, generally in reliance on the Sec. 28(e) Safe Harbor, except as noted in the following paragraph below. Consistent with DIMA’s policy regarding best execution, where more than one broker is believed to be capable of providing best execution for a particular trade, DIMA may take into consideration the receipt of research in selecting the broker-dealer to execute the trade. Research provided by brokers may include, but is not limited to, information on the economy, industries, groups of securities, individual companies, statistical information, accounting and tax law interpretations, political developments, legal developments affecting portfolio securities, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, performance analysis and measurement and analysis of corporate responsibility issues. These research services are typically received in the form of written reports, telephone contacts and personal meetings with security analysts. Research services may also be provided in the form of market data services, and meetings arranged with corporate and industry representatives. Services received from broker-dealers that executed securities transactions for an account will be not necessarily be used by DIMA to specifically service that account, provided in such instances such services fall within the Sec. 28(e) Safe Harbor. Research and brokerage services may include products obtained from third parties, if DIMA determines that such product or service constitutes brokerage and research as defined in Section 28(e) and interpretations thereunder. In certain case, DIMA may use brokerage commissions to obtain brokerage products or services that have a mixed use (i.e., it also serves a function that does not relate to the investment decision-making process), which products or services are only partially eligible for the Sec. 28(e) Safe Harbor. In those circumstances, DIMA will make a good faith judgment to evaluate the various benefits and uses to which it intends to put the mixed use product or service and will pay for that portion of the mixed use product or service that it reasonably believes does not constitute research and brokerage services with its own resources. Due to European regulatory changes affecting DIMA and certain of its affiliates, beginning in January 2018, certain clients no longer participate in the client commission arrangements described above with respect to obtaining research services. For those accounts, or relevant portions thereof, DIMA or its affiliates will pay for research services previously obtained through use of client commissions from their own assets. DIMA and its affiliates have put into place procedures to ensure that clients pay only their proportionate share of the cost of research services, as appropriate. Trading and Broker Restrictions Clients may limit DIMA’s authority by prohibiting or by limiting the purchasing of certain securities or industry groups. In addition, a client may further limit DIMA’s authority by (i) requiring that all or a portion of the client's transactions be executed through the client's designated broker-dealer ("Designated Broker") and/or (ii) restricting DIMA from executing the client's transactions through a particular broker-dealer. In situations where a client directs or restricts brokerage for their accounts ("Directed/Restricted Brokerage"), because the client has placed limitations on the selection of broker-dealers to execute Directed/Restricted Brokerage, DIMA may be unable to obtain "best execution" for such trades. Similarly, where a client directs DIMA to use a particular counterparty for swaps, OTC options, etc., DIMA may be unable to obtain best DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 65 execution for such trades. Furthermore, Directed/Restricted Brokerage may not be aggregated or "blocked" for execution with transactions in the same securities for other clients and may trade after the aggregated trades and/or directed trades for other DIMA clients. As a result, such clients may have to pay higher commissions or receive less favorable net prices than would be the case if the clients had participated in the aggregated trading order and DIMA were authorized to choose the broker through which to execute transactions for such client accounts. Where clients have Directed/Restricted Brokerage for their account and maintain that DIMA remains subject to best execution obligations, DIMA may aggregate those directed trades along with trades executed for other client accounts through the broker-dealer DIMA believes to offer the best execution for such transaction and, thereafter, instruct such broker-dealer to "step-out" or allocate a portion of the trades to the client's Designated Broker for billing and settlement. In agreeing to satisfy a client's directions to execute transactions for its account through Designated Brokers, DIMA understands that it is the client's responsibility to ensure that: (i) all services provided by the Designated Brokers (a) will be provided solely to the client's account and any beneficiaries of the account, (b) are proper and permissible expenses of the account, and may properly be provided in consideration for brokerage commissions or other remuneration paid to the Designated Brokers, (ii) using the Designated Brokers in the manner directed is in the best interest of the client's account and any beneficiaries of the account, taking into consideration the services provided by the Designated Brokers, (iii) its directions will not conflict with any obligations persons acting for the client's account may have to the account, its beneficiaries or any third parties, including any fiduciary obligations persons acting for the account may have to obtain the most favorable price and execution for the account and its beneficiaries; and (iv) persons acting for the client's account have requisite power and authority to provide the directions on behalf of the account and have obtained all consents, approvals or authorizations from any beneficiaries of the account and third parties that may be required under applicable law or instruments governing the account. Counterparty Risk Counterparty risk is the risk that a broker-dealer will not be able to complete a client's transaction, whether due to financial difficulties or otherwise, which may result in opportunity cost and/or loss of principal. DWS Investments Risk has a Counterparty Risk Management (CPRM) team who are responsible for assessing, and controlling counterparty risk for all transactions undertaken on behalf of our clients. The CPRM team has developed and maintains policies and procedures which are applicable across all business globally within DWS. DWS CPRM attempts to set both credit and settlement exposure limites for counterparties determined to be suitable and also monitors limits on a regular bases not only to ensure compliance, but also to ensure that there is no undue concentration of exposure, within levels that, in DIMA’s judgment, are prudent with regard to the counterparty's financial resources. For certain transactions involving extended settlements, CPRM team is heavily involved in the negotiation of special agreements with certain broker-dealers. In less-developed markets, there may well be a higher level of counterparty risk because broker-dealers may not be as well capitalized. In addition, there is often more limited and less reliable information about counterparties' financial condition, less regulatory supervision of securities markets, market policies that may require payment before delivery of securities, less automated clearance and settlement conditions, the uncertain enforceability of legal obligations, greater market volatility, and increased levels of sovereign and currency risk. In these markets, the effort to attain best execution may also tend to increase counterparty risk, and DIMA will attempt to balance these factors when selecting a broker-dealer to execute client transactions. Order Aggregation DIMA may attempt, to the extent appropriate, permissible and/or feasible, to aggregate multiple orders for the purchase or sell of the same security, placed at or around the same time, to achieve best execution with respect to all transactions being effected on behalf of client accounts. To the extent possible, the aggregation of orders shall be performed in a way that it does not disadvantage any client account or client whose orders are to be aggregated. DIMA should execute aggregated orders across all applicable accounts. Orders of the same security and transaction type should, to the extent possible, be aggregated. Any subsequent orders that the trading desk receives prior to full execution of an aggregated order should be added to the unfilled portion. In addition, to DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 66 the extent that aggregated orders are partially unfilled following execution, the unfilled amounts are to be combined with subsequent orders for future execution. When an aggregated order is executed at more than one price over the course of a day, the executed transactions are allocated so that each account receives the weighted average execution price per broker and bears it’s pro rata share of the commissions, fees and charges, to the extent reasonably practicable. The above is subject to the discretion of the trading desk. Certain orders may be auto-routed electronically for execution and as such may not be aggregated with other orders. There may be instances in which other DIMA client orders for the same security are being placed through a broker and, in those instances, the auto-routed and the direct orders may theoretically compete against each other in the market. Prices and availability of a security may differ depending on whether an order was auto-routed or aggregated, and this may result in certain client accounts receiving more or less favorable prices than the other client accounts in contemporaneous trades. Certain affiliated advisers of DIMA may utilize the DIMA trading desk to facilitate the routing and execution of their client orders. In such cases, the DIMA trading desk will execute these client orders along with DIMA client orders in the manner described above. DIMA may also utilize certain affiliated advisers trading desks to facilitate the routing and execution of client orders. In such cases, consistent with its best execution obligations, the affiliate advisers will execute these orders along with affiliate orders in the manner described above so as to treat all client accounts in a fair and equitable manner. Errors and Corrections A trading error is defined as an error in the placement, execution, or settlement of a client’s trade. Trade errors include improper trades resulting from incorrect information being given to, and fully accepted by, the executing broker; trades that are inconsistent with a client’s or fund client’s investment guidelines, DIMA policy or procedure, applicable laws and regulations, and operational errors that cause trading or guideline breaches. A trading error does not include, for example, a situation where DIMA invests in a particular investment that does not perform as expected. Operational mistakes which can be promptly reversed so as not to affect the client account also are not considered operational errors. In accordance with its policy, any trade error that affects a DIMA client account must be resolved promptly and fairly, and in accordance with legal/regulatory restrictions and guidelines. All trade errors caused by DIMA which result in a loss to a client account must be reimbursed regardless of the amount. With respect to certain trade errors, DIMA may determine the amount of such reimbursement by offsetting losses against gains resulting from such errors to the extent permitted by DWS's policies and procedures and applicable law. All trade errors are reported on a regular basis to DIMA management and/or DIMA Compliance. Trade error incidents resulting from the mistakes of brokers, custodians or other third parties are generally not compensable by DIMA to a client. Non-Discretionary Accounts DIMA provides non-discretionary investment advice to certain clients (including affiliates), requiring client consent prior to trading on behalf of such clients. In certain cases, depending on the time elapsed between DIMA seeking and receiving consent to purchase or dispose of an investment, such clients may not participate or receive the benefits of trading in the aggregate with other DIMA clients or may lose an investment or disposition opportunity altogether. In cases where clients receive non-discretionary advice and do not participate in an aggregated trade order, such clients’ order will be traded after the aggregated order is completed. Model Portfolio Programs As noted above in “Item 4 - Advisory Business,” DIMA may, for certain investment strategies, provide discretionary and non-discretionary investment advice in the form of model portfolios to Sponsors who may utilize such recommendations in connection with the management of their client accounts; i.e., DIMA may provide model portfolio recommendations to Sponsors who then execute securities transactions on behalf of their program clients in accordance with the model portfolios. DIMA’s model portfolio service may be tailored to a specific investor’s needs. In some instances, Sponsors may be responsible for interposing their own judgment in deciding that the model portfolio recommendations are appropriate for their client accounts. DIMA normally intends to follow the general trading approach outlined below: DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 67 1. For discretionary model portfolios provided by DIMA to Sponsors (each a “Discretionary Model Portfolio Account,” and collectively, the “Discretionary Model Portfolio Accounts”) and for affiliated Sponsors, DIMA generally will communicate information regarding model portfolios, or updates thereto, to such Sponsors at approximately the same time as it communicates to its trade desk the corresponding transactions for its advisory client accounts within the same investment strategy. 2. For non-discretionary model portfolios provided by DIMA to Sponsors (each a “Non-Discretionary Model Portfolio Account,” and collectively, the “Non-Discretionary Model Portfolio Accounts,” and together with Discretionary Model Portfolio Accounts, the “Model Portfolio Accounts”), DIMA will normally seek to communicate information regarding model portfolios or updates thereto to such Sponsors at approximately the same time as it communicates to its trade desk the corresponding transactions for its advisory client accounts within the same investment strategy; provided that for more than one such Sponsor using the same investment strategy, DIMA intends to follow a trade rotation policy where it provides model portfolio changes to such Sponsors sequentially, with model portfolio changes normally being communicated to the Sponsor that is first in line in the sequence at approximately the same time corresponding advisory client account trade orders are communicated to DIMA’s trading desk. In an effort to treat the Non-Discretionary Model Portfolio Accounts on a fair and equitable basis over time, on each day where there is trading for multiple Non-Discretionary Model Portfolio Accounts utilizing the same investment strategy, DIMA intends to randomly assign such Non-Discretionary Model Portfolio Account their spot in the trading sequence for that day. Once DIMA determines the trading sequence for a particular day for a particular investment strategy, it will normally follow that sequence for all trades that are initiated during that day (the “Initial Trade Date”). DIMA intends to release model portfolio changes to all Non-Discretionary Model Portfolio Accounts in a manner that does not intentionally systematically favor or disadvantage any particular Non- Discretionary Model Portfolio over time.

On any given day, if DIMA determines, in its discretion, that an advisory client account trade and corresponding change to Non-Discretionary Model Portfolio Accounts are likely to be market moving (a “Market Moving Trade”), DIMA will seek to implement a trading approach that it deems fair and equitable under the circumstances. When determining whether a trade is or is not likely to be market moving, DIMA primarily bases its determination on two factors: (i) the average daily trading volume for the security being traded and (ii) the total size of the trade. In addition to these two main factors, DIMA may, in its discretion, take into account other factors, such as the time of day the trade is initiated, current market conditions, and other relevant information. If DIMA determines there is a likely Market Moving Trade, DIMA may, in its discretion, take various steps, including breaking the Market Moving Trade into a number of smaller trades spread out over time in an attempt to reduce market impact. In the case of a Market Moving Trade involving an investment strategy being utilized by multiple Non-Discretionary Model Portfolio Accounts, DIMA will normally seek to communicate the advisory client account trade order to its trading desk at approximately the same time that it communicates the corresponding model portfolio change to the Non- Discretionary Model Portfolio Account that is first in line in the trade sequence for that day. Once it completes the Market Moving Trade and any and all other related trades for its advisory client accounts and any affiliated Sponsors that trade in the aggregate with DIMA’s advisory client accounts, DIMA will normally then sequentially communicate all of the corresponding model portfolio changes to the remaining Non-Discretionary Model Portfolio Accounts in accordance with the trade sequence established on the Initial Trade Date

Under the above-described circumstances, DIMA may or may not complete its trading for its advisory client accounts and any affiliated Sponsors before providing the model portfolio changes to all of the Model Portfolio Accounts. Under certain circumstances, such as when DIMA, in its discretion, determines that abnormal market conditions exist, DIMA reserves the right to modify its general trading approach in a manner that it deems fair and equitable over time to similarly situated clients. As a result of DIMA’s above-described trading activity on behalf of its advisory client accounts and affiliated Sponsors, corresponding model portfolio related trades placed by Sponsors for their Model Portfolio Accounts may, as a general matter, be subject to price movements, particularly for orders that are large in relation to a security's average daily trading volume. This could potentially result in the Model Portfolio Accounts receiving prices that are less favorable than the prices obtained by DIMA for its advisory client accounts and affiliated Sponsors. Similarly, model portfolio related trading activity by Sponsors on behalf of their Model Portfolio DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 68 Accounts could potentially result in DIMA’s advisory clients and affiliated Sponsors receiving prices that are less favorable than prices that might otherwise have been obtained absent the Sponsors’ trading activity, particularly for orders that are large in relation to a security's average daily trading volume. In addition, it is possible that the communication of the model portfolios to Sponsors may be delayed because of the Sponsors’ administrative requirements or implementation practices. In such circumstances, Sponsors, including affiliated Sponsors, who make decisions for Model Portfolio Accounts, will not have had the chance to evaluate or act upon the model portfolio recommendations prior to the time at which other advisory accounts received such model portfolio and had the opportunity to act upon it. It is also possible that Sponsors, including affiliated Sponsors, who make execution decisions for Model Portfolio Accounts, may act upon such information before other advisory accounts have commenced trading. For Sponsors participating in a trading sequence, particularly Sponsors that are not “first in line,” trades placed by such Sponsors for their clients may be subject to price movements due to the trading activity of other Sponsors. This may result in adverse price impacts for the affected Sponsors’ clients. DIMA intends to take reasonable steps to minimize the market impact on advisory client accounts and affiliated Sponsors of orders associated with model portfolio recommendations provided to all Sponsors. Because DIMA does not control the Sponsors’ execution of transactions for the Model Portfolio Accounts, DIMA cannot minimize the potential market impact of such transactions on Model Portfolio Accounts to the same extent that it may be able to for its advisory client accounts and affiliated Sponsors. DIMA believes that Sponsors are in the best position to take steps to address trading issues in furtherance of their best execution obligations to their clients. DIMA endeavors to treat its similarly situated clients fairly and equitably over time with respect to trade sequencing and allocation, recognizing that DIMA generally has different levels of responsibility with respect to its discretionary clients as compared to its non-discretionary clients. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 69 please register to get more info

Regular reviews of accounts in each strategy vary in frequency and are tailored to the specific facts and circumstances applicable to the various investment strategies. On an ongoing basis portfolio managers review accounts to ensure investments are appropriate and DIMA Compliance uses various monitoring systems to check for adherence to guidelines, restrictions and other regulatory requirements. Daily: Traders perform daily trade reviews to ensure that records are accurate and complete. Daily trade reviews are also completed by the portfolio managers who review and verify that orders were executed in accordance with the trading instructions. Monthly: DIMA has policies and procedures in place to address trade errors and the Brokerage Practice Sub- Committee (as described under Item 12) receives monthly reports on all trading errors. DIMA has policies and procedures in place to address guideline breaches. The DIMA Americas Investment Risk Oversight Committee is responsible for monitoring investment performance of client accounts on a regular basis and performing an annual product review. Annually: In addition to the aforementioned trade reviews, institutional account reviews are also performed at least annually by DIMA Client Service. DIMA may actively participate in a client's Board and Investment Committee presentations as well as provide regular performance reviews to the client. Reports to Clients The nature and frequency of reports to clients is primarily determined by the particular needs of the client, as negotiated with the client. Written client account reports are generally sent to clients on at least a quarterly basis and generally include holdings in the account with relevant transactions. Clients are also advised in writing or via telephone conversation of any material investment changes in their portfolio and per the individual client's requirements. Wrap Accounts: Wrap Sponsors typically receive market commentaries prepared by DIMA and generally send such commentaries onto wrap account clients. Wrap Sponsors also typically issue performance reports to clients on a quarterly basis. In addition, DIMA personnel who are knowledgeable about a client’s wrap account will be reasonably available to the client for consultation DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 70 please register to get more info

DIMA may compensate affiliates or non-affiliates for client referrals in accordance with Rule 206(4)-3 under the Investment Advisers Act, although it does not currently do so. The compensation paid to any such entity will typically consist of a payment stated as a percentage of the advisory fee. Employees of DIMA and/or its affiliates and/or third parties who refer or help solicit investment advisory clients may also be compensated based on a percentage of the investment advisory fee charged to that client. When required under the law, the policies and procedures require regulatory disclosure of the compensation arrangement between DIMA and the referring party. DIMA may be referred advisory clients by unaffiliated consultants that are retained by existing or prospective clients. These consultants may advise existing or prospective clients whether to engage or retain the services of DIMA as investment adviser. Additionally, while payments are not made in connection with any advisory client referral such as these, DIMA may make payments to investment consultants in order to attend industry- wide conferences sponsored by these consultants. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 71 please register to get more info

Custodian Statements Under Rule 206(4)-2 under the Advisers Act (the “Custody Rule”), DIMA has custody of the assets contained in the portfolios of certain private fund clients, because DIMA or an affiliate serves as the general partner of, or in a similar capacity for, such funds. Accordingly, DIMA is subject to the relevant provisions of the Custody Rule. Investors in such funds do not receive account statements from the custodian; rather, the pertinent funds are subject to an annual audit and the audited financial statements are distributed to each fund investor within the required time period. DIMA may also be deemed to have custody of client assets because assets are maintained with a related person as the qualified custodian or as the sub-custodian, or as a result of limited discretionary authority over certain client assets (i.e., the ability to take possession of client funds and/or securities). In these cases, DIMA’s clients generally receive statements from the qualified custodian at least quarterly. Clients are encouraged to review these statements carefully and compare statements received from DIMA with statements received from the qualified custodian. Comparing statements may allow clients to determine whether account transactions are proper. Clients who are not receiving statements from their account custodian at least quarterly, where applicable, are instructed to contact their client service representative. The assets of wrap account clients are typically deposited with the Wrap Sponsor or a qualified custodian selected by the Wrap Sponsor or client. DIMA is not involved in the selection or ongoing monitoring of client custodians for wrap account clients. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 72 please register to get more info

DIMA is retained on a discretionary or non-discretionary basis for client accounts. Clients who retain DIMA on a non-discretionary basis explicitly require that portfolio transactions be discussed in advance. Discretionary clients typically authorize DIMA to supervise and direct the investment and reinvestment of assets in an account, with full authority and at its discretion, subject to Client's investment policy or guidelines. DIMA’s advisory services are tailored according to investment policies and guidelines that are established contractually at the inception of the adviser-client relationship (as amended from time to time) in cooperation with the client. These policies and guidelines, which may include imposed restriction on investing in certain securities or types of securities assist DIMA in making investment decisions for the client as well as cover matters such as the degree of risk that the client wishes to assume, and the types and amounts of securities to make up the portfolio. As may be negotiated with each client, DIMA may delegate investment management authority for all or a portion of a client's accounts to an affiliate, including affiliates that may be outside the United States. The accounts that have been delegated will be managed in accordance with the investment policies of the affiliate. More information regarding the affiliated advisers, including applicable fees, may be available upon request. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 73 please register to get more info

DIMA has proxy voting responsibility for an advisory account as indicated in the investment advisory agreement, or pursuant to other delegated authority. DIMA has adopted a proxy voting policy and procedure (collectively, the "Guidelines"). The Proxy Voting Policy includes specific proxy voting guidelines that set forth the general principles DIMA uses to determine how to vote proxies for issuers in client accounts for which DIMA has proxy voting responsibility. DIMA believes that the Proxy Voting Policy is reasonably designed to ensure that client proxies are voted in the best economic interests of clients and to ensure that material conflicts of interest are avoided and/or resolved in a manner consistent with DIMA’s fiduciary duties under applicable law. The Guidelines set forth standard voting positions on a comprehensive list of common proxy voting matters. Guidelines are monitored and periodically updated based on considerations of current corporate governance principles, industry standards, client feedback, and the impact of the matter on issuers and the value of the investments, among other considerations. To avoid any conflicts, under normal circumstances, DIMA will vote proxies in accordance with the Guidelines or delegate to a third party to facilitate voting in accordance with the Guidelines. Any client proxy vote that is not addressed by specific client instructions, is not covered by the Guidelines, or is one in which DIMA believes that voting in accordance with the Guidelines may not be in the best economic interests of clients, will be evaluated and voted in accordance with the Proxy Voting Policy. In such circumstances, DIMA shall vote those proxies in accordance with what it, in good faith, determines to be the best economic interests of clients. Any proxy vote not covered by the Guidelines will be subject to prior review by the Conflicts of Interest Management Sub-Committee, established within DWS, which will investigate whether there are any material conflicts of interest in connection with a particular vote. The Conflicts of Interest Management Sub-Committee will review, for example, whether DIMA has any known potential conflict of interest that can be reasonably determined, with the relevant issuer as well as whether any person participating in the proxy voting process may have a conflict of interest personally. In the event that the Conflicts of Interest Management Sub- Committee determines that there is a material conflict of interest, DIMA will either follow the proxy voting recommendations of an independent third party or will obtain proxy voting instructions from affected clients. It is possible that actual proxy voting decisions by DIMA may benefit DIMA’s other clients, or businesses of DIMA or its affiliates. However, DIMA’s proxy voting decisions are made in accordance with its fiduciary responsibilities and are independent of such considerations. Clients can obtain a copy of the Proxy Voting Policy and Guidelines, or information about how DWS voted proxies with respect to securities held in their account, by calling their client service representative. It is the custodian’s fiduciary responsibility to send clients proxy materials. If a client precludes DIMA from voting proxies on its behalf, the client is responsible for directing the custodian to send proxy voting material directly to the client or to a voting agent the client has selected to vote proxies on its behalf. Clients who have delegated proxy voting responsibilities to DIMA may direct DIMA as to how to vote certain proxies on behalf of their accounts by contacting their client service representatives. Registered Investment Companies As reflected in the Guidelines, all proxies solicited by open-end and closed-end investment companies are voted in accordance with DWS’ policies and guidelines unless the investment company client directs DWS to vote differently on a specific proxy or specific categories of proxies. However, regarding investment companies for which DWS or an affiliate serves as investment adviser or principal underwriter, such proxies are voted in the same proportion as the vote of all other shareholders (i.e., “mirror” or “echo” voting). Master fund proxies solicited from feeder funds are voted in accordance with applicable provisions of Section 12 of the Investment Company Act of 1940. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 74 please register to get more info

This section is not applicable. DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 75 Additional Disclosures Business Continuity DIMA is committed to protecting its staff and ensuring the continuity of critical DIMA businesses and functions in order to protect the Deutsche Bank AG franchise, mitigate risk, safeguard revenues and sustain both stable financial markets and customer confidence. It is Deutsche Bank’s Group policy that every unit of Deutsche Bank develops, implements, tests and maintains appropriate, comprehensive and verifiable Business Continuity and Disaster Recovery strategies and plans in compliance with the goals and planning assumptions as defined by the policy. Class Action and Legal Proceedings DIMA generally does not act on behalf of client separate accounts (including sub-advised accounts) in any legal proceeding involving assets maintained in (and/or transactions effected for) the account. "Legal proceedings" include, but are not limited to, class actions, insolvency filings, SIPC filings and settlement filings. If DIMA receives documentation relating to such a legal proceeding DIMA will forward the documentation to the client and/or its trustee/custodian of record. Know Your Customer (“KYC”) and Customer Identification Program (“CIP) Policy To help the government fight the funding of terrorism and money laundering activities, U.S. laws require all financial institutions to obtain, verify, and record information that identifies each person and verifies the identity of each person who opens an account. KYC duties also mandate the on-going monitoring of relevant customer information. Deutsche Bank Americas (“DBA”) has established a U.S. Bank Secrecy Act and Anti-Money Laundering Compliance Policy (“AML Policy”), which applies to all DBA employees, all DBA offices and all DBA operations in the U.S., which includes, DIMA. KYC and CIP Policies are significant components of the AML Policy. DIMA is required to: _ Obtain at a minimum certain information such as an individual’s name, address, date of birth and social security number and a driver’s license, passport or other identity verification document. For Legal entities, it would include their formation documents and tax identification number. Information about the beneficial owners of legal entities may also be obtained _ Based upon its assessment of the level of risk, DIMA is allowed to collect as much information as it deems appropriate as well as request the source of funds and purpose of the investment _ KYC includes screening new and existing customers against Office of Foreign Assets Control Embargo and Sanctions lists as well as the lists of persons and/or legal entities compiled by the U.S. Department of Treasury pursuant to Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (US Patriot Act) and other lists such as the European Union Embargo and Sanctions list and the UN Embargo and Sanctions list _ KYC includes identifying customers unlawfully engaged in the Internet gambling business under Regulation GG, the Unlawful Internet Gambling Enforcement Act of 2006. _ KYC requires periodic review and update of a customer’s KYC information and screening against appropriate lists _ A customer’s refusal to provide KYC information can result in a decision to decline entering into a new client relationship or a decision to exit an existing customer relationship Privacy Notice DIMA collects information about clients from account application forms and other written and verbal information that clients provide to DIMA. DIMA uses this information to process the client's requests and transactions (for example, to provide them with additional information about services performed, to open an account for the client or to process a transaction). In order to service the client account and effect transactions, DIMA may provide the client’s personal information to firms that assist DIMA in servicing the client account, such as third party administrators, custodians and broker-dealers. DIMA also may provide the client’s name and address DWS Investment Management Americas, Inc. Form ADV Part 2A | 2019 76 to one of its agents for the purpose of mailing account statements and other information about DIMA's products and services to the client. DIMA generally requires these outside firms, organizations and individuals to protect the confidentiality of client information and to use the information only for the purpose for which the disclosure is made. DIMA does not provide customer names and addresses to outside firms, organizations, or individuals except in furtherance of its business relationship with clients, or as otherwise required or permitted by the law. DIMA will only share information about clients with those persons who will be working with it and its affiliates to provide products and services to clients and to manage DIMA’s relationship. DIMA maintains physical, electronic and procedural safeguards to protect our clients’ personal information. DIMA does not sell customer lists or individual client information. DIMA considers privacy fundamental to its client relationships and adheres to the policies and practices described below to protect current and former clients’ information. Internal policies are in place to protect confidentiality, while also allowing client needs to be served. Only individuals who have a business need to know in carrying out their job responsibilities may access client information. DIMA maintains physical, electronic and procedural safeguards that comply with federal and state standards to protect confidentiality. These safeguards extend to all forms of interaction with DIMA, including the internet. In the normal course of business, clients give DIMA non-public personal information on applications and other forms, on DIMA’s websites, and through transactions with DIMA or affiliates. Examples of the non-public personal information collected are name, address, social security number, and transaction and balance information. To be able to service client accounts, certain client information is shared with affiliated and non- affiliated third party service providers such as transfer agents, custodians, and broker-dealers to assist DIMA in processing transactions and servicing client accounts with DIMA. DIMA may also disclose non-public personal information about clients to other parties as required or permitted by law. For example, DIMA is required or it may provide information to government entities or regulatory bodies in response to requests for information or subpoenas, to private litigants in certain circumstances, to law enforcement authorities, or at any time it believes it is necessary to protect Deutsche Bank Group. 875 Third Avenue New York, NY 10022 Telephone number: 212-454-4500 www.dws.com

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