Capital Group Private Client Services, Inc.

CAPITAL GROUP PRIVATE CLIENT SERVICES, INC. 333 South Hope Street Los Angeles, California 90071 Phone: (213) 486-9200 capitalgroup.com Form ADV, Part 2A Date: September 25, 2026 This brochure provides information about the qualification and business practices of Capital Group Private Client Services, Inc. (“CGPCS”). Throughout this brochure and related materials, CGPCS refers to itself as a “registered investment adviser” or “being registered”. You should be aware that registration with the United States Securities and Exchange Commission (“SEC”) or a state securities authority does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at ADVPart2@capgroup.com. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about CGPCS also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  ITEM 2: MATERIAL CHANGES Form ADV Part 2A, Item 14, has been updated to disclose a new conflict of interest arising from revenue-sharing payments received by an affiliate in connection with certain investments. There have been no other material changes since the last update of CGPCS’s Form ADV, Part 2A brochure dated March 2, 2026. 2  ITEM 3: TABLE OF CONTENTS Item Page 1. Cover Page… ........................................................................................................................................... 1 2. Material Changes… ................................................................................................................................. 2 3. Table of Contents… ................................................................................................................................. 3 4. Advisory Business… ..................................................................................................................................... 4 5. Fees and Compensation… ..................................................................................................................... 5 6. Performance-Based Fees and Side-by-Side Management… ............................................................... 8 7. Types of Clients… .......................................................................................................................................... 9 8. Methods of Analysis, Investment Strategies and Risk of Loss… ........................................................ 10 9. Disciplinary Information… ......................................................................................................................... 22 10. Other Financial Industry Activities and Affiliations… ........................................................................... 23 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading… ............. 25 12. Brokerage Practices… ............................................................................................................................... 27 13. Review of Accounts… ................................................................................................................................ 33 14. Client Referrals and Other Compensation… ......................................................................................... 34 15. Custody… ..................................................................................................................................................... 35 16. Investment Discretion… ....................................................................................................................... 36 17. Voting Client Securities… .................................................................................................................... 37 18. Financial Information… ......................................................................................................................... 40 19. Requirements for State-Registered Advisers…..................................................................................... 41 3  ITEM 4: ADVISORY BUSINESS CGPCS is a wholly-owned subsidiary of Capital Group International, Inc. which in turn is owned by Capital Research and Management Company (“CRMC”), which is wholly owned by The Capital Group Companies, Inc (“CGC”). The Capital Group Companies form one of the most experienced families of investment management firms in the world, dating to 1931, and have always been privately held. CGPCS was incorporated in California in 2020 and its primary business is providing investment management and related services predominantly to high net-worth individuals and charitable organizations. These services include investments in separate securities via SMA Programs (defined below) and in mutual funds, exchange-traded funds (“ETFs”) and other pooled investment vehicles (such funds and investment vehicles, “pooled funds”). CGPCS’s investment approach is based on rigorous fundamental analysis. CGPCS’s offerings of equity, fixed-income, balanced, and other investment strategies are informed by the client’s investment profile, which takes into consideration a number of factors including their investment objectives and goals, investment time horizon, risk tolerance and guidelines (including any specific investment restrictions and limitations). In connection with our management of client accounts, CGPCS generally allocates client assets among one or more pooled funds, and affiliated separately managed account platforms (“SMA Programs”). In connection with its services, CGPCS will engage certain affiliates to provide investment research, portfolio management, securities trading and related services. In addition, with respect to SMA Programs, CGPCS may engage one or more sub-advisers that may or may not be affiliated with CGPCS (each, a “Sub-adviser”) to provide discretionary portfolio management, securities trading, and related services based on models provided by an affiliate of CGPCS. Where a Sub-adviser exercises discretionary authority over accounts in a SMA Program, and/or where the client imposes non-standard restrictions, the holdings, returns and guidelines of the client’s account in such program may differ from the corresponding CGPCS strategy or model portfolio from time to time. Clients with assets allocated to an SMA Program should carefully review the disclosures provided by CGPCS, as well as any Sub-adviser or other underlying manager regarding their services and fees. CGPCS will review and assess the suitability of pooled funds and SMA Programs for clients based on their individual investment profiles. CGPCS will also engage in periodic reviews of Sub-advisers and other underlying managers. Investment strategies that seek to enhance after-tax performance, including in SMA Programs, may be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions may limit the ability to generate tax losses. Tax-loss harvesting also involves the risks that the new investment could perform worse than the original investment and that transaction costs could offset the tax benefit. In addition, a tax-managed strategy may cause a client portfolio to, regardless of investment conviction, hold a security in order to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. client after selling a security will not be usable if the client purchases the same or a substantially identical security within thirty days before or after the sale. This is called a “wash sale” and can occur inadvertently where CGPCS or its Sub-advisers manage more than one account owned by a client, or where a client trades in other portfolios not managed by CGPCS or its Sub-advisers. Please also refer to Items 8 (Methods of Analysis, Investment Strategies and Risk of Loss) and 16 (Investment Discretion) in this brochure for further information. As described above, CGPCS’s only business is investment management and related services; it does not provide retail banking services nor does it engage in the brokerage or corporate finance businesses. As of June 30, 2026, CGPCS managed approximately $48,374,833,002 in client assets (regulatory assets under management) $43,512,695,646 on a discretionary basis and $4,862,137,356 on a non-discretionary basis. 4  ITEM 5: FEES AND COMPENSATION Clients will be assessed an advisory fee based on total managed assets for all qualifying accounts across the relationship. CGPCS generally will invest client assets in (i) SMA Programs, pooled funds and other vehicles and services for which CGPCS or an affiliate of CGPCS serves as investment adviser or Sub-adviser (the “affiliated services”), and (ii) services managed by an unaffiliated Sub-adviser or other third party (“unaffiliated services”). In addition to the advisory fee, clients are assessed a fee based on separately managed assets such as those in the SMA Programs (see “Separately Managed Service Fee” below), and there are additional fees associated with the affiliated and unaffiliated services, which vary by service and are set forth in the prospectus or other governing instrument. In addition to the fee schedules outlined below, different fee schedules apply for certain long-standing clients of CGPCS and its affiliates as well as clients with customized mandates or special service needs. Generally, fees are not negotiable. Certain CGPCS professionals, including private wealth advisors and consultants, as well as relationship managers (“CGPCS Advisory Professionals”) receive, in addition to their base salary, additional compensation based on CGPCS assets under management of (i) new clients of the CGPCS Advisory Professional and (ii) existing clients serviced by the CGPCS Advisory Professional. CGPCS Advisory Professionals also have quantitative annual sales goals that affect the amount of compensation for servicing existing clients. In addition, CGPCS Advisory Professionals are eligible to receive a qualitative bonus which includes as a factor the number of new clients of the CGPCS Advisory Professional. This additional compensation presents conflicts of interest as such associates are incentivized to: (i) recommend CGPCS’ services, and (ii) encourage their clients to increase the assets in their accounts. With respect to any investments held in an account, CGPCS will have a preference for, and will primarily use and invest in, affiliated services. As described more fully below, CGPCS expects the proportion of such affiliated services held in the account relative to holdings of other unaffiliated services to be high, usually 100%, and even where similar unaffiliated services may have lower fees or better historical returns. Any unaffiliated funds or services must meet CGPCS’s investment criteria. CGPCS and its affiliates are compensated for investment advisory and other services they provide in connection with affiliated services. These fees vary by the portfolio and are set forth in the prospectus or other governing instruments. As a result, CGPCS and its affiliates will receive more total revenue when investments managed by CGPCS or its affiliates are held in the account than when assets are allocated to unaffiliated services. This creates an incentive for CGPCS to recommend affiliated products and services. The foregoing conflicts of interest are mitigated by (i) CGPCS policies that require CGPCS Advisory Professionals to act in their clients’ best interests, in accordance with SEC Rule 3a-4 and inclusive of training, and on-going supervision and compliance monitoring; and (ii) the fact that the compensation received by CGPCS Advisory Professionals does not vary based upon their investment recommendations. Finally, clients have the right to terminate CGPCS and separately arrange for the provision of advice by another adviser that does not recommend funds or services affiliated with the adviser. Conflicts Related to Valuation of Investments CGPCS’s management fees are generally based on a percentage of assets under management. As a result, CGPCS faces an inherent conflict of interest to overstate the fair valuation of portfolio securities, thereby increasing its fees. CGPCS seeks to mitigate this conflict through the adoption of valuation policies and procedures, and through the use of third- party pricing services where available to fair value securities without readily available market quotations. CGPCS has established a Joint Fair Valuation Committee to oversee and approve these fair value determinations. To mitigate potential conflicts of interest, investment professionals (such as portfolio managers or investment analysts) are not permitted to serve on the Committee. Additionally, the Fund Board is responsible for overseeing the valuation process for funds registered with the SEC and receives periodic reporting to evaluate the operation of relevant fair value processes. 5  Advisory fees Clients are assessed an advisory fee based on total managed assets for all qualifying accounts across the relationship, with a highest advisory fee of 0.650% for relationships that meet the minimum managed relationship size. For relationships in which the minimum managed relationship size is waived, an advisory fee of up to 1.000% is assessed on total managed assets for all qualifying accounts across the relationship. Separately Managed Service Fee In addition to the advisory fees described above, clients are assessed a “Separately Managed Service Fee” on assets invested in the respective SMA program, according to the following schedules: U.S. Equity (excluding U.S. Small and Mid Cap Equity) U.S. Small and Mid Cap Equity 0.345% 0.415%1 International Equity/ Global Equity Core Plus Bond 0.385% 0.290%1 Core Bond Municipal Income 0.250% 0.250%1 Municipal Bond 0.150% The Separately Managed Service Fee includes fees charged by: (1) CGPCS affiliates for investment management, operational and systems integration, and ongoing service support; and (2) unaffiliated Sub-advisers and platform providers. Please refer to our affiliates’ and Sub-advisers’ respective ADVs for further details about their services. Certain legacy CGPCS relationships, and relationships where our legacy platform may be better suited for the Client, may be eligible for a different separately managed service fee schedule with breakpoints. Minimum Account Size There is a minimum managed relationship size of $5 million. The minimum managed relationship size may be waived from time to time, based on certain factors. Calculation Methodology and Billing Advisory and investment management fees will be calculated and determined quarterly based on the average of the daily market values within the relevant quarter (unless stated otherwise for a specific fund or strategy below), or the market value of the assets in client accounts, as determined in good faith by CGPCS at the respective fee rates set forth herein. Billing will be quarterly in arrears. Any extraordinary services rendered or expenses incurred by CGPCS will be charged separately. Any unpaid fees due to and unreimbursed expenses incurred by CGPCS at the termination of an account may be deducted from the assets in the account. Additional and other Fees Clients may be able to select certain discretionary cash management services whereby the assets are invested, and proceeds are reinvested, in short-duration fixed income securities and cash equivalent investments. For these services, a flat advisory fee of 0.10% annually will apply. 1 Anticipated launch November 16, 2026. 6  For non-advisory services, CGPCS will generally charge an administrative service fee of 0.10% annually; or 0.05% annually for clients with a standard advisory fee arrangement and at least $20 million of managed assets. Other Fee Arrangements For relationships below $10 million, CGPCS charges advisory fees lower than those set forth in the “Advisory fees” schedule to clients who are: (i) individuals currently or formerly employed by, or associated with, any CGC affiliate; (ii) a director, trustee or advisory board member, or service provider to any fund managed by a CGC affiliate; (iii) if approved, a group of individuals anticipating to share in a significant liquidity event; and (iv) registered representatives of dealers, as well as supervised persons of registered investment advisory firms. We may also offer fee credits to clients that make and meet a commitment to contribute significant additional assets to their account within a period of opening an account. All clients should refer to the fee schedule attached to their investment advisory agreement for their applicable fees and further details. Pooled funds The fees and services discussed above are for discretionary accounts invested in pooled funds. For detailed information regarding a specific fund, please refer to that fund’s offering documents. Please also refer to the “CGPCS Client Accounts” discussion under “Item 8: Methods of Analysis” below, for additional information regarding CGPCS’ use of and investments in pooled funds. Aggregation The account values of qualifying accounts across a relationship (a “Relationship”) may be aggregated for purposes of calculating CGPCS investment management and advisory fees,. For these purposes, a “Relationship” may include accounts of the following relatives of a CGPCS client: (i) a spouse;2 (ii) son/daughter, parent, brother/sister;3 (iii) grandchild, grandparent, niece/nephew, aunt/uncle, cousin; (iv) son/ daughter-in-law, parent-in-law, brother/sister-in-law, grandparent-in-law, niece/nephew-in-law, aunt/uncle-in-law, cousin-in-law;4 and (v) godchild or godparent (and individually, each person referred to in (i) through (v), a “Relative”). A Relationship may also include: (a) trust accounts established primarily for the benefit of the CGPCS client or a Relative of such client; and (b) Keogh plans. In addition, for purposes of calculating the fee rate for certain charitable entities, the assets of such charity may be aggregated with those of a CGPCS client, where the charitable account is initially established with contributions attributable to the CGPCS client and provided that such client has a substantial and continuing relationship with the charity. Finally, other relationships, such as committed life partners, former spouses and certain trustee and business relationships, may be approved on a case-by-case basis. Unaffiliated Services CGPCS also provides access to investments in unaffiliated services including private-equity funds and alternative strategy funds. Please see Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) for additional information. Investment related details including fees and expenses are described in the offering documents for these funds, which CGPCS can provide upon request to qualified investors. 2Includes legally recognized common law spouses and persons registered as domestic partners under state or local law. 3Includes step and adoptive relationships. 4References to “in-laws” include relationships derived from common law spouses and persons registered as domestic partners under state or local law. 7  ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT CGPCS charges asset-based fees for providing investment advisory services and does not directly receive fees that are based on the performance of the account. However, in limited circumstances, CGPCS’ affiliates receive fees that are based on the performance of the account. Managing both performance-based accounts and other accounts creates a risk of conflicts for the portfolio manager to (i) allocate more attractive investment opportunities to accounts with performance- based fees and/or (ii) make investments for those accounts that are more speculative than for accounts that do not have performance-based fees. To mitigate these risks, CGPCS and its affiliates have adopted allocation policies that are designed in part to address these potential conflicts of interest. See Item 12 (Brokerage Practices) of this brochure for CGPCS’s policy on allocating trades fairly, which is designed to allocate trades to clients in a fair and equitable manner over time, taking into consideration the interests of each client. Non-investment factors, such as fee arrangements, are not considered when allocating trades among clients. In addition, while CGPCS and its affiliates provide individual investment advice and treatment to each fund and account, portfolio managers focus on particular investment mandates, using similar investment strategies in connection with the management of multiple portfolios, which helps minimize the potential for conflicts of interest. CGPCS reviews accounts with similar objectives managed by CGPCS or its affiliates at least annually. These reviews generally include, among other things, information related to investment results, including dispersion of results among accounts and reasons for such dispersion, if any, significant account guidelines and the investment structure of the portfolio. 8  ITEM 7: TYPES OF CLIENTS CGPCS provides investment management and related services primarily to high-net-worth individuals and charitable organizations. Accounts with CGPCS are generally subject to a minimum relationship and account size requirement referred to in Item 5 (Fees and Compensation). 9  ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS METHODS OF ANALYSIS CGPCS, Capital International, Inc. (“CIInc”) and Capital Research and Management Company (“CRMC” and, together with CGPCS, the “Advisers”) maintain an investment philosophy that is distinguished by four key beliefs and practices: • Fundamental research underlies all investment decisions: CGPCS and the Advisers employ teams of experienced analysts who regularly gather in-depth, first-hand information on markets and companies around the globe. • Investment decisions are not made lightly: In addition to providing extensive research, investment professionals go to great lengths to determine the difference between the fundamental value of a company/security and its price in the marketplace. • A long-term approach: It is part of the big-picture view investment professionals take of the companies in which they invest. This is reflected by the typically low turnover of portfolio holdings in the funds and accounts CGPCS and the Advisers manage. In addition, investment professionals usually remain with us for many years and are compensated according to their investment results over time. • The Capital System: CGPCS and the Advisers use a system of multiple portfolio managers in managing most SMA Programs and fund assets. Under this approach, the portfolio of an account or fund is divided into segments managed by individual managers who decide how their respective segments will be invested. In addition, investment research analysts may make investment decisions with respect to a portion of the portfolio. Over time, this method has contributed to consistency of results and continuity of management. The Advisers may consider environmental, social and governance (“ESG”) factors that, depending on the facts and circumstances, are material to the value of an issuer or instrument. ESG factors may include, but are not limited to, environmental issues (e.g., water use, emission levels, waste, environmental remediation), social issues (e.g., human capital, health and safety, changing customer behavior) or governance issues (e.g., board composition, executive compensation, shareholder dilution). CGPCS and the Advisers manage portfolios that seek to capture the risk and return characteristics of other investment vehicles with the same investment strategy. To manage this type of portfolio, we implement a proprietary solution that utilizes a commercially available third-party risk model to help identify the characteristics of the underlying holdings of the strategy. CGPCS and the Advisers consider certain constraints on the resulting portfolio including but not limited to turnover, market impact, number of holdings, trading cost, trading footprint and holding period. The results of such portfolios may vary depending on a number of factors, including, but not limited to, fees and expenses, portfolio size, transaction costs, cash flows, currencies, securities pricing time, timing of trade executions, taxes and portfolio holdings and any applicable investment limitations. These risks may be heightened for vehicles that have a limitation on the number of holdings in the resulting portfolio. Investment decisions are consistent with a portfolio’s objective(s), investment guidelines, restrictions, and are subject to oversight of the appropriate investment-related committees. The objective(s), policies and restrictions of any fund are set forth in the governing documents of the fund. Clients may impose reasonable restrictions with respect to holdings in an SMA Program. For example, clients may request that certain categories of investment (e.g., tobacco) be excluded from a strategy and/or provide a list of specific issuers for exclusion. Where CGPCS implements category restrictions for a client account, CGPCS relies on third-party data, including in the application of “screens,” to help determine whether certain issuers should be included or excluded from a strategy or an individual portfolio. CGPCS will rely on third-party data with respect to some or all of these determinations, and different third-party data providers may identify different issuers as associated with different industries. These determinations may also change over time. As a result, category restrictions may be more or less inclusive depending on the methodology used by the third parties to define the categories. For example, if a client requests CGPCS exclude “fossil fuel” investments, issuers that are classified as utilities may not be restricted. In cases where third-party 10  data is not available, CGPCS will rely on internal good faith determinations to assess which issuers should be included or excluded from a strategy and to implement such strategy. With respect to account assets allocated to an SMA Program that are managed by a Sub-adviser, restrictions requested by clients will be implemented and monitored by the Sub-adviser based on definitions and screens determined by the Sub-adviser. The implementation of any investment restrictions by a Sub-adviser for an SMA Program may therefore vary from the manner in which CGPCS would implement the same investment restrictions for a client account. As discussed in Item 4 (Advisory Business) above, investment strategies that seek to enhance after-tax performance may be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions may limit the ability to generate tax losses. Tax-loss harvesting also involves the risks that the new investment could perform worse than the original investment and that transaction costs could offset the tax benefit. In addition, a tax-managed strategy may cause a client portfolio to, regardless of investment conviction, hold a security in order to achieve more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. client after selling a security will not be usable if the client purchases the same or a substantially identical security within 30 days before or after the sale. A wash sale can occur inadvertently where CGPCS or its Sub-advisers manage more than one account owned by a client, or where a client trades in other portfolios not managed by CGPCS or its Sub-advisers. Affiliated and Unaffiliated Services In its capacity as discretionary investment manager to clients, CGPCS invests client assets in affiliated services as well as unaffiliated services. CGPCS provides asset allocation advice to clients on these investment options and confirms its clients’ asset allocation in writing. With respect to client investments, CGPCS will have a preference for and will primarily use affiliated services that are directly or indirectly managed by an affiliate of CGPCS (including the SMA Program and affiliated mutual funds and ETFs). CGPCS expects the proportion of affiliated services held in the account relative to holdings of unaffiliated services to be high, usually 100%, and even where similar unaffiliated services may have lower fees or better historical returns. Unaffiliated services may be appropriate for client accounts when, for example, a: (1) client transfers a fund from a prior account to CGPCS and selling the fund would incur adverse tax consequences for the client; or (2) a fund offers exposure to an asset class or investment style that CGPCS believes is appropriate for the client but that is not offered by CGPCS or an affiliate. In addition, CGPCS will have a preference for CGPCS funds and SMA Programs over other affiliated services and non-affiliated services. Please refer to “Item 5: Fees and Compensation” for additional disclosures in this regard. The Manager Research Team of CGPCS (“MRT”) reviews any unaffiliated services for use in client discretionary portfolios, and any such services must meet CGPCS’ investment criteria and policies. When evaluating unaffiliated services for client portfolios, the MRT will conduct due diligence and may consult with and rely on information provided by outside research providers. In conducting its research and analysis, the MRT will take into consideration a number of factors, including but not limited to: the appropriateness of the investment strategy for CGPCS clients, the integrity of and stability of the manager and its investment team, consistency of investment process, long-term investment results, portfolio turnover, fees, reputational risk and conflicts of interest. Generally, no single factor will determine whether an unaffiliated service will meet the MRT’s investment criteria, and some factors carry greater weight than others. For example, MRT’s criteria are not solely based on performance relative to peers or benchmarks. Investment Strategies The following are descriptions of the CGPCS SMA Program strategies. These descriptions are intended to reflect their investment objectives and characteristics. Actual portfolio holdings may vary based on client-specific guidelines and goals, market conditions, and the discretion of the Sub-adviser and/or sponsor. Equity strategies U.S. Equity — to provide prudent growth of capital and conservation of principal. The strategy invests primarily in equity and equity related securities of U.S. issuers with a focus on prudent growth. Generally, may invest no more than 15% at 11  the time of purchase in securities of non-U.S. issuers, such as American Depositary Receipts (ADRs). U.S. Growth — The strategy’s investment objective is to provide long-term growth of capital. Takes a disciplined approach to growth investing, focusing primarily on well-managed U.S. companies with sound fundamentals. Invests in companies of any size that have solid long-term growth records and attractive future growth potential. The strategy may invest to a limited extent in securities of issuers outside the United States. U.S. Income and Growth — The strategy’s investment objective is to produce income and to provide an opportunity for growth of principal consistent with sound common stock investing. A disciplined approach to investing that uses strict eligibility criteria to screen for companies across a broad array of industries with strong balance sheets and consistent dividends. The strategy seeks to be fully invested. A portfolio may invest up to 10% of its assets in companies outside the United States and not included in the S&P 500. U.S. Core — The strategy’s investment objective is to achieve long-term growth of capital and income. With an 80-plus-year track record, this strategy invests primarily in larger, well-established companies that represent a wide cross section of the U.S. economy. It seeks to provide long-term growth of capital and income with a focus on future income. A portfolio may invest up to 15% of its assets in securities of issuers domiciled outside the United States. U.S. Flexible Growth and Income — The strategy’s investment objective is to achieve long-term growth of capital and income. With an emphasis on growth over income, the strategy seeks undervalued and overlooked opportunities. It invests in companies with high-quality products and leading market shares with the underappreciated potential for growth in sales, earnings and dividends. It has the flexibility to invest a sizable portion of its assets outside of the United States. The strategy may invest up to 35% of assets in securities of issuers outside the United States. U.S. Flexible Growth — The strategy’s investment objective is to provide growth of capital. This strategy takes a flexible approach to growth investing, seeking opportunities in traditional growth stocks as well as cyclical companies and turnarounds with significant potential for growth of capital. Geographic flexibility also allows portfolio managers to pursue opportunities outside of the United States. The strategy may invest up to 25% of assets in securities of issuers outside the United States. U.S. Conservative Growth and Income — The strategy strives for the balanced accomplishment of three objectives: current income, growth of capital and conservation of principal. Conservatively managed to reduce volatility and risk, this strategy seeks to invest in common stocks of companies that are likely to participate in the growth of the American economy and whose dividends appear to be sustainable. The strategy may invest up to 20% of its assets in securities of issuers domiciled outside the United States and not included in the S&P 500 Index. May invest up to 5% of its assets in securities of issuers domiciled outside the United States and Canada and not included in the S&P 500 Index. International Equity — The strategy’s investment objective is to provide prudent growth of capital and conservation of principal. This international strategy invests in companies that are predominantly based in developed markets. Seeks to provide a smoother return profile over a full market cycle – with less volatility and lower downside capture than the market – by focusing on companies with characteristics associated with long-term growth and resilience to market declines, including strong balance sheets and dividend payments., The portfolio may invest in securities of non-U.S. issuers that trade in the United States, and may invest up to 10% at the time of purchase in securities of emerging market issuers. International Growth — The strategy’s primary investment objective is to provide long-term growth of capital. This international strategy seeks growth of capital by employing a flexible approach to investing in attractively valued companies in developed and emerging markets that are positioned to benefit from innovation, global economic growth, increasing consumer demand or a turnaround in business conditions. Normally, at least 80% of assets must be invested in securities of issuers in Europe or the Pacific Basin. Global Equity — The strategy’s investment objective is to provide prudent growth of capital and conservation of principal. This global strategy pursues prudent growth of capital and conservation of principal by investing in companies that are predominantly based in developed markets. The strategy seeks to provide a smoother return profile over a full market cycle — with less volatility and lower downside capture than the market —by focusing on companies with characteristics associated with long-term growth and resilience to market declines, including strong balance sheets and dividend payments. For non-U.S. holdings, a portfolio may invest in securities of non-U.S. issuers that trade in the United States, and may invest up to 10% at the time of purchase in securities of emerging market issuers. 12  Global Growth — The strategy’s primary investment objective is to provide long-term growth of capital. Seeks to take advantage of evolving global trade patterns by predominantly investing in companies that have potential for growth in capital. Invests primarily in multinational companies with a meaningful share of their sales and operations outside of their home countries. This approach provides the strategy’s portfolio managers with geographic flexibility and the ability to navigate different markets. A portfolio may invest up to 100% of assets outside the United States, though the strategy has typically invested in issuers throughout the world. Fixed-Income strategies U.S. Intermediate Bond — The strategy’s investment objective is to provide current income and capital preservation. Invests primarily in debt securities rated BBB/Baa or better or unrated but determined to be of equivalent quality by CGPCS. May not invest in high-yield bonds. Under normal circumstances, the dollar-weighted average effective maturity of the portfolio will be between three and five years and will have a duration range of +/– one year of the benchmark duration. Core Bond — The strategy’s investment objective is to provide as high a level of current income as is consistent with the preservation of capital. Has the ability to invest in every sector of the bond market and pursue multiple sources of active return, with a limited percentage of below-investment-grade holdings. Typically, the portfolio will be invested in intermediate- to long-term securities. Core Plus — The strategy’s investment objective is to provide current income and seek maximum total return, consistent with preservation of capital. Primarily invests in bonds and other debt securities, which may be represented by derivatives. Has the ability to invest in every sector of the bond market and pursue multiple sources of active return. Short Municipal — The strategy’s investment objective is to provide current income exempt from federal tax, and capital preservation. A short-term tax-exempt fixed income allocation with an emphasis on high-quality and liquid short maturity credits. Invests in municipal bonds with quality ratings of BBB-/Baa3 or better while seeking to maintain a high level of liquidity. Normally, the strategy has a duration range of +/–0.5 year of the benchmark duration. Will not invest in securities that subject the investor to the federal alternative minimum tax (AMT). Intermediate Municipal — The strategy’s investment objective is to provide current income exempt from federal tax, and capital preservation. An intermediate-term tax-exempt fixed income allocation with an emphasis on investment grade and intermediate maturity credits. Invests in municipal bonds with quality ratings of BBB-/Baa3 or better while seeking to maintain a high level of liquidity. Normally, the strategy has a duration range of +/– one year of the benchmark duration. Will not invest in securities that subject the investor to the federal alternative minimum tax (AMT). Long Municipal — The strategy’s investment objective is to provide current income exempt from federal tax, and capital preservation. A longer-term tax-exempt fixed income allocation with an emphasis on investment-grade and long-maturity credits. Invests in municipal bonds with quality ratings of BBB-/Baa3 or better while seeking to maintain a high level of liquidity. Normally, the strategy has a duration range of +/– one year of the benchmark duration. Will not invest in securities that subject the investor to the f AMT. Municipal Income — The strategy’s investment objective is to provide a high level of current income exempt from regular federal income tax, consistent with the preservation of capital. Primarily invests in, or seeks to derive a majority of its income from, securities that are exempt from regular federal income tax. Invests in municipal bonds with quality ratings of BBB-/Baa3 or better. Normally, the strategy has a duration range of +/– one year of the benchmark duration. Balanced and total opportunity strategies World Dividend Growers — The strategy aims to provide long-term total returns by investing in companies globally that have the potential to provide combinations of current yield and dividend growth. The strategy invests primarily in equity and equity-related securities we believe will increase dividends paid over a multiyear period. Investments are limited to securities on the strategy’s eligible list, based on current yield and anticipated dividend growth. 13  INVESTMENT RISKS Investing in securities involves risk of loss that funds and their shareholders or other clients should be prepared to bear. Each fund or account is subject to certain risks associated with the investments made by CGPCS in accordance with that fund’s policies and restrictions. The risks associated with an investment in each fund are set forth in that fund’s prospectus and statement of additional information or other disclosure documents. These risks may include, but are not limited to, certain of the risks set forth below. • Management — CGPCS actively manages investments. Consequently, the funds and accounts are subject to the risk that the methods and analyses including models, tools and data employed by the investment adviser in this process may be flawed or incorrect and may not produce the desired results. This could cause a fund or account to lose value or their investment results to lag relevant benchmarks or other funds or accounts with similar objectives. • Market conditions — The prices of, and income generated by, the common stocks and other securities held by the funds or accounts may decline – sometimes rapidly or unpredictably – due to various factors, including events or conditions affecting the general economy or particular industries or companies; overall market changes; local, regional or global political, social or economic instability; governmental, governmental agency or central bank responses to economic conditions; levels of public debt and deficits; changes in inflation rates; and currency exchange rate, interest rate and commodity price fluctuations. Economies and financial markets throughout the world are highly interconnected. Economic, financial or political events, trading and tariff arrangements, wars, terrorism, cybersecurity events, natural disasters, public health emergencies (such as the spread of infectious disease), bank failures and other circumstances in one country or region, including actions taken by governmental or quasi-governmental authorities in response to any of the foregoing, could have impacts on global economies or markets. As a result, whether or not the fund or account invests in securities of issuers located in or with significant exposure to the countries affected, the value and liquidity of the fund’s or account’s investments may be negatively affected by developments in other countries and regions. • Investing in stocks — Investing in stocks may involve larger price swings and greater potential for loss than other types of investments. As a result, the value of the underlying funds and accounts may be subject to sharp declines in value. Income provided by an underlying fund or account may be reduced by changes in the dividend policies of, and the capital resources available at, the companies in which the underlying fund or account invests. These risks may be even greater in the case of smaller capitalization stocks. • Investing in growth-oriented stocks — Growth-oriented common stocks and other equity-type securities (such as preferred stocks, convertible preferred stocks and convertible bonds) may involve larger price swings and greater potential for loss than other types of investments. These risks may be even greater in the case of smaller capitalization stocks. • Investing in income-oriented stocks — The value of the securities and income provided by the funds and accounts may be reduced by changes in the dividend policies of, and the capital resources available for dividend payments at, the companies in which a fund or account invests. • Issuer risks — The prices of, and the income generated by, securities held by the fund or account may decline in response to various factors directly related to the issuers of such securities, including reduced demand for an issuer’s goods or services, poor management performance, major litigation, investigations or other controversies related to the issuer, changes in the issuer’s financial condition or credit rating, changes in government regulations affecting the issuer or its competitive environment and strategic initiatives such as mergers, acquisitions or dispositions and the market response to any such initiatives. An individual security may also be affected by factors relating to the industry or sector of the issuer or the securities markets as a whole, and conversely an industry or sector of the securities markets may be affected by a change in financial condition or other event affecting a single issuer. To the extent that the market prices of securities of issuers in the same or related industries or sectors tend to move in the same direction at the same time, and these issuers make up a sizeable portion of the market, events affecting one issuer, industry or sector or the securities markets generally may have a larger impact. If such issuers represent a substantial portion of major market indices, or the economy, a downturn in the prices of their securities may have a disproportionate adverse effect on the overall market, even if other segments of the market perform well. The fund or account invests in issuers based on their level of investment conviction. At times, the fund or account may invest more significantly in a single issuer, which could increase the fund’s or account’s volatility and the risk of loss arising from the factors described above. 14  • Currency — The prices of, and the income generated by, most debt securities held by a fund or account may also be affected by changes in relative currency values. If the U.S. dollar appreciates against foreign currencies, the value in U.S. dollars of the fund’s or account’s securities denominated in such currencies would generally fall and vice versa. • Currency transactions — In addition to the risks generally associated with investing in derivative instruments, the use of forward currency contracts involves the risk that currency movements will not be accurately predicted by the investment adviser, which could result in losses to the fund or account. While entering into forward currency contracts could minimize the risk of loss due to a decline in the value of the hedged currency, it could also limit any potential gain that may result from an increase in the value of the currency. Additionally, CGPCS may use forward currency contracts to increase exposure to a certain currency or to shift exposure to currency fluctuations from one country to another. Forward currency contracts may expose the fund or account to potential gains and losses in excess of the initial amount invested. The fund or account may also enter into currency transactions to provide for the purchase or sale of a currency needed to purchase a security denominated in such currency. In addition, the fund or account may enter into forward currency contracts to protect against changes in currency exchange rates, to increase exposure to a particular foreign currency, to shift exposure to currency fluctuations from one currency to another or to seek to increase returns. A forward currency contract is an agreement to purchase or sell a specific currency at a future date at a fixed price. • Investing in small companies — Investing in smaller companies may pose additional risks. For example, it is often more difficult to value or dispose of small company stocks and more difficult to obtain information about smaller companies than about larger companies. Furthermore, smaller companies often have limited product lines, operating histories, markets and/or financial resources, may be dependent on one or a few key persons for management, and can be more susceptible to losses. Moreover, the prices of their stocks may be more volatile than stocks of larger, more established companies, particularly during times of market turmoil. • Investing outside the United States — Securities of issuers domiciled outside the United States or with significant operations or revenues outside the United States, and securities tied economically to countries outside the United States, may lose value because of adverse political, social, economic or market developments (including social instability, regional conflicts, terrorism and war) in the countries or regions in which the issuers are domiciled, operate or generate revenue or to which the securities are tied economically. These securities may also lose value due to changes in foreign currency exchange rates against the U.S. dollar and/or currencies of other countries. Issuers of these securities may be more susceptible to actions of foreign governments, such as nationalization, currency blockage or the imposition of price controls, sanctions or punitive taxes, each of which could adversely impact the value of these securities. Securities markets in certain countries may be more volatile and/or less liquid than those in the United States. Investments outside the United States may also be subject to different regulatory, legal, accounting, auditing, financial reporting and recordkeeping requirements, and may be more difficult to value, than those in the United States. In addition, the value of investments outside the United States may be reduced by foreign taxes, including foreign withholding taxes on interest and dividends. Further, there may be increased risks of delayed settlement of securities purchased or sold by the fund or account, which could impact the liquidity of the fund’s or account’s portfolio. These risks of investing outside the United States may be heightened in connection with investments in emerging market. • Investing in emerging markets — Investing in emerging markets may involve risks in addition to and greater than those generally associated with investing in the securities markets of developed countries. For instance, emerging market countries tend to have less developed political, economic and legal systems than those in developed countries. Accordingly, the governments of these countries may be less stable and more likely to intervene in the market economy, for example, by imposing capital controls, nationalizing a company or industry, placing restrictions on foreign ownership and on withdrawing sale proceeds of securities from the country, and/or imposing punitive taxes that could adversely affect the prices of securities. Information regarding issuers in emerging markets may be limited, incomplete or inaccurate, and such issuers may not be subject to regulatory, accounting, auditing, and financial reporting and recordkeeping standards comparable to those to which issuers in more developed markets are subject. The fund’s or account’s rights with respect to its investments in emerging markets, if any, will generally be governed by local law, which may make it difficult or impossible for the fund or account to pursue legal remedies or to obtain and enforce judgments in local courts. In addition, the economies of these countries may be dependent on relatively 15  few industries, may have limited access to capital and may be more susceptible to changes in local and global trade conditions and downturns in the world economy. Securities markets in these countries can also be relatively small and have substantially lower trading volumes. As a result, securities issued in these countries may be more volatile and less liquid, more vulnerable to market manipulation, and more difficult to value, than securities issued in countries with more developed economies and/or markets. Less certainty with respect to security valuations may lead to additional challenges and risks in calculating the fund’s or account’s net asset value. Additionally, emerging markets are more likely to experience problems with the clearing and settling of trades and the holding of securities by banks, agents and depositories that are less established than those in developed countries. • Exposure to country, region, industry or sector — Subject to the investment limitations, the fund or account may have significant exposure to a particular country, region, industry or sector. Such exposure may cause the fund or account to be more impacted by risks relating to and developments affecting the country, region, industry or sector, and thus its net asset value may be more volatile, than a fund or account without such levels of exposure. For example, if the fund or account has significant exposure in a particular country, then social, economic, regulatory or other issues that negatively affect that country may have a greater impact on the fund or account than on a fund or account that is more geographically diversified. • Investing in private companies — The fund may invest in companies that have not publicly offered their securities. Investing in private companies can involve greater risks than those associated with investing in publicly traded companies. For example, the securities of a private company may be subject to the risk that market conditions, developments within the company, investor perception, or regulatory decisions may delay or prevent the company from ultimately offering its securities to the public. Furthermore, these investments are generally considered to be illiquid until a company’s public offering and are often subject to additional contractual restrictions on resale that would prevent the fund from selling its company shares for a period of time following the public offering. Investments in private companies can offer the fund significant growth opportunities at attractive prices. However, these investments can pose greater risk, and, consequently, there is no guarantee that positive results can be achieved in the future. • Investing in debt instruments — The prices of, and the income generated by, bonds and other debt securities held by the fund or account may be affected by factors such as the interest rates, maturities and credit quality of these securities. Rising interest rates will generally cause the prices of bonds and other debt securities to fall. Also, when interest rates rise, issuers of debt securities that may be prepaid at any time, such as mortgage- or other asset- backed securities, are less likely to refinance existing debt securities, causing the average life of such securities to extend. A general change in interest rates may cause investors to sell debt securities on a large scale, which could also adversely affect the price and liquidity of debt securities and could also result in increased redemptions from the fund. Falling interest rates may cause an issuer to redeem, call or refinance a debt security before its stated maturity, which may result in the fund or account having to reinvest the proceeds in lower yielding securities. Longer maturity debt securities generally have greater sensitivity to changes in interest rates and may be subject to greater price fluctuations than shorter maturity debt securities. Bonds and other debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer or guarantor will weaken or be perceived to be weaker, and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Changes in actual or perceived creditworthiness may occur quickly. A downgrade or default affecting any of the fund’s or account’s securities could cause the value of the fund’s or account’s shares to decrease. Lower quality debt securities generally have higher rates of interest and may be subject to greater price fluctuations than higher quality debt securities. Credit risk is gauged, in part, by the credit ratings of the debt securities in which the fund or account invests. However, ratings are only the opinions of the rating agencies issuing them and are not guarantees as to credit quality or an evaluation of market risk. CGPCS and its affiliates rely on their own credit analysts to research issuers and issues in assessing various credit and default risks. 16  • Investing in lower rated debt instruments — Lower rated debt securities or instruments, rated Ba1/ BB+ or below by Nationally Recognized Statistical Rating Organizations, generally have higher rates of interest and involve greater risk of default or price declines due to changes in the issuer’s creditworthiness than those of higher quality debt securities. The market prices of these securities may fluctuate more than the prices of higher quality debt securities and may decline significantly in periods of general economic difficulty. • Investing in depositary receipts — Depositary receipts are securities that evidence ownership interests in, and represent the right to receive, a security or a pool of securities that have been deposited with a bank or trust depository. Such securities may be less liquid or may trade at a lower price than the underlying securities of the issuer. Additionally, receipt of corporate information about the underlying issuer and proxy disclosure may not be timely and there may not be a correlation between such information and the market value of the depositary receipts. • Investing in securities backed by the U.S. government — U.S. government securities are subject to market risk, interest rate risk and credit risk. Securities backed by the U.S. Treasury or the full faith and credit of the U.S. government are guaranteed only as to the timely payment of interest and principal when held to maturity. Accordingly, the current market values for these securities will fluctuate with changes in interest rates and the credit rating of the U.S. government. Notwithstanding that these securities are backed by the full faith and credit of the U.S. government, circumstances could arise that would prevent or delay the payment of interest or principal on these securities, which could adversely affect their value and cause the fund to suffer losses. Such an event could lead to significant disruptions in United States and global markets. Securities issued by U.S. government-sponsored entities and federal agencies and instrumentalities that are not backed by the full faith and credit of the U.S. government are neither issued nor guaranteed by the U.S. government. • Interest rate risk — The values and liquidity of the securities held by a fund or account may be affected by changing interest rates. For example, the values of these securities may decline when interest rates rise and increase when interest rates fall. Longer maturity debt securities generally have greater sensitivity to changes in interest rates and may be subject to greater price fluctuations than shorter maturity debt securities. The fund or account may invest in variable and floating rate securities. When the fund or account holds variable or floating rate securities, a decrease in market interest rates will adversely affect the income received from such securities and the net asset value of the fund’s or account’s shares. Although the values of such securities are generally less sensitive to interest rate changes than those of other debt securities, the value of variable and floating rate securities may decline if their interest rates do not rise as quickly, or as much, as market interest rates. Conversely, floating rate securities will not generally increase in value if interest rates decline. During periods of extremely low short-term interest rates, the fund or account may not be able to maintain a positive yield or total return and, in relatively low interest rate environments, there are heightened risks associated with rising interest rates. • Tax-exempt securities — While the funds and accounts seeks to purchase securities which bear interest that is exempt from federal income taxes there are risks that such interest may be reclassified as taxable by the Internal Revenue Service, or a state tax authority. Actions by the issuer or future legislative, administrative or court actions also could adversely affect the tax-exempt status of interest paid by such securities. Such reclassifications or actions could cause interest from a security to become includable in the gross income of the holder of the security, possibly retroactively, subjecting fund shareholders to increased tax liability. In addition, such reclassifications or actions could cause the value of a security, and therefore the value of the fund’s shares, to decline. • Investments in future delivery contracts — A fund or account may enter into transactions involving future delivery contracts, such as to-be-announced (TBA) contracts and mortgage dollar rolls. These contracts involve the purchase or sale of mortgage backed securities for settlement at a future date and predetermined price. When the fund enters into a TBA commitment for the sale of mortgage-backed securities (which may be referred to as having a short position in such TBA securities), the fund may or may not hold the types of mortgage-backed securities required to be delivered. The fund may choose to roll these transactions in lieu of settling them. When the fund rolls the purchase of these types of future delivery transactions, the fund or account simultaneously sells the mortgage backed securities for delivery in the current month and repurchases substantially similar securities for delivery at a future date at a predetermined price. When the fund or account rolls the sale of these transactions rather than settling them, the fund or account simultaneously purchases the mortgage backed 17  securities for delivery in the current month and sells substantially similar securities for delivery at a future date at a predetermined price. Such roll transactions can increase the turnover rate of the fund or account and may increase the risk that prices may move unfavorably between the original and new contracts, potentially resulting in losses or reduced returns for the fund or account. • Investing in mortgage-related and other asset backed securities — Mortgage-related securities, such as mortgage- backed securities, and other asset-backed securities, include debt obligations that represent interests in pools of mortgages or other income-bearing assets, such as consumer loans or receivables. Such securities often involve risks that are different from or more acute than the risks associated with investing in other types of debt securities. Mortgage-backed and other asset-backed securities are subject to changes in the payment patterns of borrowers of the underlying debt, potentially increasing the volatility of the securities and a fund’s or account’s net asset value. When interest rates fall, borrowers are more likely to refinance or prepay their debt before its stated maturity. This may result in the fund or account having to reinvest the proceeds in lower yielding securities, effectively reducing the fund’s or account’s income. Conversely, if interest rates rise and borrowers repay their debt more slowly than expected, the time in which the mortgage-backed and other asset-backed securities are paid off could be extended, reducing the fund’s or account’s cash available for reinvestment in higher yielding securities. Mortgage- backed securities are also subject to the risk that underlying borrowers will be unable to meet their obligations and the value of property that secures the mortgages may decline in value and be insufficient, upon foreclosure, to repay the associated loans. Investments in asset-backed securities are subject to similar risks. • Investing in derivatives — The use of derivatives involves a variety of risks, which may be different from, or greater than, the risks associated with investing in traditional securities, such as stocks and bonds. Changes in the value of a derivative may not correlate perfectly with, and may be more sensitive to market events than, the underlying asset, rate or index, and a derivative instrument may cause a fund or account to lose significantly more than its initial investment. Derivatives may be difficult to value, difficult for the fund or account to buy or sell at an opportune time or price and difficult to terminate or otherwise offset. The fund’s or account’s use of derivatives may result in losses to the fund, and investing in derivatives may reduce the fund’s or account’s returns and increase the fund’s or account’s price volatility. The fund’s or account’s counterparty to a derivative transaction (including, if applicable, the fund’s or account’s clearing broker, the derivatives exchange or the clearinghouse) may be unable or unwilling to honor its financial obligations in respect of the transaction. In certain cases, the fund or account may be hindered or delayed in exercising remedies against or closing out derivative instruments with a counterparty, which may result in additional losses. Derivatives are also subject to operational risk (such as documentation issues, settlement issues and systems failures) and legal risk (such as insufficient documentation, insufficient capacity or authority of a counterparty, and issues with the legality or enforceability of a contract). • Investing in swaps — Swaps, including interest rate swaps and credit default swap indices, or CDSIs, are subject to many of the risks generally associated with investing in derivative instruments. Additionally, although swaps require no initial investment or only a small initial investment in the form of a deposit of initial margin, the amount of a potential loss on a swap could greatly exceed the initial amount invested. The use of swaps involves the risk that the investment adviser will not accurately predict anticipated changes in interest rates or other economic factors, which may result in losses to a fund or account. If the fund or account enters into a bilaterally negotiated swap, the counterparty may fail to perform in accordance with the terms of the swap. If a counterparty defaults on its obligations under a swap, the fund or account may lose any amount it expected to receive from the counterparty, potentially including amounts in excess of the fund’s or account’s initial investment. Certain swaps are subject to mandatory central clearing or may be eligible for voluntary central clearing. Although clearing interposes a central clearinghouse as the ultimate counterparty to each participant’s swap, central clearing will not eliminate (but may decrease) counterparty risk relative to uncleared bilateral swaps. Some swaps, such as CDSIs, may be dependent on both the individual credit of the fund’s or account’s counterparty and on the credit of one or more issuers of any underlying assets. If the fund or account does not correctly evaluate the creditworthiness of its counterparty and, where applicable, of issuers of any underlying reference assets, the fund’s or account’s investment in a swap may result in losses to the fund. • Investing in futures contracts — In addition to the risks generally associated with investing in derivative instruments, futures contracts are subject to the creditworthiness of the clearing organizations, exchanges and futures commission merchants with which a fund or account transacts. Additionally, although futures require only a small initial investment in the form of a deposit of initial margin, the amount of a potential loss on a futures contract could 18  greatly exceed the initial amount invested. While futures contracts are generally liquid instruments, under certain market conditions futures may be deemed to be illiquid. For example, the fund or account may be temporarily prohibited from closing out its position in a futures contract if intraday price change limits or limits on trading volume imposed by the applicable futures exchange are triggered. If the fund or account is unable to close out a position on a futures contract, the fund or account would remain subject to the risk of adverse price movements until the fund or account is able to close out the futures position. The ability of the fund or account to successfully utilize futures contracts may depend in part upon the ability of the fund’s or account’s investment adviser to accurately forecast market and other economic factors (such as interest rates) and to assess and predict the impact of such market and economic factors on the futures in which the fund or account invests. If the investment adviser incorrectly forecasts economic developments or incorrectly predicts the impact of such developments on the futures in which it invests, the fund or account could suffer losses. • Investing in options — Options on currencies, securities and other instruments (referred to as the “underlying instruments”) are subject to additional risks aside from those generally associated with investing in derivatives instruments. For example, there may be significant differences between the underlying instruments and options markets that could result in an imperfect correlation between these markets, which could cause a given transaction not to achieve its objectives. When a put or call option on a particular underlying instrument is purchased to hedge against price movements in a related underlying instrument, for example, the price to close out the put or call option may move more or less than the price of the related underlying instrument. Options prices can diverge from the prices of their underlying instruments for a number of reasons. Options prices are affected by such factors as current and anticipated short-term interest rates, changes in the volatility of the underlying instrument, and the time remaining until expiration of the contract, which may not affect security prices in the same way. Imperfect correlation may also result from differing levels of demand in the options markets and the markets for the underlying instruments, from structural differences in how options and underlying instruments are traded, or from imposition of daily price fluctuation limits or trading halts. The fund or account may purchase or sell options contracts with a greater or lesser value than the underlying instruments it wishes to hedge or intends to purchase in order to attempt to compensate for differences in volatility between the contract and the underlying instruments, although this may not be successful. If price changes in the fund’s or account’s options positions are less correlated with its other investments, the positions may fail to produce anticipated gains or result in losses that are not offset by gains in other investments. There is no assurance that a liquid market will exist for any particular options contract at any particular time. • Hedging — There may be imperfect or even negative correlation between the prices of the options and futures contracts in which a fund or account invests and the prices of the underlying securities or indexes which the fund or account seeks to hedge. For example, options and futures contracts may not provide an effective hedge because changes in options and futures contract prices may not track those of the underlying securities or indexes they are intended to hedge. In addition, there are significant differences between the securities market, on the one hand, and the options and futures markets, on the other, that could result in an imperfect correlation between the markets, causing a given hedge not to achieve its objectives. The degree of imperfection of correlation depends on circumstances such as variations in speculative market demand for options and futures, including technical influences in options and futures trading, and differences between the financial instruments being hedged and the instruments underlying the standard contracts available for trading. A decision as to whether, when and how to hedge involves the exercise of skill and judgment, and even a well-conceived hedge may be unsuccessful to some degree because of market behavior or unexpected interest rate trends. In addition, the fund’s or account’s investment in exchange-traded options and futures and their resulting costs could limit the fund’s or account’s gains in rising markets relative to those of the underlying fund, or to those of unhedged funds or accounts in general. • Lending of portfolio securities — Securities lending involves risks, including the risk that the loaned securities may not be returned in a timely manner or at all, which would interfere with the fund’s or account’s ability to vote proxies or settle transactions, and/or the risk of a counterparty default. Additionally, a fund or account may lose money from the reinvestment of collateral received on loaned securities in investments that decline in value, default or do not perform as expected. • Liquidity risk — Certain fund or account holdings may be or may become difficult or impossible to sell, particularly during times of market turmoil. Liquidity may be impacted by the lack of an active market for a holding, legal or contractual restrictions on resale, or the reduced number and capacity of market participants to make a market in 19  such holding. Market prices for less liquid or illiquid holdings may be volatile or difficult to determine, and reduced liquidity may have an adverse impact on the market price of such holdings. Additionally, the sale of less liquid or illiquid holdings may involve substantial delays (including delays in settlement) and additional costs and the fund or account may be unable to sell such holdings when necessary to meet its liquidity needs or to try to limit losses, or may be forced to sell at a loss. • Asset allocation — The fund’s or account’s percentage allocation to equity securities, debt securities and money market instruments could cause the fund or account to underperform relative to relevant benchmarks and other funds with similar investment objectives. The fund or account may also hold cash or cash equivalents, including commercial paper and short-term securities issued by the U.S. government, its agencies and instrumentalities. The percentage of the fund or account invested in such holdings varies and depends on various factors, including market conditions and purchases and redemptions of fund or account shares. CGPCS may determine that it is appropriate to invest a substantial portion of the fund’s or account’s assets in such instruments in response to certain circumstances, such as periods of market turmoil. For temporary defensive purposes, the fund or account may invest without limitation in such instruments. A larger percentage of such holdings could moderate the fund’s or account’s investment results in a period of rising market prices. Alternatively, a larger percentage of such holdings could reduce the magnitude of the fund’s or account’s loss in a period of falling market prices and provide liquidity to make additional investments or to meet redemptions. • Cybersecurity risks — With the increased use of technologies such as the Internet to conduct business, the fund or account has become potentially more susceptible to operational and information security risks through breaches in cybersecurity. In general, a breach in cybersecurity can result from either a deliberate attack or an unintentional event. Cybersecurity breaches may involve, among other things, “ransomware” attacks, injection of computer viruses or malicious software code, or the use of vulnerabilities in code to gain unauthorized access to digital information systems, networks or devices that are used directly or indirectly by the fund or account or its service providers through “hacking” or other means. Cybersecurity risks also include the risk of losses of service resulting from external attacks that do not require unauthorized access to the fund’s or account’s systems, networks or devices. For example, denial-of-service attacks on the investment adviser’s or an affiliate’s website could effectively render the fund’s or account’s network services unavailable to fund or account shareholders and other intended end-users. Any such cybersecurity breaches or losses of service may, among other things, cause the fund or account to lose proprietary information, suffer data corruption or lose operational capacity or may result in the misappropriation, unauthorized release or other misuse of the fund’s or account’s assets or sensitive information (including shareholder personal information or other confidential information), the inability of fund or account shareholders to transact business, or the destruction of the fund’s or account’s physical infrastructure, equipment or operating systems. These, in turn, could cause the fund or account to violate applicable privacy and other laws and incur or suffer regulatory penalties, reputational damage, additional costs (including compliance costs) associated with corrective measures and/or financial loss. While the fund or account and its investment adviser have established business continuity plans and risk management systems designed to prevent or reduce the impact of cybersecurity attacks, there are inherent limitations in such plans and systems due in part to the ever-changing nature of technology and cybersecurity attack tactics, and there is a possibility that certain risks have not been adequately identified or prepared for. In addition, cybersecurity failures by or breaches of the fund’s or account’s third-party service providers (including, but not limited to, the fund’s or account’s investment adviser, transfer agent, custodian, administrators and other financial intermediaries) may disrupt the business operations of the service providers and of the fund, potentially resulting in financial losses, the inability of fund or account shareholders to transact business with the fund or account and of the fund or account to process transactions, the inability of the fund or account to calculate its net asset value, violations of applicable privacy and other laws, rules and regulations, regulatory fines, penalties, reputational damage, reimbursement or other compensatory costs and/or additional compliance costs associated with implementation of any corrective measures. The fund or account and its shareholders could be negatively impacted as a result of any such cybersecurity breaches, and there can be no assurance that the fund or account will not suffer losses relating to cybersecurity attacks or other informational security breaches affecting the fund’s or account’s third-party service providers in the future, particularly as the fund or account cannot control any cybersecurity plans or systems implemented by such service providers. 20  Cybersecurity risks may also impact issuers of securities in which the fund or account invests, which may cause the fund’s or account’s investments in such issuers to lose value. • Operational events — To the extent that a strategy relies on proprietary and third-party data analysis and systems to support investment decision making, there is a risk of software or other technology malfunctions or programming inaccuracies that may impair the performance of these systems. System impairment may negatively impact performance. • Loss of investment — An investor may lose money by investing in a fund. The likelihood of loss may be greater if the investor invests for a shorter period of time. • Investments are not guaranteed — Investments in a fund or account are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other governmental agency, entity or person. • Long-Term perspective — Investors in a fund or account should have a long-term perspective and be able to tolerate potentially sharp declines in value. • Past investment results are not predictive of future investment results. Clients should also refer to account guidelines as well as to each account’s governing documents or other disclosure documents for further information specific to their account investments. CGPCS occasionally, as needed for account servicing, discloses nonpublic personal information about your account such as name, account information, portfolio holdings or other relevant details to unaffiliated third parties. If information is provided to a third party, such third party is required to protect the confidentiality and security of this information and use it only for its intended purpose. If a third party delivers client securities or funds to the investment adviser in connection with, among other things, a securities law related lawsuit or regulatory order (e.g., proceeds from a class action settlement or Fair Fund account), corporate action, tax refund or reclaim, such securities or funds will be forwarded to the client or the client’s custodian. In certain circumstances, however, if the intended recipient cannot be readily identified, they may be returned to sender, escheated or donated as deemed appropriate by the investment adviser. 21  ITEM 9: DISCIPLINARY INFORMATION Neither CGPCS nor any of its management persons has been the subject of legal or regulatory findings, or is the subject of any pending criminal proceedings that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. From time to time, CGPCS or its management persons may be subject to regulatory examinations, investigations, litigation or inquiries that arise in the ordinary course of our business. In the event we become aware of any regulatory matter or litigation that we believe would be material to an evaluation of our advisory business, we notify all clients or prospective clients affected by those events, subject to applicable law and regulation. 22  ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS CGPCS has the following arrangements with certain affiliated entities that are material to its advisory business. Some of CGPCS’s directors and executive officers and employees are also directors, officers or employees of one or more affiliates. Broker-dealer Capital Client Group, Inc. (“CCG”) is a registered broker-dealer and a member of the Financial Industry Regulatory Authority and Municipal Securities Rulemaking Board. CCG acts as the principal underwriter and distributor of mutual funds, including investment companies advised and administered by CGPCS’s affiliates, and provides related services. CCG is also registered as an insurance agency or producer in certain states. CCG is also an investment adviser which provides investment advisory related services in connection with various wrap-fee programs sponsored by unaffiliated broker-dealers or other financial institutions, where CGPCS’s affiliates can be retained as an investment manager. Registered Investment Companies Capital International, Inc. (“CIInc”) and Capital Research and Management Company (“CRMC”) serve as investment advisers for investment companies registered under the Investment Company Act of 1940. CIInc and CRMC receive advisory and other fees and expenses from each fund based upon the value of the fund’s assets; those fees are described in each fund’s governing documents. Commodity Pool Operator CRMC, an affiliated investment adviser, is registered as a commodity pool operator and a member of the National Futures Association. Banks and Trust Companies Capital Bank and Trust Company (“CB&T”), a federal savings bank and an investment adviser registered with the U.S. Securities and Exchange Commission, is a wholly-owned subsidiary of CGC. CB&T provides trustee services to certain CGPCS clients. Other Investment Advisers Because our funds, accounts, and our personnel are located around the world, we conduct business through a number of affiliated entities licensed to offer services in various jurisdictions and to perform particular business functions. Though legally distinct, our affiliates function as a unified, global business. We believe that our globally integrated model helps us to serve our clients’ needs better. We often engage our affiliates and their personnel to assist in managing client mandates. For example, our affiliated personnel provide research, portfolio management or trading services to certain client accounts. Certain portfolio managers employed by the following affiliated investment advisers, under the supervision and review of CGPCS or its affiliates, determine the securities to be purchased and sold for certain clients and funds of CGPCS: CRMC is an affiliated investment adviser registered with the U.S. Securities and Exchange Commission with which CGPCS shares supervised persons. Capital Research Company is an affiliated registered investment adviser and indirectly provides investment advisory research to CGPCS. This includes managing assets, subject to the supervision and control of CGPCS, or its other advisory affiliates. 23  CIInc is an affiliated investment adviser registered with the U.S. Securities and Exchange Commission as well as with the Hong Kong Securities and Futures Commission, the Financial Services Commission of South Korea and the Australian Securities and Investment Commission as it also conducts investment advisory and asset management services in those regions. Capital International K.K. (“CIKK”) is based in Japan and has been authorized by the Financial Services Agency to provide investment advisory and asset management services. Capital International K.K. provides research information and services to CGPCS. Capital Group Investment Management Pte. Ltd. (“CGIMPL“) is based in Singapore and has been authorized by the Monetary Authority of Singapore to provide investment advisory and asset management services. Capital International Sarl (“CISA”) is based in Switzerland and has been authorized by the Financial Markets Supervisory Authority to provide investment advisory services. Capital International Limited (“CIL”) is based in the U.K. and has been authorized by the U.K. Financial Services Authority to provide investment advisory and asset management services. Capital Group UK Management Company (“CGUKMC”) is authorized by the U.K. Financial Conduct Authority as a U.K. management company. CGUKMC serves as a management company only and does not undertake other financially regulated activities, nor does it undertake any activities outside of the U.K. Capital International Management Company Sarl (“CIMC”) is based in Luxembourg and has been authorized by the Luxembourg financial regulator and other financial regulators in the European Union to provide investment advisory or asset management services in Luxembourg and European Union countries. None of CIKK, CGIMPL, CISA, CIL nor CIMC are registered as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and each is deemed to be a “Participating Affiliate” of CGPCS and its affiliates, as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirements for certain affiliates of registered investment advisers. 24  ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING CGPCS and its affiliated companies have adopted a Code of Ethics for its associates (Code of Ethics) that requires all associates: (i) act with integrity, competence and in an ethical manner; (ii) comply with applicable U.S. federal securities laws, as well as all other applicable laws, rules and regulations; and (iii) promptly report violations of the Code of Ethics. All associates are required to certify at least annually that they have read and understand the Code. A copy of the Code of Ethics is available to clients and prospective clients upon request and on americanfunds.com. The Code of Ethics includes: • Protection of Non-Public Information: Policies and procedures designed to prevent and detect the misuse of material non-public information (“MNPI”) by associates. These procedures require all associates who believe they may be in possession of material non-public information MNPI regarding an issuer to notify the Legal Department, which will determine the appropriate actions to be taken. Associates may come into possession of MNPI through various channels and must comply with CGPCS’s Insider Trading Policy. • Personal Investing: Policies related to personal investing by our associates, and their covered family members. The policies ban excessive trading of any Capital-managed investment vehicles worldwide, including the American Funds. Associates generally may not participate in the acquisitions of securities in initial public offerings. Additional restrictions apply to associates with access to non-public information relating to current or imminent fund/client transactions, investment recommendations or fund portfolio holdings (Covered Associates). Covered Associates generally may not affect securities transactions for their own account when any investment advisory account is transacting in the issuer in question. All such Covered Associates must report their securities transactions on a quarterly basis and disclose their holdings annually. Covered Associates must pre-clear certain personal security transactions and special review of private placements is required. Additional restrictions and reporting apply to Investment Access Persons, including blackout periods on personal investing and a ban on short-term trading. • Gifts and Entertainment: Policy prohibiting associates from accepting and extending gifts or entertainment that are excessive, repetitive or extravagant, if such gifts or entertainment involve a third party’s business relationship (or prospective business relationship) with Capital. Procedures include quarterly reporting of gifts or entertainment received or extended, a dollar limit on gifts that can be accepted from any one source during a calendar year, and preclearance of entertainment beyond a certain dollar limit. • Outside Business Activities: Policies governing avoidance of outside business interests or affiliations that may give rise to conflicts of interest or that may create divided loyalties, divert substantial amounts of associates’ time, or compromise their independent judgment. Associates must obtain prior approval to serve on the board of directors or as an advisory board member of any public or private company and must disclose if they serve on the board of a non-profit or charitable organization that has issued or has future plans to issue publicly held securities, including debt obligations. Associates must also disclose if they or certain close family members serve as a board director or as an advisory board member of, holds a senior officer position with, or owns 5% or more of any public company or any private company that may be reasonably expected to go public. • Political Contributions: Policy governing political contributions and/or other activities that directly support officials, candidates, or organizations that may be in a position to influence decisions to award business to investment management firms. Specific rules exist for political contributions and activities within the United States and restricted associates are required to seek preclearance and approval for political contributions to state and local government officials (or candidates for those positions), federal candidate campaigns and affiliated committees, and political organizations, such as Political Action Committees (“PACs”). • Charitable Contributions: Associates must not allow CGPCS’s present or anticipated business to be a factor in soliciting charitable contributions. In addition, it is generally not appropriate to solicit for donations to a charitable organization in which an associate or their family members are significantly involved. Participation or Interest in Client Transactions CGPCS and its affiliates recommend that certain clients invest in commingled funds and other limited partnerships or pooled funds managed by CGPCS or its affiliates. Additionally, CGPCS, in its capacity as investment agent, will be 25  empowered to invest CGPCS client assets in certain of these funds. In all cases, the nature and scope of the financial interest (e.g., investment management fees or economic interest in such partnerships or funds) is disclosed. CGPCS’s employees may also purchase shares in certain commingled funds and other pooled funds advised by CGPCS or an affiliate of CGPCS. Such purchases take place either through their personal CGPCS account or through retirement plans sponsored by CGC. All such transactions are conducted at net asset value and in accordance with the purchase and redemption provisions as described in either the prospectus or offering memorandum of the fund. 26  ITEM 12: BROKERAGE PRACTICES Selecting Broker-Dealers Portfolio Transactions CGPCS and its affiliates place orders with broker-dealers for clients’ portfolio transactions. Purchases and sales of equity securities on a securities exchange or an over-the-counter market are effected through broker-dealers who receive commissions for their services. Purchases and sales of fixed-income securities and currency foreign exchange transactions are generally made with an issuer or a primary market-maker acting as principal with no stated brokerage commission. Prices for fixed-income securities in secondary trades usually include undisclosed compensation to the market-maker reflecting the spread between the bid and ask prices for the securities. The prices for equity and fixed- income securities purchased in primary market transactions, such as initial public offerings, new fixed-income issues, secondary offerings and private placements, may include underwriting fees. Best Execution In selecting broker-dealers, CGPCS and its affiliates strive to obtain “best execution” (the most favorable total price reasonably attainable under the circumstances) for its clients’ portfolio transactions, taking into account a variety of factors. These factors include the size and type of transaction, the nature and character of the markets for the security to be purchased or sold, the cost, quality, likely speed and reliability of execution and settlement, the broker- dealer’s or execution venue’s ability to offer liquidity and anonymity, applicable tax considerations, and the tradeoff between market impact and opportunity costs. CGPCS considers these factors, which involve qualitative judgment, when selecting broker-dealers and execution venues for its clients’ portfolio transactions. CGPCS views best execution as a process that should be evaluated over time as part of an overall relationship with particular broker- dealer firms. In this regard, CGPCS does not consider itself as having an obligation to obtain the lowest commission rate available for a portfolio transaction to the exclusion of price, service and qualitative considerations. Brokerage commissions are only a small part of total execution costs and other factors, such as market impact and speed of execution, contribute significantly to overall transaction costs. Oversight The Capital Group Companies Equity Trading Oversight and Best Execution Committee and the Capital Group Companies Fixed-Income Best Execution Committee provide oversight to CGPCS’s policies, procedures and practices relating to best execution. CGPCS obtains third-party analysis of trading execution quality. These analyses compare execution results with various benchmarks which provide quantitative data that is one of many data points that is evaluated to ensure that CGPCS is meeting its best execution obligation. The Market and Transaction Research group performs in-depth analysis on equity trade execution data and reviews the findings with the Global Equity Trading Manager to enhance the ability to measure and interpret trading costs and their effects on portfolio performance. The Equity Trading Oversight and Best Execution Committee meets periodically to review such trade execution analysis and evaluate the overall quality of execution and trades. The Equity Trading Oversight and Best Execution Committee also reviews equity trading policies and approves changes as appropriate. Fixed-income analysis of trade execution data and trading costs is performed in coordination with the traders and reviewed by the Fixed Income Trading Management team to enhance the ability to measure and interpret trading costs and their effects on portfolio performance. The Fixed-Income Best Execution Committee meets periodically to review fixed-income trading practices and overall quality of execution for fixed-income and foreign exchange trades. The Fixed-Income Best Execution Committee also reviews fixed income trading policies and approves changes as appropriate. The Capital Group Companies Investment Group provides oversight of Capital Group’s research management program. It is responsible for (a) overseeing the quality of the research acquired by CGPCS and its affiliates to inform future procurement processes, decisions and payment levels and (b) approving an annual research budget. 27  Commission Rates CGPCS and its affiliates negotiate commission rates with brokers based on what they believe is reasonably necessary to obtain best execution. CGPCS and its affiliates do not consider the appropriate commission to necessarily be the lowest available commission, but attempt to maximize the overall benefits received by their clients for their commissions. Commission rates vary based on the nature of the transaction, the market in which the security is traded and the venue chosen for trading, among other factors. CGPCS and its affiliates seek, on an ongoing basis, to determine what the reasonable levels of commission rates for execution services are in the marketplace, taking various considerations into account, including the extent to which a broker-dealer has put its own capital at risk, historical commission rates and, commission rates that other institutional investors are paying. Brokerage and Investment Research Services CGPCS and its affiliates execute portfolio transactions with broker-dealers who provide certain brokerage and/or investment research services to CGPCS and its affiliates but only when in CGPCS’s and its affiliates’ judgment the broker-dealer is capable of providing best execution for that transaction. CGPCS and its affiliates make decisions for procurement of research separately and distinctly from decisions on the choice of brokerage and execution services. The receipt of these research services permits CGPCS and each affiliate to supplement its own research and analysis and makes available the views of, and information from, individuals and the research staffs of other firms. These services include, among other things, reports and other communications with respect to individual companies, industries, countries and regions, economic, political and legal developments, as well as scheduling meetings with corporate executives and seminars and conferences related to relevant subject matters. This information may be provided in the form of written reports, telephone contacts and meetings with securities analysts. CGPCS and its affiliates bear the cost of all third-party investment research services for all client accounts they advise. However, in order to compensate certain U.S. broker-dealers for research consumed, and valued, by their investment professionals, affiliates of CGPCS operate a limited commission sharing arrangement with commissions on equity trades for registered investment companies managed by such affiliates. Affiliates of CGPCS voluntarily reimburse such registered investment companies for all amounts collected into the commission sharing arrangement. In order to operate the commission sharing arrangement, affiliates of CGPCS may cause such registered investment companies to pay commissions in excess of what other broker-dealers might have charged for certain portfolio transactions in recognition of brokerage and/or investment research services. In this regard, CGPCS and its affiliates have adopted a brokerage allocation procedure consistent with the requirements of Section 28(e) of the U.S. Securities Exchange Act of 1934. Section 28(e) permits an investment adviser to cause an account to pay a higher commission to a broker- dealer to compensate the broker-dealer or another service provider for certain brokerage and/or investment research services provided to CGPCS and its affiliates, if CGPCS and each affiliate makes a good faith determination that such commissions are reasonable in relation to the value of the services provided to CGPCS and its affiliates in terms of that particular transaction or CGPCS’s or its affiliates overall responsibility to their clients. Certain brokerage and/or investment research services may not necessarily benefit all accounts paying commissions to a broker-dealer, therefore, CGPCS and its affiliates assess the reasonableness of commissions in light of the total brokerage and investment research services provided to CGPCS and its affiliates. Further, research services may be used by all investment associates of CGPCS and its affiliates regardless of whether they advise accounts with trading activity that generates eligible commissions. In accordance with its internal brokerage allocation procedure, CGPCS and its affiliates periodically assess the brokerage and investment research services provided by each broker-dealer and each other service provider from whom they receive such services. As part of ongoing relationships, CGPCS and its affiliates routinely meet with firms to discuss the level and quality of the brokerage and research services provided, as well as the value and cost of such services. In valuing the brokerage and investment research services CGPCS and its affiliates receive from broker-dealers and other research providers in connection with their good faith determination of reasonableness, CGPCS and its affiliates take various factors into consideration, including the quantity, quality and usefulness of the services to CGPCS and its affiliates. Based on this information and applying their judgment, CGPCS and its affiliates set an annual research budget. Research analysts and portfolio managers periodically participate in a research provider poll to determine the usefulness and value of the research provided by individual broker-dealers and research providers. Based on the results of this research provider poll, CGPCS and its affiliates may, through commission sharing arrangements with certain broker-dealers, direct a portion of commissions paid to a broker-dealer by registered investment 28  companies managed by affiliates of CGPCS to be used to compensate the broker-dealer and/or other research providers for research services they provide. While CGPCS and its affiliates may negotiate commission rates and enter into commission sharing arrangements with certain broker-dealers with the expectation that such broker-dealers will be providing brokerage and research services, none of CGPCS, any of its affiliates or any of their clients incurs any obligation to any broker-dealer to pay for research by generating trading commissions. CGPCS and its affiliates negotiate prices for certain research that may be paid through commission sharing arrangements or by themselves with cash. Cross Trades As part of its authority to invest client assets on a discretionary basis, CGPCS places cross-trades between client accounts managed by CGPCS and its affiliates from time to time. CGPCS recognizes that a potential conflict of interest may exist when placing trades between client accounts. To address such potential conflicts, CGPCS maintains cross-trade policies and procedures and places a cross-trade under those limited circumstances when such a trade: (a) is in the best interest of all participating clients and (b) is not prohibited by the participating clients’ investment advisory agreement or applicable law. Sale of Fund Shares Not Considered CGPCS may place orders for a client’s portfolio transactions with broker-dealers who have sold shares in the funds managed by CGPCS or its affiliated companies; however, it does not consider whether a broker-dealer has sold shares of the funds managed by CGPCS or its affiliated companies when placing any such orders for a client’s portfolio transactions. Client Referrals CGPCS does not consider client referrals from a broker-dealer or third party in selecting or recommending broker-dealers. Directed Brokerage In some instances, CGPCS or its affiliates will accept a client’s instructions to direct a portion of the account’s brokerage commissions to a particular broker or group of brokers so long as the direction is consistent with CGPCS’s policy of seeking best execution. CGPCS’s ability to meet client direction requests will depend on the broker(s) selected by the client and the securities and markets in which the account invests, among other factors. Furthermore, CGPCS and its affiliates will only accept requests to direct brokerage from clients who are subject to ERISA only if the client’s direction program complies with ERISA. Occasionally, clients direct CGPCS to place all or a portion of their account’s annual brokerage costs to one or several broker-dealers and do not require that directed trades be subject to CGPCS’s policy of seeking best execution. In these cases, CGPCS may be limited in negotiating commissions with broker-dealers to whom it directs trades and such accounts may therefore pay higher commissions than those that do not direct brokerage in this way. Further, such trades are not aggregated with trades for CGPCS’s other clients and funds, and may be executed subsequent to trades for other CGPCS accounts and funds. CGPCS believes clients are best served when it has the full authority to determine the broker and negotiate commissions for securities transactions. With directed brokerage arrangements of this type, CGPCS cannot assure clients that they will be able to obtain best execution. Aggregation and Allocation of Portfolio Transactions Frequently, CGPCS will place orders to purchase or sell the same security for a number of clients of CGPCS and its affiliates that are advised by the same investment division. CGPCS has determined that it is fair and equitable to participating funds and accounts to aggregate orders and allocate executions within each investment division in accordance with this policy. CGPCS believes that placing aggregated or “block” trades is consistent with its duty to seek best execution. Further, a client’s trades are aggregated with those of other clients only if it is consistent with the terms of the client’s investment advisory agreement. CGPCS may not aggregate certain trades when it believes that doing so will not have a material impact on the price or quality of other transactions. This policy is designed to allocate trades of the same security to clients in a fair and equitable manner over time, taking 29  into consideration the interests of each fund and account. Non-investment factors, such as fee arrangements, are not considered in selecting clients or allocating trades. Equity Securities Within each equity investment division, if orders to purchase or sell the same security are open for more than one fund or account, executed trades are generally allocated pro rata to the funds and accounts based on the authorized order size for each fund and account at the time the trade is executed. Allocated amounts will be rounded to reflect the Advisers’ and market practices for lot sizes. All funds and accounts receive shares at the average price and pay a pro rata portion of all transaction costs. In aggregating and allocating trades, CGPCS seeks to allocate executions fairly and equitably over time, taking into consideration relevant factors, including without limitation, applicable account investment restrictions or guidelines, regulatory restrictions, relevant market practices, tax considerations, amounts of available cash, the need to rebalance an account portfolio (e.g., due to investor contributions and redemptions) and whether the allocation would result in an account receiving an amount below the established minimum quantity. See additional information regarding these factors in the paragraphs below. Restrictions in client accounts, such as broker selection requirements, may require that a client’s order be traded separately. Client accounts that are traded separately from the aggregate order may receive a less favorable execution price than the accounts that are part of the aggregate order. Certain clients have requested CGPCS to direct a portion of their trades to a particular broker-dealer, subject to the CGPCS’s duty to seek best execution. If the trader believes that best execution would not be harmed by directing the client’s trade to the requested broker-dealer, then the trade for that client may be removed from the block to place the trade with the requested broker-dealer. Additional equity authorizations: If an additional order to purchase or sell a security is placed after the trader has begun to work the initial orders, the equity trading platform allocates executed trades to participating accounts based on the initial orders and then begins a new allocation process based on the remaining open orders and the new orders. Under certain circumstances, traders are given discretion to include orders they receive after the trader has started to work an initial order with the initial aggregated order for allocation purposes. This may occur for example when an analyst has issued a recommendation in the morning and not all managers have had the opportunity to hear the recommendation before the start of trading or an order for the same security is subject to additional compliance approvals. The traders have discretion to allocate on this basis when to do so will be fair and equitable to all participating client accounts. Special instructions: In certain circumstances, parts of an aggregated order may be subject to special portfolio manager instructions, such as a price limit, or other factors that do not apply to the entire aggregated order. This may result in an allocation other than pro rata to all accounts in the aggregated order. For example, trades executed above a price limit (in the case of purchases) or below the limit (in the case of sales) would be allocated on a pro rata basis only to orders that were not subject to the price limit. Occasionally when there is a relatively small remaining open order and a very large new order is placed, trading may complete the small order before proceeding with the larger new order, rather than aggregating the orders. Program and list trades: CGPCS and its affiliates serve as investment adviser for certain accounts that are designed to be substantially similar to another account. This type of account will often generate a large number of relatively small trades when it is rebalanced to its reference fund due to differing cash flows or when the account is initially started up. CGPCS may not aggregate program trades or electronic list trades executed as part of this process. Non-aggregated trades performed for these accounts will be allocated entirely to that account. This is done only when CGPCS believes doing so will not have a material impact on the price or quality of other transactions. Minimum allocation size: Often, a single aggregated order is executed in a series of smaller transactions over a period of time. In those circumstances, some clients, particularly those that represent a small portion of an aggregated order, may incur significant trade ticket, custody and related fees due to multiple allocations. CGPCS may observe a minimum transaction size per client account and allocate trades in a manner that seeks to reduce the transaction costs that clients may incur as a result of small allocations. These minimums may vary by client account in an effort to treat all clients fairly and equitably. In-kind transactions: From time to time, an affiliate of CGPCS may facilitate in-kind creation or redemption basket 30  transactions for certain pooled investment vehicles, including exchange-traded funds and other investment vehicles. Because these transactions may involve unique operational, liquidity, tax-management or counterparty considerations, they may be executed separately from other client orders involving the same securities. As a result, transactions associated with an in-kind basket will not be aggregated with other orders and may receive different execution timing, prices, transaction costs or market impact outcomes than would have resulted from aggregating such orders with orders for other funds and accounts. Initial Public Offerings Orders for initial public offerings of equity securities (“IPOs”) are allocated in the same manner as described above. The trading department aggregates authorized orders it receives for IPOs and places a block trade with the underwriting syndicate. If the resulting allocation we receive from the underwriting syndicate is not sufficient to fill all orders, each equity investment division generally allocates the transaction on a pro rata basis based on each account’s authorized order size, unless the relevant investment committee approves another allocation. In certain circumstances orders are placed based on approximate fund or account asset size; however, no fund or account will be allocated more than its indication. Allocations may be subject to CGPCS’s and its affiliates market practices for lot sizes. If the allocation places some client accounts below the minimum lot size, then the trading department will exclude those accounts in the allocation process and allocate the remaining shares to other clients on a pro rata basis. Fixed-Income Securities In allocating trades to accounts, portfolio managers and analysts review client guidelines and consider a variety of other factors including: the other securities held in the account’s portfolio; the appropriateness of the security for the fund’s objective; the industry/sector, issue/issuer holdings, portfolio analytic data; the size of the account; the size of the confirmed, executed transaction; the invested position of the account; and the marketability of the security. Once a fixed-income trade has been executed and participating client accounts are identified, all accounts receive the same purchase price when participating in a block trade. All fixed-income trades are reviewed a final time after allocation and execution by the Fixed-Income Compliance team against the compliance guidelines of the accounts. New Fixed-Income Issues Funds and accounts are selected to participate in new issuance of fixed-income securities in the same manner as described above. Orders are aggregated for new issues and a block order is placed with the lead arrangers or bookrunners. If the resulting allocation received from the arrangers is not sufficient to fill all orders, the trade is generally allocated on a pro rata basis based on each account’s authorized order size, unless the relevant investment committee approves another allocation methodology. Consideration may be given to the factors listed above. Allocations may be subject to CGPCS’ and market practices for lot sizes. If the allocation places some client accounts below the minimum lot size, those accounts may not receive an allocation. Foreign Currency Exchange Transactions CGPCS generally executes foreign currency transactions for funds or accounts over which it has investment discretion directly through broker-dealers; however, a fund’s or account’s custodian may be used to execute certain foreign exchange transactions. These include transactions in markets with legal restrictions or operational risks that make executing directly in those markets impractical. Identification and Resolution of Trade Errors CGPCS maintains policies and procedures that address the identification and remediation of trade errors. These policies and procedures are designed to address the resolution of errors and to provide appropriate oversight and review of such errors. To the extent a trade error occurs, CGPCS seeks to identify and resolve such error in a manner that is fair to its clients as promptly as possible. When determining the loss associated with an error, CGPCS will typically net gains and losses arising from a single error or a series, unless prohibited by applicable law or a specific 31  agreement with the client. CGPCS will address and resolve errors on a case-by-case basis, in its discretion, based on each error’s facts and circumstances. CGPCS attempts to resolve similar trade errors in a consistent manner, although CGPCS may elect to compensate a client for a loss in certain circumstances where it believes it is not a compensable trade error. Non-Advisory Asset Trades As an accommodation for certain clients, CGPCS may agree to provide non-advisory services with respect to certain assets (“Non-Advisory Assets”). Clients retain investment discretion and trading authority over such Non-Advisory Assets, and CGPCS has no investment discretion or trading authority or any responsibility to provide investment advice or recommendations with respect to the Non-Advisory Assets. For clients whose assets are custodied by Pershing Advisor Solutions LLC (“Pershing”), Pershing will execute all trades for equity Non-Advisory Assets pursuant to clients’ instructions. With the consent of CGPCS, clients may transfer Non-Advisory Assets to their respective managed accounts and CGPCS will determine how to manage such securities in the context of the overall investment strategy for each client, which may include selling or retaining them in the discretion of CGPCS. 32  ITEM 13: REVIEW OF ACCOUNTS CGPCS investment professionals review client account allocations with clients on a periodic basis, generally at least once a year. Compliance teams monitor pooled funds and SMA Programs on an ongoing basis and perform periodic reviews. This monitoring and review is conducted to verify that pooled funds and SMA Programs are in compliance with their objectives and guidelines. In addition, certain portfolio data for pooled funds and SMA Programs is periodically reviewed by investment professionals, including portfolio managers. Investors in pooled funds are provided periodic portfolio statements and such other reports as specifically requested from time to time. CGPCS clients receive monthly or quarterly statements and such other reports as agreed between the client and CGPCS from time to time. 33  ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION From time to time CGPCS compensates affiliates and associates for client referrals, client relations and marketing services. CGPCS or its affiliates from time to time compensate eligible third parties for CGPCS client referrals pursuant to a written agreement with the eligible third party. At the time a third-party recommends CGPCS services, CGPCS or its affiliate provides – either directly or through the third-party – written disclosure to prospective clients regarding the fee that the third-party stands to receive from CGPCS should the prospective clients decide to hire CGPCS. The disclosure also addresses any material conflicts of interest on the part of the third-party with respect to their recommendation of CGPCS resulting from such fee arrangement. Some of CGPCS’s clients and prospective clients retain investment consultants to evaluate and recommend investment advisers and their services. CGPCS may provide investment management services to these consultants or their affiliates. CGPCS is not affiliated with an investment consultant business and does not pay to gain favor from consultants in terms of future or continuing new business opportunities. Many consultants offer valuable services to investment managers, and CGPCS and its affiliates regularly subscribe to various consultant services to gain access to their index and peer data and occasionally participate in their conferences and training programs. In addition, from time to time, CGPCS and its affiliates co-sponsor industry events such as conferences with other managers or consultants. Also, CGPCS and its affiliates purchase other products or services from certain consultants such as data feed transmission, electronic services and related software. Kohlberg Kravis Roberts & Co. L.P. (“KKR”) provides distribution payments to CCG, an affiliate of CGPCS, in connection with investments by certain funds and accounts managed by CRMC or its affiliates in KKR-sponsored investments, including units offered by KKR Private Equity Conglomerate LLC (“K-PEC”), other KKR Vehicles and KKR-sourced co-investments. These payments are determined by the collective amount the fund or account invests in such KKR-sponsored investments and are calculated as a revenue share of the fees and performance allocations received by KKR from such investments. Any such compensation will apply regardless of how an investment is acquired and will not be contingent on the fund or account realizing a gain on its investments in such KKR-sponsored investments. This may create an incentive for CRMC to allocate a greater portion of the fund’s or account’s assets to K-PEC, other KKR Vehicles and KKR-sourced co-investments, even when it may conflict or appear to conflict with the fund’s and shareholders’ interests and may create a disincentive for CRMC to attempt to negotiate lower fees on such investments. 34  ITEM 15: CUSTODY CGPCS does not have physical custody of client assets but is deemed to have custody of certain client assets, as defined under rule 206(4)-2 of the Advisers Act. Clients for which CGPCS is deemed to have custody will receive account statements from a third-party custodian bank quarterly or monthly and should carefully review those statements against the account statements provided by CGPCS, if applicable. If a third party inadvertently delivers client securities or funds to CGPCS, such securities or funds generally will be forwarded to the client or the client’s custodian. In certain circumstances, however, they may be returned to sender. 35  ITEM 16: INVESTMENT DISCRETION When CGPCS is retained on a discretionary basis pursuant to an investment advisory agreement, CGPCS is generally authorized, without client consultation or consent to determine, among other things: • what securities are to be bought or sold; the amount of securities to be bought or sold; • the prices at which securities are to be bought or sold; • the broker or dealer to be used; and • the commissions to be paid. • CGPCS’ discretion is to be exercised in accordance with the agreed upon investment advisory agreement and guidelines that set forth the objectives of the account and specific investment restrictions and limitations. The guidelines typically describe the investment mandate and types of securities that are eligible for (or prohibited from) the account. However, assets that a client delivers to their account are considered non-discretionary assets until that client and CGPCS have agreed on the asset allocation applicable to such assets and whether any such assets will not be managed by CGPCS. Investment discretion and authorizations are described in the investment advisory agreement signed by CGPCS and the client. The agreement, including any unique investment guidelines, is typically reviewed by administrative and legal personnel (as required) before being signed. 36  ITEM 17: VOTING CLIENT SECURITIES CGPCS (the “Adviser”) accepts proxy voting authority from its clients and follows its Proxy Voting Procedures and Principles (the “Principles”), which are summarized below. If the Adviser has voting authority for a client account, it generally does not provide the client the option to direct a proxy vote. With respect to SMA Programs, proxies associated with securities held in an SMA Program will be voted by the applicable Sub-adviser. An unaffiliated Sub-adviser will have different proxy voting procedures and principles than those of the Adviser and, as a result, may vote differently on proxy matters than the Adviser. Please refer to the Form ADV Part 2A brochure of the Sub-adviser for further information regarding the proxy voting practices applicable to an SMA Program. Some clients reserve the right to vote proxies and do not give the Adviser the authority to vote on their behalf. In those cases, clients should contact their custodian about receiving proxies. The Adviser would not expect to discuss particular solicitations with clients for whom it does not have proxy voting authority. This summary of the Adviser’s Proxy Voting Procedures and Principles is qualified by the full Principles, which is available on request. The Principles provide an important framework for analysis and decision-making by the Adviser. However, they are not exhaustive and do not address all potential issues. The Principles provide a certain amount of flexibility so that all relevant facts and circumstances can be considered in connection with every vote. As a result, each proxy received is voted on a case-by-case basis considering the specific circumstances of each proposal. The voting process reflects the Adviser’s understanding of the company’s business, its management and its relationship with shareholders over time. In all cases, long-term value creation the investment objectives and policies of the funds and accounts managed by the Adviser or its affiliates remain the focus. Voting Procedures The Adviser seeks to vote all U.S. proxies. Proxies for companies outside the U.S. also are voted where there is sufficient time and information available, taking into account distinct market practices, regulations and laws, and types of proposals presented in each country. Where there is insufficient proxy and meeting agenda information available, the Adviser will generally vote against such proposals in the interest of encouraging improved disclosure for investors. The Adviser may not exercise its voting authority if voting would impose costs on clients, including opportunity costs. For example, certain regulators have granted investment limit relief to the Adviser and its affiliates, conditioned upon limiting voting power to specific voting ceilings. To comply with these voting ceilings, the Adviser will scale back its votes across all funds and accounts it manages on a pro rata basis based on assets. In addition, certain countries impose restrictions on the ability of shareholders to sell shares during the proxy solicitation period. The Adviser may choose, due to liquidity issues, not to expose the funds and accounts it manages to such restrictions and may not vote some (or all) shares. Finally, the Adviser may determine not to recall securities on loan to exercise its voting rights when it determines that the cost of doing so would exceed the benefits to clients or that the vote would not have a material impact on the investment. Proxies with respect to securities on loan through client-directed lending programs are not available to vote and therefore are not voted. After a proxy statement is received, the Adviser’s stewardship and engagement team prepares a summary of the proposals contained in the proxy statement. Investment analysts are generally responsible for making voting recommendations for their investment division on significant votes that relate to companies in their coverage areas. Analysts also have the opportunity to review initial recommendations made by the Adviser’s stewardship and engagement team. Depending on the vote recommendation, a second opinion may be made by a proxy coordinator (an investment professional with experience in corporate governance and proxy voting matters) within the appropriate investment division, based on knowledge of the Principles and familiarity with proxy-related issues. Each of the Adviser’s equity investment divisions has its own proxy voting committee, which is made up of investment professionals within each division. Each division’s proxy voting committee retains final authority for voting decisions made by such division. 37  In cases where a fund or account is co-managed and a security is held by more than one of the Adviser’s equity investment divisions, the divisions may develop different voting recommendations for individual ballot proposals. If this occurs, and if permitted by local market conventions, the position will generally be voted proportionally by divisional holding, according to their respective decisions. Otherwise, the outcome will be determined by the equity investment division or divisions with the larger position in the security as of the record date for the shareholder meeting. In addition to its proprietary proxy voting, governance and executive compensation research, the Adviser may utilize research provided by third-party advisory firms on a case-by-case basis. It does not, as a policy, follow the voting recommendations provided by these firms. It periodically assesses the information provided by the advisory firms and reports to the applicable governance committees that provide oversight of the application of the Principles. Conflicts of Interest From time to time, the Adviser may vote proxies issued by, or on proposals sponsored or publicly supported by, (i) a client with substantial assets managed by the Adviser or its affiliates, (ii) an entity with a significant business relationship with The Capital Group Companies, Inc. or its affiliates, or (iii) a public company with a U.S. registered fund director either on its board or as a senior executive (each referred to as an “Interested Party”). Other persons or entities may also be deemed an Interested Party if facts or circumstances appear to give rise to a potential conflict. The Adviser has developed procedures to identify and address instances where a vote could appear to be influenced by such a relationship. Each equity investment division of the Adviser has a Special Review Committee (“SRC”) of senior investment professionals and legal and compliance professionals with oversight of potentially conflicted matters. If a potential conflict is identified according to the procedure above, the SRC will take appropriate steps to address the conflict of interest. These steps may include engaging an independent third party to review the proxy and using the Principles to provide an independent voting recommendation to the Adviser for vote execution. The Adviser will generally follow the third party’s recommendation, except when it believes the recommendation is inconsistent with the Adviser’s fiduciary duty to its clients. Occasionally, it may not be feasible to engage the third party to review the matter due to compressed timeframes or other operational issues. In this case, the SRC will take appropriate steps to address the conflict of interest, including reviewing the proxy after being provided with a summary of any relevant communications with the Interested Party, information on the organization’s relationship with the Interested Party and any other pertinent information. Proxy Voting Principles The below sets forth at a high level the general positions of the Adviser on various types of proposals. A copy of the full Principles is available upon request, free of charge, by visiting the Capital Group website (capitalgroup.com). Director matters — The election of a company’s slate of nominees for director generally is supported. Votes may be withheld for some or all of the nominees if this is determined to be in the best interest of shareholders or if, in the opinion of the Adviser, such nominee has not fulfilled his or her fiduciary duty. In making this determination, the Adviser considers, among other things, a nominee’s potential conflicts of interest, track record (whether in the current board seat or in previous executive or director roles) with respect to shareholder protection and value creation as well as their capacity for full engagement on board matters. The Adviser generally supports a breadth of experience and perspective among board members, and the separation of the chairman and CEO positions. Governance provisions — Proposals to declassify a board (elect all directors annually) generally are typically supported based on the belief that this increases the directors’ sense of accountability to shareholders. Proposals for cumulative voting generally are supported in order to promote management and board accountability and an opportunity for leadership change. Proposals designed to make director elections more meaningful, either by requiring a majority vote or by requiring any director receiving more withhold votes than affirmative votes to tender his or her resignation, generally are supported. Shareholder rights — Proposals to repeal an existing poison pill generally are supported. (There may be certain circumstances, however, when a proxy voting committee or an investment division of the Adviser believes that a company needs to maintain anti-takeover protection). Proposals to eliminate the right of shareholders to act by written consent or to take away a shareholder’s right to call a special meeting typically are not supported. 38  Compensation and benefit plans — Equity incentive plans are complicated, and many factors are considered in evaluating a plan. Each plan is evaluated based on protecting shareholder interests and a knowledge of the company and its management. Considerations include the pricing (or repricing) of options awarded under the plan and the impact of dilution on existing shareholders from past and future equity awards. Compensation packages should be structured to attract, motivate and retain existing employees and qualified directors; in addition, they should be aligned with the long-term success of the company and the enhancement of shareholder value. Routine matters — The ratification of auditors, procedural matters relating to the annual meeting and changes to company name are examples of items considered routine. Such items generally are voted in favor of management’s recommendations unless circumstances indicate otherwise. Shareholder proposals on environmental and social issues — The Adviser believes environmental and social issues present investment risks and opportunities that can shape a company’s long-term financial sustainability. Shareholder proposals, including those relating to environmental and social issues, are evaluated in terms of their materiality to the company, overall value of transparency and standardization of disclosure, the prescriptive and/or nonbinding nature of the shareholder proposal, best-in-class practices by peer group companies and best practices in the applicable sector. The Adviser generally supports transparency and standardized disclosure, particularly that which leverages existing regulatory reporting or industry best practices. With respect to environmental matters, this includes disclosures aligned with industry standards and reporting on sustainability issues that are material to investment analysis. With respect to social matters, the Adviser encourages companies to disclose the composition of the workforce in a regionally appropriate manner. The Adviser supports relevant reporting and disclosure that is consistent with broadly applicable standards. Proxy Voting for Fund of Funds and Other Pooled Funds In cases where the underlying fund of an investing fund managed by the Adviser, including a fund of funds, holds a proxy vote, such vote is reviewed based on the procedures described above for potentially conflicted matters. Voting Information With respect to client accounts advised by the Adviser or its affiliate where the Adviser or its affiliate has accepted proxy voting authority, information regarding how securities in such accounts were voted are provided upon request. Please contact your Capital Group representative for this information. 39  ITEM 18: FINANCIAL INFORMATION CGPCS does not require or solicit pre-payment of investment advisory fees. As of the date of this ADV Part 2A brochure, CGPCS is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments. 40  ITEM 19: REQUIREMENTS FOR STATE-REGISTERED ADVISERS CGPCS is not registered with any state securities authority. 41