Genesis Investment Management, LLP (the “Firm”) specialises in managing investments in emerging market equities for institutional investors. Please see Item 7 of this Brochure for more information with respect to the Firm’s clients. The Firm provides such investment management services on a discretionary basis. The Firm was organised in the United Kingdom in 2004 but taking into account its predecessor entities, the Firm has been in business since 1989. The Firm currently has two corporate partners, ten individual partners and a trust and operates through a series of boards/committees and appointments described below. The Firm’s principal office is at 21 Grosvenor Place, SW1X 7HU United Kingdom. The Firm serves as an investment manager, investment adviser or sub-adviser to various clients, including, but not limited to, pension plans, endowments, foundations, investment companies and governmental entities. Please see Item 7 of this Brochure for more information with respect to the Firm’s clients.

Principal Ownership Affiliated Managers Group, Inc., a publicly-traded asset management company (NYSE: AMG) with equity investments in boutique investment management firms (“AMG”), owns a majority of the equity interests of the Firm. AMG holds its majority interest in the Firm indirectly through three wholly owned subsidiaries: AMG Genesis, LLC, AMG Atlantic Holdings Ltd and AMG New York Holdings Corp. AMG also holds equity interests in other investment management firms (“AMG Affiliates”). Each of the AMG Affiliates, including the Firm, is operated autonomously and independently, except, with respect to the Firm, as described in this Brochure. Further information on both AMG and AMG’s Affiliates is provided in Item 10. The remaining interest in the Firm is owned by ten individual partners, a corporate partner and a trust, which facilitates the recycling of partnership interests and future awards for the benefit of individual partners. Since the formation of the Firm in 2004, the individual partners in aggregate have held approximately 40% of the equity in issue and AMG have held the balance of 60%. After giving effect to the Reorganisation, the individual partners and trust in aggregate own approximately 41% of the equity in issue and AMG owns approximately 59%. Three of the individual partners and the trust each own more than 5%. The individual partners have each contributed capital to the Firm and entered into a commitment to remain in the Firm for a minimum fixed period. Nine of these partners are Investment Team members and the tenth partner serves as the Managing Director and Chief Compliance Officer (“CCO”). Further details on these individuals are included in the Brochure Supplement.
The Firm
The Firm is registered in England and Wales as a limited liability partnership and has 60 employees, including clerical, part-time staff and contractors, working in its London office as of the 31st December 2019. The Firm’s Governing Board is comprised of three senior AMG representatives and two Genesis representatives. The Governing Board deals by exception with major corporate matters including the admissions or retirement of individual partners. Authority to set policy on all other matters, including investment management policy, is delegated to the Firm’s Operating Board under the Firm’s partnership agreement. The Firm is managed by the Operating Board which is comprised of the Joint Managing Partners, the Managing Director (who is also CCO), and two independent non-executive members. The Operating Board has overall responsibility for managing the Firm. The day-to-day business is overseen by several formal committees which include the PCT (Investment), Operations Executive Committee (“OpEx”), Group Audit Committee and Group Risk Committee In addition to the formal committees, certain matters are delegated to a number of management committees, including the Valuation Committee, Risk Management Committee, Business Continuity and Cyber Security Committee, Product Governance Committee, Service Provider Oversight Committee and Conduct Breach Committee. Such committees meet regularly and are comprised of partners, directors and certain members of staff. Further details of the roles and responsibilities of some of these committees are set forth below. Genesis Group Structure and Reorganisation The “Genesis Group” is organised as two interlocking entities, both of which are registered as investment advisers under the Investment Advisers Act of 1940. Prior to the Reorganisation, Genesis Asset Managers, LLP (“GAM”) was the parent of the Genesis Group and was appointed by clients as an investment manager/adviser. Upon consummation of the Reorganisation effective after the close of business on 30th June 2019, the Firm (formerly a subsidiary of GAM) became the parent of the Genesis Group and assumed ownership and substantially all of the assets and liabilities of GAM, with the exception of the QFII Securities. After the Reorganisation, clients of the Genesis Group appoint the Firm as their investment manager/adviser and the Firm delegates to GAM certain of its responsibilities relating to the QFII Securities. The delegation of the Firm’s investment management responsibilities to GAM is set forth in a written QFII Agency Agreement. The consummation of the Reorganisation did not result in a change in the form of organisation of the Firm, a dissolution of the Firm, nor a change in the state or territory in which the Firm is organised. After giving effect to the Reorganisation, AMG remains as the owner of a majority of the economic interests of the Genesis Group. After the transfer of GAM’s client investment management agreements or equivalent documents to the Firm as part of the Reorganisation, investment advisory services continue to be provided by the Firm, which is a registered investment adviser under the Investment Advisers Act of 1940. Although each of GAM and the Firm are registered as investment advisers under the Investment Advisers Act of 1940, such registration does not imply that GAM, the Firm or their respective personnel have a certain level of skill or training. More details on GAM are available on the SEC’s website at www.adviserinfo.sec.gov.

Advisory Services The Firm aims to generate excellent long-term investment performance in emerging market equities for institutional clients. In general, the Firm may invest client assets in the following securities and instruments: equity securities, listed and unlisted securities, securities traded over the counter, non-U.S. securities, warrants, private placements, rights offerings, open-end funds, convertible bonds and preferred stock. The Firm primarily utilises its own independent research and analysis and uses a bottom-up investment approach to create a diversified portfolio of emerging market equities. The Firm does not construct portfolios with reference to an index. The Firm believes that it can best deliver excellent long-term investment performance by working as a team to make investments in quality businesses at attractive prices.

The Firm’s emerging markets opportunity set consists of countries defined as low- and middle-income economies by the World Bank as well as high income economies (such as South Korea and Taiwan) included in the major emerging markets benchmark indices. In addition, the Firm’s client portfolios may also contain companies that are listed on the stock markets of high-income economies, but that generate a significant proportion of their revenues, profits or cashflow from, or whose assets or intellectual property are mostly located in emerging markets. As a general principle, the Firm does not use derivatives to supplement investment strategy and the Firm does not short stock. The Firm may also invest in depositary receipts, synthetics or participation notes if direct local holdings in a market are not permitted or less advantageous. In addition, the Firm may engage in a securities lending programme for its sponsored pooled investment vehicles. The Firm does not hedge directly against currency fluctuations between the currencies of emerging markets stocks and its base currency of US$. As a specialist manager in emerging market equities, the majority of client portfolios follow a similar global emerging market investment strategy. However, the Firm recognises that all of our clients are unique and therefore, their investment needs may be different. As such, we may modify our core global emerging market equity strategy, as necessary, to meet the goals that our clients specify, in order to accommodate the particular investment objectives and accompanying restrictions requested by our clients. At the commencement of the client relationship for a separate account client, each of such clients executes an investment management agreement, which sets forth their investment objectives, investment strategy and any investment restrictions that will be applicable to our management of the assets in the client’s account. Prior to the execution of the agreement, we review requested objectives and restrictions and work with the client as needed to refine these objectives and restrictions to both meet the client’s needs and provide us with sufficient discretion to properly invest the client’s assets. For example, some clients do not permit investment in the securities of companies which operate in certain countries, or which produce alcohol or are involved in the gambling industry. With respect to the management of pooled vehicles, the investment objectives and restrictions are set forth in the relevant offering document.

Wrap Fee Programmes The Firm does not have any involvement in wrap fee programmes whereby clients select an investment adviser to manage funds through an investment programme presented to the clients by a third-party programme sponsor and clients generally pay the wrap programme sponsor a single fee (called a “wrap fee”) for consulting, brokerage, custodial, portfolio monitoring, and investment management services and such sponsor pays a portion of the wrap fee to the investment adviser.

Foreign Exchange (“FX”) Transactions Foreign exchange transactions for client accounts are generally limited to those necessary to settle trades in emerging market securities which are not denominated in US$. The key factors in informing the Firm’s approach on FX are: FX is not a discretionary part of the investment management process; FX transactions are undertaken to minimise operational risk and maximise efficiency and best execution. The Firm does not hedge directly against currency fluctuations between the currencies of emerging markets stocks and uses a base currency of US$. For its pooled vehicles and as instructed by several segregated account clients, the Firm has the ability to execute FX transactions in certain currencies through an FX trading platform operated by a third-party provider. For the majority of its segregated account clients, it is the responsibility of the client’s appointed custodian to handle FX transactions. The Firm can instruct a third-party provider to execute FX transactions on a client account’s behalf if requested by the client. For clients who have not elected to use the FX platform, the Firm will instruct the client’s custodian to execute the necessary FX transaction. This is done either through standing instructions communicated to the custodian when the account is established or at the time settlement instructions are sent to the custodian for a particular transaction. The custodian is responsible for executing FX transactions, including the timing and applicable rate of such execution pursuant to its own internal processes. Where a client has arrangements in place with its custodian regarding the execution of FX transactions, such arrangements may impact the overall fees and expenses charged to the client by the custodian. Therefore, all such FX transactions are effected with the client’s custodian, and the Firm does not seek to obtain different FX rates from other sources. Because of various local limitations regarding transactions for some restricted currencies, transactions in restricted currencies are often effected by each client’s custodian pursuant to standing instructions (both pooled vehicles and separate account clients). The Firm also instructs other types of FX transactions, such as those related to dividend and interest repatriation. Where possible such FX activity will utilise an FX trading platform. Where required the Firm will issue standing instructions to each client’s custodian to fulfil these FX transactions. Assets Under Management As of 31st December 2019, the Firm’s client assets under management total (“AUM”) was US$20.8 billion. Of this, the Firm delegated management of US$248 million to GAM, which is comprised of the value attributable to the QFII Securities. Please see Firm’s Form ADV Part 1A – Item 5.F for more information.
Other Jurisdictions
The Firm also provides financial services to institutional clients in other countries including Canada, and in Australia where it is exempt from the requirement to hold an Australian financial services licence under the Corporations Act 2001 in respect of the financial services it provides. The Firm is registered with the SEC under U.S. laws and the financial services are regulated by the FCA under UK Laws, which differ from Australian Laws. please register to get more info

The Firm’s standard fee schedule for a new segregated account for global emerging market equities is set forth below:
Assets under management Annual fee rate
up to and including US$100,000,000 Zero point ninety five percent (0.95%) per annum from US$100,000,000 up to and including US$250,000,000 Zero point seventy five percent (0.75%) per annum from US$250,000,000 up to and including US$400,000,000 Zero point sixty five percent (0.65%) per annum from US$400,000,000 up to and including US$600,000,000 Zero point sixty percent (0.60%) per annum from US$600,000,000 up to and including US$750,000,000 Zero point fifty five percent (0.55%) per annum Flat rate on all assets if investors’ total net asset value is above US$750,000,000 Zero point fifty five percent (0.55%) per annum Notwithstanding this fee schedule, and subject to applicable laws and regulations, the Firm retains discretion over the fees that it charges to its clients, as well as any changes in its fee schedules. Fees may be negotiated in the Firm’s sole discretion in light of a client’s special circumstances, such as asset levels, service requirements or other factors. In some cases, the Firm may agree to offer clients a fee schedule that is lower than that of any other comparable clients in the same investment style. In addition, there may be historical fee schedules with longstanding clients that differ from those applicable to new client relationships. At the discretion of the Firm, clients may opt to have their fees deducted from their assets or to be billed separately for fees incurred. For comparable services, other investment advisers may charge higher or lower fees than those charged by the Firm. The above fees are payable quarterly in arrears and are charged either on the valuation of the portfolio at each quarter end or on the average of the month-end or daily valuations during each quarter as specified by the client. The Firm does not have the authority to deduct its fees from client accounts. Fees are also prorated at the inception of the investment advisory agreement to cover only the period of time the account assets were under management. This standard fee schedule may be modified from time to time. No minimum fee per annum is set by the Firm but the Firm has imposed a minimum initial investment level for a segregated account. See Item 7. Certain clients are charged fees based on the management fee scale in place at the time such client first placed assets under management with the Genesis Group. Thus long term clients may be charged a different management fee scale to that set forth above. For certain clients which have multiple accounts managed by the Firm (either in a separately managed account and/or holdings in pooled vehicles), provided the investment guidelines are substantially similar and that the clients are serviced as a single client relationship, the Firm may agree to aggregate such related accounts and apply the relevant management fee scale to the total assets for purposes of calculating the management fee. This may be referred to as ‘family pricing’. Dependent on the instructions of the client, the settlement of such aggregate fees can be made either through a credit against the fees (which may in turn be used to purchase additional units or reduce any redemption of units) and/or a subscription by the Firm on behalf of such client in the pooled vehicle(s). Clients are provided invoices or statements reflecting the fee calculations with respect to such aggregation of assets on a regular basis and have agreed to such treatment. Performance fees on a segregated account may also be available under certain conditions and subject to applicable law; however performance fees are not available on the Firm’s standard global emerging markets portfolios.

Fees for Specialised Accounts and Funds
Sub‐advisory Arrangements
The Firm has been engaged by certain investment advisers (including advisers to non-US registered investment companies) to manage certain accounts of such advisers. In its capacity as “sub-adviser” to such accounts, the Firm’s fees and services are determined by contract with the adviser. Information concerning these sub-advised funds including a description of the services provided and advisory fees, is generally contained in the fund’s prospectus, which can be obtained from the fund sponsor. Other fees payable as an investor in a sub-advised fund or other account are described below, and also in the sub-advised fund’s prospectus or the adviser’s fee brochure or client investment management agreement.

Private Pooled Investment Vehicles Sponsored by the Firm The Firm sponsors various privately-offered pooled investment vehicles, including domestic and non-US global emerging market equity. These entities are neither registered under the Securities Act of 1933, nor registered under the Investment Company Act of 1940. Accordingly, interests in these funds are offered exclusively to investors satisfying the applicable eligibility and suitability requirements either in private placement transactions within the United States or in offshore transactions. No offer to sell these funds is made by the descriptions in this Brochure, and as noted these funds are available only to investors that are properly qualified. The standard management fee schedule for a new investor in a global emerging markets fund is set forth below:

Assets under management Annual fee rate
up to and including US$100,000,000 Zero point ninety percent (0.90%) per annum from US$100,000,000 up to and including US$250,000,000 Zero point seventy five percent (0.75%) per annum from US$250,000,000 up to and including US$400,000,000 Zero point sixty five percent (0.65%) per annum from US$400,000,000 up to and including US$600,000,000 Zero point sixty percent (0.60%) per annum from US$600,000,000 up to and including US$750,000,000 Zero point fifty five percent (0.55%) per annum Flat rate on all assets if investors’ total net asset value is above US$750,000,000 Zero point fifty five percent (0.55%) per annum The above fees are payable monthly in arrears and are calculated on the valuation of the funds under management of each individual investor in the pooled fund. The minimum initial subscription in such a fund is currently US$75 million but this minimum may be amended at any point subject to the Firm’s internal or regulatory approvals required. Also such minimum may be achieved in tranches at the discretion of the Firm. See also Item 7. Certain clients are charged fees based on the fee scale in place at the time such client first placed assets in the fund. Thus long-term investors in the Firm’s pooled vehicles may be charged a different fee scale and such fee scale may be calculated in a different manner. For certain clients which have as their primary account with the Firm a separately managed portfolio and also assets invested in a pooled fund or fund(s) under the management of the Firm, the Firm may aggregate such client’s assets and apply the segregated account fee scale to the aggregate for the purpose of calculating management fees. Dependent on the instructions of the client, the settlement of such aggregate fees can be made either through a credit against the fees of the segregated portfolio and/or a subscription by the Firm on behalf of such client in the pooled vehicle(s). The Firm also provides investment management services to a Guernsey organised, closed end fund which pays the Firm 0.90% per annum of the fund’s assets under management. The Firm waives management fees and performance fees on investments in its funds by eligible Genesis individuals. Other fees payable as an investor in a privately-offered investment vehicle sponsored by the Firm are set forth in the fund’s offering memorandum or other relevant document.

Additional Fees and Expenses Payable by Clients The Firm’s fees are exclusive of brokerage commissions, transaction fees, service provider fees (e.g., fund administrator, and securities lending agent), and other related costs and expenses which will be incurred by the client. Execution of client transactions typically requires payment of brokerage commissions by clients. Item 12 entitled “Brokerage Practices” further describes the factors that the Firm considers in selecting or recommending brokers for the execution of transactions and determining the reasonableness of their compensation (e.g., commissions). Investment activity may also involve other transaction fees payable by clients, such as sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. In addition, clients may incur certain charges imposed by custodians, depositaries, broker/dealers, third-party investment consultants, and other third parties, such as custodial fees, consulting fees, administrative fees, and transfer agency fees.
Fees for Investment of Client Assets in Third Party Mutual Funds, Private Funds, and Other
Pooled Investment Vehicles At times and only if permitted under the relevant investment guidelines, the Firm may invest client assets in funds (including money market funds or similar short-term investment funds) or other pooled investment vehicles sponsored by third parties. To the extent that a client’s assets are invested in other pooled vehicles, the client will also typically pay management and/or other fees (such as performance fees) to each such fund or other pooled vehicle that are in addition to the fees paid by the client to the Firm. Those fees are described in each pooled vehicle’s offering documents (e.g., prospectus or offering memorandum). Such charges, fees, and commissions are exclusive of, and in addition to, the Firm’s fee.

Fees for the Sale of Securities Neither the Firm nor its partners or employees receive, directly or indirectly, any compensation from the sale of securities or investments that are purchased or sold for a client’s account. The Firm is compensated through the stated management fee agreed upon in the investment management/advisory agreement. Accordingly, the Firm believes that it does not have any conflicts of interest regarding the receipt of additional compensation relating to the client assets that it manages, except as specifically disclosed from time to time. please register to get more info

Performance‐Based Fees While the Firm generally does not offer performance-based fee arrangements, from time to time, the Firm may agree to such a structure in light of various client requests and in accordance with applicable regulations regarding performance-based fees. A performance-based fee is a fee representing an asset manager’s compensation for managing an account which is based upon a percentage of the net profits of the account being managed. When calculating net profits, performance-based fees may be based on absolute or benchmark relative returns. For accounts with specific investment restrictions, performance- based fees may be agreed. In any event, we may have both performance-based fee accounts and asset- based fee accounts within a similar investment strategy. Performance-based fees create certain inherent conflicts of interest with respect to the Firm’s management of assets. Specifically, the Firm’s entitlement to a performance-based fee in managing one or more accounts may create an incentive for the Firm to take risks in managing assets that the Firm would not otherwise take in the absence of such arrangements. Additionally, since performance-based fees reward the Firm for strong performance in accounts which are subject to such fees, the Firm may have an incentive to favour these accounts over those that have only asset-based fees (i.e., fees based simply on the amount of assets under management in an account) with respect to areas such as trading opportunities, trade allocation, and allocation of new investment opportunities. The Firm does not receive performance based fees for its investment management services. To maintain fair and equitable treatment of all accounts, the Firm has implemented specific controls to further its efforts to treat all accounts fairly, regardless of their corresponding fee-structure.
• The Firm’s portfolio and dealing procedures are designed to ensure that all eligible portfolios (segregated accounts and pooled vehicles) have an equal opportunity to participate in any investment opportunity at the same time. This includes IPOs and limited offerings.
• Trades are allocated on a pro-rata basis across eligible client accounts unless there are specific business reasons to allocate otherwise. Partial fills are allocated pro-rata unless they are so small that this is uneconomic (less than US$5,000).
• Holdings of client portfolios are reviewed on a regular basis by the relevant members of the Investment Team (PCT). See Item 8.
• Monthly cross comparison by the Performance Team of client portfolios with similar mandates. Regular Investment Team (PCT) review of such findings including full review of performance, attribution and omissions.
• Allocations are tested internally on a semi-annual basis as a part of trade execution monitoring.
• Relevant controls are externally reviewed as part of the AAF Report on Internal Controls.
• A written Conflicts of Interest Policy is maintained and reviewed at least annually. See Item 11. These activities, along with other controls existing in our organisation, provide an environment that fosters the fair and equitable treatment of all accounts managed by the Firm.

Side‐by‐Side Management As a specialist in emerging market equities, (core product – one format), the Firm’s investment professionals simultaneously manage multiple types of client portfolios (including separate accounts and pooled funds) according to the same or a similar investment strategy (i.e., side-by-side management). The simultaneous management of these different portfolios creates certain potential conflicts of interest, as the fees for the management of certain types of client accounts may be higher than others. Nevertheless, when managing the assets of such accounts, the Firm has an affirmative duty to treat all such accounts fairly and equitably over time. Although the Firm has a duty to treat all portfolios within an investment strategy fairly and equitably over time, such portfolios will not necessarily be managed the same at all times. Specifically, there is no requirement that the Firm use the same investment practices consistently across all portfolios. In general, investment decisions for each client account may be made independently from those of other client accounts, and will be made with specific reference to the individual objectives of each client account. Furthermore, different client guidelines and/or restrictions, operational issues such as custody facilities and availability of cash, may lead to the use of different investment practices for portfolios within a similar investment strategy. As a result, although the Firm manages numerous portfolios with similar or identical investment objectives, or may manage accounts with different objectives that trade in the same securities, the portfolio decisions relating to these accounts, and the performance resulting from such decisions, may differ from portfolio to portfolio. Since side-by-side management of various types of portfolios raises the possibility of favourable or preferential treatment of a portfolio or a group of portfolios, the Firm has procedures designed and implemented in furtherance of its efforts to treat all portfolios fairly and equally over time. By utilising the following procedures, the Firm believes that portfolios that are subject to side-by-side management alongside other products are receiving fair and equitable treatment over time.
• The Firm’s portfolio and dealing procedures are designed to ensure that all eligible portfolios (segregated accounts and pooled vehicles) have an equal opportunity to participate in any investment opportunity at the same time. This applies to IPOs and limited offerings.
• Trades are allocated on a pro-rata basis across eligible client accounts unless there are specific business reasons to allocate otherwise. Partial fills are allocated pro-rata unless they are so small that this is uneconomic.
• Holdings of client portfolios are reviewed on a regular basis by the relevant members of the Investment Team (PCT). See Item 8.
• Monthly cross comparison by the Performance team of client portfolios with similar mandates. Regular Investment Team (PCT) review of such findings including full review of performance, attribution and omissions.
• Allocations are tested internally on a semi-annual basis as part of trade execution monitoring.
• Relevant controls are externally reviewed as part of the AAF Report on Internal Controls.
• Written Conflicts of Interest Policy maintained and reviewed at least annually. See Item 12. These activities, along with other controls existing in the Firm, provide an environment that fosters the fair and equitable treatment of all accounts managed by the Firm. please register to get more info

Types of Clients The Firm provides portfolio management services to institutional clients including corporate pension and certain defined contribution plans, Taft-Hartley plans, public pension plans, charitable institutions, foundations, endowments, registered mutual funds (on a sub-advisory basis), private investment funds, limited partnerships, trust programmes, sovereign funds, foreign collective investment funds such as SICAVs (Société d’Investissement A Capital Variable), and other U.S. and international public, quasi- public, and private institutions.

Conditions for Managing Accounts As a general rule, the Firm currently requires a minimum account size of US$75 million for institutional investors in its pooled funds and US$400 million for segregated client accounts. However, the minimum account size may be waived or modified at the Firm’s discretion. Lower minimums have applied in the past. Generally, the Firm requires each client to execute an investment management agreement that details the nature of the discretionary investment advisory authority given to the Firm. With respect to investments in pooled vehicles established by the Firm, a summary of the terms of the investment management agreement as between the pooled vehicle and the Firm are generally set forth in the offering document for such fund. The Genesis Group had been closed to new clients since November 2011, and any new subscriptions from existing clients since January 2015. In November 2018, Genesis Group took the decision to reopen to limited new subscriptions in the second quarter of 2019, capping inflows as a percentage of prior-year outflows. The Genesis Group’s intention with this soft reopening was to accommodate existing clients who are growing, and potentially welcome a limited number of new clients for the first time in eight years. The Genesis Group expects to remain capacity constrained but soft-opened for new assets for the foreseeable future. please register to get more info

Strategy Overview The Firm is a discretionary asset management firm specialising in emerging market equities. All client portfolios consist of global emerging market equities. The Firm uses a pure bottom-up investment approach and the Firm follows a stock-picking investment philosophy. The Firm believes that it can best deliver excellent long-term investment performance by working as a team to make investments in quality businesses at attractive prices. The Firm has a long-term investment horizon. The Firm’s primary emphasis is on the analysis and interpretation of information from individual companies operating in emerging markets. The Firm expects to create value for its clients through its analysis and valuation of businesses rather than through macro-economic forecasting. At the same time, investment judgement requires the incorporation of macro-economic risks. Client portfolios are diversified across countries and industries and are comprised of approximately 100- 120 holdings. The Firm concentrates on a limited number of ideas so that its research can be deeper and our insights more valuable. The average holding period of investments in client portfolios has been over five years and the Firm expects this characteristic to persist. Investment Process The Investment Team is structured to enable a cohesive team of experienced investors to generate fundamental research insights and, subject to rigorous challenge, express those insights in client portfolios. The primary division is by country but team members also take responsibility for global industry research. All the Investment Team members are based in a single office. Portfolio managers directly oversee clients’ portfolios and are individually accountable for investment decisions. At the same time, Investment Partners—as the owner-operators of Genesis—share overall responsibility for the performance of clients’ portfolios. The Firm aims to reflect investment ideas in portfolios at weights that can make a meaningful contribution to performance. Weighting decisions require a deep understanding of a business and expected returns based on various scenarios. Weighting also requires a good knowledge of the existing portfolio including the competing ideas. Portfolio weights take into account conviction, quality of company, expected return, investability and correlated risks. The Portfolio Coordination Team (PCT) is comprised of a three-member sub-group of the Investment Team, including the Managing Partner (permanent member), the Chair and a rotating third member, plus one representative of the Risk Management Committee who is functionally and hierarchically separate from the Investment Team. Its primary role is to:
• Ensure that Investment Team members act in accordance with our agreed process
• Analyse, and provide feedback to team members about portfolio risk and return
• Coordinate and initiate process improvements and investment discussions The PCT operates on behalf of the team and acts in a manner which preserves our shared ownership of the process and honours our non-hierarchical organisational philosophy. The PCT does not make investment decisions. For any purchase or sale in client portfolios, the Firm requires:


• A Portfolio Manager recommendation: All recommendations are circulated to the entire investment team. Portfolio Managers need to allow a reasonable period for any feedback. A Portfolio Manager recommendation requires the presence of: - The investment case document - The valuation model stored on our investment database, providing an assessment of the intrinsic value (IV) of the business - A recommended portfolio weighting and price limit


• Portfolio Coordination Team (PCT) approval - Evidence that the process has been followed - Consideration of the recommended investment’s effect on portfolio risk and return Once these requirements have been met, both the investment and its weighting are the responsibility of the Portfolio Manager.
Modelling and Valuation
To enhance returns we aim to invest at a discount to IV. Spreadsheet models are the tools we use for the IV assessment. Our valuation yardstick is the five-year annualised expected return expressed in U.S. dollars.
• Fair value: We believe a 10% US$ expected return annualised over five years represents a reasonable long-term return for our clients
• While our spreadsheet models reflect reasonable base case scenarios, our IVs reflect our best estimate of what businesses are worth. Dispersion of outcomes around the IV informs the portfolio weighting. Our investment database provides a standardised output to enable the comparability of our valuation models. Models are a tool not only for assessing intrinsic value, but also for providing the rest of the team with a transparent description of the drivers of that value. The model helps back-ups, sector specialists, the broader team and the PCT to provide robust, constructive challenge. Risk Management The most relevant way to think of investment risk is, in our view, the risk of disappointing investment returns, either on an absolute or relative basis. This risk manifests in two ways:
• Stock-specific risk: holdings where disappointing fundamental performance results in poor client investment returns
• Portfolio risk: performance risks across groups of holdings and benchmark omissions, relating to the way in which the portfolio has been constructed We manage risk in several ways, including:
• Our philosophy encourages risk management. By making investments in quality businesses at attractive prices we mitigate the risk of intrinsic value erosion and the risk of over-payment.
• Our process encourages risk management. Constructive challenge from other team members serves to alert portfolio managers of any risks and opportunities they may not have considered fully.
• The PCT plays a key role in risk management
• Despite the various risk management measures, our process places a significant responsibility on portfolio managers. The risk that a portfolio manager fails to generate performance over a prolonged period, despite following our process, is real. This risk is managed by the Managing Partner, who is responsible for managing Investment Team resources. We do not track any benchmark index but, to mitigate relative risk, the largest stocks in the investable universe are regularly reviewed in team discussions.

Related Risks Investment in emerging markets involves a multitude of risks. All emerging market securities include a risk of loss of principal and any profits that have not been realised. The stock markets, on which such emerging market securities trade, can fluctuate substantially and performance of any investment is not guaranteed. As a result, there is a risk of loss of the assets the Firm manages on its clients’ behalf, and such a loss may be out of our control. We cannot guarantee any level of performance and cannot guarantee that clients will not experience a loss of account assets. Investment in emerging markets may involve additional risks not typically associated with investing in high-income economies. Such risks include but are not limited to those specifically discussed below. Some of the emerging market countries have securities markets to which foreign investors have only limited direct or indirect access, while others have securities markets to which foreign investors do not presently have access. While the Firm would expect that at some time in the future some or all of these markets will become accessible to foreign investors, there can be no assurance that this will be the case. In certain emerging market countries, portfolio investment by foreign investors may require consents or be subject to limitations, and repatriation of investment income, capital and the proceeds of sales by foreign investors may require government registration and/or approval. A client’s portfolio could be adversely affected by delays in or a refusal to grant any required government approval or licence or by the lack of availability of foreign exchange. A client’s portfolio will be invested in securities of companies in various countries and income will be received by the client in a variety of currencies. However, the Firm will compute the portfolio’s net asset value in US dollars. The value of the assets of the client’s portfolio as measured in U.S. dollars may be affected favourably or unfavourably by fluctuations in currency rates and exchange control regulations. The Firm does not hedge against currency movements or other risks. Further, the client’s portfolio may incur costs in connection with conversions between various currencies. Companies in emerging market countries are not always subject to accounting, auditing and financial reporting standards, practices and disclosure requirements comparable to those applicable to companies in high-income economies. As a result, investment decisions may be based on less accurate and limited information. In addition, there is generally less government supervision and regulation of business and industry practices, stock exchanges, brokers and listed companies in emerging market countries than in countries with more advanced securities markets. Capital requirements for brokerage firms are generally lower in emerging market countries. Further, foreign investors may encounter difficulties or be unable to pursue legal remedies and obtain judgments while practical settlement difficulties are more common than in high-income economies. Part of a client’s portfolio will generally be invested (directly or indirectly) in the securities of small or medium capitalisation companies. Such securities may have a more limited market than the securities of larger companies. Accordingly, it may be more difficult to effect sales of such securities at an advantageous time or without a substantial drop in price than securities of a company with a large market capitalisation and broad trading market. In addition, securities of small or medium capitalisation companies may have greater price volatility as they are generally more vulnerable to adverse market factors such as unfavourable economic reports. Additionally, some of the companies in whose securities a client’s portfolio may be invested may have limited operating histories. Such businesses may be characterised by a lack of (i) market-oriented experienced management, (ii) modern industrial technology and (iii) a sufficient capital base with which to develop and expand their operations. As a result, the availability, quality and reliability of corporate information and equity research (including official data) is likely to be lower than that which is used to evaluate investments in high-income economies, with the attendant risk that pricing decisions may be less than optimal to the extent they are based upon inaccurate or insufficient information. Brokerage commissions, custodial services, and other costs relating to investment activities are generally more expensive in emerging market countries than in high-income economies. Such markets have different clearance and settlement procedures, which can be less developed and reliable. Certain emerging market countries’ markets use physical share delivery settlement procedures. Satisfactory custodial services may be unavailable and the client may be exposed to risk in circumstances in which the custodian and sub-custodian have no or limited liability or where recovery may be conditioned on the ability to recover in the relevant market. In such instances, the client may be required to bear the full custody risk in such countries in order to access such investments. Furthermore, the client may experience additional cost and delays in transporting and maintaining custody of securities outside such countries. In such circumstances there may be share registration and delivery delays, and settlements may lag, making it difficult to close securities transactions. Inability to dispose of a security on a timely basis due to settlement problems could result in losses to the client. A client’s portfolio may be invested in participation notes or similar equity linked instruments issued by a bank or broker-dealer to access certain markets where direct investment is not available or permitted. Investments in such participation notes involve the same risks associated with a direct investment in the securities of the underlying company that they seek to replicate and are also subject to the risk that the issuer of the participation note will not fulfil its contractual obligations. A client’s portfolio may have exposure to local shares which are held in the legal name and/or account set up by the Firm or its affiliates in order to satisfy local requirements including for example, local China A-shares held under the Qualified Foreign Institutional Investor (“QFII”) and Renminbi Qualified Foreign Institutional Investor (“RQFII”) programmes. Such holdings are subject to the rules and restrictions under QFII and RQFII regulations including rules on investment restrictions, minimum investment holding period and repatriation of principal and profits. The uncertainty and change of the laws and regulations may adversely impact the client and the rules and regulations which regulate QFII and RQFII investment are also subject to changes. The client may also have exposure to China A-shares which are transacted through the cross border investment channel between Hong Kong and the Mainland China, called Stock Connect. Stock Connect is subject to quota limitations which may restrict the Genesis Group’s ability to deal via Stock Connect on a timely basis. This may impact the Genesis Group’s ability to implement its investment strategy effectively. In many of the emerging market countries there may be limited organised public trading markets for securities with little liquidity or transparency, resulting in relatively slow and cumbersome execution of transactions. In particular, there may be no approved settlement procedure and trades may be settled by a free delivery of stock with payment of cash in an uncollateralised manner. This may give rise to a credit risk in relation to the counterparty. In general there may be an increased risk of defaults and delays in settlement compared to the markets in high-income economies. As a result, a client may experience difficulty in realising all entitlements attaching to the securities acquired. A client’s portfolio may be engaged in a securities lending programme. Securities lending involves the risk of loss of rights in the collateral or delay in recovery of the collateral if the borrower fails to return the security loaned or becomes insolvent. There is also a risk of loss if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, declines. Other risks associated with securities lending include delayed settlement, failed delivery, and the inability to vote proxies or respond to corporate actions in a timely manner. Securities lending may also have certain adverse tax consequences. Reduced secondary market liquidity in emerging market countries may have an adverse effect on market price and a client’s ability to dispose of particular instruments when necessary to meet its liquidity requirements or in response to specific economic events such as deterioration in the creditworthiness of the issuer. Reduced secondary market liquidity for certain emerging market securities may also make it more difficult for a client to obtain accurate market quotations for purposes of valuing its portfolio and calculating its net asset value. Market quotations are generally available on many emerging market securities from only a limited number of dealers and may not necessarily represent firm bids of those dealers or prices for actual sales. The banking and other financial systems of many emerging market countries are not all well developed or well regulated. Delays in transfers by banks may result as may liquidity crises and other problems arising as a result of the under-capitalisation of the banking sector as a whole. A general banking crisis in any of the emerging market countries would have a material adverse impact on a client’s portfolio. Some emerging market countries have experienced substantial rates of inflation in recent years. Inflation and rapid fluctuations in inflation rates have had, and may in the future have, negative effects on the economies and securities markets of certain emerging economies. There can be no assurance that inflation will not become a serious problem in the future and have an adverse impact on a client’s investments in these countries or a portfolio’s returns from such investments. A client’s portfolio will generally be invested in countries where the market economy is relatively less developed. Although the recent general trend in such countries has been towards more open markets and the promotion of private business initiatives, no assurance can be given that the governments of these countries will continue to pursue such policies or that such policies may not be altered significantly. The legal and tax system of many emerging market countries is less predictable than most legal systems in countries with fully developed capital markets. Currently, the tax rules and regulations prevailing in many emerging market countries are, as a general matter, either new or under varying stages of review and revision, and there is considerable uncertainty as to whether new tax laws will be enacted and, if enacted, the scope and content of such laws. Reliance on oral administrative guidance from regulators and procedural inefficiencies hinder legal remedies in many areas, including bankruptcy and the enforcement of creditors’ rights. There can be no assurance that current taxes will not be increased or that additional sources of revenue or income, or other activities, will not be subject to new taxes, charges or similar fees in the future. Any such increase in taxes, charges or fees payable by the portfolio companies may reduce the returns for clients. In addition, changes to tax treaties (or their interpretation) between countries in which a client’s portfolio is invested and countries through which a client conducts its investment programme may have significant adverse effects on a client’s ability to efficiently realise income or capital gains. Consequently, it is possible that a client may face unfavourable tax treatment resulting in an increase in the taxes payable on their investments. With respect to certain countries, there is a possibility of nationalisation, expropriation, annexation, government regulation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains or other income, limitations on the removal of funds or other assets of a client, and political or social instability, diplomatic developments (including war, imposition of sanctions and asset freezing) or terrorism, organised crime of other factors that could affect investments in those countries. Such events may also limit, interfere and/or delay the pricing or trading of securities in the stockmarkets of such countries for significant periods of time. Furthermore, with respect to certain countries, the United States, the European Union or other governmental entities may impose economic sanctions against companies operating in specific countries, sectors or in association with identified individuals. These sanctions could impact a client’s investment in certain countries or securities. For example, a client may be prohibited from investing in securities issued by companies subject to such sanctions. In addition, the sanctions may require the client to freeze its existing investments in certain companies, prohibiting the sale or otherwise transacting in these investments. This could impact the client’s ability to trade securities in such companies for extended periods. A client account’s investments may also be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of infectious disease, pandemic or any other serious public health concern, war, terrorism, etc.). The economies, the currencies and the financial markets of a number of emerging market countries have experienced extreme volatility in recent years, exposing investment in the markets of those countries to greater risk than usual. An issuer of securities may be domiciled in a country other than the country in whose currency the instrument is denominated. The values and relative yields of investments in the securities markets of different countries, and their associated risks, are expected to change independently of each other. The economies of emerging market countries can be heavily dependent on international trade and, accordingly, have been and may continue to be adversely affected by trade barriers, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade and international economic developments generally. Although there may be investment restrictions in place with respect to issuer and security concentration, a client’s portfolio may at certain times hold relatively few investments in a single or related sector, industry or geographic area. A client could be subject to significant losses if it held a large position in a particular sector, industry or region that declined in value or is otherwise adversely affected. The realisation of a cash return on an investment by a client will depend on the appreciation in value of, and income from, the securities and other investments acquired or made in the client’s portfolio. No assurance can be given that any such appreciation will occur or that such income will be realised. In addition, no assurance can be given that a client’s portfolio will not suffer a loss of its capital as a result of a general reduction in the value of securities or a loss of value in a particular security or securities. The value of a client’s portfolio may be affected by substantial adverse movements in interest rates. Dependent on the investment guidelines, a client’s portfolio may be invested in illiquid and/or unquoted securities or instruments. Such investments or instruments are typically valued as to their probable realisation value. Such investments are inherently difficult to value and are the subject of substantial uncertainty. There is no assurance that the estimates resulting from the valuation process will reflect the actual sales or close-out prices of such securities. A client will compete with other potential investors to acquire interests in its targeted investments. Certain of the Firm’s competitors may have greater financial and other resources and may have better access to suitable investment opportunities. This could restrict availability of investments to the Firm’s clients and add to the price volatility of shares traded on the securities markets of emerging market countries. There can be no assurance that the Firm will be able to locate and complete suitable investments that satisfy a client’s objectives. Whether or not suitable investment opportunities are available, the client may bear the fees and other expenses described herein. Investment advisers, including the Firm, must rely in part on digital and network technologies to conduct their businesses. Such cyber networks might in some circumstances be at risk of cyber attacks that could potentially seek unauthorised access to digital systems for purposes such as misappropriating sensitive information, corrupting data, or causing operational disruption. Cyber attacks might potentially be carried out by persons using techniques that could range from efforts to electronically circumvent network security or overwhelm websites to intelligence gathering and social engineering functions aimed at obtaining information necessary to gain access. The Firm maintains an information technology security policy and certain technical and physical safeguards intended to protect the confidentiality of its internal data. Nevertheless, cyber incidents could potentially occur, and might in some circumstances result in unauthorised access to sensitive information about the Firm or its clients. please register to get more info

There are no applicable legal or disciplinary events relating to the Firm. In May 2012 the Firm’s affiliate, Genesis Asset Managers, LLP (“GAM”), entered into a settlement agreement with the US Treasury Department, Office of Foreign Assets Control (“OFAC”) to settle potential civil liability for an apparent violation of the US Iranian Transactions Regulations that occurred in 2007. OFAC stated that the apparent violation was ‘not egregious’ and made no finding of fault. As part of the settlement, GAM remitted US$112,500 to the US Treasury. In brief, in August 2007 a Guernsey organised fund (which is not marketed to US investors) managed by GAM made a small investment (30 bps of the fund’s NAV) in First Persia Equity Fund (“First Persia”), a Cayman-based investment fund that invests in listed securities in Iran. In 2009, First Persia was added to the OFAC sanctions list. GAM promptly notified OFAC of its association with an entity on the sanctions list and appointed external counsel to perform an independent assessment of the issue. GAM also conducted a full review of its relevant compliance resources and procedures in place at this time. As a result of this review, enhancements were made to the Genesis Group’s compliance and monitoring processes, including the addition of an automated sanctions screening service to supplement manual review. At the time of the settlement, segregated account clients and investors in Genesis managed funds were notified of the matter. please register to get more info

Affiliations The Firm is approximately 41% owned by the individual partners, one corporate partner and a trust. More information on these individuals is disclosed in the Brochure Supplement. The remaining 59% is owned by Affiliated Managers Group, Inc. (“AMG”) through various wholly owned subsidiaries. AMG, a publicly traded asset management company (NYSE:AMG) with equity investments in boutique investment management firms, holds a majority equity interest in the Firm. AMG also holds equity interests in certain other investment advisers (“AMG Affiliates”). Each of the AMG Affiliates, including the Firm, is operated autonomously and independently, and except as described in this Brochure, the Firm does not have any business dealings with these AMG Affiliates and does not conduct any joint operations with them. Moreover, the AMG Affiliates do not formulate advice for the Firm’s clients. As such, AMG’s ownership interest in the Firm does not, in the Firm’s view, present any potential conflict of interest for the Firm with respect to our clients. More information regarding AMG, including its public filings and a list of all AMG Affiliates, is available at www.amg.com. The Firm has entered into two arrangements with AMG: for the provision of legal and regulatory compliance support as may be requested; and for marketing support in Europe and the Middle East. AMG holds (indirectly) equity interests in the Firm and in certain AMG Affiliates, some of which may also be broker/dealers. As a result of AMG’s equity interest in the Firm, the AMG Affiliates may be considered “related persons” to the Firm for the purposes of this Brochure. Other than the compliance support arrangement noted above, the Firm does not have any business dealings with AMG or the AMG Affiliates and does not conduct any joint operations with them. Neither AMG nor the AMG Affiliates formulate advice for the Firm’s clients and do not, in the Firm’s view, present any potential conflict of interest with the Firm.

Certain of the Firm’s subsidiaries and affiliates include entities that are investment advisers. However, with the exception of the Firm’s subsidiary, GAM, these advisory entities are engaged in business exclusively outside of the United States and do not directly advise or effect securities transactions involving the assets of U.S. residents. Although such entities have no clients of their own in the U.S., certain of them (the “Affiliates”), through their personnel, provide research, advice and financial services to the Firm for the benefit of its clients. The Affiliates of the Firm are, as follows: GAM is a Delaware limited liability partnership and wholly-owned subsidiary of the Firm, registered as an investment adviser with the SEC. GAM provides investment services to the Firm and the Firm’s clients relating to the QFII Securities pursuant to the terms of a written Intra-group QFII Agency Agreement. Genesis Management Australia Limited (“GMAL”), an Australian limited company holds a financial services license from the Australian Securities and Investments Commission. GMAL holds such license to permit the offer and issuance of interests in non-US funds managed by the Firm to Australian investors.

Other Financial Activities Neither the Firm nor any of its management persons are registered, or have an application pending to register, as a broker/dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of one of the foregoing types of entities. please register to get more info

Transactions, and Personal Trading The Firm has established a variety of restrictions, procedures and disclosures designed to address conflicts of interest arising between and among client accounts as well as between client accounts and the Firm and its personnel. All the Firm’s partners and personnel must act in accordance with the fiduciary standard. In addition to the provisions of the Code of Ethics which are described in greater detail below, the Firm maintains a written Conflict of Interest Policy which identifies conflicts and potential conflicts of interest faced by the Firm and the relevant controls in place to address such conflicts. The Conflicts of Interest Policy is reviewed at least annually and approved by the Group Risk Committee (which includes the CCO). A current copy may be obtained by contacting: Genesis Investment Management, LLP 21 Grosvenor Place London SW1X 7HU United Kingdom +44 2072 017200 bricout@giml.co.uk Attention: Legal, Compliance & Risk Department, Conflicts of Interest Policy Request Code of Ethics The Firm has a fiduciary duty to its clients, and accordingly has adopted a Code of Ethics (the “Code”) that applies to all partners and employees. The Code describes the standard of conduct the Firm requires of its partners and employees and sets forth restrictions on certain activities, including personal trading in accounts owned, managed or beneficially owned by the individual. The Code’s provisions also include requirements relating to areas such as gifts and business hospitality, confidentiality of information, the provision and solicitation of political and charitable contributions and outside appointments. The Code prohibits all personal political contributions for any purpose to a U.S. federal, state or local government elected official, candidate, or entity (including any political action committee) without the written consent of the CCO. By setting forth the regulatory and ethical standards to which the Firm’s partners and employees must adhere, the Code supports our efforts to promote a high level of professional ethical conduct in furtherance of our fiduciary duty to our clients. The Code of Ethics is reviewed at least annually and approved by the Risk Management Committee.

Personal Trading Among other things, the Code limits and monitors the personal trading activity of our partners and employees, including members of their immediate households. These limitations seek to further the Firm’s efforts to prevent partners and employees from personally benefiting from the Firm’s investment decisions for its clients and/or any short-term market effects of the Firm’s recommendations to clients. Specifically, the Code prohibits partners and employees and certain members of their households from purchasing or selling emerging market securities which are held in or suitable for client accounts. Limitations also exist for such persons on the participation in initial public offerings and private placements. All partners and employees must provide the Firm with a listing of their securities holdings, as well as copies of trade confirmations and details of their brokerage accounts. These restrictions and requirements of the Code apply to all accounts over which employees have investment discretion, or in which they have a direct or indirect beneficial ownership interest.

Participation or Interest in Client Transactions Certain partners and directors of the Firm may invest for their personal account in pooled vehicles managed by the Firm. We may have an incentive to favour accounts in which our partners or employees invest with respect to trading opportunities, trade allocation and allocation of investment opportunities. As such, the Firm requires that any personal transactions in pooled vehicles managed by the Firm are reported to and monitored by the Legal, Compliance & Risk Department. The Firm does not buy or sell, for the Firm’s accounts, securities that the Firm has recommended to our clients. The Firm also does not engage in principal trades with our clients. The Firm has maintained a small investment in one pooled vehicle since such fund’s inception. This investment was intended to satisfy the minimum number of investors. For several other vehicles, the Firm or one of its affiliates may hold ‘founder shares’ to satisfy local requirements. Insider Trading/Material Non‐Public Information All partners and employees of the Firm are subject to the Affiliated Managers Group, Inc. Insider Trading Policy and Procedures (the “AMG Insider Trading Policy”). The AMG Insider Trading Policy broadly prohibits the use of material, non-public information, and also imposes restrictions on the trading of AMG’s stock. In addition, the Firm’s Code of Ethics also includes policies and procedures prohibiting the use of material non-public information that are designed to prevent insider trading by any partner or employee of the Firm. In accordance with these policies, any matter which may involve inside information is required to be brought to the attention of the Legal, Compliance & Risk Department prior to any trading activity. In addition, to prevent trading of public securities based on material, non-public information, the Firm maintains a “restricted list” that identifies any securities that cannot be purchased for personal or client accounts because material, non-public information may have been received by a partner or employee of the Firm. Provided such issuers are set up in the Firm’s systems, such issuers named on this restricted list are coded as “prohibited” in the Firm’s trading and portfolio compliance system, thus blocking the Firm from trading in these securities without the consent of the Firm’s Legal, Compliance & Risk Department. The Firm investigates any suspicious activity of any security held in personal holdings accounts which may suggest the use of insider trading. The trading patterns of securities held in client accounts are monitored on a regular basis including a review of trading patterns of stock held in client accounts which moves by more than a set percentage on any one day. In addition, the Firm’s partners and employees certify compliance with the Code of Ethics on a quarterly basis.

Gifts and Business Hospitality The Firm’s Code of Ethics includes policies and procedures regarding giving or receiving gifts and business hospitality between the Firm’s partners, employees and certain third parties (e.g. vendors, broker/dealers, consultants, etc.) to help mitigate the potential for conflicts of interest surrounding these practices. In general, the Firm monitors the amount (i.e., value and frequency) of gifts and business hospitality that may be provided to and by partners and employees to these parties, and requires the pre-approval of certain items by our CCO or General Counsel. The Firm specifically monitors for any potential conflicts of interest with respect to individual instances of gifts or hospitality, as well as patterns of the same over time, to prevent the interests of the Firm and its partners and employees from being placed ahead of the interests of our clients. Gifts and hospitality of any sort to certain clients and US public and foreign officials are prohibited without the prior consent of the General Counsel.

Charitable Contributions From time to time, the Firm may donate to charitable enterprises and has identified several charities which it supports on a regular basis. In general, those donations are made in response to requests from the Firm’s partners or employees. The Managing Partner approves all charitable contributions to be made by the Firm. Requests for charitable contributions from clients or potential clients are not permitted without the consent of the CCO or Managing Partner. The solicitation of charitable contributions from clients or potential clients is forbidden. In addition, partners of the Genesis Group have launched the Genesis Charitable Trust which provides grants for public benefit within countries with low- and middle-income economies. This Trust provides or assists in the provision of education, training, and infrastructure projects and is operated independently of the Firm’s business. All grants are approved by the trustees of the Trust and no grants will be made if a conflict or potential conflict with the Genesis Group’s business is present. Political Contributions The Firm prohibits its partners and employees from making political contributions on behalf of the Firm or to be reimbursed for personal political contributions, or from making political contributions for the purpose of securing or retaining business. All requests for political or campaign contributions from clients or potential clients are required to be declined. The solicitation of political or campaign contributions from clients or potential clients is forbidden. Distribution of the Code We are firmly committed to making our partners, employees and clients (both current and prospective) aware of the requirements within our Code of Ethics. All of our partners and employees are provided with a copy of our Code at the time of hire and annually thereafter, and each must affirm that they have received a copy of the Code, and that they have read and understand its provisions. Additionally, the Legal, Compliance & Risk Department conducts periodic compliance training that addresses the requirements of the Code and the other policies described in this Item. A current copy of the Firm’s Code is available at all times to partners and staff via the Firm’s SharePoint and also available to clients or prospective clients upon request, and may be obtained by contacting: Genesis Investment Management, LLP 21 Grosvenor Place London SW1X 7HU United Kingdom bricout@giml.co.uk Attention: Legal, Compliance & Risk Department, Code of Ethics Request please register to get more info

Generally, the Firm is retained on a discretionary basis and is authorised to determine the brokers to be used when effecting transactions on behalf of its clients. Certain clients request that the Firm consider using a specified list of brokers and the Firm has agreed on a best efforts basis bearing in mind the Firm’s duty of best execution. Certain client accounts may prohibit execution of trades for such client account through specified brokers. The Firm has a fiduciary duty to seek best execution, and to ensure that trades are allocated fairly and equitably among clients over time.

Brokerage Relationships The Firm is not directly related to any brokers but may be considered affiliated with other brokers as a result of the common ownership with AMG. With respect to such brokers which may be viewed as affiliated to the Firm through AMG, the Firm does not use such entities to execute trades on behalf of its clients. The Firm may have many other relationships with brokerage firms. For example:
• the Firm may invest client assets in securities issued by brokers or their affiliates.
• the Firm may provide investment management services to affiliates or pension arrangements related to certain brokers. Notwithstanding such relationships or business dealings with these brokers, the Firm has a fiduciary duty to its clients to seek best execution when trading with these firms, and has implemented policies and procedures to monitor its efforts in this regard. Best Execution – Selection Factors for Brokers As noted above, the Firm has a duty to seek best execution of transactions for client accounts. “Best execution” is generally understood to mean the most favourable cost or net proceeds reasonably obtainable under the circumstances. In seeking best execution, the Firm looks for the best combination of transaction price, quality of execution (e.g., the speed of execution, the likelihood the trade will be executed, etc.), sourcing liquidity and other valuable services that an executing broker may provide. The Firm, in seeking best execution, will make this selection based on a number of factors, which may include, but are not limited to, the following; the broker’s financial soundness; the broker’s ability to effectively and efficiently execute, report, clear, and settle the order; the broker’s ability to commit capital; the broker’s ability to timely and accurately communicate with the Firm’s Dealing Desk and settlements team; the broker’s commission rates; and similar factors. Northern Trust are an outsourced provider of Broker Services in markets and/or securities where it is the designated broker and for these securities these same obligations for best execution apply. Best Execution committee The OpEx has responsibility for best execution and oversees the Firm’s brokerage practices. The OpEx has established a process for determining the brokers to be used in executing trades (with the specific decision on which broker to use in a particular transaction to be made by the Dealing Desk) and the general level of commissions to be paid to each broker.

Broker Approval Process Prior to using a broker, the Firm conducts a general due diligence review of the broker and will consider various criteria including, but not limited to, creditworthiness and appropriate regulatory authorisation. The Legal, Compliance & Risk Department approves such brokers but if a broker fails to satisfy one of the criterion, additional due diligence will be performed and the approval of the CCO or the Head of the Legal, Compliance & Risk Department is also required. All approved brokers are added to the Approved Broker List. Brokers on this list are monitored on an annual basis using a risk based approach. Results of the monitoring are reported to senior management.

Broker Review Process With respect to best execution factors, the Dealing Desk performs a semi-annual review and input may be obtained from the Settlements team. These combined reviews are used as general guidelines for the Dealing Desk in deciding which broker to use for specific transactions although best execution always prevails in all transactions.

Monitoring The Firm regularly monitors the broker performance and reasonableness of brokerage commissions. As part of the dealing process, the Dealing Desk monitors broker executions against other traded prices shown on Bloomberg. The internal monitoring programme reviews commission rates achieved on a quarterly basis as part of the more general trade execution monitoring. In addition, the Firm has employed a third party to provide transaction cost analysis as well as an assessment of our transaction costs and market impact in certain countries versus a representative peer group of other emerging markets managers. The results of the monitoring and third party report are included in quarterly reports provided to the OpEx and senior management. The internal procedures relating to brokerage practices are maintained in a written Best Execution policy which is reviewed at least annually by the OpEx. Please refer to Item 4 above for a description of arrangements relating to FX transactions for client accounts. Research and Soft Dollar Benefits The Firm pays for research services out of the Firm’s resources across all of its client accounts. The Firm has implemented a research policy and procedures intended to ensure that the research services are allocated fairly across client portfolios and that the research services are regularly assessed with a view to costs and quality and its ability to contribute to better investment decisions. The determination of the eligibility of research and the substantive value of the research services is made by the relevant member of the Investment Team as part of their quarterly assessment of research services. Such assessment is aided by the use of a research interaction tracking platform and these results are reviewed by the PCT and the Firm’s Operating Board. The overall research budget is set by the Firm’s Operating Board as an estimate of research costs expected to be incurred. The Firm’s Operating Board apportions the overall research budget across each member of the Investment Team so that each member has a defined monetary amount for research services which they may allocate across the external research providers. Additional research services must be approved by the Managing Partner. Commission Sharing Arrangements

The Firm is not involved in any CSAs.

Contra Orders The Firm may submit opposing orders in the same security although it is expected that such occasions would be rare and likely to be the result of client-directed cash flows. Other than in exceptional circumstances, it is expected that contra orders would be executed at market prices. See also Cross Trades below.

Directed Brokerage In some cases, clients have requested that the Firm use specified brokers for portfolio transactions in their accounts. The Firm has agreed to do so on a best efforts basis subject to its duty of best execution and bearing in mind the specialist nature of its underlying asset class of emerging markets. Records of any trades in connection with a directed brokerage arrangement are maintained and provided to the relevant brokers and clients as required. The Firm reserves the right to reject or limit client requests for directed brokerage.

Cross Trades In general, cross trades are rare and restricted due to client account regulations. Crossing, where permitted, takes place, other than in exceptional circumstances, at market prices and the CCO must approve any cross trade. In considering such requests the regulatory requirements, client guideline restrictions and fairness of the trade to both parties are assessed.

Liquidity Rebates In selecting brokers to execute transactions for client accounts, the Firm does not consider any “liquidity rebates” that may be available to those brokers. Brokers may earn “liquidity rebates” (i.e., a certain cash rebate) when placing orders in certain market centres while trading on behalf of the Firm. However, the Firm chooses brokers based on our policy of seeking best execution, which is determined by several quantitative and qualitative factors. It is against the Firm’s policy to take into consideration a broker’s potential to earn liquidity rebates when deciding whether to choose a particular broker.

Trade Aggregation and Allocation When two or more portfolios are simultaneously engaged in the purchase or sale of the same security, the Firm may, but is not obligated to, combine and aggregate the transactions to form a “bunched trade” or “block trade.” In such cases, these accounts will receive the average price of the transactions in that security for the day. Trades in the same security for different accounts will be accumulated for a reasonable period of time to allow for aggregation, unless a particular account’s interest would be unduly prejudiced. The Firm may, but is not required to, aggregate orders into block trades where the Firm believes this is to be appropriate, in the best interests of the client accounts, and consistent with applicable legal requirements. Transactions executed in a block will typically be allocated to the participating client accounts before the close of the business day. Since more than one account’s orders are included in a block trade, the Firm has adopted a policy of using a “pro rata allocation” to allocate the trade among each account whose order makes up part of the block. Under a pro rata allocation, as securities are being purchased or sold as part of the block trade, the securities are being allocated to (or away from, in the case of a sale) accounts in the proportion by which each account’s order size (as determined by the portfolio manager at the time of order entry) makes up a percentage of the entire block. In cases where the Firm is unable to fulfil a block trade the same day (i.e., purchase or sell all securities within the block trade), those securities that have been purchased or sold by the end of the day will generally be allocated pursuant to the Firm’s pro rata allocation methodology. Allocation is imposed through our automated order management system. All allocation objectives and implementation procedures are designed to ensure that all clients receive equitable treatment, ensuring as far as possible that all portfolios with the same mandate look alike. Partial fills are allocated pro rata, to the value of orders placed unless resultant allocation is so small to make settlement uneconomic (typically less than US$5,000). Separate and pooled accounts are treated alike under this allocation process. Allocations across portfolios are reviewed as part of the compliance monitoring programme.

Initial Public Offerings (“IPOs”) An initial public offering is a company’s first offer of stock for sale to the public. Depending on the interest in this initial offering, the Firm’s access to these newly offered shares may be limited in amount at the time of the initial offering. In the event that the Firm participates in any initial public offerings and other securities with limited availability (collectively, “IPOs”), the Firm allocates IPOs among accounts as it would for any other security that is, on a pro rata basis and taking into consideration factors such as client eligibility, client account objectives and preference, investment restrictions, account sizes, cash availability, and current specific needs. Allocation of IPOs and other limited offerings across client accounts is monitored periodically as part of the internal monitoring process to ensure that all accounts are treated fairly and equitably over time.

Trade Errors and Trade Error Accounts If a trade error were to occur, it is the Firm’s policy to make the client account whole. Also if a client account were to benefit from a trade error, any profits would remain with the account (unless the client instructed otherwise). Any material breach of an investment restriction would be disclosed to the client. Internally such a material matter is required to be reported immediately to the CCO who in turn would inform the wider group of partners. Where possible, procedures are put in place to ensure that such an incident does not recur. please register to get more info

The Portfolio Coordination Team (PCT) is comprised of a three-member sub-group of the Investment Team, including the Managing Partner (permanent member), the Chair and a rotating third member, plus one representative of the Risk Management Committee who is functionally and hierarchically separate from the Investment Team. In addition, the Investment Team hold the following meetings to discuss research ideas:
Frequency Purpose Attendees
Weekly General meeting to discuss research and
investment decisions, particularly ideas resulting from company and country visits
All London‐based investment
professionals
Quarterly Portfolio Week during which each stock – as
well as major omissions – are reviewed; also All Investment Team members (in person) includes a review of correlated risks
Semi‐
Annually
Investment ‘away days’, focusing on investment process improvements Investment Team With respect to compliance, responsibility rests with the CCO. The Firm’s day-to-day compliance functions are performed by the Legal, Compliance & Risk Department which has responsibility for amongst other things: trade approvals, compliance with investment guidelines (client and internal), the compliance monitoring programme, personal trading, gifts/hospitality approvals, broker reviews and approvals, conflicts of interest and global regulatory filings. The compliance monitoring programme is designed on a risk assessment basis and consists of a scheduled programme of testing covering a broad range of areas. The frequency is determined by the assessed level of risk, which reflects inherent risk, any recent regulatory changes, any internal changes and previous monitoring results. Testing consists of both review activity and substantive testing and focuses on the quality of operating procedures and the effectiveness of relevant internal controls. Results are reported to the Risk Management Committee. The compliance monitoring programme is reviewed at least annually. In addition to the compliance monitoring programme conducted by the Compliance Team, the Assurance Team performs team and thematic reviews entailing periodic detailed walkthroughs of processes and controls to confirm whether controls are effectively designed and performed and meet internal policy and external regulatory requirements. Ensuring compliance with clients’ investment guideline compliance is, as far as possible, automated using the compliance module of the Firm’s process system. Client-specified restrictions and guidelines are set up and maintained by the Legal, Compliance & Risk Department. When a new transaction order is created on the system, pre-trade compliance checks are run automatically. Any order which creates a new ‘breach’ (or increases an existing breach) will be referred to the Legal, Compliance & Risk Department. Post-trade compliance limits are run automatically overnight and the Legal, Compliance & Risk Department reviews and investigates these results daily. The Performance Team also compare on a monthly basis individual client accounts against other accounts invested in a similar manner to assess the consistency of holdings and performance, and to reconcile any outliers or other exceptions that are found. In addition to the pre and post trade automated restrictions, regular guideline reviews of client accounts are also conducted as part of the internal monitoring function. With respect to reconciliations, the Firm also reconciles its records of the securities and cash held within its clients’ accounts against the records of the custodians who hold the securities and cash. These reconciliations are performed daily by Watson Wheatley Ltd, a specialist provider in reconciliations. Exceptions are reported back to the respective operational teams at the Sub-Adviser for further investigation and resolution. Custodian statements and records of the are the official books and records for each client account. Operational risks are identified, monitored and mitigated via Genesis’ risk management framework. The Risk Management Committee is responsible for the design, implementation and monitoring of the internal risk management framework. The Risk Management Committee reports into the Group Risk Committee which meets quarterly and oversees the effectiveness of the risk management framework, governance and compliance activity within Genesis. The majority of the Group Risk Committee members are independent non-executive directors. The risk committees will raise issues to the Firm’s Operating Board as appropriate. Reporting With respect to client reporting, the Firm delivers to each of its clients a periodic report typically including:
• Listing of individual holdings, including number of shares and current market value;
• Quarterly, year-to-date, and/or since-fund’s inception time-weighed rates of return;
• Historical statement of changes describing clients’ original capital and additions of capital;
• Purchase and sale transactions occurring during the period; and
• Market commentary. Such reports are generally delivered on a monthly basis or quarterly if so requested by the clients. Upon request by a client, valuations and other reports may be available on a more frequent basis. In addition, clients also receive quarterly reports on performance attribution, proxy voting and brokerage commissions. Clients generally receive monthly account reports from independent qualified custodians. These reports typically include:
• Listing of individual holdings, including number of shares and current market value;
• Quarterly, year-to-date, and/or since-inception time-weighed rates of return;
• Historical statement of changes describing clients’ original capital and additions of capital; and,
• Purchase and sale transactions occurring during the period. The reports for segregated client portfolios may be customised to meet each client’s individual needs. The reporting packages for pooled vehicles are standardised to the extent possible but additional confirmations or reports may be agreed by the Firm with an investor in such fund. As noted, the custodian statements reflect the official books and records for the client accounts managed by the Firm. please register to get more info

Relationships with Consultants Many of our clients and prospective clients retain investment consultants to advise them on the selection and review of investment managers. The Firm may have certain accounts that were introduced to the Firm through consultants. These consultants or their affiliates may, in the ordinary course of their investment consulting business, recommend the Firm’s investment advisory services, or otherwise place the Firm into searches or other selection processes for a particular client. The Firm has extensive dealings with investment consultants, both in the consultants’ role as adviser for their clients and through independent business relationships. Specifically, we provide consultants with information on portfolios we manage for our mutual clients, pursuant to our clients’ requests. The Firm also provides information on our investment styles to consultants, who use that information in connection with searches they conduct for their clients. Other interactions that the Firm may have with consultants include, but are not limited to, the following:
• the Firm may, from time to time, purchase software applications, access to databases, and other products or services from some consultants.
• the Firm may pay registration or other fees for the opportunity to participate, along with other investment managers, in consultant-sponsored industry forums or conferences. These conferences or forums provide the Firm with the opportunity to discuss a broad variety of business topics with consultants, clients, and prospective clients.
• In some cases, the Firm may serve as investment adviser for the proprietary accounts of consultants or their affiliates, or as adviser or sub-adviser for funds offered by consultants and/or their affiliates. In general, the Firm relies on each consultant to make appropriate disclosure to its clients of any conflict that the consultant may believe to exist due to its relationship with the Firm. Consulting Databases The Firm does not at the current time but may at a point in the future pay consultants or other third parties to include information about the Firm’s investment approaches in databases that they maintain to describe the services provided by investment managers to prospective clients. Relationships with Solicitors The Firm is party to a client service/marketing agreement with one or more non-U.S. subsidiaries of AMG under which the non-U.S. AMG subsidiaries introduce the Firm’s investment management services to prospective institutional clients and/or provide institutional client services to certain of the Firm’s clients in various foreign jurisdictions. The Firm pays the non-U.S. AMG subsidiaries a fee for these services. The non-U.S. AMG subsidiaries are not broker-dealers, investment advisers, or any of the other financial institutions described in Item 7.A. of the Form ADV Part 1A. Depending on the foreign jurisdiction, the non-U.S. AMG subsidiaries may be registered or exempt from registration, as appropriate, with the relevant foreign financial regulatory authorities.

Other than as described above, the Firm has no other agreements with third party solicitors pursuant to which the Firm pays a fee to these parties in connection with their solicitation of clients and other services.

Compensation from Third Parties The Firm does not receive any monetary compensation or any other economic benefit from a non-client for the Firm’s provision of investment advisory services to a client. please register to get more info

The Firm does not act as a custodian over the assets in the accounts it manages for clients (except as may be deemed a “custodian” by applicable law, as discussed below). Clients must make their own arrangements for custody of securities in their accounts. Such custodians may be banks, trust companies, or other qualified institutions. The qualified custodian will typically provide the client with at least quarterly account statements relating to the assets held within the account managed by the Firm. Each client should carefully review the qualified custodian’s statement upon receipt to determine that it completely and accurately states all holdings in the client’s account and all account activity over the relevant period. Any discrepancies identified by a client should be immediately reported to the Firm and the qualified custodian. In addition to the account statements provided by qualified custodians to our clients, the Firm also provides account statements to clients on a monthly basis. As such, we encourage clients to compare the statements provided to them by the Firm against those provided to them by the qualified custodians who hold the assets of their accounts, and to report any questions, concerns, or discrepancies to both the Firm and the qualified custodian promptly. Such questions, concerns, or discrepancies may be communicated to the Firm by writing, e-mailing, or telephoning us using the following contact information: Genesis Investment Management, LLP 21 Grosvenor Place London SW1X 7HU United Kingdom +44 2072 017200 clientservice@giml.co.uk Attention: Client Service, Report Query The Firm’s statements may vary from custodial statements based on accounting procedures, reporting dates, and/or valuation methodologies of certain securities. However, please note that custodian statements reflect the official books and records for the accounts managed. The Firm may be deemed, under the federal securities laws, to have custody of client assets by virtue of the fact that it also serves as the investment manager and the general partner of the limited partnership referenced in Item 7. In neither capacity (as the investment manager nor as the general partner) does the Firm have actual physical custody of any client assets or securities invested in such fund; rather, all such assets are held in the name of the applicable fund by an independent qualified custodian. Such fund is audited annually, and investors receive annual financial statements, as required by applicable law. please register to get more info

The Firm is granted discretionary authority by our clients at the outset of an advisory relationship to determine the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives/guidelines for the particular client account. When selecting securities and determining amounts of securities for purchase or sale, the Firm observes the investment policies, limitations, and restrictions that are applicable to our clients’ accounts, as set forth by our clients. Any investment guidelines and restrictions, including amendments, must be provided to the Firm by the clients in writing. A separately managed client account will grant the Firm discretionary authority by executing an investment management agreement, which includes, among other items, a statement giving the Firm full authority to invest the assets identified by the client in a manner consistent with the investment objectives and limitations delineated by the client, and to engage in transactions on a discretionary basis in the client account. For pooled vehicles, the appointment of the Firm as investment manager, the scope of the authority and investment objectives and limitations are outlined in the relevant offering document. Clients are likely to restrict the areas in which their assets may be invested to exclude certain countries, regions, stock exchanges or types of securities. Additionally, clients generally place restrictions as to the proportions of managed funds which may be invested in individual securities, issuers or in particular countries, regions or sectors. As a general matter, all client portfolios are restricted from short selling securities or using leverage as an investment tool.

Class Action Suits and Other Legal Actions As a general matter, the Firm provides instructions to custodians regarding tender offers and rights offerings for securities in client accounts. In general and due to the fact that class actions are not common in emerging markets, the Firm is unlikely to be under any obligation to, and typically does not, take any legal action with regard to class action suits relating to securities purchased by the Firm for its clients. Furthermore, the Firm does not provide legal advice to clients and, accordingly, does not determine whether a client should join, opt out of or otherwise submit a claim with respect to any legal proceedings, including bankruptcies or class actions, involving securities held or previously held by the client. The Firm generally does not have authority to submit claims or elections on behalf of clients in legal proceedings. Should a client, however, wish to retain legal counsel and/or take action regarding any class action suit proceeding, the Firm will provide the client or the client’s legal counsel with information that may be needed upon the client’s reasonable request. For pooled accounts, advice and/or instruction is expected to be obtained from the governing board/entity of the fund. please register to get more info

Since client accounts may hold stocks or other securities with voting rights, our clients often have the right to cast votes at the corporate issuers’ shareholder meetings. However, since shareholders often do not attend shareholder meetings, they have the right to cast their votes by “proxy.” In such cases, the Firm’s clients will either retain proxy voting authority or delegate it to the Firm. If a client has delegated such authority to the Firm (whether in the client’s investment management agreement with the Firm or otherwise), the Firm will vote proxies for that client. Where clients have delegated proxy voting authority to the Firm, as an investment adviser and fiduciary of client assets, the Firm accepts such responsibility to vote proxies on behalf of the client. However, it is the responsibility of the custodian appointed by the client to ensure that the Firm receives notice of the relevant proxies sufficiently in advance of the relevant meeting to allow the Firm to vote. Also given the underlying markets in which the Firm invests, the Firm may encounter other administrative obstacles in voting proxies on behalf of clients including share blocking and language requirements. The Firm has implemented proxy voting guidelines and procedures intended to protect the value of shareholder investments and designed to reasonably ensure that the Firm votes proxies in the best interest of clients. In voting proxies, we seek to both maximise the long-term value of our clients’ assets and to cast votes that we believe to be fair and in the best interest of the affected client(s). Voting decisions are determined by the relevant member of the Investment Team. The Firm instructs the voting agent (see below) on how to vote and the voting agent in turn liaises with the relevant custodian. Records are maintained as to the manner in which proxies are voted and are distributed to clients in accordance with their reporting requirements (see Item 13). Such reports include further information when a decision has been made to vote against management. Where clients have not delegated proxy voting authority to the Firm, such clients may on occasion seek information or advice from the Firm as to how the Firm views the relevant issues. On certain occasions, the Firm may contact those clients for whom it does not have proxy voting authority and advise such clients of how it intends to vote for other client accounts. Voting Agent The Firm has contracted with Institutional Shareholder Services, Inc. (“ISS”), an independent third-party provider of proxy voting and corporate governance services (“proxy agent”) which specialises in providing a variety of services related to proxy voting. Specifically, this proxy agent has been retained to provide proxy research, execute proxy votes as instructed by the Firm, and keep various records necessary for tracking proxy voting materials and proxy voting actions taken for the appropriate client account. Conflicts of Interest If a material conflict should arise between the Firm’s interests and those of the clients, it is the Firm’s policy to advise the client of such conflict and obtain their consent or instruction as to how to vote. Details of how the Firm has voted in the past five years on a particular security held in its funds are available on the Firm’s website. Separate account clients (which have delegated proxy voting authority to the Firm) may use the contact details below to request the details of how votes were instructed by the Firm for their account. If you would like a copy of the Firm’s Proxy Voting Guidelines, if you would like to review how the Firm voted on a particular security in your account, or if you would like further information on the proxy agent’s proxy voting policy guidelines, please contact:

Genesis Investment Management, LLP 21 Grosvenor Place London SW1X 7HU United Kingdom +44 207 201 7200 mills@giml.co.uk Re: Proxy Voting Guidelines Request please register to get more info

The Firm has no financial condition that impairs our ability to meet our contractual and fiduciary commitments to our clients, and the Firm has not been the subject of a bankruptcy proceeding. please register to get more info