DWS INVESTMENT MANAGEMENT AMERICAS, INC.

Form ADV Part 2A DWS Investment Management Americas, Inc. April 21, 2026 . -454 -4500. SEC”) www.adviserinfo.sec.gov This Brochure provides information about the qualifications and business practices of DWS Investment Management Americas, Inc (“DIMA”). If you have any questions about the contents of this Brochure, please contact us at the following number: 212 The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“ or by any state securities authority. Additional information about DIMA is available via the SEC’s web site Note: DIMA is a registered investment adviser. Registration of an investment adviser does not imply a certain level of skill or training. 875 Third Avenue | New York, NY 10022 | Telephone number: 212 -454 -4500 | www.dws.com  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 2 / Summary of Material Changes is dated April 21, 2026, and is an This disclosure document (“the Brochure”) for DWS Investment Management Americas Inc. update to the annual amendment made on March 31, 2026. DIMA periodicall y makes changes in this Brochure to improve and clarify the descriptions of its own and affiliates’ business practices and compliance policies. To the extent necessary, other updates are made in accordance with evolving industry and firm practices. \ 1  Item 3 / Table of contents Item 2 / Summary of Material Changes ................................ ................................ ........... 1 Item 3 / Table of contents ................................ ................................ .............................. 2 Item 4 / Advisory Business ................................ ................................ ............................. 3 Item 5 / Fees and Compensation ................................ ................................ ................... 6 Item 6 / Performance -Based Fees and Side -by -Side Management ................................ 9 Item 7 / Types of Clients ................................ ................................ ............................... 10 Item 8 / Methods of Analysis, Investment Strategies, and Risk of Loss ......................... 11 Item 9 / Disciplinary Information ................................ ................................ .................. 60 Item 10 / Other Financial Industry Activities and Affiliates ................................ ........... 61 Item 11 / Code of Ethics, Participation, or Interest in Client Transactions, and Personal Trading ................................ ................................ ................................ ................................ ...... 65 Item 12 / Brokerage Practices ................................ ................................ ........................ 70 Item 13 / Review of Accounts ................................ ................................ ........................ 79 Item 14 / Client referrals and Other Compensation ................................ ...................... 80 Item 15 / Custody ................................ ................................ ................................ .......... 81 Item 16 / Investment Discretion ................................ ................................ ................... 82 Item 17 / Voting Client Securities ................................ ................................ ................. 83 Item 18 / Financial Information ................................ ................................ ..................... 85 Additional Disclosures ................................ ................................ ................................ .. 86 \ 2  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 4 / Advisory Business Overview Group”), a separate publicly listed financial services firm that is an indirect majority -owned subsidiary -national financial services company (together with its affiliates, directors, officers, and DWS Investment Management Americas, Inc. (“DIMA”), a Delaware corporation, is an investment adviser registered with the Securities and Exchange Commission (“SEC”). DIMA is part of the global investment management business of DWS Group GmbH & Co. KGaA (“DWS of Deutsche Bank AG, a multi employees, the “Deutsche Ban k Group”). DIMA is an indirect, wholly owned subsidiary of DWS Group. DIMA is also registered as a Portfolio Manager in several Canadian provinces: British Columbia, Newfoundland and Labrador, Ontario, and Quebec. DIMA has offered its products and services to clients, across a range of asset classes, investment strategies, a nd products since its reorganization in 1984, although various predecessors have been registered with the SEC since 1940. In order to provide financial services in Australia, DIMA relies on an exemption from the requirement to hold an Australian financial services license under the Corporations Act 2001 (Cth). DIMA is regulated by the SEC under U.S. laws, which differ from Australian laws. This brochure, including any brochure supplement, is intended for those clients to whom DIMA provides investment advisory services. Investors in any DIMA -advised fund should rely on the fund’s prospectus or offering materials, and may therefore refer to th is brochure, or any brochure supplement, for informational purposes only. Advisory Services ual pre- -client relationship (as amended from time to time) in ons. The separately managed accounts (or separate accounts) and pooled investment DIMA offers a range of advisory services to clients, with capabilities of tailoring investment strategies to meet the individ needs of clients. DIMA’s advisory services are tailored according to investment policies and guidelines that are either established by its client or established at the inception of the adviser cooperation with the client. Each private commingled fund and registered investment company (the “DIMA Advised Funds”) managed by DIMA is managed in accordance with its investment guidelines, restrictions and is generally not tailored to address the specific investment objectives or circumstances of any fund shareholder or fund investor. Accordingly, an investment in such vehicle does not, in and of itself, create an advisory relationship between the shareholder or investor and DIMA. DIMA uses both quantitative and/or qualitative processes to manage portfolios in accordance with their stated portfolio investment guidelines and restricti vehicles such as mutual funds, collective trusts and private investment funds that are sponsored, managed, or advised by DIMA are collectively referred to in this Brochure as “Advisory Accounts.” se Additionally, DIMA may bring together investment professionals throughout the platform to discuss and debate geographic markets, industry sectors, asset classes and investment styles to leverage the global capabilities of DWS. The outcome of the discussi ons and debates provides directional guidance to inform individual portfolio managers in implementing an investment strategy, including through the use of lead portfolios . \ 3  Form ADV Part 2A DWS Investment Management Americas, Inc. Institutional Separately Managed Accounts -discretionary investment advisory services to institutional investors, including [certain] DIMA provides discretionary and non qualified institutional family offices, who generally enter into an Investment Advisory Agreement (“IAA”) with DIMA (unless DIMA is appointed as a subadvisor). DIMA provides services to both U.S. and non -U.S. clients. IMA strategies through a separately managed account (“SMA”) sub -advisory -advisor. DIMA requires a Ultra-high net worth clients may access certain D program (“SMA Program”) sponsored by a DIMA affiliate, under which DIMA may be appointed as sub minimum account size for certain of its investment strategies, which varies among SMA Programs. For institutional SMAs, DIMA is responsible for establishing that the client is a sophisticated institutional account, understanding the investment objectives, and investmen t restrictions. Model Portfolio Programs ortfolios available to clients through investment platforms. DIMA -discretionary and discretionary basis to various sponsors of model portfolio -discretionary basis and/or the independent advisers that t accounts. With respect to model portfolios provided to affiliated advisers, ses n Item 12 – Brokerage Practices. In accordance with Rule 3a -4 under the For certain investment strategies, DIMA provides non -discretionary or discretionary investment advice in the form of model portfolios to unaffiliated or affiliated advisers who may use such model portfolios to assist in the development of their own investment recommendations or who may make such model p currently provides model portfolios on a non programs who utilize such recommendations in connection with the management of their client accounts. As a general matter, program sponsors that receive model portfolios from DIMA on a non may participate in such progra ms are responsible for exercising their own judgment in deciding whether DIMA’s model portfolio recommendations are appropriate for their client accounts. Sponsors of model portfolio programs are typically responsible for implementing trades in their clien DIMA may execute securities transactions for such advisers. Such transactions will be treated like any other orders for purpo of DIMA’s order execution policies as set forth i Investment Company Act, clients who participate in reasonable restrictions on the management of their third -party model portfolio programs generally have the ability to impose program accounts. -discretionary basis will include ged by unaffiliated mutual funds and ETFs. Therefore, DIMA has an incentive to use such DWS regarding the extent to which model portfolios provided by DIMA include Certain model portfolios provided to unaffiliated model portfolio program sponsors on a non mutual funds and/or exchange traded funds (“ETFs”) that are advised by DIMA or an affiliate of DIMA. DIMA’s inclusion of such DWS f unds and/or ETFs in such model portfolios raises conflicts of interest. To the extent DIMA uses DWS funds and/or ETFs as components in such model portfolios, it will benefit DIMA and its affiliates by generating management fees and other fees and compensat ion for DIMA and its affiliates when intermediary accounts and other persons utilize such model portfolios. Moreover, the management fees and other fees and expenses of the DWS funds and/or ETFs so used by DIMA may be higher than the fees and expenses char funds and/or ETFs as components in such model portfolios. Clients should review the brochure provided by the managed account program sponsor for further information DWS funds and/or ETFs. or In addition, DIMA may have business relationships with investment managers of unaffiliated mutual funds and ETFs that are included in the model portfolios. For example, certain intermediaries may distribute other funds or products advised by DIMA its af filiates. Similarly, some model portfolio sponsors and intermediaries to whom DIMA provides model portfolios may have other business relationships with DIMA or its affiliates. In these regards, DIMA may benefit from its relationships with such other partie s when entering into the model portfolio arrangements. \ 4  Form ADV Part 2A DWS Investment Management Americas, Inc. Insurance Asset Management such as asset liability management; liquidity planning; portfolio risk analyses; DIMA offers advisory services focused on insurance companies, a segment of large institutional investors. DIMA partners with the insurance company client in developing customized investment policies and guidelines based on their unique objectives, needs an d constraints that serve as the basis for how DIMA manages portfolios for the client. Advisory services are performed in partnership with the client and include matters and st rategic asset allocation that considers regulatory constraints and investment income goals. These services are performed at the overall client level and may include a variety of asset classes, including fixed income, public equities, and private offerings, managed and non -managed assets. DIMA Advised Funds and Other Pooled Vehicles -advisory capacity to a variety of U.S. DIMA Advised Funds (including open -end and closed - -adviser, sub -sub -adviser, DIMA also acts in an advisory or sub end funds) and U.S and non -U.S. pooled vehicles for which an affiliate may act as adviser, sub manager, or distributor. In connection with these funds, certain DIMA employees may serve as directors, trustees, or officers. These arrangements are disclosed in each fund's prospectus or offering document in accordance with any disclosure requirements. DIMA also acts in an administrator capacity to a variety of open -end and closed -end investment companies. DIMA has sought and obtained a permanent order from the SEC providing exemptive relief under Section 9 of the Investment Company Act of 1940, as amended (“Investment Company Act’), on which it relies in connection with the continued provision of investment advisory services to registered investment companies. Retail SMAs -party program sponsors (“Program -dealer/registered investment advisor, and each -wrap fee or DIMA provides investment advisory services to retail SMAs (“Retail SMAs”) in a “dual contract” capacity. In a dual contract managed account arrangement or program, DIMA has separate agreements with third Sponsor(s)”), which may be either a registered investment advisor or a broker applicable client . The agreement between DIMA and the client outlines the scope and limitations of the advisory relationship between DIMA and the clie nt. In dual contract arrangements, the Program Sponsor also has a direct contractual relationship with the client and as noted below, is generally responsible for determining whether a strategy offered by DIMA is suitable and appropriate for the client based on the client’s investment objectives, risk tolerance and financial situation. The Program Sponsor’s relationshi p with its client can be structured either as a “wrap fee” or “bundled” arrangement or as a non “unbundled” arrangement. DIMA In traditional wrap fee programs, a client selects a Program Sponsor that provides a bundle of services for a single fee. For example, for third -party wrap fee programs that utilize DIMA as portfolio manager, the Program Sponsor’s bundle of services would typically include the payment of DIMA’s investment advisory fee , ongoing monitoring , and evaluation of DIMA’s performance, provision of periodic market commentaries prepared by DIMA, and/or execution of the client’s portfolio transactions. In non -wrap fee or unbundled arrangements, fees are charged separately for various services. In such arrangements, DIMA’s inv estment advisory fees would be charged separately to the client. In DIMA’s current dual contract arrangements, DIMA’s advisory fees typically are not bundled with fees for services provided by the Program Sponsor. may have limited authority to withdra w its advisory fee directly from a client’s account subject to various conditions. acts as an investment adviser, in various “single -wrap fee basis. . The Program Sponsor identifies investment managers that it believes are suitable for In addition to acting as an investment adviser in dual contract programs, DIMA contract” managed account arrangements or programs. Such arrangements may either be on a wrap fee or non In such programs, the Program Sponsor enters into an investment management agreement with each client with respect to the overa ll management of the client’s assets each client, and either the Program Sponsor or the client selects an investment manager or managers to manage the client’s assets. When selected for a single contract program, DIMA enters into an agreement with the Program Sponsor pursuant to \ 5  Form ADV Part 2A DWS Investment Management Americas, Inc. does not enter into a which DIMA provide s investment advice with respect to a portion of the program clients’ assets. DIMA separate agreement with each client. -party needs and financial situations, it is the Program Sponsor that is typically responsible for certain egy or appropriate or suitable for the client. As a result, determinations by DIMA as to the ard ons may be different than would have been had DIMA had access to more fulsome The services provided by DIMA to Retail SMA clients in dual contract or single contract arrangements, be they structured as wrap fee or non -wrap fee programs, may differ from the services provided to its institutional separate managed accounts and DIMA Adv ised Funds, which do not participate in such programs. The investment strategy DIMA uses in managing third wrap fee and non -wrap fee advisory programs is similar to strategies offered to its other clients but may involve fewer securities holdings due to smaller account sizes and less ability for customization. In addition, DIMA typically will rely on the Program Sponsor to provide client portfolio reporting. In certain cases, there may be limitations on DIMA’s ability, in the ordinary course, to commu nicate directly, on its own initiative, with the Program Sponsor’s clients without going through the Program Sponsor. While DIMA may use information gathered by the Program Sponsor to assess the appropriateness of its investment style to individual client determining the appropriateness or suitability of the program, including DIMA’s investment strategy, for the client. In programs, the Program Sponsor may restrict DIMA’s access to client information, including, for example, information about the client’s other investments or risk tolerance or other information relevant to determining whether DIMA’s investment strat certain specific investments would be appropriateness or suitability of an investment strategy or a particular investment for such clients will be made without reg to such information, and such determinati information regarding the client. -dealers in accordance with its duty at -dealer’s charge for the trade is built into r es -dealers serving as custodian charge fees for settling transactions In wrap and non -wrap fee advisory programs, DIMA typically has discretion to select broker to seek best execution. Due to the unique nature of the municipal bond asset class, DIMA generally will execute transactions financial institutions other than the Program Sponsor in its municipal bond strategy accounts (see “Item 8” below for more information). Such transactions ordinarily occur at net prices, meaning that the broker the security’s purchase or sale price and is ultimately borne by the client in addition to any charges for execution otherwise included in a wrap fee sponsor’s overall fee. Each client should evaluate whether particular wrap programs are appropriate fo his or her needs, including the fees charged and services provided. Depending upon the level of the wrap fee charged by a third - party wrap fee Program Sponsor, the amount of portfolio activity in a client’s account, the value of the custodial and other servic es that are provided under a wrap arrangement and other factors, a wrap fee client should consider whether the wrap fee would exceed the aggregate cost of such services if they were to be provided separately. A client paying separate fe in a non -wrap arr angement should consider whether the fees charged by different parties for custody, advisory services, portfolio management services, securities execution and other services would exceed the aggregate cost of such services if they were provided in a wrap f ee arrangement. Some broker executed through other broker Sponsor for additional information regar -dealers. Clients should refer to the Form ADV or other disclosure documents of the Program ding fee arrangement for single contract or dual contract arrangements. Assets Under Management -discretionary assets -discretionary advisory assets held in certain client ’s portfolio management As of December 31, 2025, DIMA had discretionary assets under management of $196,431,598,979 and non under management of $7,205,881,341. The assets noted above include non accounts o f an affiliate that use DIMA ’s model portfolio recommendations as an input into the affiliate decisions on behalf of such clients. Principal investment strategies and products currently offered by DIMA: - Products listed below are managed by DIMA either directly or through sub -advisory relationships with affiliated and non affiliated advisors. See Item 10 – Other Financial Industry Activities and Affiliations for information regarding certain DIMA arrangements with affiliates rela ted to its advisory business. DIMA’s investment policies and practices can vary by strategy and/or product type. \ 6  Form ADV Part 2A DWS Investment Management Americas, Inc. — U.S. Sector Strategy — U.S. Structured Securities Alternatives — U.S. Large Cap Growth — Global Fixed -Income — Asset Allocation -Alternatives — U.S. Growth Equity Focus — Global Short Duration — Commodities — U.S. Small Cap Growth — Global Government Bond Index — Commodities with Fixed Income — U.S. Small & Mid Cap Growth — Global Inflation Protected Securities — Commodity Securities — Global Sector Healthcare — Global High Yield — U.S. Real Estate Equity — Global Sector Technology — Canada Fixed Income — Global Real Estate Equity — Emerging Markets Fixed -Income — Global Infrastructure — Glo bal S ectors – Digital Horizons C omm unications and Technology — Emerging Markets Fixed -Income Index — Multi-Asset Allocation — Global Sector Communications — U.S. Municipals — Multi-Asset Income — U.S. Large Cap Value (CROCI) — U.S. Municipals Index — Multi-Asset Highly Active — U.S. Large Cap Dividend (CROCI) — U.S. Municipals Long Term Liquidity Management — Equity Index — U.S. Municipals Intermediate — U.S. Cash Prime — Institutional Managed Equity — U.S. Municipals Short Term — U.S. Cash Government Fixed Income — U.S. Municipals State Specific — U.S. Cash Municipals — Core Fixed -Income — U.S. Municipals High Yield — U.S. Cash Municipals State -Specific — Core Plus Fixed -Income — U.S. Municipals Intermediate Ladder Equities — Core Intermediate — U.S. Municipals Short Term Ladder — International Equity Growth — Core Short Duration — ESG U.S. Municipals — International Equity Value — U.S. Government — Fixed Income Multi Product — Global Small Cap — U.S. Mortgage Backed — Strategic Asset Allocation — Latin America Equity — U.S. High Yield — Liability Driven Investing — Emerging Markets Equity — U.S. High Yield Index — U.S. Large Cap Core — U.S. Corporate Investment Grade — U.S. E nhanced Large Cap Core — U.S. Corporate Investment Grade Index — U.S. Small Cap Core — U.S. Syndicated Loans Multi -Manager Strategies/Other Arrangements -advisory relationships with affiliated and non -affiliated advisers DIMA offers a variety of non -U.S. strategies through its sub located in the U.S. and outside the U.S. When delegating advisory services to other advisors, DIMA will have ultimate responsibility to oversee any sub -advisor and to recommend the hiring, termination, and replacement of a sub -advisor. \ 3  Form ADV Part 2A DWS Investment Management Americas, Inc. -party Apart from furnishing investment advice to clients, DIMA also provides various investment advisory, consulting, trading, administrative, and research support services to its affiliates pursuant to intercompany agreements. DIMA may offer and negotiate fees regarding its investment advisory, trading, administrative, and research support services to certain third banks, trust companies, insurance companies and other fiduciaries, and may also render investment advice to specific accounts of these ba nks, t rust companies, and other fiduciaries that contract with DIMA. DIMA may also provide certain other services such as investment company administrative services and executing broker evaluations and selections. Consideration of S ustainability Risks tive -specific sustainability In DIMA’s Active business for traditional asset classes, sustainability risks are considered at multiple stages of the respec investment processes such as in issuer analysis, portfolio construction, implementation, and ongoing monitoring. The considera tion is governed by internal procedures, taking into account fiduciary obligations, applicable law and regulatory requirements, and may further be guided by an individual portfolio’s investment policy and product characteristics. -based -party research, company disclosures, is embedded within the portfolio To facilitate the consideration of sustainability risks, DIMA leverages a set of information sources. These include DWS’s proprietary ESG tool’s (also referred to as the “ESG Engine”) data and assessments on e.g., climate risk, norm controversies, an d overall issuer sustainability profiles. Additional inputs comprise third general news flow, and insights gained through dialogue with issuers. The ESG Engine management platform, BRS® Aladdin, ensuring efficient access to ESG data and its effective utilization in investment strategies. ‑related investment Sustainability risks do not, in themselves, preclude investments. Instead, they are evaluated alongside a broad spectrum of factors and risks within the overall context of each investment case. However, where sustainability guidelines ap ply, as directed by a client or by product design , they may directly impose specific investment restrictions DWS ESG Engine -source ESG data aggregation, structuring and processing device, which allows a consolidated and qualified ernal ESG research. This internal research might take into account factors beyond the processed DIMA’s investment professionals generally use output from a proprietary DWS ESG software tool referred to as the DWS ESG Engine. It is a multi ESG ana lysis based on the ESG inputs from several ESG data providers, public sources and/or DWS internal assessment meeting. Even though the DWS ESG Engine is mainly populated from external vendor data, the DWS ESG Engine also includes ESG data based on DWS’s int data vendor information, such as an issuer’s future expected ESG development, plausibility of the data with regard to past or future events, an issuer’s willing ness not only to engage in dialogues on ESG matters or corporate decisions, but also to commit to a path of improvement. DWS internal ESG research results are complementary data points to the DWS ESG Engine standard data sources and may consider the releva nce of the exclusion criteria for the market sector of the investee company. Key ESG assessments derived from the ESG Engine include the following: that score lower in the comparison receive a worse assessment. For sovereign issuers, the ESG The DWS ESG Quality Assessment distinguishes between investments in companies and investments in sovereign issuers. For companies, the ESG Quality Assessment allows for a peer group comparison based on an overall ESG assessment, for example, concerning the handling of environmental changes, product safety, employee management or corporate ethics. The peer group for companies is made up from the same industry sector. Companies that score higher in this comparison receive a better assessment, while companies Quality Assessment assesses countries based on a peer group comparison considering E/S criteria as well as indicators for good governance, including, for example, the political system, the existence of institutions and the rule of law. is designed to evaluate the behavior of issuers within the framework of the principles of the United The DWS Norm Assessment Nations (UN) Global Compact, the standards of the International Labor Organization, and other generally accepted internationa l \ 4  Form ADV Part 2A DWS Investment Management Americas, Inc. of responsible business conduct within, amongst others, the framework of the principles of the United acts standards and principles Nations Global Compact, the United Nations Guiding Principles, the standards of the International Labor Organization and the OECD Guidelines for Multinati onal Enterprises. Examples of topics covered within these standards and principles include, but are not limited to, human rights violations, violations of workers' rights, child or forced labor, negative environmental imp and b usiness ethics. The Norm Controversy Assessment evaluates reported violations of the aforementioned international standards. involvement in, or exposure to, a number of business areas and business ural gas), and mining and exploration of and services in In addition, the DWS ESG Engine evaluates issuers for activities, including controversial weapons, the defense industry, civil handguns or ammunition, tobacco products, gambling, adult entertainment, palm oil, nuclear power generation, uranium mining and/or uranium enrichment, extraction of crude oil, unconventional extraction of crude oil and/or natural gas, coal mining and oil extraction, power generation from coal, power generation from and other use of other fossil fuels (excluding nat connection with oil sands and oil shale . \ 5  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 5 / Fees and Compensation Fee Schedules, Account Minimums and Payment Arrangements are s vary depending on the circumstances of a particular client rwise agreed lso charge a lower fee depending on the entirety of the overall DIMA’s general policy is to assess client fees according to the current fee schedule of the investment strategy in which they invested. Actual fees, minimum fees and minimum account size (e.g., whether a client is an institutional client or an individual), additional or differing levels of servicing, or as othe with specific clients. Fees are negotiable, and DIMA may a relationship with a particular client, or for any other reason, in DIMA’s discretion. — For fixed income strategies, the fees are generally in the range of 2.25 basis points – 59 basis points. — For liquidity management strategies, the fees are generally in the range of 3 basis points – 40 basis points. — For equities strategies, the fees are generally in the range of 1 0 basis points -100 basis points. - or month -end value, as applicable, and as also DIMA also enters into performance -based fee arrangements Fees are generally based on the combined market value of all securities and cash on the accounting date and are payable quarterly or monthly either in advance or in arrears based on the quarter dictated by th e client’s investment management agreement (IMA). with eligible clients. Certain separately managed account clients may also be charged a flat fee for administrative and/or account services performed by DIMA, in addition to any applicable management and performance fees. Such flat fee will vary by client and is subject to negot iation. d. For a mandate with multiple managed portfolios there is a per portfolio charge of up to $25,000 in addition to the fees quote This fee covers the additional administrative, operational, and reporting costs associated with multiple portfolios. For certain model portfolio arrangements, DIMA will benefit by generating management fees and other fees and compensation for DIMA and its affiliates when intermediary accounts and other persons utilize such model portfolios. its clients for fees. However, there may be instances where DIMA de ducts a fee without . For example, with respect to its dual contract t Rule 206(4) -2 of the Advisers - ted to, administration, custody, transfer agent, and other associated fees . With respect to In the majority of cases, DIMA invoices invoicing the client . In these instances, DIMA may be deemed to have custody retail SMA arrangements, DIMA may have limited authority to withdraw its advisory fee directly from a client’s account subjec to various conditions. As a result, DIMA has policies and procedures in place to address this under Act . For separately managed accounts, DIMA does not impose multiple advisory fees when an advisory client’s assets are invested in DIMA Advised Funds. As a result, DIMA generally does not charge an account level advisory fee for assets of separately managed acc ounts invested in DIMA Advised Funds. Separately managed accounts only pay such advisory fees charged by the DIMA Advised Funds. Separately managed accounts will incur additional fees and expenses relating to third party services including, but not limi the registered investment vehicles advised by DIMA that hold DIMA Advised Funds, please refer to the applicable prospectus, semiannual report, or annual report that sets forth the applicable fees and expenses. In addition, DIMA faces a conflict of interest when allocating client assets between DIMA Advised Funds and investment funds managed by advisers who are not affiliated with DIMA (“Unaffiliated Funds”). DIMA has policies and procedures reasonably designed t o appropriately identify and manage the conflicts of interest described above. For additional information regarding the investments in DIMA Advised Funds, please see Item 11 Code of Ethics, Participation, or interest in Client Transactions. In \ 6  Form ADV Part 2A DWS Investment Management Americas, Inc. -ups, mark -downs, and/or other commission addition to paying advisory fees, clients will pay brokerage commissions, mark equivalents related to transactions in their Advisory Accounts. See Item 12 for a discussion on Brokerage Practices. -contract clients should refer to their agreement – Advisory Business for additional information The fees described herein do not include information about fees for advisory services DIMA provides through Retail SMAs. The terms of each client’s Retail SMA are governed by the client’s agreement with the Program Sponsor and disclosure document for each Retail SMA. Retail SMA clients are urged to refer to the appropriate disclosure document and client agreement for more information about the Retail SMA and advisory services. Similarly, dual with their Progr am Sponsor, as applicable, the disclosure document for the applicable program, and the client's agreement with DIMA, which will vary depending on the strategy selected. See Item 4 regarding Retail SMAs. Termination Arrangements eriod and/or certain events to occur prior to the termination of the investment advisory provide that DIMA cannot resign as investment adviser until a successor has any fees paid An advisory relationship with a client is generally terminable at will by either party. Certain agreements require a notice p before the termination becomes effective relationship. Furthermore, certain agreements been appointed. In the event of termination, investment advisory fees are prorated to the date of termination and in adva nce for periods beyond the date of termination are refunded to the client. DIMA Advised Funds/Unregistered Commingled Vehicles DIMA acts as investment adviser to certain DIMA Advised Funds. The management fees paid by the DIMA Advised Funds are subject to negotiation with the Board of Trustees/Directors of each DIMA Advised Fund and the approval of the respective shareholders. DIM A’s current investment management fees range up to 1.00% of aggregate net assets on an annual basis depending on the nature of the DWS Fund, the advisory fee structure, and the size of the DWS Fund's assets. DIMA acts as an investment adviser to unregistered U.S. and non -U.S. pooled investment vehicles. With respect to such unregistered pooled investment vehicles advised by DIMA, please refer to the applicable Offering Memorandum, subscription agreement and/or other governing document that sets forth the applicable fees and expenses. Collateral Management of Structured Securities as The fee arrangements for CLOs generally are described in the offering circular for each CLO. The fees are calculated as well performance fees based on the total portfolio collateral and may include both senior and subordinated components. Compensation of DIMA and Supervised Persons t Compensation of sales staff varies by types of products offered. In some functional areas outside of sales roles supervised individuals do not earn commissions; rather they receive a set annual “base” pay, along with a discretionary annual bonus tha is de termined on a variety of factors including profitability of DWS, profitability of the division, and contributions of that individual to the successes of the division. -based sales charges or service fees from the sale of DIMA Advised Funds, certain of its -dealer, may from time to time receive compensation for Compensation (may be paid in cash or deferred compensation) . Under the Plan, DWS’s While DIMA does not receive asset supervised persons, through their association with an affiliated broker the sal e of DIMA Advised Funds. Such personnel may market the DIMA Advised Funds to financial intermediaries, including financial advisors, who in turn may recommend that their clients purchase these products. The DWS Incentive Plan (the “Plan”) comb ines monthly incentive components (paid in cash) with quarterly incentive award potential, based on achieving certain sales and other performance metrics Wholesalers will receive a monetary monthly incentive based on the number of sales generated from their marketing of the \ 7  Form ADV Part 2A DWS Investment Management Americas, Inc. DIMA Advised Funds, and that incentive will differ depending on the product tier of the DIMA Advised Fund. Each DIMA Advised Fund is assigned to one of four product tiers taking into consideration, among other things, the following criteria, where applicab le: — DIMA Advised Fund’s consistency with DWS branding and long -term strategy; — The DIMA Advised Fund’s competitive performance; — The DIMA Advised Fund’s Morningstar rating; — The length of time the DIMA Advised Fund’s Portfolio Managers have managed the DIMA Advised Fund/strategy; — Market size for the DIMA Advised Fund tier; and — The DIMA Advised Fund’s size, including sales and redemptions of the DIMA Advised Fund’s shares. d Funds’ Web site at https://fundsus.dws.com/EN/wholesaler s -compensation.jsp . s This information and other factors are discussed with senior representatives from various groups within DIMA, who review on a regular basis the DIMA Advised Funds assigned to each product tier described above and may make changes to those assignments perio dically. No one factor, whether positive or negative, determines a DIMA Advised Fund’s placement in a given product tier; all these factors together are considered, and the designation of DIMA Advised Funds in a particular tier represents management’s judg ment based on the above criteria. In addition, management may consider a DIMA Advised Fund’s profile over the course of several review periods before making a change to its tier assignment. These tier assignment will be posted quarterly to the DIMA Advise DWS Wholesalers receive the highest compensation for Tier 1 DIMA Advised Funds and successively less for Tier 2, successively less for Tier 3 funds and successively less for Tier 4 funds. The level of compensation among these product tier may differ sig nificantly. The prospect of receiving or the receipt of additional compensation by a DWS Wholesaler under the Plan may provide an incentive to favor marketing DIMA Advised Funds in higher payout tiers over DIMA Advised Funds in lower payout tiers. The Plan, however, w ill not change the price that investors pay for shares of a fund. The DWS Compliance Department monitors DWS Wholesaler sales and other activity in an effort to detect unusual activity in the context of the compensation structure under the Plan. Disclosure regarding the Plan appears in the Statement of Additional Information for DIMA Advised Funds and investors may wish to take the compensation structure into account when considering purchasing a fund or evaluating any recommendations relating to fund share s. \ 8  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 6 / Performance -Based Fees and Side -by - Side Management -based fees in connection with are managed side -by-side under the so suitable for non - -based fees create an incentive for DIMA to make ns and other factors within DIMA's control also have an effect on the fee amount. As may not necessarily correspond to realizable value. To manage these allocate In addition to asset -based investment management or advisory fees, DIMA receives performance certain pooled investment vehicles and separately managed accounts. These accounts same investment strategy with accounts and/or funds that do not pay such fees. This type of arrangement creates an incentive for DIMA to favor its performance -fee accounts when allocating investment opportunities that are al performance fee accounts ma naged under the same strategy. Performance riskier or more speculative investments than those potentially made in the absence of such fees. The method of calculating performance fees, the timing of dispositio agreed to under the relevant agreements, certain performance fees are determined based on realized and/or unrealized returns, and calculations based on unrealized returns conflicts, DIMA has implemented policies and procedures reasonably designed to provide fair and equitable treatment of similarly situated clients. Under these policies and procedures, and consistent with its fiduciary obligations, DIMA will investment opportunities among client accounts based upon a number of factors that include, but are not limited to: — Investment objectives and guidelines; — Risk tolerance; — Availability of other investment opportunities; — Available cash for investment; — Tax sensitivity and objectives; — Investment minimums, minimum increments, de minimis threshold and round lot considerations; and — Whether DIMA has investment discretion over the account or has to request client approval for investments. -rata average price basis (based on applicable minimum lot size -rata or not is dependent on factors including, but not line or DIMA will allocate investment opportunities on a pro requirements) to eligible accounts. Whether an allocation will be pro limited to, eac h client’s investment objectives, remaining investable capital, ability to execute, core geographical focus, investment guidelines, and restrictions (e.g., whether an allocation could potentially result in the client breaching a guide other constrai nt, such as constraints related to financing documentation). \ 9  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 7 / Types of Clients - DIMA provides investment advice directly or indirectly to many client types including: banks, corporations, governments (U.S. federal and state entities), international public authorities, foundations, endowments, financial institutions, insurance -profit or not -for-profit organizations, individuals, trusts, qualified companie s, non -governmental organizations (“NGO”), non institutional family offices, DIMA Advised Funds, including open -end and closed -end funds, pension plans, including those covered under th e Employee Retirement Income Security Act of 1974, as amended (“ERISA”), pooled investment vehicles, non U.S. funds and private investment funds, issuers of collateralized bond and loan obligations and other structured products in the U.S. and abroad. tain a separately managed account. Typically, clients are required to sign an Investment DIMA may impose a minimum dollar value of assets in order to open or maintain an account depending upon the type of product and type of client. However, DIMA does consider the minimum annual fee an account is expected to generate when determining whether t o open or maintain an account. DIMA takes into account the dollar value of assets expected to be managed in an account, the expected length of the engagement, as well as the type of investment strategy to be employed, in determining whether to open or main Agreement that describes the investment management authority given to DIMA. In the case of DIMA Advised Funds and other pooled vehicles, the minimum amount investors must invest in DIMA managed funds is set forth in each fund’s prospectus or relevant offering document and varies from fund to fund depending on the particular invest ment product. -party “manager In addition, DIMA may from time to time provide investment advice to individual retail investors through either a traditional “single contract” wrap fee structure or through “dual contract” wrap accounts, each sponsored by unaffiliated investment advisers, banks, or broker -dealers. DIMA may also manage separately managed account clients through a third of managers” program, under which the third -party investment adviser hires or recommends DIMA to its own advisory clients. DIMA may rely on various Prohibited Transaction -14, which is only available Deutsche Bank Group’s past criminal , together with DWS Alternatives and DWS Investments Australia Limited (collectively, the “DWS QP AMs”), has been -02”) . PTE in -02, DIMA’s ERISA clients have a right, among With regard to transactions for clients that are subject to the ERISA, Exemptions (“PTEs”) available under ERISA, including with respect to certain of its affiliates, PTE 84 to qualified professional asset managers (the “QPAM Class Exemption”). Because of conviction in the LIBOR matter, which did not involve asset management activities, DIMA Global Limited, RREEF America LLC, required to seek an individual QPAM exemption to avoid disqualification from relying on the QPAM Class Exemption. In April 2024, the U.S. Department of Labor (“DOL”) extended the DWS QPAMs’ individual QPAM exemption (“PTE 2024 2024 -02 is now scheduled to expire on April 17, 2027, but may terminate earlier if, among other things, DIMA, its affiliates or any owner, direct or indirect, of a five percent or more interest in DIMA, were to be convicted of crimes or were to engage cond uct set forth in the QPAM Class Exemption in other matters. Under PTE 2024 other rights, to obtain a copy of the summary of the written policies developed in connection with the exemption. \ 10  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 8 / Methods of Analysis, Investment Strategies, and Risk of Loss such as yield, value, growth, income, y tive vestment risk, DIMA offers a wide range of investment products and opportunities. Portfolio management teams typically invest in securities that appear to offer the best potential to meet client needs, which may include factors etc. In making their buy and sell determinations, a manager can weigh any number of factors against each other ranging from economic outlook, possible interest rate movements, supply, demand, analyst research and price. Portf olio management periodically reviews account allocations and may adjust them based on current or anticipated market conditions or to manage risk consistent with the account's overall investment strategy. In the course of adjusting these positions, a client would pa transaction costs when th e strategy buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs, affect performance, and may mean higher taxes, if you are investing in a taxable account. Within each investment strate gy there is a team that manages and specializes in the particular asset category being employed. The team may use a variety of quantitative and qualitative techniques in trying to meet a client’s investment goals. Irrespec of what strategy clients sele ct, investing in securities involves varying risks, principally the risk of loss. Additional risks include, but are not limited to, asset allocation risk, stock market risk, credit risk, interest rate risk, liquidity risk, foreign in and deri vative risk. -average strength, and effective siness DIMA may use research that is "bottom up" or focuses on individual companies that it believes have a history of above growth, strong competitive positioning, attractive prices relative to potential growth, sound financial management, among other factors. Additionally, DIMA may use research that is "top down" or considers the economic outlook for various industries as a key indicator while looking for investments that may benefit from changes in the overall bu environmen t. DIMA may also utilize its own individual research and the research it receives from a variety of sources, including other DWS companies and third -party research providers when selecting securities. A general description of each strategy and basic invest ment risks are represented below and in the appendix. . When making investment decisions, DIMA applies a “bottom up” research analysis to . The signals generated by the system are one of the many factors . The system does not directly select investments or determine trades on For certain fixed income strategies that invest in high yield debt, DIMA utilizes a proprietary system that employes machine learning to identify leaders and laggers within the particular bond universe. The system generates signals for bonds by combining v arious performance factors the securities generated by the system as leaders or laggers used by DIMA when ma king investment decisions behalf of DIMA’s clients. Alternatives Strategy: Asset Allocation Alternatives Strategy description : The strategy is designed to provide access to a diversified portfolio of alternative investment strategies. The strategy invests predominantly in a combination of affiliate funds. Investment strategies may fall into the following categories: absolute retu rn, real return and non -traditional, in addition to employing a blend of alternative investment strategies to help enhance diversification. To maintain the desired allocations, the strategy will be rebalanced periodically. \ 11  Form ADV Part 2A DWS Investment Management Americas, Inc. Associated Material Risks: (see, “associated material risks” below for further definitions.) Asset allocation risk Commodities – related investments risk Concentration risk Convertible securities risk Counterparty risk Credit risk Currency risk Currency strategies risk Dividend -paying stock risk Emerging markets risk ETF risk ETN risk Focus risk Foreign investment risk High yield debt securities risk Inflation -indexed bond risk Inflation risk Infrastructure -related companies’ risk Interest rate risk Interest rate strategies risk Liquidity risk Market disruption risk Non-diversification risk Operational and technology risk Preferred stock risk Prepayment and extension risk Pricing risk Real estate securities risk Regional focus risk Security selection risk Securities lending risk Senior loans risk Small company risk Stock market risk Subsidiary risk Tax risk Underlying funds risk Strategy: Commodities iencies Strategy description : The strategy seeks to provide the benefits of commodities investing with higher returns and lower volatility than otherwise investing in a passive commodity index. This strategy seeks to identify and exploit pricing ineffic among listed commodities through tactical positions in individual commodities. Associated Material Risks Active trading risk Commodities - related investments risk Derivatives risk Foreign investment risk Liquidity risk Market disruption risk Non-diversification risk Pricing risk Securities lending risk Security selection risk Tax risk Strategy : Commodities with Fixed Income -linked derivative instruments management strategy to Strategy description : The strategy invests in commodity -related securities and commodity backed by a portfolio of fixed income instruments. The investment team seeks to use an active improve return potential and decrease risk potential. Associated Material Risks Commodities - related investments risk Concentration risk Counterparty risk Credit risk Derivative risk Emerging markets securities risk Foreign investment risk Inflation-indexed bond risk Inflation risk Interest rate risk Liquidity risk Market disruption risk -backed Operational and technology risk Prepayment and extension risk Mortgage -backed and other asset securities risk Pricing risk Securities lending risk Security selection risk Subsidiary risk Tax risk Senior loans risk \ 12  Form ADV Part 2A DWS Investment Management Americas, Inc. Strategy: Commodity Securities Strategy description : The strategy seeks to invest in equity issuers providing a broad exposure to the global commodity universe through exchange -traded commodities, commodity companies and commodity -related securities. Associated Material Risks Active Trading risk Commodities -related investments risk Counterparty risk Derivatives risk Foreign investment risk IPO risk Liquidity risk Market disruption risk Non-diversification risk Pricing risk Securities lending risk Security selection risk Stock market risk Tax risk Strategy: U.S. Real Estate Equity ying Strategy description : The strategy looks to invest in real estate securities that portfolio management believes will provide supe- rior returns over the long term, particularly in companies with the potential for stock price appreciation and a record of pa dividends. In part icular, the strategy will invest in different types of domestic (U.S.) Real Estate Investment Trusts ("REITS") and Real Estate Operating Companies ("REOC"). Associated Material Risks Active trading risk Concentration risk Counterparty risk Credit risk Interest rate risk Liquidity risk Market disruption risk Non-diversification risk Operational and technology risk Pricing risk Real estate securities Risk Securities lending risk Security selection risk Stock market risk Strategy: Global Real Estate Equity Strategy description : The strategy seeking current return, mainly invests in the equity securities of REITS and REOC listed on recognized stock exchanges around the world, including the U.S. Associated Material Risks Concentration risk Counterparty risk Credit risk Currency risk Emerging market risk Foreign investment risk Interest rate risk Liquidity risk Market disruption risk Operation and technology risk Pricing risk Real estate securities risk Securit ies lending risk Security selection risk Small company risk Stock market risk Strategy : Global Infrastructure -U.S. infrastructure securities that have derived their Strategy description : The strategy primarily invests in both U.S. and non gross income or net profits from ownership, management, construction, operation, utilization, or financing of infrastructure \ 13  Form ADV Part 2A DWS Investment Management Americas, Inc. assets. These assets can include physical assets, structures, and networks that provide necessary services and operations to society. The strategy can invest in both equity and fixed income securities. Associated Material Risks Con centration risk Coun terparty risk Credit risk Curren cy risk Emerging markets risk Foreign in vestment risk Interest rate risk Liquidi ty risk Market disruption risk Medium sized Compa ny risk Non-diversification risk Opera tional and technology risk Pricing risk S ecurities lending r isk S ecurity selection r isk S mall company risk St ock ma rket risk Infrastructure -related companies’ risk Multi -Asset Strategy : Multi-Asset Allocation Strategy description : The strategy seeks to maximize total return by investing in a broad range of both traditional asset classes (such as equity and fixed income investments) and alternative asset classes (such as real estate including real estate investment trusts (REITs), i nfrastructure, convertibles, commodities, currencies, and absolute return strategies). -term market -term Using a risk/return strategic asset allocation process, portfolio management allocates assets among various asset categories. Portfolio management periodically reviews the strategy allocations and may adjust them based on current or anticipated market cond itions, to manage risk consistent with the overall investment strategy or based upon other relevant considerations. Portfolio management also utilizes a tactical asset allocation process to adjust allocations in response to short changes from t ime to time. Tactical allocations reflect views from DWS’s Chief Investment Officer and global research platform. Tactical allocations, which may include derivative instruments, have shorter investment horizons as positions reflect short views and may be implemented as: (i) changes to the strategic asset allocation, (ii) through the addition of new allocations, or (iii) through changes to prior tactical allocations. Associated Material Risks Active trading risk Asset allocation risk Co mmodities – related investments risk Co ncentration risk Cou nterparty risk Cre dit risk Curr ency strategies risk Derivatives risk Emerging markets risk ETF risk Focus risk Foreign i nvestment risk Interest rate risk L iquidity risk Market disruption risk Operational and technology risk Prepayment and extension risk Pricing risk Quantitative model risk Real estate securities risk S ecurities le nding risk Security selection risk Stock market risk Underlying funds risk Strategy : Multi-Asset Allocation – Income Strategy description : Portfolio management seeks to maximize risk adjusted returns by allocating assets among various asset categories. Portfolio management draws upon a broad investible universe to establish a strategic allocation based upon collective, long -term views on ass et class selection, implementation, expected returns and other relevant factors. Portfolio management periodically reviews the strategy’s allocations and may adjust them based on current or anticipated market conditions or to manage risk consistent with ov erall investment strategy. \ 14  Form ADV Part 2A DWS Investment Management Americas, Inc. -house research and resources to determine the appropriateness of specific securities Within each asset category, portfolio management uses one or more investment strategies for selecting equity and debt securities. Each investment strategy is managed by a team that specializes in a particular asset category, and that may use a variety of q uantitative and qualitative techniques. As a general matter, in buying and selling securities for the portfolio, the portfolio management teams utilize in and use sector s pecialists to determine relative value within each relevant sector. Associated Material Risks Co mmodities – related investments risk Active trading risk Asset allocation risk Con centration risk Coun terparty risk Cred it risk Curren cy risk Derivatives risk Dividend paying stock risk Emerging markets risk ETF risk ETN risk Foreign in vestment risk Focus risk High yield debt securities risk Inflation-indexed bond risk Interest rate risk L iquidity risk Market disruption risk Municipal securities risk Operational and technology risk Prepayment and extension risk Pricing risk Quantitative model risk Real estate securities risk Reg ional focus risk S ecurities le nding risk S ecurity selection risk S enior loan risk S mall company risk St ock ma rket risk Underlying funds risk Strategy : Multi-Asset Allocation – Highly Active -controlled framework that targets Strategy description : The strategy seeks to achieve total return by employing an active and flexible approach without benchmark constraints. It leverages a wide range of investment ideas within a stringent risk a maximum 10% per annum volatili ty and a maximum 10% drawdown within a calendar year. -down macro views and bottom -up research along -down macro views, the portfolio management team outlines a strategic tion, allocation by regions and sectors as well as position sizing are important features of the en y part of the strategic allocation and the investment selection process. Currencies are ha-generation . Active currency positions may be taken across developed and - and/or over -valued currencies and to benefit from currency fluctuations. Portfolio Portfolio management constructs the strategy using a combination of top with risk management strategies. Based on the top allocation among as set classes for the portfolio which is a reflection of the team’s broad market view. The portfolio management team further takes into consideration news flows, market sentiment and technical factors and then decides on a targeted level of risk. Idea genera strategic allocation process during which exposures to different asset classes are determined. Selection of investments is th made using bottom - up fundament al analysis. The portfolio management team evaluates the strategic allocations and fund investments on an ongoing basis from a risk/return perspective. Currencies are considered an asset class in their own right b portfolio management and form an integral actively managed and portfolio management attempts to hedge against undesired currency risk. Portfolio management views currency as an important additional source of alp emerging market currencies to exploit under icial source of risk diversification. Completely or partially applied management also views currency management as a benef currency hedges may also impact overall fund performance. Portfolio management may consider information about ESG issues in its fundamental research process and when making investment de cisions. \ 15  Form ADV Part 2A DWS Investment Management Americas, Inc. Associated Material Risks Active trading risk Asset allocation risk Co mmodities – related investments risk Con centration risk Counterparty risk Credit risk Currency risk Derivatives risk Dividend paying stock risk Emerging markets risk ETF risk ETN risk Focus risk Foreign investment risk High Yield debt securities risk Inflation -indexed bond risk Interest rate risk Liquidity risk Market disruption risk Municipal securities risk Operational and technology risk Prepayment and extension risk Pricing risk Quantitative model risk Real estate securities risk Regional focus risk Securities lending risk Security selection risk Senior loan risk Small -company risk Stock market risk Underlying funds risk Liquidity management Stra teg y: U.S . Cas h Pri me Strategy Description: The strategy seeks a high level of current inc ome co nsistent with liquidity and the prese rvation of capital. The strategy invests in hi gh quality, shor t-term, U.S. dollar denom inated mon ey market instrume nts paying a fixed, variable, or floating inte rest rate. Asso c iated Material Ris ks Concentration r isk Counterparty risk Credit risk Foreign inv estment risk – mon ey funds Inflation risk Interest rate risk Liquidity and transaction r isk Market risk Market disruption risk Money mark et fund risk Municipal Securities risk Operational and technolo gy risk Prepayme nt and extension r isk Repurchase agreement risk Risks of holding c ash Security sel ection r isk – money market U.S. Government default risk Stra teg y: U.S . Cas h Government Strategy Description: The strategy seeks a high level of current income co nsistent with liquidity and the prese rvation of capital. The stra tegy inves ts in high quality, short-term, U.S. dollar denominated mon ey ma rket instrumen ts issued by the U.S. Gover nment, its age ncies, or instrume ntalities (or in repurc hase agr eements collateralized by such obligations) paying a fixed, variable, or floating interest rate. Asso c iated Material Ris ks Coun terparty risk Cred it risk Interest rate risk Liquidi ty and trans action risk Market disruption risk Market risk Money mar ket risk Opera tional and technology risk Prepayment and extension risk Repu rchase agreement r isk Ris ks of Hold ing cash S ecurity selection risk \ 16  Form ADV Part 2A DWS Investment Management Americas, Inc. Stra teg y: U.S . Cas h Municipals Strategy description : The strategy seeks a hi gh level of current income ex empt from federal i ncom e taxes consistent with liquidity and t he prese rvation of ca pital by investing in hi gh q uality, shor t-term, tax-exem pt money ma rket i nstrumen ts. T he strategy inves ts its assets in investments the income fr om which is exclu ded from federal income t axes. T he st rategy may invest in mun icipal ob liga tions that pay interest that is subject to the federal al ternative m inimum tax (AMT ). Asso c iated Material Ris ks Coun terparty risk Cred it risk Inflation risk Interest rate risk Liquidity and transaction r isk Market disru ption risk Money mark et fund risk Municipal securities risk Municipal tr ust recei pts risk Operational and technolo gy risk Prepayme nt and extension r isk Risks of Holding cash Security selection risk Tax Risk Equ ity Stra teg y: U.S . Large Cap Core Strategy description : T he strategy invests prima rily in equities of large U.S. compa nies but can invest in c ompa nies of any si ze and from any country. Portfolio manag ement uses proprietary quantitative sto ck selection mo dels to select attract ive securi ties and a systemat ic proce ss for portfolio co nstruction. The investment objective is long term cap ital apprecia tion, current income, and growth of income with risk management. Associated Material Risks Counterparty risk Derivatives risk Focus risk Large -sized companies risk Liquidity risk Market disruption risk Medium -sized company risk Operational and technology risk Pricing risk Quantitative model risk Securities lending risk Security selection risk Stock market risk Strat eg y: U.S. Enhanced Large Cap Core T he investment objective is lo ng -term capital appr ecia tion, cur rent income, and g rowth of Strategy description : T he strategy invests prima rily in equities of large U.S. companies but can invest in companies of any si ze and fr om any c ountry. Portfolio ma nag ement uses pr oprietary q uantitative m odels to sel ect attra ctive securities and a syst ematic pr ocess for portfolio construction. Portfolio management will also utilize internal research to implement certain risk, sector, or style tilts to the strategy. income wi th risk ma nag emen t. Asso c iated Material Ris ks Coun terparty risk Derivatives risk ETF risk Focus risk Liquidi ty risk Market disruption risk Opera tional and technology risk Quan titative model risk Pricing risk S ecurities lending r isk S ecurity selection r isk St ock ma rket risk \ 17  Form ADV Part 2A DWS Investment Management Americas, Inc. Stra teg y: U.S . Sec tor S trat egy Strategy description : U.S. Sec tor St rateg y employ s an activ e inves tmen t strateg y that inves ts primaril y in the stock s comp risin g the S&P 50 0 Index . T he strateg y is to “tilt” (over/unde r weigh t) toward and away from select indus tries and sec tors in order to outperform the S&P 50 0 Index . T he tilts will be base d on the mac ro view s of the DWS CIO America s strateg y team and globa l DWS CIO View forecasts . Asso c iated Material Ris ks Counterparty risk Derivatives risk ETF risk Focus risk L iquidity risk Market disruption risk Operational and technology risk Pricing risk S ecurities le nding risk St ock ma rket risk St rategy risk Stra teg y: U.S . Sma ll Ca p – C ore Strategy description : The strategy invests prima rily in U.S . sma ll cap equities but can invest in companies of any size and from any count ry. Portfolio man agement us es fundamental analysis to identify attractive securiti es with a preference for compan ies with d emonstra ted profitability. T he investment objective is long te rm cap ital ap preci ation with risk man ageme nt. Asso c iated Material Ris ks Counterparty risk Derivatives risk Focus risk Foreign investment risk L iquidity risk Market disruption risk Operational and technology risk Pricing risk S ecurities le nding risk Security selection risk Small company risk Stock market risk Stra teg y: U.S . Large Ca p Grow th and U.S . Grow th Equity Focus Strategy descript ion: The strategy invests prima rily in U.S. large cap equities of com panies with sup erior growth potential over time. T he stra tegy uses fundamental analys is to seek companies that create shareholder value on the basis of competitive advantage and that are well posi tioned for secular tre nds. The portfolio is diversified ac ross various corpora te life c ycle stag es to deliver an investment exposure mix of both establ ish ed and earlier stage and high grow th poten tial compa nies. The investment objective is long term capital appreciation with risk management. Asso ciated Material Risks Coun terparty risk Focus r isk Focus r isk – limited num ber of securities Grow th investing r isk Liquidi ty risk Market disruption risk Opera tional and technology risk Non-diversification r isk Securities lending risk Security selection risk Stock market risk Stra teg y: U.S . Sma ll Ca p Grow th Strategy description : The strategy invests primari ly in U.S . sm all cap equities, with a preference for compa nies with superior growth potential over time but can invest in compa nies of any size and from any country. Port folio management uses fund amental ana lysis to identify attractive securi ties acr oss secto rs. Th e investment objective is long term ca pital app recia tion with risk ma nagement. \ 18  Form ADV Part 2A DWS Investment Management Americas, Inc. Asso c iated Material Ris ks Counterparty risk Emerging markets risk Focus r isk Foreign inv estment risk Growth inv esting r isk Liquidity r isk Market disru ption risk Operational and technolo gy risk Pricing risk Securities lending r isk Security sel ection r isk Small c ompany risk St ock ma rket risk Strat eg y: U.S . Sma ll & Mid-C ap Growth th Strategy description : The st rategy invests primarily in U.S . sm all and mid-cap e quities, w ith a pr eference for companies wi supe rior grow th potential over time but can invest in co mpanies of any size and from any count ry. Portf olio ma nag ement us es fund amental analysis to identify attractive secur ities acr oss secto rs. The investment objective is long -term capital app reciation with r isk ma nag ement. Asso c iated Material Ris ks Coun terparty risk Emerging markets risk Focus r isk Foreign in vestment risk Grow th investing r isk IPO risk Liquidi ty risk Market disruption risk Medium -sized company risk Opera tional and technology risk Pricing risk S ecurity lending r isk Security selection risk Small company risk Stock market risk Stra teg y: Glo bal S ector – Health care Strategy description : The strategy inves ts in equities of healthcare compa nies. The ma nag ement te am foc uses on biotech nology, pharmaceutica l, medical device, life sci ence instru mentation and medical service comp anies with sta ble earnings and superior growth potential with a so lid pipeline of products and serv ices. The strategy prima rily invests in large -cap stoc ks, su pplemen ted with mid-cap and sma ll-cap stock s. The stra tegy is diversified ac ross industries in Health C are to help mana ge risk. Asso c iated Material Ris ks Concentration r isk Counterparty risk Foreign inv estment risk Growth investing risk Health care securities risk Liquidity risk Market disruption risk Operational and technolo gy risk Pricing risk Securities lending risk Security sel ection r isk Small c ompany risk Stock market risk Stra teg y: Glo bal S ector – T echnology Strategy description : The strategy inves ts in equities of compan ies in the tech nology secto r, including semic onductors, softwa re, telecom equipment, co mputer/hardw are, internet, IT ser vices, and financial tech nology service s . As a compre hens ive Scie nce & Technology stra tegy, it also invests in equities of comp anies that i nvent and develop techn ology-based sol utions and/or apply and integra te leading edge techn ology-based solutions as a key element of their cor porate strategies. This includes compan ies in the techn ology sector but also includes compani es applying techn ological and sci entific advancem ent to other market secto rs including, but not limited to, advertising, comme rce, healthca re, and industrial . The strategy may invest in \ 19  Form ADV Part 2A DWS Investment Management Americas, Inc. compan ies of any size and may invest in initial public offerings. While the strategy invests mai nly in U.S. st ocks, it also inves ts in foreign s ecu rities inc luding emer ging ma rkets secu rities. Asso c iated Material Ris ks Concentration risk Counterparty risk Credit risk Derivatives risk Eme rging markets risk Foreign inv estment risk Growth inv esting risk Interest rate risk IPO risk L iquidity risk Market disruption risk Medium-sized company risk Non-diversification risk Operational and technology risk Prepayme nt and extension risk Pricing risk Restricted securities risk S ecurities le nding risk S ecurity s election risk Small company risk St ock ma rket risk Technology sector risk Stra teg y: Glo bal S ector – C omm unications Strategy description: The st rategy invests p rima rily in securities of C omm unications compani es i nclu ding th ose th at provide con nectivity se rvices, c ontent, interac tive media p latforms that facilitate communications and c omme rce, and related co mmu nications t ech nologies. Th is gr oup inclu des tr aditional pr oviders of Co mmunications a nd Media se rvices, but a lso inc ludes newer C ommun ica tions busin esses empl oying digita l, clo ud a nd mo bile tech nologies. Por tfolio holdings primari ly inc lude common sto cks but may also include convertible bonds and debt secur ities of C omm unications comp anies wor ldwide. Asso ciated Material Risks Concentration r isk Counterparty risk Credit risk Derivatives risk Emerging markets risk Foreign inv estment risk Growth inv esting r isk IPO risk Liquidity r isk Market disru ption risk Medium -sized company risk Non-diversif ication risk Operational and technolo gy risk Pricing risk Real est ate secur ities risk Securities lending r isk Security sel ection r isk Small c ompany risk St ock ma rket risk Stra teg y: Glo bal S ectors – Digital Horizons ( C omm unications and Technology and other related industries) The strategy invests primarily in common stock of digital companies . Digital companies are those that ision of such services. A ned by the Global Industry Classification Standard (GICS ®). Currently these . In addition, companies classified in industries within other GICS . Portfolio holdings primari ly inc lude common sto cks but may also include convertible Strategy description: provide services or content primarily via the internet or other forms of electronic communication or digital technologies, including software or that provide the physical infrastructure and/or equipment that enable the prov company will be considered a digital company if it is in one of the industries that make up the information technology or communication services sector, as defi industries are: software and services, technology hardware and equipment, semiconductors and semiconductor equipment, telecommunication services, and media and entertainment sectors may be digital companies based on portfolio management’s assessment of whether their services and products rely on the internet or other digital technologies bonds and debt secur ities of digital comp anies wor ldwide. \ 20  Form ADV Part 2A DWS Investment Management Americas, Inc. Asso ciated Material Risks Concentrat ion risk Counterpart y risk Cred it risk Derivatives risk Emerging markets risk Foreign inv estment risk Growth inv esting r isk IPO risk Liquidity r isk Market disru ption risk Medium -sized company risk Non-diversif ication risk Operational and technolo gy risk Pricing risk Real est ate secur ities risk Securities lending r isk Security sel ection r isk Small c ompany risk St ock ma rket risk Communications services sector risk Stra teg y: U.S. Large Ca p Value and US Large Ca p Equity Dividend Strategy description : Th ese strategi es follow DWS Group’s re gistered trademark CR OC I® (Cash Return on C apital Invested) appro ach. These st rategies use rules -based s tock sel ection based on a prop rietary equity v aluation techn ique that aims to de- liver inves tment exposure to underapp reciat ed econ omic val ue. Strate gy imp lementation is sys tema tic based on ranking of stoc ks acco rding to CR OC I® Econ omic Price Earnings Ratios. The resea rch and analys is within this valuation technique includes co nsistent method adjustments to reported financial statement measur es that inclu de adjustmen ts for inflation, hidden liabili- ties, depr ecia ting similar asse ts in the same ma nner and estimating the value of unreported asse ts. T hese adjustments improve compara bility for investment purposes. St rateg ies are rebalanced on a regu lar (mo nthly or quarte rly) basis. Extra scr eens are app lied for the equity dividend st rateg ies to f ocus mo re on higher d ividend yield s tocks a nd to minimize financial, ope ration al and ma rket risks. Associated Material Risks Counterparty risk CROCI® risk Dividend -paying stock risk Focus risk Foreign investment risk Large -sized companies risk Liquidity risk Market disruption risk Operational and technology risk Pricing risk Securities lending risk Security selection risk Stock market risk Value investing risk Stra teg y: Instituti onal Manag ed Equity Strategy description : These strategi es provide cus tom ized equity sol utions in separa tely manag ed acc ounts for insurance compan ies and other i nstitutions. Th ese strategies target client desired equity exposur es with risk and tax man agement. Tax ma nagement is ach ieved by manag ing ga ins and loss es with qu antitative port folio man agement tools to optimize after-tax total returns wit hin risk budge ts and other paramete rs. Th ese stra tegi es can be tailo red across a wide range of U.S. and International equi ty benchma rk indices and can inclu de customized ESG criteria and act ive stra tegi es from ac ross the firm. DIMA will endeavor to trigger cap ital losses to offset ca pital ga ins from other transac tions, however, these losses may on occas ion be disa llowed by certain tax rules, such as the wash sale rules. DIMA mon itors acc ounts to attempt to prevent wash sa les but may not be able to prevent them in every case. \ 21  Form ADV Part 2A DWS Investment Management Americas, Inc. Asso c iated Material Ris ks Active trading risk Coun terparty risk Cred it risk Derivatives risk ESG investing risk Foreign inv estment risk Indexing risk Interest rate risk L iquidity risk Market disruption risk Pricing risk S ecurities le nding risk S ecurity s election risk St ock ma rket risk Stra teg y: Equity Index Strategy description : The strategy’s prima ry strategy seeks to replicate the performan ce of a broad market equity index. The strategy gains exposure to the larg est s toc ks in the index in approximate ly the same proportion they are rep resented in the index, then gaining exposu re to a statistica lly selected samp le of the sma ller stocks found in the index. This process is intended to produce a portfolio whose indu stry wei ghtings, mark et capitalizations and fund amen tal char acte ristics (price-to-book ratios, pric e-to-earnings ratios, deb t-to-asset ratios, and dividend yields) closely replicate those of the index. Th is approach attempts to maximize the stra tegy ’s liquidity and returns while minimizing i ts cos ts. Asso c iated Material Ris ks Counterparty risk Derivat ives risk Index-related r isk Liquidity r isk Market disru ption risk Non-diversif ication risk Operational and technolo gy risk Pass ive investing r isk Pricing risk Securities lending r isk St ock ma rket risk Tracking error risk Stra teg y: Active CR OCI Strategy description : The strategy follows DWS Group’s registered tradema rk CR OC I® (Cash Return on C apital Investe d) appro ach. These strategies use rules -based stock sel ection based on a prop rietary equity valuation techn ique that aims to deliver investment exposu re to under-apprecia ted economic value. S trategy implementation is systema tic based on rankings of stoc ks acco rding to CR OCI ® Econ omic Price Earnings Ratio. The resea rch and analys is within the valuation tech nique inc ludes co nsistent method adjustments to reported financial statement measur es that inclu de adjustmen ts for inflation, hidden liabilities, depr ecia ting similar assets in the same manner and estima ting the value of underreported assets. T hese adjustmen ts improve compara bility for inv estment purposes . Stra tegi es are rebalanc ed on a regular (monthly or quarterl y) basis. Associated Material Risks Counterparty risk CROCI® risk Currency risk Dividend -paying stock risk Focus risk Foreign investment risk Large -sized companies risk Liquidity risk Market disruption risk Operational and technology risk Pricing risk Securities lending risk Security selection risk Stock market risk Value investing risk Stra teg y: International Equi ty – Grow th Strategy descripti on: The strategy invests prima rily in equities of foreign large cap companies with supe rior growth potential over time. T he strate gy uses fund amen tal ana lysis to seek comp anies that crea te shar eholder value on the basis of competitive \ 22  Form ADV Part 2A DWS Investment Management Americas, Inc. advantage and that are well posi tioned for secular tre nds. The portfolio is diversified ac ross various corpora te life cy cle stag es to deliver an inves tment exposure mix of both establ ish ed and earlier sta ge and high growth potenti al com panies. While most holdings are of devel oped ma rket equities, the fund also invests in eme rging market equities and companies with business in emerging ma rkets. The inv estment ob jective is long-term capital app recia tion with risk manag ement. Ass oc iated Material Ris ks Coun terparty risk Cu rrency risk Emerging mark ets risk Focus r isk Foreign i nvestm ent risk Growth inv esting r isk Liquidi ty risk Market disruption risk Medium-sized company risk Opera tional and technology risk Pricing risk Regio nal focus risk Secur ities len ding r isk Secur ity sel ection r isk Small c ompa ny risk St ock ma rket risk Stra teg y: International Equi ty – Value Strategy description : Th ese strategi es follow DWS Group’s re gistered trademark CR OC I® (Cash Return on C apital Invested) appro ach. These st rategies use rules -based s tock sel ection based on a prop rietary equity v aluation techn ique that aims to deliver inves tment exposure to underapp reciated econ omic val ue. Strate gy imp lementation is sys tema tic based on ranking of stoc ks acco rding to CR OC I® Econ omic Price Earnings Ratios. The resea rch and analys is within this valuation technique includes co nsistent method a djustm ents to reported financial statem ent measur es that inclu de adjustmen ts for inflation, hidden liabilities, depr ecia ting similar asse ts in the same ma nner and estimating the value of unreported asse ts. T hese adjustments improve compara bility for inves tment purposes. St rategies are rebalanced on a reg ular (month ly or quarte rly) bas is. Investment Unive rse includes major developed ma rkets outside of the US. Ass oc iated Material Ris ks Counterparty risk Currency risk CROCI ® risk Focus r isk Foreign inv estment risk Liquidity r isk Market disru ption risk Operational and technolo gy risk Pricing risk Securities lending r isk Security sel ection r isk St ock ma rket risk Stra teg y: Global Small Cap Strategy description : The strategy invests prima rily in equities of s mall co mpanies th rough out the world but can invest in co mpan ies of any size. Po rtfolio mana gement uses prop rietary quantitative stock sel ection models to select attractive securities and a syst ema tic proc ess for portfolio const ruc tion. Portfo lio man age ment can use discr etion to remove stocks from the portfolio or pass on quan titatively identified candidates. The investm ent objective is lo ng-term ca pital apprecia tion with risk management. \ 23  Form ADV Part 2A DWS Investment Management Americas, Inc. Asso c iated Material Ris ks Counterparty risk Currency risk Derivatives risk Emerging markets risk Foreign inv estment risk Liquidity r isk Market disru ption risk Operational and technolo gy risk Pricing risk Quantitative model risk Securities lending r isk Security sel ection r isk Small c ompany risk St ock ma rket risk Strategy : Latin America Equity Strategy description : The strategy see ks long -term capital appreciation by inves ting primar ily in Latin American common stocks and other La tin Amer ica-related equi ties, such as those iss ued by a compa ny traded ma inly on Lat in Ame rican marke ts, issued, or guaranteed by a Latin American government or issued by a comp any with more than ha lf of its busin ess in Latin Americ a. Po rtfolio man agement uses quantitative and fi eld resea rch to identify key reg ional economic and in dust rial th emes, as well as ch ang es such as privat ization, imp roved inflow of direct foreign investment, and the development of a busin ess envi ronment co nducive to investm ent and growth. Associated Material Risks Active trading risk Counterparty risk Credit risk Currency risk Emerging markets risk Focus risk Foreign investment risk Frontier market risk Growth investing risk Interest rate risk Latin America risk Regional focus risk Liquidity risk Market disruption risk Non-diversification risk Operational and technology risk Prepayment and extension risk Pricing risk Securities lending risk Security selection risk Stock market risk Stra teg y: Eme rging Markets Equity Strategy description : The strategy seeks long -term grow th of ca pital. The strategy invests in emerg ing mar ket equities (equities traded mainly in emerg ing markets or issued by compa nies that are organized in eme rging ma rkets or have more than half of their bus iness there). The strategy typical ly invests in equities from the U.S. or other develop ed markets or but may have a portion of its assets in U.S. or emerging ma rket debt securit ies when portfolio manag ement believes the secu rities may perform as we ll as equities. Asso c iated Material Ris ks Coun terparty risk Cred it risk Curr ency risk Emerging marke ts risk Focus r isk Foreign i nvestment risk Fron tier markets risk Grow th investing r isk Interest rate risk Liquidi ty risk Market disruption risk Medium -sized comp any risk Opera tional and technology risk Prepayment and extension risk Pricing risk Regio nal focus risk S ecurities len ding risk S ecurity selection risk S mall compa ny risk St ock ma rket risk \ 24  Form ADV Part 2A DWS Investment Management Americas, Inc. Stra teg y: Grow th Equity Strategy description : This strategy is design ed to capture shif ts in glo bal tren ds and econom ic devel opm ents. The strategy invests sign ificant ly in comm on stocks of U.S . and foreign comp anies. The stra tegy can i nvest in compa nies of any size from any co untry but inves ts mai nly in esta blished g lobal comp anies. Asso c iated Material Ris ks Active trading risk Con centration risk Coun terparty risk Cred it risk Curren cy risk Derivatives risk Emerging markets risk ETF risk ETN risk Focus risk Foreign in vestment risk High yield debt securities risk Interest rate risk L iquidity risk Market disruption risk Operational and technology risk Prepayment and extension risk Pricing risk Real estate securities risk Reg ional focus risk S ecurities le nding risk S ecurity selection risk St ock ma rket risk \ 25  Form ADV Part 2A DWS Investment Management Americas, Inc. Fixed inc ome Stra teg y: C anada Fixe d Income Strategy descrip tion : The strategy seeks high total investment return consistent with prese rvation of c apital and prudent investment man agement. The strate gy typical ly invests in Canad ian dollar-denominated inv estment grade debt secur ities of Canad ian and non-C anadian issue rs: government and governm ent age ncies, instrumentalities, provinc ials and mu nicipals, corpo rate and asse t-backed securiti es. Asso c iated Material Ris ks Active trading risk Credit risk Currency risk Derivatives risk Foreign investment risk High -yield debt securities risk Interest rate risk Liquidity risk Market disruption risk Pricing risk Securities lending risk Security selection risk Strategy : Emer ging Markets Fixed Income Strategy descripti on: The strategy see ks to provide high curre nt income and long -term ca pital apprecia tion. The strategy typica lly inves ts in high yield bonds rated below the fourth highest credit rating and o ther debt secu rities issued by govern ments and corpo rations in eme rg ing mar ket count ries. Asso c iated Material Ris ks Counterparty risk Credit risk Currency risk Derivatives risk Emerging markets risk Foreign investment risk High -yield debt securities risk Interest rate risk Liquidity risk Market disruption risk Non-diversification risk Operational and technology risk Prepayment and extension risk Pricing risk Regional focus risk Securities lending risk Security selection risk Stra teg y: Eme rging Markets Fi xed Income Index Strategy descri ption : The strategy seeks to replicate the perfo rma nce of an eme rging markets fixed inc ome index. The strategy gains exposure to securities in the index in app roximately the same proportion they are represented in the index. Th is process is intended to produce a por tfolio whose industry weigh tings and fu ndament al c harac terist ics c losely re plicate those of the ind ex. Asso c iated Material Ris ks Counterparty risk Currency risk Credit risk Derivatives risk Emerging markets risk Foreign investment risk High -yield debt securities risk Index-related risk Interest rate risk Liquidity risk Market disruption risk Multi-Manager risk Non-diversification risk Operational and technology risk Passive investing risk \ 26  Form ADV Part 2A DWS Investment Management Americas, Inc. Prepayment and extension risk Pricing risk Regional focus risk Securities lending risk Security selection risk Tracking -error risk Stra teg y: Fixed Income Multi Product . He strategy employs numerous investment -U.S. debt, fixed and floating -rate debt of both investment grade . The exact portfolio composition will vary over time as a result of market changes as Strategy description : The strategy seeks high current income and total return techniques including, but not limited to leverage, U.S., and non and high yield debt of varying maturities well as DIMA’s view of the portfolio composition that best enables the strategy to achieve its investment objectives. Asso c iated Material Ris ks Active trading risk Cre dit risk Cou nterparty risk Curr ency risk Derivatives risk Foreign i nvestment risk High -yield debt securities risk Interest rate risk L iquidity risk Machine learning risk Market disruption risk Prepayment and extension risk Pricing risk Securities lending risk S ecurity selection risk Stra teg y: Global Fixe d Income Strategy description : T he strategy seeks total return by investing primari ly in fixed income securiti es of issuers loc ated outs ide the U.S. The strategy will typic ally inve st in bon ds of all maturities issu ed by governments, age ncies, and cor poratio ns around the world, whi ch m ay be rated below inves tment grade. Asso c iated Material Ris ks Active trading risk Cou nterparty risk Cre dit risk Curr ency risk Derivatives risk Em erging markets risk Foreign i nvestment risk High -yield debt securities risk Interest rate risk L iquidity risk Market disruption risk Non-diversification risk Operational and technology risk Prepayment and extension risk Pricing risk Regi onal focus risk S ecurities le nding risk S ecurity s election risk Stra teg y: Global Infl ation Protecte d Sec urit ies Strategy description : T he strategy seeks to provide maximum inflated adjusted return. The strategy will typically invest in inflation indexed bonds or other fixed i ncome inves tments th at are linked to the rate of inflation. T he strategy can inclu de investmen ts in both U.S. and non-U.S. governm ents, government ag enc ies, instrumen talities, corpo ration s, and other derivativ es related to th ese types of secu rities. \ 27  Form ADV Part 2A DWS Investment Management Americas, Inc. Asso c iated Material Ris ks Active trading risk C omm odities – related investments risk Co nflict of interest risk Cou nterparty risk Cre dit risk Curr ency risk Derivatives risk Emerging markets risk Focus risk Foreign i nvestment risk High -yield debt securities risk Inflation-indexed bond risk Interest rate risk Interest rate strategies risk L iquidity risk Market disruption risk Prepayment and extension risk Pricing risk S ecurities le nding risk S ecurity selection risk S enior loans risk Stock market risk Tax risk Stra teg y: Global S hort Dur ation Strategy description : The strategy seeks to maximize total return co nsis tent with prese rvation of cap ital and prudent investment mana gement. The strate gy typically invests in investment gra de debt secu rities of domes tic (U.S .) and foreign: gov ernm ent ag enc ies, inst rumenta lities, corporate, mo rtga ge backed, ass et backed, taxab le and tax-exempt mun icipal bonds. In keeping wi th a sho rt du ration strate gy, investmen ts are ty pica lly in securi ties that have short to inte rmediate maturities . Asso c iated Material Ris ks Coun terparty risk Cred it risk Derivat ives risk Emerging marke ts risk Focus r isk Foreign i nvestm ent risk Forward co mmitment risk High -yield debt securities r isk Interest rate risk Liquidi ty risk Market disruption risk Mortg age -backed and other ass et-backed secur ities r isk Opera tional and technology risk Prep ayme nt and extension risk Pricing risk Secur ities len ding r isk Secur ity sel ection r isk Senior l oans risk Stra teg y: Global Governme nt Bo nd Index Strategy description : T he st rategy seeks an investm ent return that approxima tes as cl osely as practicab le be fore expens es, the performance of the J.P. Morgan Government Bond Index Global (GBI Global Index), net coupon reinvested, unhedg ed in USD. The strategy will typica lly invest directly in securi ties of companies inc luded in GBI Global Index, in approximate ly the same proportions as they are represented in the GBI Global Index. The po rtfolio sh all be rebala nced on a mon thly basis, in line with the rebalancing of the GBI Global Index. Asso c iated Material Ris ks Cred it risk Curr ency risk Derivat ives risk Indexing r isk Interest rate risk Liquidi ty risk Market disruption risk Prep ayme nt and extension risk Pricing risk Secur ities len ding r isk Secur ity sel ection r isk Tracking error risk \ 28  Form ADV Part 2A DWS Investment Management Americas, Inc. Stra teg y: C ore Fi xed Income Strategy description : The strategy seeks high to tal investment return consistent with prese rvation of c apital and prudent investment man agement. The strategy typica lly invests in U.S . dollar -denom inated inves tment gra de debt securities of domestic (U.S.) and foreign issue rs: government and government age ncies, inst rum entalities, co rporate, mortg age backed, asset backed, and t axable mu nicipal bonds. Asso c iated Material Ris ks Active trading risk Counterparty risk Currency risk Cred it risk Derivatives risk Foreign inv estment risk High -yield debt securities risk Interest rate risk L iquidity risk Market disruption risk Prepayme nt and extension risk Pricing risk S ecurities le nding risk S ecurity s election risk Strategy : C ore Intermediate Strategy description : The strategy seeks high total investment return consistent with preservation of capital and prudent investmen t man age ment. The strategy typically invests in U.S. dolla r-denom inated investment grade deb t securities of domes tic (U.S.) and foreign issue rs: go vernm ent and government age ncies, ins trum entalities, co rporate, mortgage backed , asset back ed, and taxable mun icipal bon ds. In keeping with an intermediate duration strategy , inves tments are typically in secu rities that hav e intermediate maturities. Asso c iated Material Ris ks Active trading risk Counterparty risk Currency risk Cred it risk Derivatives risk Foreign inv estment risk High -yield debt securities risk Interest rate risk L iquidity risk Market disruption risk Prepayme nt and extension risk Pricing risk S ecurities le nding risk S ecurity s election risk Stra teg y: C ore Pl us Fi xed Income Strategy description : The strategy se eks h igh to tal i nvestment re turn c ons istent with prese rvation of c apital and p rudent investment management by investing for both current income and capi tal appreciation. T he strategy primari ly invests in U.S . dollar-denomina ted investm ent g rade and debt secu rities of dom estic (U.S .) and foreign issue rs: gover nment and governme nt age ncies, instrumen talities, co rporate, mortgage backed, asset bac ked, and taxab le mu nicipal bon ds. It also may invest in below investmen t-grade de bt secu rities of domestic (U.S.) and foreign iss uers: emerg ing -market government and government age ncies, corpo rate, mo rtga ge ba cked, asset backed, and t axable mun icipal bon ds. \ 29  Form ADV Part 2A DWS Investment Management Americas, Inc. Asso c iated Material Ris ks Active trading risk Counterparty risk Credit risk Derivatives risk Emerging markets risk Foreign investment risk High -yield debt securities risk Inflation risk Interest rate risk Liquidity risk Market disruption risk Market risk Operational and technology risk Prepayment and extension risk Mortgage -backed and other asset -backed securities risk Pricing risk Securities lending risk Securities selection risk US government default risk Strategy : Core Short Duration Strategy description : The strategy se eks h igh to tal i nvestment re turn c ons istent with prese rvation of c apital and p rudent investment man agement. The strategy typica lly invests in U.S. dolla r-denominated inves tment gra de debt securi ties of domestic (U.S.) and foreign issue rs: government and governm ent ag encies, instrumen talities, cor porate, mortgage backed, ass et backed and taxable mun icipal bonds. In keeping with a sho rt duration stra tegy, investmen ts are typica lly in secu rities that have sh ort matu rities. Associated Material Risks Active trading risk Counterparty risk Credit risk Derivatives risk Emerging markets risk Focus risk Foreign investment risk Forward commitment risk High -yield debt securities risk Inflation risk Interest rate risk Liquidity risk Market disruption risk - Operational and technology risk Mortgage -backed and other asset backed securities risk Prepayment and extension risk Pricing risk Securities lending risk Security selection risk Senior loans risk US government default risk Stra teg y: U.S. C orporate Inves tme nt Grade Strategy description : T he strategy seeks high total investment return. The stra tegy invests in investment grade fixed income securi ties of U.S. dollar-denominated cor porate iss uers. Asso c iated Material Ris ks Active trading risk Cou nterparty risk Cre dit risk Derivatives risk High -yield debt securities risk Interest rate risk L iquidity risk Market disruption risk Prepayment and extension risk Pricing risk S ecurities le nding risk S ecurity selection risk Stra teg y: U.S. C orporate Inves tme nt Grade Index Strategy description : The strategy seeks to replicate the perform ance of US cor porate investment grade securi ties index. The strategy gains exposure to securities in the ind ex in app roximately the s ame proportion th ey are represented in the index. Th is \ 30  Form ADV Part 2A DWS Investment Management Americas, Inc. proc ess is intended to produce a por tfolio whose industry weigh tings and fu ndamental c harac terist ics clos ely replicate those of the ind ex. Asso c iated Material Ris ks Active trading risk Counterparty risk Credit risk Derivatives risk High-yield debt securities risk Index-related risk Interest rate risk L iquidity risk Market disruption risk Passive investing risk Prepayment and extension risk Pricing risk Securities lending risk Security selection risk T racking error risk Stra teg y: U.S. Governme nt Strategy description : The strategy seeks to provide current income, liquidity, and secu rity of principal. T he strategy typica lly invests in securities backed by the full faith and credit of the U.S. Government, including related repurchase agreeme nts, age ncies w ith the explicit gu arantee of the U.S. Government, and U.S. Treasury securities. Depending on the implementation of the strategy and needs of a client, the strategy can include debt and mortgag e-bac ked secu rities, including securities that are issued by U.S. government ag encies or instrumentalities, but are not backed by the full faith and credit of the U.S. Government. Asso c iated Material Ris ks Active trading risk Cre dit risk Derivatives risk High -yield debt securities risk Interest rate risk L iquidity risk Market disruption risk Prepayment and extension risk Pricing risk Sec urities le nding risk S ecurity s election risk Stra teg y: Global High Yield Strategy description : T he strategy seeks a high level of current inc ome. The strategy invests prima rily in below investment grade debt bonds that are be low the f ourth hig hest credit rating of G lobal fixed i ncome s ecurities. Associated Material Risks Active trading risk Counterparty risk Credit risk Currency risk Derivatives risk Emerging markets risk Focus risk Foreign investment risk High -yield debt securities risk Inflation risk Interest rate risk Liquidity risk Market disruption risk Operational and technology risk Prepayment and extension risk Pricing risk Securities lending risk Security selection risk Stock market risk \ 31  Form ADV Part 2A DWS Investment Management Americas, Inc. Stra teg y: U.S. High Y ield Strategy description : T he strategy seeks a high level of current inc ome. The strategy invests prima rily in below investment grade or b elow the f ourth hig hest credit rating of U.S. fixed income secu rities. Asso c iated Material Ris ks Active trading risk Counterparty risk Credit risk Derivatives risk Eme rging markets risk Focus risk Foreign i nvestment risk High -yield debt securities risk Inflation risk Interest rate risk Liquidity risk Market disruption risk Market risk Operational and technology risk Prepayment and extension risk Pricing risk Securities lending risk Security selection risk Machine learning risk Stock market risk Stra teg y: U.S. High Y ield Index Strategy description : Th e strategy seeks to replicate the performance of US high yield index. The strategy ga ins exposure to securi ties in the index in approximately the same proportion they are represen ted in the index. This proc ess is intended to prod uce a port folio wh ose industry weightings and fund amental char acte ristics closely replicate t hose of the ind ex. Asso c iated Material Ris ks Coun terparty risk Cred it risk Derivat ives risk Emerging marke ts risk Focus r isk Foreign i nvestm ent risk High -yield debt securities risk Index-related risk Inflation risk Interest rate risk Liquidity risk Machine learning risk Market disruption risk Market risk Operational and technology risk Passive investing risk Prepayment and extension risk Pricing risk Securities lending risk Security selection risk Tracking -error risk Strategy: U.S. Mortgage Backed -backed securities that are issued by one of the U.S . Strategy description : T he strateg y seek s income by investing in mortgage Government sponsored enterprises, including but not limited to Government National Mortgage Associate (GNMA), Federal. Asso c iated Material Ris ks Active trading risk Credit risk Counterparty risk Derivative s risk Forwar d com mitment risk Inflation risk Interes t rate risk Liquidity risk Market disrupt ion risk Operational and techno log y risk Prepay ment and extens ion risk Mortgage -backe d and other asset -backe d securit ies risk Pricing risk Securit ies le nding risk Security selection risk US government default risk \ 32  Form ADV Part 2A DWS Investment Management Americas, Inc. Strategy: U.S. Municipals ular Strategy description : T he strategy seeks a high level of income exempt from regular federal income tax. The strategy will typically invest in securities issued by municipalities across the U.S. and in other securities whose income is free from reg federal income tax. Asso c iated Material Ris ks Counterparty risk Credit risk Derivatives risk ETF risk Focus risk High-yield debt securities risk Interest rate risk L iquidity risk Market disruption risk Market risk – municipals Municipal securities risk Operational and technology risk Prepayment and extension risk Pricing risk S ecurity selection risk Tax risk Tender option bonds risk U.S . territory and Co mmonwea lth obliga tions risk Strategy: U.S. Municipals Index Strategy description : The st rategy seeks to replica te the p erform ance of a US mun icipal index. T he stra tegy gains exposure to securi ties in the index in a pproxima tely the s ame pr oportion they are repr esented in the index. Th is process is intended to prod uce a po rtfolio wh ose industry weightings and fund amental char acte ristics closely replicate t hose of the ind ex. Asso c iated Material Ris ks Counterparty risk Credit risk Derivatives risk ETF risk Focus risk High -yield debt securities risk Index-related investing Interest rate risk Liquidity risk Market disruption risk Market risk - municipals Municipals securities risk Operational and technology risk Passive investing risk Prepayment and extension risk Pricing risk Security selection risk Tax risk Tender option bonds risk Tracking -error risk U.S . territory and Co mmonwea lth obliga tions risk Strategy: U.S. Municipals High Yield Strategy description : The strategy seeks a high level of inc ome exempt fr om reg ular federal inc ome tax. The stra tegy will typica lly invest in securi ties issued by mun icipalities across the U.S. and in other s ecuri ties whose income is free from regular federal income tax. While the strategy can invest in investment grade municip al debt, it can also invest in high-yield bonds which are those rated b elow the fou rth cr edit grade. \ 33  Form ADV Part 2A DWS Investment Management Americas, Inc. Asso c iated Material Ris ks Credit risk Counterparty risk Derivatives risk Focus r isk -Municipal Forward commitment risk - Municipal High -yield debt securities risk Inflation risk Interest rate risk Liquidi ty risk Market disruption risk Market risk - Municipal Municipal securities risk Opera tional and technology risk Prepayment and extension risk Pricing risk S ecurity selection r isk Tax risk Tender op tion bonds r isk Strategy: U.S. Municipals Short Term Strategy description : The s trategy seeks a high level of income exempt from regu lar federal income tax, co nsistent with the prese rvation of capital. T he strategy will typically invest in securi ties issued by mun icipalities across the U.S. and in other securi ties whose income is free from regu lar federal inc ome tax. Usually, the strategy is primari ly invested in investment gra de mu nicipal debt and f ocuses on securities with sho rt maturi ties. Asso c iated Material Ris ks Counterparty risk Credit risk Focus risk -Municipal Forward commitment risk Interest rate risk Liquidity risk Inflation risk Tax risk Market disruption risk Municipal securities risk Operational and technology risk Prepayment and extension risk Pricing risk Security selection risk Tax risk Private activity and industrial development bond risk When-issued and delyaed delivery securities risk Strate g y: U.S. Muni cipals Interme diate Strategy description : The strategy seeks a high level of income exempt from regular fe deral inc ome taxes and seeks to limit princip al fluctua tion. The strat egy will typica lly invest in securi ties issued by mun icipalities across the U.S. and in other secu rities whose inc ome is free from regular federal income tax. Usu ally, the stra tegy is prima rily invested in investment grade mun icip al debt. As the strate gy is intermedia te, it will typical ly invest in securi ties that are betwe en long and short matu rities. Asso c iated Material Ris ks Counterparty risk Credit risk Focus r isk -Municipal Forward commitment risk - Municipal Inflation risk Interest rate risk Liquidity r isk Market disru ption risk Market risk - Municipal Municipal securities risk Operational and technolo gy risk Prepayme nt and extension r isk Pricing risk Security sel ection r isk Tax risk Stra teg y: U.S. Muni cipals L ong T erm Strategy description : The s trategy seeks a high level of income exempt from regu lar federal income tax, co nsistent with the prese rvation of capital. T he strategy will typically invest in securi ties issued by mun icipalities across the U.S. and in other \ 34  Form ADV Part 2A DWS Investment Management Americas, Inc. securi ties whose inco me is free from regu lar federal inc ome tax. Usually, the strategy is primari ly invested in investment gra de mu nicipal debt. As the stra tegy is long, it wi ll typ ica lly invest in s ecuriti es that h ave lo ng maturities . Asso c iated Material Ris ks Counterparty risk Credit risk Focus r isk -Municipal Forward commitment risk - Municipal Inflation risk Interest rate risk Liquidity risk Market disru ption risk Market risk - Municipal Municipal securities risk Operational and technology risk Prepayme nt and extension risk Pricing risk Security sel ection r isk Tax risk Stra teg y: U.S. Muni cipals S tate S pec ific Strategy description : T he strategy seeks inc ome that is exempt from sin gle state personal and federal income taxes. The strategy will typical ly invest in securi ties issu ed by municipalities in a single state that are exempt from state taxes and whose income is free from reg ular federal income tax. Wh ile the st rategy can invest in i nvestment grade s ing le state mun icipal debt, it can a lso i nvest in h igh-yield b onds which are those rated bel ow the fourth credit g rade. Associated Material Risks Counterparty risk Credit risk Focus risk -state municipal securities Forward commitment risk -Municipal Inflation risk Interest rate risk Liquidity risk Market disruption risk Market risk -Municipal Non-diversification risk Operational and technology risk Prepayment and extension risk Pricing risk Security selection risk Private activity and industrial development bond risk Tax risk Strategy: U.S. Municipals Intermediate Ladder The strategy seeks a high level of income exempt from regular federal income taxes and seeks to limit ree from regular federal income tax. Usually, the strategy is primarily invested in investment grade ities. Strategy description: principal fluctuation. The strategy will typically invest in securities issued by municipalities across the U.S. and in other securities whose income is f municipal debt. As the strategy is intermediate, it will typically invest in securities that are between long and short matur The strategy invests in securities that mature at regular intervals across the intermediate maturity range. Securities are typically held until maturity or minimum maturity and proceeds are reinvested at the longer end of the range. \ 35  Form ADV Part 2A DWS Investment Management Americas, Inc. Associated Material Risks Counterparty risk Credit risk Focus risk -Municipal Forward commitment risk - Municipal Inflation risk Interest rate risk Liquidity risk Market disruption risk Market risk - Municipal Municipal securities risk Operational and technology risk Prepayment and extension risk Pricing risk Security selection risk Tax risk Strategy: U.S. Municipals Short Term Ladder er Strategy description: The strategy seeks a high level of income exempt from regular federal income tax, consistent with the preservation of capital. The strategy will typically invest in securities issued by municipalities across the U.S. and in oth secu rities whose income is free from regular federal income tax. Usually, the strategy is primarily invested in investment grade municipal debt and focuses on securities with short maturities. The strategy invests in securities that mature at regular intervals across the short maturity range. Securities are typically held until maturity or minimum maturity and proceeds are reinvested at the longer end of the range . Associated Material Risks Counterparty risk Credit risk Focus risk -Municipal Interest rate risk Liquidity risk Market disruption risk Municipal securities risk Operational and technology risk Prepayment and extension risk Pricing risk Security selection risk Private activity and industrial development bond risk Tax risk When-issued and delayed delivery securities risk Stra teg y: ESG U.S. municipals Strategy description : T he strategy seeks a high level of income exempt fr om regular federal inc ome tax, using a proprietary ESG scr eening process whi le seeking to promo te environmental, social and governance impact. The strategy will typica lly inves t \ 36  Form ADV Part 2A DWS Investment Management Americas, Inc. in securiti es issu ed by municipalities across the U.S. and in other secu rities wh ose inc ome is free from regular federal income tax. Asso c iated Material Ris ks Counterparty risk Credit risk Derivatives risk ESG investing risk ETF risk Foc us risk High-yield debt securities risk Interest rate risk L iquidity risk Market disruption risk Market risk – municip als Municip al securities risk Operational and technology risk Prepayme nt and extension risk Pricing risk S ecurity s election risk Tax risk Tender option bonds risk U.S. t erritory and Co mm onwea lth obliga tions risk Stra teg y: U.S. Sy ndica ted L oans Strategy description : The strategy seeks high yielding investmen ts through the U.S. sy ndicated loan market, in add ition to investmen ts in U.S. corpo rate debt securi ties that are be low investment g rade, below the f ourth high est rating gr ade. Asso c iated Material Ris ks Active trading risk Counterparty risk Credit risk Derivatives risk High -yield debt securities risk Interest rate risk Liquidity risk Market disruption risk Prepayment and extension risk Pricing risk Securities lending risk Security selection risk Stra teg y: Liability Driven Investing Strategy description : T he strategy provides a custom approach to strategic asset allocation that seeks to hedge the risk factors inherent in pension liabilities, wh ile providing total return. A custom benchmark is created from a client's projected liabilities and rate of interest. The strategy then seeks to hedge the interest rate and credit risk factors inherent in pension liabilities throu gh fixed income investments, while seeking a specific rate of return in equities. Depending on the client, it can also include alternative asset classes, including but not limited to hedge funds, private equity, real estate, and other complex products. Asso c iated Material Ris ks Active trading risk Counterparty risk Credit risk Derivatives risk High-yield debt securities risk Interest rate risk Liquidity risk Market disruption risk Strat eg y: U.S. Structured S ecurit ies Strategy description : The strategy se eks h igh to tal i nvestment re turn c ons istent with prese rvation of c apital and prudent investment manag ement. T he strat egy typically invests in U.S . dollar-denomin ated securi ties that are backed by pools of assets, inc luding, but not limited to, of Comme rcial Mortga ges (CM BS), Ba nk Lo ans (CLO), Residential Mortgag es (RMBS), Cr edit Card Rece ivables (Cred it Card AB S ), and Automob iles L oans (Au tomo bile ABS ). \ 37  Form ADV Part 2A DWS Investment Management Americas, Inc. Asso c iated Material Ris ks Active trading risk Coun terparty risk Cred it risk Derivatives risk Forwar d c ommitment risk Interest rate risk L iquidity risk Market disruption risk Mortgag e-backed and other ass et-bac ked securities risk Operational and technology risk Prepayme nt and extension risk Pricing risk Strat eg y: Strategic As set Alloca tion Strategy description : The strategy seeks to achieve as high a total return as is co nsistent with its allocation to one or mo re as set class es over a given p eriod. T he stra tegy will t ypically in vest in other investment compa nies and other pooled vehic les that in turn, invest in fixed income, equity, and other asset class es (wh ich may inc lude closed end funds, open end mutual fund s, exchan ge traded funds, or private investments) some of w hich m ay be affiliated with D IMA. Asso c iated Material Ris ks Asset allocation risk Co mm odities – related investments risk Con centration risk Con centration -Real estate securities risk Coun terparty risk Cred it risk Curren cy st rateg ies risk Derivatives risk Eme rging markets risk ETF risk Foreign inv estment risk Interest rate risk Interest rate strateg ies risk L iquidity risk Market disruption risk Operational and technology risk Prepayme nt and extension risk Pricing risk S ecurity s election risk St ock ma rket risk Underlying f unds risk US government default risk Infrastructure -related companies’ risk Associated Material Risks Active trading risk The strategy may trade securities actively and this distributions that would be taxable to shareholders at higher federal income tax rates could result in increased taxable distributions to shareholders and (e.g. short -term capital gains) . Asset allocation risk Portfolio management may favor one or more types of investments or assets that underperform other investments, assets, or securities markets as a whole. Anytime portfolio management buys or sells securities in order to adjust the strategy’s asset allocatio n this will increase portfolio turnover and generate transaction costs. Commodities – related investments risk -linked derivatives, commodity -based exchange -traded products, and Exposure to commodity markets may subject the fund to greater volatility than investments in traditional securities. Commodity -related investments (including commodity instruments that provi de exposure to commodity indices or commodity prices) may be affected by a variety of factors, including changes in overall market movements, commodity price and index volatility, changes in interest rates, embargoes, tariffs and trade policies, policies o f commodity cartels and international economic, political and regulatory developments. In addition, certain commodities may be particularly sensitive to events such as climate changes, drought, floods, weather, livestock disease and changes in storage cost s. \ 38  Form ADV Part 2A DWS Investment Management Americas, Inc. to The value of commodity -related investment generally is based upon the price movements of a physical commodity (such as energy, minerals, or agricultural products), a futures contract, swap or commodity index, or other economic variables linked changes i n the value of commodities or the commodities markets, which can fluctuate substantially over short periods of time. A liquid secondary market may not exist for the types of commodity make it difficult for the fund to sell them at an acceptable price. The fund -linked derivative instruments the fund buys, which may -linked ’s ability to gain exposure to commodity investments and achieve its investment objective may be limited by its intention to qualify as a regulated investment company under the Internal Revenue Code of 1986, as amended. Communications services sector risk tion services sector can be adversely affected by, among other things, changes in government To the extent that a fund invests significantly in the communication services sector, the fund will be sensitive to changes in, and the fund’s performance may depend to a greater extent on, the overall condition of the communication services sector. Companies in the communica regulation and policies, intense competition, dependency on patent protection, equipment incompatibility, changing consumer preferences, techno logical obsolescence, and large capital expenditures and debt burdens. Concentration risk y’s performance. A particular sector or industry strategy that Any market price movements, regulatory or technological changes affecting a particular sector in which a strategy concentrates, may have a significant impact on a strateg concentrates in a particular segment of the market will generally be more volatile than a strategy that invests more broadly. Convertible securities risk the er will not n. rket of mes The market value of a convertible security performs like that of a regular debt security; that is, when interest rates rise, price of a convertible security generally declines. In addition, convertible securities are subject to the risk that the issu be able to pay interest or dividends when due, and their price may change based on changes in the issuer’s financial conditio Because a convertible security derives a portion of its value from the common stock into which it may be converted, ma and issuer risks that apply to the underlying common stock could impact the price of the convertible security. Certain types convertible securities may decline in value or lose their value entirely in the event the issuer’s financial condition beco significantly impaired. Counterparty risk ny e A financial institution or other counterparty with whom DIMA does business, or that underwrites, distributes, or guarantees a investments or contracts that the strategy owns or is otherwise exposed to, may decline in financial health, and become unabl to honor its commitments. This could cause losses for the client or could delay the return or delivery of collateral or other assets to the client. Credit risk t The strategy’s performance could be hurt if an issuer of a debt security suffers an adverse change in financial condition tha results in the issuer not making timely payments of interest or principal, a security downgrade, or an inability to meet a financ ial obligation. -grade debt securities. Credit risk for high -yield securities is greater than for higher - Because the issuers of high -yield debt securities (debt securities rated below the fourth highest credit rating category) may be in uncertain financial health, the prices of their debt securities can be more vulnerable to bad economic news or even the expectation of bad news, than investment rated securities. For securities that rely on third -party guarantors to support their credit quality, the same risks may apply if the financial condition of the guarantor deteriorates, or the guarantor ceases to ensure securities. Because guarantors may ensure many \ 39  Form ADV Part 2A DWS Investment Management Americas, Inc. -risk bonds, their financial condition could deteriorate as types of securities including subprime mortgage bonds and other high a result of events that have little or no connection to securities within the strategy. or Some securities issued by U.S. government agencies or instrumentalities are backed by the full faith and credit of the U.S. government. Other securities that are supported only by the credit of the issuing agency or instrumentality are subject to greater c redit risk than securities backed by the full faith and credit of the U.S. government. This is because the U.S. government might provide financial support but has no obligation to do so if there is a potential or actual loss of principal failure to make interest payments. - payment of Any non -payment of principal or interest could result in a reduction of income to the strategy, a reduction in the value of the strategy’s interest in the senior loan and a reduction in the strategy’s net asset value. There can be no assurance that the liquidation of any collateral securing a senior loan would satisfy the borrower’s obligation in the event of non scheduled interest or principal payments or that such collateral could be readily liquidated. CROCI® risk Investment Process , which is based on portfolio management’s belief that, cs. This premise may not always be correct, and prospec- sed by n a the strategy’s ability to invest in some stocks that may have the most attractive financial met- The strategy is managed using the CROCI® over time, stocks which display more favorable financial metrics (for example, the CROCI® Economic P/E ratio) as generated by this process may outperform stocks which display less favorable metri tive investors should evaluate this assumption prior to investing in the strategy. The calculation of the financial metrics u the strategy (such as, among others, the CROCI® Economic P/E ratio is determined by the CROCI® Investment Strategy and Valuation Group using publicly available information. This publicly available information is adjusted on assumptions made by tment Strategy and Valuation Group that, subsequently, may prove not to have been correct. As financial the CROCI® Inves metrics are calculated using historical information, there can be no guarantee of the future performance of the CROCI® strat- egy. The measures utilized b y portfolio management to attempt to reduce portfolio turnover, market impact and transaction costs could affect performance. In addition, certain regulatory restrictions (e.g., limits on percentage of assets invested i single industry) could constrain rics as determined by the CROCI® Investment Process. Currency risk n rade, ng Changes in currency exchange rates may affect the value of the strategy’s investment. The strategy’s U.S. dollar share price may go down if the value of the local currency of the non−U.S. markets in which the strategy invests depreciates against the U.S. d ollar. This is true even if the local currency value of securities in the strategy’s holdings goes up. Furthermore, the strategy’s use of forward currency contracts may eliminate some or all of the benefit of an increase in the value of a foreig currency versus the U.S. dollar. The value of the U.S. dollar measured against other currencies is influenced by a variety of factors. These factors include interest rates, national debt levels and trade deficits, changes in balances of payments and t domestic and foreign interest, and inflation rates, global or regional political, economic, or financial events, actual or potential government intervention, global energy prices, political instability and government monetary policies and the buying or selli of currency by a country’s government. In order to minimize transaction costs or for other reasons, the strategy’s exposure to non−U.S. currencies of the portfolio’s investments may not be fully hedged at all times. Currency exchange rates can be very volatil e and can change quickly and unpredictably. Therefore, the value of an investment in the strategy may also go up or down quickly and unpredictably. Currency strategies risk may The success of the currency strategies depends, in part, on the effectiveness and implementation of portfolio management's proprietary strategies. If portfolio management's analysis proves to be incorrect, losses to the fund may be significant and subs tantially exceed the intended level of market exposure for the currency strategies. -US currency markets. Foreign As part of the currency strategies, the fund could have substantial exposure to the risks of non currency rates may fluctuate significantly over short periods of time for a number of reasons, including changes in interest rates \ 40  Form ADV Part 2A DWS Investment Management Americas, Inc. e and economic or political developments in the US or abroad. As a result, the fund's exposure to foreign currencies could caus lower returns or even losses to the fund. Although portfolio management seeks to limit these risks through the aggregation of various long and short positions, there can be no assurance that it will be able to do so. Derivatives risk ies and elated Derivatives involved risks different from, and possibly greater than, the risks associated with investing directly in securit other more traditional investments. Risks associated with derivatives include the risk that the derivative is not well corr with the underlying asset, security or, index to which it relates; the risk that derivatives may result in losses or missed opportunities; the risk that the strategy will be unable to sell the derivative because of an illiquid secondary market; the a counterparty is unwilling or unable to meet its obligation; which risk may be heightened in derivative transactions entere into “over -the-counter” (i.e., not on an exchange or contract market); and the risk that the derivative transaction cou the strategy to the effects of leverage, which could increase the client’s exposure to the market and magnify potential losse risk that d ld expose s. r y fo r There is no guarantee that derivatives, to the extent employed, will have the intended effect, and their use could cause lowe returns or even losses to a strategy. The use of derivatives by a particular strategy to hedge risk may reduce the opportunit gain by offsetting the positive effect of favorable price movements. Dividend -paying stock risk -dividend paying stocks (and the stock market as a whole) over -paying stocks held by the strategy reduce As a category, dividend -paying stocks may underperform non any period of time. In addition, issuers of dividend -paying stocks may have discretion to defer or stop paying dividends for a stated period of time. If the dividend -paying stocks held by a strategy reduce or stop paying dividends, the strategy’s ability to generate income may be adversely affected, or an anticipated acceleration of dividends may not occur as a result of among other thin gs, a sharp rise in interest rates or an economic downturn. If the dividend or stop paying dividends, the strategy’s ability to generate income may be adversely affected. Emerging markets risk Foreign investment risks are greater in emerging markets than in developed markets. Investments in emerging markets are often considered speculative. Emerging market countries typically have economic and political systems that are less developed and can be expected to be less stable than developed markets. For example, the economies of such countries can be subject to rapid and unpredictable rates of inflation or deflation. Emerging markets securities risk ated The securities of issuers located in emerging markets tend to be more volatile and less liquid than securities of issuers loc in more mature economies, and emerging markets generally have less diverse and less mature economic structures and less stable political systems than those of developed countries. The securities of issuers located or doing substantial business in emerging markets are often subject to rapid and large changes in price. Equity Securities risk e nd t he -U.S. stock markets have experienced Equity securities are subject to changes in value due to the fact that they can be more volatile than other asset classes. Th value of equity securities varies in response to many factors, including, but not limited to, factors specific to an issuer a industry in which the issuer securities are subject to stock risk. Historically, U.S. and non periods of substantial price volatility and should be expected to do so again in the future. ESG investing risk strategy may forgo otherwise attractive In addition, the strategy may be required to sell a security when it might otherwise be Investing primarily in investments that meet ESG criteria carries the risk that the investment opportunities or increase or decrease its exposure to certain types of companies and, therefore, may underperform strategies that do not consider ESG factors. disadvantageous to do so . Additionally, investors can differ in their views of what constitutes positive or negative ESG \ 41  Form ADV Part 2A DWS Investment Management Americas, Inc. SG of any characteristics. As a result, the strategy may invest in issuers that do not reflect the beliefs and values with respect to E particular investor. Similarly, strategies that exclude certain industries and/or issuers based on specified ESG criteria may underperform strategies that do not make such exclusions. ETF risk may Because ETFs trade on a securities exchange, their shares may trade at a premium or discount to their net asset value. An ETF is subject to the risks of the assets in which it invests as well as those of the investment thesis it follows. The strategy incur brokerage costs when it buys and sells shares of an ETF and also bears its proportionate share of the ETF’s fees and expenses, which are passed through to ETF shareholders. Exchange Traded Notes (“ETNs”) risk turns y s, ets . Because ETNs are senior, unsecured, unsubordinated debt securities of an issuer (typically a bank or bank holding company), ETNs are subject to the credit risk of the issuer and may lose value due to a downgrade in the issuer’s credit rating. The re of an ETN are linked to the performance of an underlying instrument (typically an index), minus applicable fees. ETNs typicall do not make periodic interest payments and principal typically is not protected. The value of an ETN may fluctuate based on facto rs such as time to maturity, level of supply and demand for the ETN, volatility and lack of liquidity in the underlying asset changes in the applicable interest rates, and economic, legal, political, or geographic events that affect the underlying ass The strategy bears its proportionate share of any fees and expenses borne by the ETN. Because ETNs trade on a securities exchange, their shares may trade at a premium or discount to their net asset value. Focus risk y To the extent that the strategy focuses its investments in particular industries, asset classes or sectors of the economy, an market price movements, regulatory or technological changes, or economic conditions affecting companies in those industries, asse t classes or sectors will have a significant impact on the strategy’s performance. The strategy may become more focused in particular industries, asset classes or sectors of the economy as a result of changes in the valuation of the strategy’s investments or fluctuations in the strategy’s assets, and the strategy is not required to reduce such exposures under these circumstances. Focus risk – limited number of securities sks of ets, To the extent that the strategy invests in a limited number of securities, it will have a relatively large exposure to the ri each individual security and may be more volatile than a strategy that invests more broadly. The strategy may become more focused in a limited number of securities as a result of changes in the valuation of the investments or fluctuations in the ass and the strategy is not required to reduce such exposures under these circumstances. Focus risk – municipal et, ate, To the extent that the strategy focuses on investments from a single state, region or sector of the municipal securities mark its performance can be more volatile than that of a strategy that invests more broadly. As an example, factors affecting a st region, or sector such as severe fiscal difficulties, an economic downturn, court rulings, and increased expenditures on domestic security or reduced monetary support from the federal government could over time impair a state’s, regions or sector’s ab ility to repay its obligations. Focus risk – state municipal securities y can in cuses its ore The municipal securities market in general can be susceptible to increases in volatility and decreases in liquidity. Liquidit decline unpredictably in response to overall economic conditions or credit tightening. Increases in volatility and decreases liquidity may be caused by a rise in interest rates (or the expectation of a rise in interest rates). Because the strategy fo investments in state municipal securities, its performance can be more volatile than that of a strategy that invests m broadly, and it has a relatively large exposure to financial stresses affecting the single state it invests in. \ 42  Form ADV Part 2A DWS Investment Management Americas, Inc. For example, the State of California relies heavily on income tax revenues and these revenues are likely to drop during economic downturns but covering any shortfall by increasing taxes could be difficult due to California law restricting the imposition of new taxes. Examples of other factors include the costs and disruption caused by natural disasters, a fiscal crisis brought on by a national or regional economic downturn, and costs of maintaining certain government programs. California could also face sev ere fiscal difficulties, for example, from an economic downturn, increased costs for domestic security and reduced monetary support from the federal government. es, n For example, industries significant to the State of Massachusetts’ economy, such as the technology, biotech, financial servic or healthcare industries could experience downturns or fail to develop as expected, hurting the local economy. Fluctuations i unemployment levels or in the state or national economy could result in decreased tax revenues, including decreases in personal income tax, corporate business tax, or sales and use tax revenues, and other sources of revenue. Massachusetts could also face s evere fiscal difficulties, for example, an economic downturn, increased expenditures on domestic security, reduced monetary support from the federal government or costs and disruption caused by natural disasters. he A default or credit rating downgrade of a small number of municipal security issuers could affect the market values and marketability of all Massachusetts municipal securities and hurt the fund’s performance. Over time, these issues may impair t ability of the state, municipalities, or other authorities to repay their obligations or to pay debt service on those obligations and could result in a downgrade of Massachusetts’ credit rating or the ratings of authorities or political subdivisions of Massachuset ts, which may negatively impact the value of bonds issued by those entities. For example, a downturn in the financial industry could bring on a fiscal crisis in New York City, or a national or regional economic downturn could bring on such a crisis in New York State. Examples of other factors that may affect strategy performance in clude, but are not limited to, the costs and disruptions caused by national disasters, increased costs for domestic security and reduced monetary support from the federal government. Foreign investment risk -money funds. Foreign investments include certain special risks, such as unfavorable political and legal developments, limited financial information, regulatory risk, and economic and financial instability. Foreign investment risk .S. The strategy faces the risks inherent in foreign investing. Adverse political, economic, or social developments, as well as U and foreign government actions such as the imposition of tariffs, economic and trade sanctions or embargoes could undermine the value of the strategy’s foreign investments, prevent the strategy from realizing the full value of its foreign investments or prevent the strategy from selling securities it holds. -U.S. -US markets may be open on days when the e gn exchanges generally are smaller and less liquid than U.S. exchanges, buying and selling Financial reporting standards for companies based in foreign markets differ from those in the U.S. Additionally, foreign securities markets generally are smaller and less liquid than U.S. markets. To the extent that the strategy invests in non dollar denominated foreign securities, changes in currency exchange rates may affect the U.S. dollar value of foreign securities or the income or gain received on these securities. In addition, because non strategy does not price its shares, the value of the securities in the strategy’s portfolio may change on days when shareholders will not be able to purchase or sell the strategy’s shares. Foreign governments may restrict investment by foreigners, limit withdrawal of tradi ng profit or currency from the country, restrict currency exchange or seize foreign investments. The investments of the strategy may also be subject to foreign withholding taxes. Foreign brokerage commissions and other fees are generally higher than those for U.S. investments or other taxes and the transactions and custody of foreign assets may involve delays in payment, delivery or recovery of money or investments. Foreign markets can have liquidity risks beyond thos typical of U.S. markets. Because forei foreign investments can be more difficult and costly. Relatively small transactions can sometimes materially affect the price and availability of securities. In cert ain situations, it may become virtually impossible to sell an investment in an orderly fashion \ 43  Form ADV Part 2A DWS Investment Management Americas, Inc. at a price that approaches portfolio management's estimate of its value. For the same reason, it may at times be difficult to value the strategy’s foreign investments. Forward commitment risk -issued, delayed delivery or forward commitment transactions (e.g., TBAs), the strategy relies When a strategy engages in when on the counterparty to consummate the sale. Failure to do so may result in the strategy missing the opportunity to obtain a price or yield considered to be advantageous. Such transactions may also have the effect of leverage on the strategy and may cause it to be more volatile. Additionally, these transactions may create a higher portfolio turnover rate. Forward commitment risk - Municipal When the fund engages in forward or delayed delivery transactions, the fund relies on the counterparty to consummate the transaction. Failure to do so may result in the fund missing the opportunity to obtain a price or yield considered to be advantageous. Such transactions may also have the effect of leverage on the fund and may cause the fund to be more volatile. Frontier market risk Frontier market countries generally have smaller, less diverse economies and even less developed capital markets and legal, regulatory, and political systems than traditional emerging markets. Growth investing risk As a category, growth stocks may underperform value stocks (and the stock market as a whole) over any period of time and may shift in and out of favor with investors generally, sometimes rapidly, depending on changes in market, economic and other factors t hat could impact expectations of future earnings. Because the prices of growth stocks are based largely on the expectation of future earnings, growth stock prices can decline rapidly and significantly in reaction to negative news about such factors as earn ings, the economy, political developments, or other news. Health care securities risk n long -term impact, reductions in government funding and . Moreover, many health care companies are subject to product liability or When a strategy invests in companies in the health care sector, or in the wellness sector, it may be vulnerable to setbacks i those industries . Health care companies may be negatively affected by scientific or technological developments, research and development costs, increased competition within the health care industry, rapid product obsolescence and patent expirations. The price of securities of health care companies may fluctuate widely due to changes in legislation or other government regulations, in cluding uncertainty regarding health care reform and its the unpredictability of winning government approvals other litigation which may have a significant impact on a company’s market value or share price. Hedging Risk put . A on will Hedging techniques could involve a variety of derivatives, including futures contracts, exchange listed and over the counter and call options on securities, financial indices, forward foreign currency contracts, and various interest rate transactions transaction used as a hedge to reduce or eliminate losses associated with a portfolio holding or particular market that a portfolio has exposure, including currency exposure, can also reduce or eliminate gains. Hedges are sometimes subject to imperfect m atching between the hedging transaction and its reference portfolio holding or market (correlation risk), and there can be no assurance that a portfolio’s hedging transaction will be effective. In particular, the variable degree of correlati between pric e movements of hedging instruments and price movements in the position being hedged creates the possibility that losses on the hedge will be greater than gains in the value of the positions of the portfolio. Increased volatility will generally reduce the e ffectiveness of the portfolio’s currency hedging strategy. Hedging techniques involve costs, which could be significant, whether or not the hedging strategy is successful. Hedging transactions, to the extent they are implemented, not necessarily be co mpletely effective in insulating portfolios from currency or other risks. \ 44  Form ADV Part 2A DWS Investment Management Americas, Inc. High yield debt securities risk. ity to ate -grade debt securities. A real or perceived economic downturn or an increase d/or certain l and value -grade debt securities as there may be no established secondary market. Investments in high yield xperience High yield debt securities, or junk bonds, are generally regarded as speculative with respect to the issuer’s continuing abil meet principal and interest payments. High yield debt securities’ total return and yield may generally be expected to fluctu more than the total return and yield of investment in market interest rates could cause a decline in the value of high yield debt securities, result in increased redemptions an result in increased portfolio turnover, which could result in a decline in net asset value of the fund, reduce liquidity for investments and/or increase costs. High yield debt securities are often thinly traded and can be more difficult to sel accurately than investment debt securities could increase liquidity risk for the fund. In addition, the market for high yield debt securities can e sudden and sharp volatility which is generally associated more with investments in stocks. Indexing risk rs ks all e or An index strategy’s performance may not exactly replicate the performance of its target index. For example, the strategy incu fees, administrative expenses, and transaction costs that an index itself does not. The strategy also bears the costs and ris associated with buying and selling securities while such costs and risks are not factored into the return of an index. The strategy may use sampling techniques (investing in a representative selection of securities included in the index rather than sec urities in the index), or the composition of its portfolio may diverge from that of the index. Also, while the exposure of th index to its component securities is by definition 100%, the strategy’s effective exposure to index securities may be greater less than 100% and may vary over time. Because an index strategy is designed to maintain a high level of exposure to its targ index at all times, it will not take any steps to invest defensively or otherwise reduce the risk of loss during market downt et urns. Index -related risk as d An index strategy seeks to replicate, as closely as possible, before the deduction of expenses, the performance of the index published by the index provider. There is no assurance that the index provider will compile the index accurately, or that the index will be determined, composed, or calculated accurately. Market disruptions could cause delays in the index’s rebalancing schedule. During any such delay, it is possible that the index and, in turn, the strategy will deviate from the index’s state meth odology and therefore experience returns different than those that would have been achieved under a normal rebalancing schedule. Generally, the index provider does not provide any warranty, or accept any liability, with respect to the quality, accuracy or completeness of the index or its related data and does not guarantee that the index will be in line with its stated methodology. Errors in the index data, the index computations and/or the construction of the index in accordance with its stated methodology may occur from time to time and may not be identified and corrected by the index provider for a period of time or at all, which may have an adverse impact on the strategy and its shareholders. DIMA and its affiliates do not provide any warranty or guarant ee against such errors. Therefore, the gains, losses or costs associated with the index provider’s errors will generally be borne by the strategy and its shareholders. Inflation risk income ors’ sses to icy Inflation risk is the risk that the real value of certain assets or real income from investments (the value of such assets or after accounting for inflation) will be less in the future as inflation decreases the value of money. Inflation, and invest expectation of future inflation, can impact the current value of the fund's portfolio, resulting in lower asset values and lo shareholders. This risk may be elevated compared to historical market conditions and could be impacted by monetary pol measures and the current interest rate environment. Inflation -indexed bond risk -indexed bonds to decline in price, hurting the strategy’s -indexed bonds may not be fully protected from the Any actual or anticipated rise in interest rates may cause inflation performance . Interest rates in the US have been rising and may continue to increase in the near future. If interest rates rise owing to reasons other than inflation, the strategy’s investment in inflation effects of ris ing interest rates. The performance of any bonds that are indexed to non -U.S. rates of inflation may be higher or \ 45  Form ADV Part 2A DWS Investment Management Americas, Inc. ous ’s lower than those indexed to U.S. inflation rates. Inflation rates may change frequently and significantly as a result if vari factors, including unexpected shifts in the domestic or global economy or changes in fiscal or monetary policies. The client actual returns could fail to match the real rate of inflation. Infrastructure - related companies risk -related companies. Infrastructure -related companies can be nterest -related companies. Infrastructure -related her sectors or the broader market as a whole. A downturn in these sectors could have an Investment in the securities of infrastructure -related companies, and will therefore be susceptible to adverse economic, business, regulatory or other occurrences affecting infrastructure negatively affected by various factors, including general or local economic conditions and political developments, general changes in market sentiment towards infrastructure assets, high interest costs in connection with capital construction and improvement program s, difficulty in raising capital, costs associated with compliance with changes in regulations, regulation or intervention by various government authorities, including government regulation of rates, inexperience with and potential losses resulting from th e deregulation of a particular industry or sector, changes in tax laws, tariffs and trade policies, environmental problems, costs or disruptions caused by extreme weather or other natural disasters, the effects of energy conservation policies, commodities markets disruptions (e.g., significant changes over short time periods in the price of oil), technological changes, surplus capacity, casualty losses, threat of terrorist attacks and changes in interest rates. Rising i rates could lead to higher fin ancing costs and reduced earnings for infrastructure companies may be focused in the energy, industrials and utilities sectors. At times, the performance of securities in these sectors may lag the performance of ot adverse impact. Interest rate strategies risk The success of the interest rate futures strategies depends, in part, on the effectiveness and implementation of portfolio management’s proprietary models. If portfolio management’s analysis proves to be incorrect, losses to the strategy may be significant . The risk of loss is heightened during periods of rapid rises in interest rates. Interest rate risk ies, the all in value C hanges in monetary policy made by central b anks the When interest rates rise, prices of debt securities generally decline. The longer the duration of the strategy’s debt securit more sensitive the strategy will be to interest rate changes. (As a general rule, a 1% rise in interest rates means a 1% f for every year of duration.) Interest rates can change in response to the supply and demand for credit, government and/or central bank monetary policy and action, inflation rates, and other factors. or governments are likely to affect the level of interest rates. Changing interest rates may have unpredictable effects on markets, may result in heightened market volatility and potential illiquidity and may detract from performance to the extent strategy is exposed to such interest rates and/or volatility. Rising interest rates could cause the value of the strategy’s investments — and therefore its share price as well — to decline. A rising interest rate environment may cause investors to move out of fixed -income securities and related markets on a large scale, which could adversely affect the price and liquidity of such securities and could also result in increased redemptions from the strategy, increased redemptions may force the strategy to sel l investments at a time when it is not advantageous to do so, which could result in losses. Interest rate risk (money market) -income securities and related markets on a large scale, which could adversely affect the lt . long ed -income and related markets may experience Rising interest rates could cause the value of the strategy’s investments to decline. A rising interest rate environment may cause investors to move out of fixed price and liquidity of such securities and could also result in increased redemptions from the strategy. Increased redemptions from the strategy may force the strategy to sell investments at a time when it is not advantageous to do so, which could resu in los ses. Beginning in 2022, the US Federal Reserve ("Fed") raised interest rates significantly in response to increased inflation It is unclear if and when the Fed may begin to implement interest rate cuts, if rates will remain at current levels for a pro period or, if the Fed deems necessary in response to certain economic developments such as a turnaround in the decline of inflation, the Fed may consider additional rate increases. As a result, fixed heightened levels of risk and impair the strategy’s ability to maintain a stable $1.00 share price. Conversely, any decline in \ 46  Form ADV Part 2A DWS Investment Management Americas, Inc. ates, the om uld ates. ity. interest rates is likely to cause the strategy’s yield to decline, and during periods of unusually low or negative interest r strategy’s yield may approach or fall below zero. A low or negative interest rate environment may prevent the strategy fr providing a positive yield. Over time, the total return of money market securities may not keep pace with inflation, which wo result in a net loss of purchasing power for long -term investors. Interest rates can change in response to the supply and demand for credit, government and/or central bank monetary policy and action, inflation rates, and other factors. Recent and potential future changes in monetary policy made by central banks or governments are likely to affect the level of interest r Ch anging interest rates may have unpredictable effects on markets, may result in heightened market volatility and potential illiquidity and may detract from fund performance to the extent the strategy is exposed to such interest rates and/or volatil Money market funds try to minimize interest rate risk by purchasing short -term securities. -neutral portfolio, either growth or value strategies may outperform the strat- Investment style risk To the extent that the strategy maintains a style egy during any time period when one or the other is in favor. To the extent that the strategy favors either growth or value stock s, it may perform less well than if it had remained style -neutral if the style it favors underperforms the overall market. r s IPO risk. Prices of securities bought in an initial public offering (IPO) may rise and fall rapidly, often because of investo perceptions rather than economic reasons. To the extent a client’s investment is relatively small in size, its IPO investment ma y have a significant impact on its performance since they may represent a larger proportion of the strategy’s overall. Large -sized companies risk -sized companies to -managed smaller and medium -sized companies. During Returns on investments in securities of large companies could trail the returns on investments in securities of smaller and medium -sized companies. Larger companies may be unable to respond as quickly as smaller and medium competitive ch allenges or to changes in business, product, financial or other market conditions. Larger companies may not be able to maintain growth at the high rates that may be achieved by well different market cycles , the performance of large -capitalization companies has trailed the overall performance of the broader securities markets. Latin America risk tes, or the U.S. The economies of Latin American countries have in the past experienced considerable difficulties, including high inflation ra high interest rates, high unemployment, government overspending and political instability. Similar conditions in the present future could impact the strategy’s performance. Many Latin American countries are highly reliant on the exportation of commodities and their economies may be significantly impacted by fluctuations in commodity prices and the global demand for certain com modities, as well as the trade policies of their trading partners. Investments in Latin American countries may be subject to currency risks, such as restrictions on the flow of money in and out of a country, extreme volatility relative to dollar, and devaluation, all of which could decrease the value of the strategy. Other Latin American investment risks may include inadequate investor protection, less developed regulatory, accounting, auditing and financial standards, unfavorable changes in laws o r regulations, natural disasters, corruption, and military activity. The governments of many Latin American countries may also exercise substantial influence over many aspects of the private sector, and any such exercise could have a significant effect on companies in which the strategy invests. Liquidity and transaction risk general t a ity and The liquidity of portfolio securities can deteriorate rapidly due to credit events affecting issuers or guarantors or due to market conditions and a lack of willing buyers. When there are no willing buyers and an instrument cannot be readily sold a desired time or price, the strategy may have to accept a lower price or may not be able to sell the instrument at all. The potential for liquidity risk may be magnified by a rising interest rate environment or other circumstances where investor redempt ions from money market funds may be higher than normal, potentially causing increased supply in the market due to selling activity. If dealer capacity in debt instruments is insufficient for market conditions, it may further inhibit liquid increase volatility in the debt markets. Additionally, market participants other than the portfolio may attempt to sell debt holdings at the same time as the portfolio, which could cause downward pricing pressure and contribute to illiquidity. An \ 47  Form ADV Part 2A DWS Investment Management Americas, Inc. inability to sell one or more portfolio securities can prevent the strategy from being able to take advantage of other investment opportunities. Unusual market conditions, an unusually high volume of redemption requests, or other similar conditions, could cause the strategy to be unable to pay redemption proceeds within a short period of time. f the -sell Certain shareholders, including DIMA’s clients or affiliates, may from time to time own or control a significant percentage o strategy’s shares. These shareholders may include, for example, institutional investors and other shareholders whose buy decisions; are controlled by a single decision maker. Redemptions by these shareholders, or a high volume of redemption requests generally, may further increase the strategy’s liquidity risk. Liquidity risk (For s senior for In certain situations, it may be difficult or impossible to sell an investment in an orderly fashion at an acceptable price. senior loans: No active trading market may exist for some senior loans and certain senior loans may be subject to restriction on resale. The inability to dispose of senior loans in a timely fashion could result in losses to the strategy. Because some loans that the strategy invests in have a limited secondary market, liquidity risk is more pronounced for the strategy than strategy’s that invest primarily in equity securities.) Machine learning risk sufficient, of poor quality, or contain biased information. Although DIMA obtains data and y these sources. While the algorithm is a component in identifying potential For strategies where DIMA utilizes a proprietary algorithm that employes machine learning, any changes to an algorithm or underlying assumptions may have unintended consequences, which could have an adverse effect on the performance of any strategy that em ployes such algorithm. Algorithms may not perform as intended for a variety of reasons, including, but not limited to, incorrect assumptions, changes in the market and changes to data inputs. In addition, the datasets that the algorithm processes may be in information from third party sources that it considers to be reliable, DIMA does not guarantee the accuracy and/or completeness of any data or information provided b securities for investment, the machine learning algorithms employed by DIMA’s strategies do not directly select securities or make trades . All security selection decisions are mad e by a portfolio manager. Market disruption risk tariffs, extreme weather events, and natural disasters. Such supply chain disruptions can lead -reaching effects on financial markets worldwide. The value y adverse changes in overall economic or market conditions, such as the level of s eld by the strategy. In addition, geopolitical and other globally tainty or financial crises, contagion, tariffs and trade the vestments. Ongoing trade disputes between the d ding partners, as well as financial Economies and financial markets throughout the world have become increasingly interconnected, which has increased the likelihood that events or conditions in one country or region will adversely impact markets or issuers in other countries or regions. This includes reliance on global supply chains that are susceptible to disruptions resulting from, among other things, war and other armed conflicts, to, and have led to, economic and market disruptions that have far of investments may be negatively affected b economic activity and productivity, unemployment and labor force participation rates, inflation or deflation (and expectation for inflation or deflation), interest rates, dem and and supply for particular products or resources including labor, debt levels and credit ratings, and trade policies, among other factors. Such adverse conditions may contribute to an overall economic contraction across entire economies or markets, which may negatively impact the profitability of issuers operating in those economies or markets, including the investments h interconnected occurrences, including war, terrorism, economic uncer disputes, government debt crises (including defaults or downgrades) or uncertainty about government debt payments, public health crises, natural disasters, supply chain disruptions, climate change and related events or conditions have led, and in future may lead, to disruptions in the US and world economies and markets, which may increase financial market volatility and have significant adverse direct or indirect effects on the strategy and its in United States and other countries may lead to tariffs and investment restrictions, negatively impacting affected companies an their securities. These disputes can also harm the economies of the United States and its tra markets overall. Adverse market conditions or disruptions could cause the strategy to lose money, experience significant \ 48  Form ADV Part 2A DWS Investment Management Americas, Inc. redemptions, and encounter operational difficulties. Although multiple asset classes may be affected by adverse market conditions or a particular market disruption, the duration and effects may not be the same for all types of assets. ch s and Current military and other armed conflicts in various geographic regions, including those in Europe and the Middle East, can lead to, and have led to, economic and market disruptions, which may not be limited to the geographic region in which the conflict is occurring. Such conflicts can also result, and have resulted in some cases, in sanctions being levied by the United States, the European Union and/or other countries against countries or other actors involved in the conflict. In addition, su conflicts and related sanctions can adversely affect regional and global energy, commodities, financial and other markets and thus could affect the value of the strategy's investments. The extent and duration of any military conflict, related sanction resultin g economic and market disruptions are impossible to predict but could be substantial. -19, which -19 is no longer considered to be a viruses . In addition, markets are becoming increasingly susceptible to disruption events resulting from the -attacks or to take over the websites and/or social media accounts of or public officials, or to otherwise pose as or impersonate such, which then may be used to Other market disruption events include pandemic spread of viruses, such as the novel coronavirus known as COVID at times has caused significant uncertainty, market volatility, decreased economic and other activity, increased government activity, including economic stimulus measures, and supply chain disruptions. While COVID public health emergency, the strategy's investments may be adversely affected by lingering effects of this virus or future pandemic spread of use of new and emerging technologies to engage in cyber companies, governmental entities disseminate false or misleading information that can cause volatility in financial markets or for the stock of a particular company, group of companies, industry or other class of assets. osses Adverse market conditions or particular market disruptions, such as those discussed above, may magnify the impact of other risks and may increase volatility in one or more markets in which the strategy invests leading to the potential for greater l for the strategy. Market risk Although individual securities may outperform the market, the entire market may decline as a result of rising interest rates, regulatory developments or deteriorating economic conditions. Market risk – municipals Deteriorating market conditions might cause a general weakness in the market that reduces the prices of securities in that market. Developments in a particular class of debt securities or the stock market could also adversely affect the strategy by reducin g the relative attractiveness of debt securities as an investment. Also, to the extent that the strategy emphasizes debt securities from any given state or region, it could be hurt if that state or region does not do well. Medium -sized company risk -sized companies are less widely . Industry -wide reversals may have a greater -sized company Medium -sized company stocks tend to be more volatile than large company stocks. Medium followed by stock analysts and less information about them is available to investors impact on medium -sized companies, since they may lack the financial resources of larger companies. Medium stocks are typically less liquid than large company stocks. Money market fund risk DIMA determines a liquidity fee is in the strategy’s best interest. You could lose money by investing in the strategy. Because the share price of the strategy will fluctuate, when you sell your shares, they may be worth more or less than what you originally paid for them. The strategy may impose a discretionary liquidity f ee (not exceed 2%) upon t redemption of shares if DIMA may impose such a fee in times of market stress, impaired liquidity of the strategy’s investments or in other circumstances . A liquid ity fee would reduce the amount a shareholder receives upon redemption of shares. An investment in the strategy is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. The \ 49  Form ADV Part 2A DWS Investment Management Americas, Inc. strategy’s sponsor has no legal obligation to provide financial support to the strategy, and you should not expect that the sponsor will provide financial support to the strategy at any time. Money market risk led with An investment in the strategy is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the strategy generally seeks to preserve the value of a client’s investment, it isn’t guaranteed, and a client could lose money. The credit quality of the strategy’s holdings can change rapidly in certain markets, and the default of a single holding could cause the value of the client’s portfolio to decline. If the client’s investment is comming other inves tors, redemptions could have a significant, adverse effect on the portfolio. DIMA and its affiliates have no legal obligation to provide financial support to a money market product and you should not expect that it will provide financial support at any tim e. Mortgage -backed and other asset -backed securities risk se, the market values of mortgage -backed securities generally decline. At the trategy. Conversely, when market interest rates decline, the market values of mortgage -backed he increase, which shortens the effective duration of these securities and may expose the -backed securities, and in particular those not backed by a at underlying borrowers will be unable to meet their obligations and the value These securities represent interests in “pools” of mortgages or other assets such as consumer loans or receivables held in trust and often involve risks that are different from or possibly more acute than risks associated with other types of debt instruments. When market interest rates increa same time, however, increased rates typically cause mortgage refinancing and prepayments slow, which lengthens the effective duration of th ese securities. As a result, the negative effect of an interest rate increase on the market value of mortgage -backed securities is usually more pronounced than it is for other types of fixed income securities, potentially increasing the volatility of the s securities generally increase. However, as mortgage holders seek to refinance at the lower rates, the rate of prepayment of t underlying mortgages also tends to strategy to a lower rate of return on reinvestment. Mortgage government guarantee, are subject to the risk th of property that secures the mortgage may decline in value and be insufficient, upon foreclosure, to repay the associated loa n. -backed securities are subject to risks similar to those associated with mortgage -backed securities, and Investments in other asset as well as additional risks associated with the nature of the assets and the servicing of those assets. Payment of principal interest on asset -backed securities may be largely dependent upon the cash flows generated by the assets backing the securities, and asset -backed securities may not have the benefit of any security interest in the related assets. Multi-manager risk -advisors are intended to be complementary, they may not in -advisors may result in -advisors -advisors that could have been selected for the -manager approach could increase the strategy’s portfolio turnover rate which may result in higher levels of locating assets to those sub -advisers and the skill of the sub -advisers in executing the relevant While the investment strategies employed by the strategy’s sub fact be complementary. The interplay of the various strategies employed by the strategy’s multiple sub the stra tegy holding a significant amount of certain types of securities. This may be beneficial or detrimental to the strategy’s performance depending upon the performance of those securities and the overall economic environment. The sub selected for the strategy may underperform the market generally or other sub strategy. The multi realized capital gai ns or losses with respect to the strategy’s portfolio securities, higher brokerage commissions and other transaction costs. The success of the strategy’s investment strategy depends on, among other things, both DIMA’s skill in selecting sub -advisers and al investment strategy and selecting investments for the strategy. The degree of correlation among the various investment strategies of the sub -advisers and the market as a whole will vary as a result of market conditions and other factors, and certain sub - advisers could have a greater degree of correlation with each other and with the market than other sub -advisers. Municipal securities risk Municipal instruments may be susceptible to periods of economic stress, which could affect the market values and marketability of many or all municipal obligations of issuers in a state, US territory, or possession. The strategy could als o be \ 50  Form ADV Part 2A DWS Investment Management Americas, Inc. ments, overall st ack ed -exempt income to investors. te flooding, and fires. Climate risks, if they materialize, can adversely impact a municipal impacted by events in the municipal securities market, including the supply and demand for municipal securities. Negative events, such as severe fiscal difficulties, an economic downturn, unfavorable legislation, court rulings or political develop or reduced monetary support from the federal government, could hurt strategy’s performance. The municipal securities market can be susceptible to increases in volatility and decreases in liquidity. Liquidity can decline unpredictably in response to economic conditions or credit tightening. Increases in volatility and decreases in liquidity may be caused by a rise in intere rates (or the expectation of a rise in interest rates). Municipal securities may include revenue bonds, which are generally b by revenue from a specific project or tax. The issuer of a revenue bond makes interest and principal payments from revenues generated from a particular source or facility, such as a tax on particular property or revenues generated from a municipal water or sewer utility or an airport. Revenue bonds generally are not backed by the full faith and credit and general taxing power of the issuer. The value of municipal securities is strongly influenced by the value of tax Changes in tax and other laws, including changes to individual or corporate tax rates, could alter the attractiveness and overall demand for municipal securities. Municipal securities may also have exposure to potential physical risks resulting from clima change, including extreme weather, issuer’s financial plans in current or future years or may impair a facility or other source generating revenues backing a municipal issuer’s revenue bonds. As a result, the i mpact of climate risks may adversely impact the value of the strategy. Municipal trust receipts (“MTRs”) risk te sen ted d The strategy’s investment in MTRs is subject to similar risks as other investments in debt obligations, including interest ra risk, credit risk and security selection risk. Additionally, investments in MTRs raise certain tax issues that may not be pre by direct investments in municipal securities. There is some risk that certain issues could be resolved in a manner that coul adversely impact the performance of the strategy. Non -diversification risk The strategy invests in securities of relatively a few issuers. Thus, the performance of one or a small number of portfolio holdings can affect overall performance. Operational and technology risk by sses -attacks, n, Cyber -attacks, disruptions, or failures that affect the strategy’s service providers or counterparties, issuers of securities held the strategy, or other market participants may adversely affect the strategy and its shareholders, including by causing lo for the strategy or impairing its operations. For example, the strategy’s or its service providers’ assets or sensitive or confidential information may be misappropriated, data may be corrupted, and operations may be disrupted (e.g., cyber operational failures or broader disruptions may cause the release of private shareholder information or confidential informatio interfere with the processing of shareholder transactions, impact the ability to calculate the net asset value and impede tradin g). Market events and disruptions also may trigger a volume of transactions that overloads current information technology and communication systems and processes, impacting the ability to conduct the strategy’s operations. -attacks, disruptions or failures, there are inherent limitations in such plans and or While the strategy and its service providers may establish business continuity and other plans and processes that seek to address the possibility of and fallout from cyber systems, including that they do not apply to third parties, such as counterparties, issuers of securities held by the strategy other market participants, as well as the possibility that certain risks have not been identified or that unknown threats may emerge in the future and there is no assurance that such plans and processes will be effective. Among other situations, disruptions (for example, pandemics or health crises) that cause prolonged periods of remote work or significant employee absences at the strategy’s service providers could impact the ability to conduct the strategy’s operations. In addition, the strategy cannot directly control any cybersecurity plans and systems put in place by its service providers, strategy counterparties, issuers of se curities held by the strategy or other market participants. \ 51  Form ADV Part 2A DWS Investment Management Americas, Inc. Passive investing risk its. steps Unlike a strategy that is actively managed, in which portfolio management buys and sells securities based on research and analysis, the strategy invests in securities included in, or representative of, the index, regardless of their investment mer Beca use the strategy is designed to maintain a high level of exposure to the index at all times, portfolio management generally will not buy or sell a security unless the security is added or removed, respectively, from the index, and will not take any to invest defensively or otherwise reduce the risk of loss during market downturns. Preferred stock risk ties, on on Preferred stock generally has a preference as to dividends and liquidation over an issuer’s common stock but ranks junior to debt securities in an issuer’s capital structure. Preferred stock is subject to many of the risks associated with debt securi including interest rate risk. In addition, preferred stock may not pay a dividend, an issuer may suspend payment of dividends preferred stock at any time, and in certain situations an issuer may call or redeem its preferred stock or convert it to comm stock. Prepayment and extension risk isk), changes or unexpected behavior in interest rates could increase the volatility of the When interest rates fall, issuers of high interest debt obligations may pay off the debts earlier than expected (prepayment r and the strategy may have to reinvest the proceeds at lower yields. When interest rates rise, issuers of lower interest debt obligations may pay off the debts later than expected (extension risk), thus keeping the strategy’s assets tied up in lower interest debt obligations. Ultimately, any strategy’s yield and could hurt performance. Prepayments could also create capital gains tax liability in some instances. Pricing risk e and thus sell a security for its full If market conditions make it difficult to value some investments, DIMA may internally value these investments using more subjective methods, and the value determined for an investment may be materially different from the value realized upon such investment’s sale. Secondary markets may be subject to irregular trading activity, wide bid/ask spreads, and extended trade settlement periods, which may prevent the strategy from being able to realize full valu valuation. Private activity and industrial development bond risk eet The payment of principal and interest on these bonds is generally dependent solely on the ability of the facility’s user to m its financial obligations and the pledge, if any, of property financed as security for such payment. Quantitative model risk . The h The strategy relies heavily on quantitative models and the analysis of specific metrics to construct the strategy’s portfolio impact of these metrics on a stock’s performance can be difficult to predict, and stocks that previously possessed certain desirable quantitative characteristics may not continue to demonstrate those same characteristics in the future. In addition, relying on quantitative models entails the risk that the models themselves may be limited or incorrect, that the data on whic the m odels rely may be incorrect or incomplete, and that DIMA may not be successful in selecting companies for investment or determining the weighting of particular stocks in the strategy’s portfolio. Any of these factors could cause the strategy to underperfor m similar strategies that do not select stocks based on quantitative analysis. Real estate securities risk in real The value of real estate securities in general, and REITs in particular, are subject to the same risks as direct investments estate and will depend on the value of the underlying properties or the underlying loans or interest. The value of these se curities will rise and fall in response to many factors, including economic conditions, the demand for rental property and changes in interest rates. In particular, the value of these securities may decline when interest rates rise and will also be affecte d by the real estate market and by the management of the underlying properties. In addition, real estate values have \ 52  Form ADV Part 2A DWS Investment Management Americas, Inc. regional, and national basis in the past and may continue to be to rest rates may also mean that financing for property . Further, real estate companies may be negatively impacted ve regional, and national basis in the past and may continue to be /or an been subject to substantial fluctuations and declines on a local, in the future. During periods of rising interest rates, real estate securities may lose appeal for investors who may be able obtain higher yields from other income -producing investments. Rising inte purchases and improvements is more costly and difficult to obtain by liabilities or losses due to environmental problems, extreme weather or natural disasters. In addition, real estate values ha been subject to substantial fluctuations and declines on a local, in the future. Highly leveraged real estate companies are particularly vulnerable to the effects of rising interest rates and economic downturn. REITs may be more volatile and/or more illiquid th an other types of equity securities. Regional focus risk d hey Focusing investments in a single country or few countries, or regions, involves increased currency, political, regulatory, an other risks. Market swings in such a targeted country or region will be likely to have a greater effect on performance than t would in a more geographically diversified strategy. Repurchase agreement risk -upon time and If the party that sells the securities to the strategy defaults on its obligation to repurchase them at the agreed price, the client could lose money. Restricted securities risk . The security, and it may be more difficult to determine a market value for a restricted The strategy may purchase securities that are subject to legal or contractual restriction on resale ("restricted securities") strategy may be unable to sell a restricted security. This investment practice, therefore, could increase the level of illiquidity of the strategy. Risks of holding cash e The strategy will at times hold cash positions, which may hurt the strategy’s performance. Cash positions may also subject th strategy to additional risks and costs, including any fees imposed by the strategy’s custodian for large cash balances. Securities lending risk ategy’ s eeds of tegy could the the Securities lending involves the risk that the strategy may lose money because the borrower of the loaned securities fails to return the securities in a timely manner or at all. A delay in the recovery of loaned securities could interfere with the str ability to vote proxies or settle transactions. Delayed settlement may limit the ability of the strategy to reinvest the proc a sale of securities or prevent the strategy from selling securities at times and prices it considers desirable. The stra also lose money in the event of a decline in the value of the collateral provided for the loaned securities, or a decline in value of any investments made with cash collateral or even a loss of rights in the collateral should the borrower of securities fail financially while holding the securities. Security selection risk (money market) Although short -term securities are relatively stable investments, it is possible that the securities in which the strategy invests will not perform as expected. This could cause the client’s returns to lag behind those of similar money market investments. Security selection risk (non -money market) , among sustainability risks, the relative attractiveness of different The securities in the client’s portfolio may decline in value. Portfolio management could be wrong in its analysis of others, municipalities, industries, companies, economic trends, securities or other matters. Senior loans risk Senior loans are not rated by a rating agency, registered with the US Securities and Exchange Commission or any state securities commission or listed on any national securities exchange. Therefore, there may be less publicly available informat ion \ 53  Form ADV Part 2A DWS Investment Management Americas, Inc. -public information regarding the borrower to which other about them than for registered or exchange -listed securities. Also, because portfolio management relies mainly on its own evaluation of the creditworthiness of borrowers, the strategy is particularly dependent on portfolio management’s analytical abilities . Senior loans involve other risks described elsewhere in this Form ADV, including conflict of interest risk, credit risk, interest rate risk, liquidity risk, and prepayment and extension risk. Because DIMA may wish to invest in the publicly traded securit ies of a borrower, it may not have access to material non lenders have access. Small company risk -wide reversals may have a greater impact on small Small company stocks tend to be more volatile than large company stocks. Small companies are less widely followed by stock analysts and less information about them is available to investors. Industry compan ies, since they lack the financial resources of larger companies. Small company stocks are typically less liquid than large company stocks. Stock market risk and returns on such securities may drop precipitously. To the extent the strategy invests in When stock prices fall, you should expect the value of your investment to fall as well. Stock prices can be hurt by poor management on the part of the stock’s issuer, shrinking product demand and other business risks. These may affect single companies as w ell as groups of companies. In addition, movements in financial markets may adversely affect a stock’s price, regardless of how well the company performs. The market as a whole may not favor the types of investments the strategy makes, which could affect t he ability to sell them at an attractive price. To the extent that the strategy invests in a particular geographic region, capitalization or sector, client’s performance will be affected by that region’s general performance. High market volatility may also result from significant shifts in momentum of one or more specific stocks due to unusual increases or decreases in trading activity. Momentum can change quickly, and securities subject to shifts in momentum may be more volatile than the market as a whole a particular capitalization or market sector, performance may be affected by the general performance of that region, capitalization, or sector. Strategy risk The securities in the fund’s portfolio may decline in value. Portfolio management could be wrong in its analysis of sectors, industries, companies, economic trends, ESG risks and opportunities, the relative attractiveness of different sectors and industrie s, or other matters. Subsidiary risk 0. The strategy may invest in the Subsidiary, which is not registered as an investment company under the Investment Company Act of 1940, as amended, and therefore is not subject to all of the investor protections of the Investment Company Act of 194 A chang e in the US or the Cayman Islands laws or regulations, under which the strategy and the Subsidiary, respectively, are organized, that impacts the Subsidiary or how the strategy invests in the Subsidiary, such as a change in tax law, could adversely affect the strategy. By investing in the Subsidiary, the strategy is exposed to the risks associated with the Subsidiary’s investments, which generally include the risks of investing in derivatives and commodities -related investments. Tax risk -linked derivatives generally do not constitute “qualifying income” Income and gains from commodities and certain commodity to the client. If such income were not to constitute qualifying income, the client might be subject to additional taxes. Technology sector risk will concentrate in the group of industries cy changes, and other occurrences The strategy investing in common stocks of science and technology companies and constituting the technology sector and may concentrate in one or more industries in the technology sector. The strategy will therefore be susceptible to adverse economic, business, government regulatory and poli affecting the technology sector and science and technology companies. In particular, science and technology companies are \ 54  Form ADV Part 2A DWS Investment Management Americas, Inc. aggressive pricing of products and services, new market entrants and dependency on patent vulnerable to market saturation and rapid product obsolescence. Many science and technology companies operate under constantly changing fields and have limited business lines and limited financial resources, making them highly vulnerable to business and ec onomic risks. Other investment risks associated with investing in science and technology securities include abrupt or erratic market movements, management that is dependent on a limited number of people, short product cycles, changing consumer preferences, protection. Tender option bonds (“TOB”) risk der ent rs, decrease The strategy’s participation in tender option bond transactions may reduce the strategy’s returns or increase volatility. Ten option bond transactions create leverage. Leverage magnifies returns, both positive and negative, and risk by magnifying the volatility of returns. An investment in TOB Inverse Floater Residual Interests will typically involve more risk than an investm in the underlying municipal bonds. The interest payment on TOB Inverse Floater Residual Interests generally will decrease when short -term interest rates increase. There are also risks associated with the tender option bond structure, which could result in terminating the trust. If a TOB Trust is terminated, the strategy must sell other assets to buy back the TOB Floate which co uld negatively impact performance. Events that could cause a termination of the TOB Trust include a deterioration in the financial condition of the liquidity provider, a deterioration in the credit quality of underlying municipal bonds, or a in th e value of the underlying bonds due to rising interest rates. Tracking error risk The in the lue d tax purposes , the strategy may sell certain The strategy may be subject to tracking error, which is the divergence of the strategy’s performance from that of the index. performance of the strategy may diverge from that of in the index for a number of reasons, including operating expenses, transa ction costs, cash flows and operational inefficiencies. The strategy’s return also may diverge from the return of the underlying index for the strategy (Underling Index) because the strategy bears the costs and risks associated with buying and selling secu rities (especially when rebalancing the strategy’s securities holdings to reflect changes in the index) while such costs and risks are not factored into the return of the index. Market disruptions and regulatory restrictions could have an adverse effect on the strategy’s ability to adjust its exposure to the required levels in order to track the index. To the extent the portfolio management uses a representative sampling approach (investing in a representative selection of securities included the Underly ing Index rather than all securities in the index) such approach may cause the strategy’s return to not be as well correlated with the return of the index as would be the case if the strategy purchased all of the securities in the index in proportions represented in the Underlying Index. In addition, the strategy may not be able to invest in certain securities included in the index or invest in them in the exact proportions in which they are represented in the index, due to legal restrictions or limitat ions imposed by the governments of certain countries, a lack of liquidity in the markets in which such securities trade, potential adverse tax consequences or other reasons. To the extent the strategy calculates its net asset va based on fair value pric es and the value of the index is based on market prices (i.e., the value of the index is not based on fair value prices), the strategy’s ability to track the index may be adversely affected. Tracking error risk may also be heightene during times of increa sed market volatility or other unusual market conditions. For securities, and such sale may cause the strategy to recognize a taxable gain or a loss and deviate from the performance of index. In light of the factors discussed above, the strategy’s return may deviate significantly from the return of the index. US g overnment default risk at . Such a credit event may adversely impact the Due to the rising US government debt burden and potential limitations caused by the statutory debt ceiling, it is possible th the US government may not be able to meet its financial obligations or that securities issued by the US government may experienc e credit downgrades. In the past, US sovereign credit has experienced downgrades and there can be no guarantee that it will not experience further downgrades in the future by rating agencies financial markets a nd the fund. From time to time, uncertainty regarding the status of negotiations in the US government to increase the statutory debt ceiling and/or failure to increase the statutory debt ceiling could increase the risk that the US government may default on payments on certain US government securities, cause the credit rating of the US government to be \ 55  Form ADV Part 2A DWS Investment Management Americas, Inc. ies downgraded or increase volatility in financial markets, result in higher interest rates, reduce prices of US Treasury securit and/or increase the costs of certain kinds of debt. U.S. territory and Commonwealth obligations risk s may negatively affect Adverse political and economic conditions and developments affecting any territory or Commonwealth of the U.S. may, in turn, Puerto Rico in the recent past has negatively affect the value of the strategy’s holdings in such obligations. For example, experienced significant fiscal and economic crises, including major debt restructurings of certain issuers of Puerto Rico municipal instruments, and any adverse developments in Puerto Rico's fiscal and economic condition the value of the f und's holdings in Puerto Rico municipal obligations. Underlying funds risk the Because the strategy invests in underlying funds, the strategy’s relative performance is affected by the performance of the underlying funds. Because the strategy may invest in a few underlying funds, the performance of a small number of underlying funds c ould affect overall performance. The strategy also indirectly pays a portion of the expenses of the underlying funds, which lowers the strategy’s returns. Allocations to underlying funds with higher expenses will cause the overall expenses of strategy to be higher. Value investing risk in market , economic and As a category, value stocks may underperform growth stocks (and the stock market as a whole) over any period of time and may shift in and out of favor with investors generally, sometimes rapidly, depending on changes other factors. In addition, value stocks selected for investment by portfolio management may not perform as anticipated. When-issued and delayed delivery securities risk. Certain investment strategies may involve the purchase or sell of a security at a future date for a predetermined price. There is risk that the market value of the securities may change before delivery. Other Risk Factors In addition to the risk described above, the following risk s are applicable to all strategies. Banking Laws and Regulations -U.S. banking laws and regulations. By virtue of DWS’s co -investment or seed positions in regulations, among other things, impose restrictions on the types and amounts of investments that a Due to Deutsche Bank AG’s (“DBAG”) majority shareholding, DWS and its subsidiaries, including DIMA, remain subject to a broad array of U.S. and certain non certain funds advised by DIMA, these funds may become subject to the banking laws and regulations that are applicable to DBAG. Such laws and fund may make, the types o f activities in which the fund may engage and the amount of influence and control DIMA or the fund may have over the operations of the underlying investments. ng -Frank Act”) included s ,” which or and Under the U.S. Bank Holding Company Act of 1956, as amended (“BHCA”), if a fund were deemed to be controlled by DIMA or an affiliate, the fund may be subject to the same limitations under the BHCA that applies to DBAG and its affiliates, includi DIMA. Additionally, the Dodd -Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd significant alterations to the regulations applicable to financial institutions and investment advisers including DIMA and it affiliates, as well as the Advisory Accounts DIMA sponsors and manages. Among other requirements, the “Volcker Rule came into full effect on July 21, 2017, limits the ability of banking entities and their affiliates, including DIMA, to spons invest in, and in some cases serve as investment manager of Advisory Accounts. in -to-day management of a target company or holding periods of the underlyin g n As a result of these laws and regulations, DWS may be subject to restrictions that could limit an advised fund’s investments third parties or its ability to be involved in the day investments. DBAG or its affiliates may not be permitted to extend credit to or enter into financing arrangements with certai funds advised by DIMA due to the Volcker Rule and/or other banking regulations. Certain bank regulatory limits may apply to \ 56  Form ADV Part 2A DWS Investment Management Americas, Inc. DBAG, and funds advised by DIMA on an aggregate basis, and the size of DWS’s and DWS personnel’s ownership interest in, as well as DWS’s seed contributions to, funds advised by DIMA may be limited by the Volcker Rule. Other DWS personnel may be prohibited from obtaining or retaining interests in such funds. Additionally, some otherwise appropriate investments may not be available to, or may need to be unprofitably disposed of by, funds advised by DIMA. -Frank Act and comparable European laws and regulations relating to the Other final regulations adopted under the Dodd regulation of swaps and derivatives will continue to impact the manner by which DIMA and its Advisory Accounts and trade swaps and other d erivatives and may increase the costs of derivatives trading. Overall, regulatory reforms, together with increased regulatory scrutiny more generally, including ESG and other reforms have had and continue to have a significant impact on executing and/or may impact adversely DIMA’s investment strategies. They may resu lt in increased planning uncertainty, a higher cost base or higher capital demands, and hence may significantly affect DWS’s business model, financial condition, and results of operations as well as the competitive environment generally. As regulatory guid ance and industry standards evolve, regulations like the Volcker Rule could pose other potential risks for DWS, and while DWS attempts to limit the impact of such regulations on the funds they advise, DWS’s regulatory requirements may conflict with the int erests of clients, which may be adversely affected by any such actions. Cybersecurity risk The computer systems, networks and devices used by DIMA and its service providers to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and tele communication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity br each. , Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes or we bsite access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses; interference with DIMA’s ability to calculate the value of an investment in a client account; impediments to trading; inability to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. ts; In Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client inves counterparties with which a Client engages in transactions; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, insurance companies, and other financial institutions; and other parties. addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity security breaches in the future. Economic Sanction Laws r ces Act -boycott regulations, may also apply to, and restrict -corruption, anti -bribery and anti -boycott d regulations. As a result, DIMA may be adversely affected because of its unwillingness to Economic sanction laws in the United States and other jurisdictions or other governmental action may significantly restrict o completely prohibit DIMA and investment Advisory Accounts from investing or continuing to hold an investment in, or transacting w ith or in certain countries, individuals, and companies, including, among other things, transactions with, and the provision of services to certain foreign countries, territories, in entities and individuals. The U.S. Foreign Corrupt Practi (the “FC PA ”) and other anti -corruption laws and regulations, as well as anti the activities of DIMA and investment Advisory Accounts (and their respective portfolio companies). DIMA seeks to comply with economic an d trade sanctions laws and regulations, the FCPA, and other anti laws and regulations to which it is subject and has implemented policies and procedures reasonably designed to ensure compliance with such laws an participate in transactions that may violate such laws or regulations. \ 57  Form ADV Part 2A DWS Investment Management Americas, Inc. Sustainability and ESG -Related Risks This can either represent a risk on its own or have . For l climate risks, that could materialize as eit her -term impacts of climatic conditions so far as investments into securities are f ability risks and an event or condition ble Sustainability and ESG -related Risks refer to an event or condition, that, if it occurs, could potentially or actually cause a negative material impact on the value of the investments selected for clients. an impact on other risks and contribute significantly to the risk, such as market risks, liquidity risks or operational risks example, real estate assets could be severely damaged or destroyed by physica singular extreme weather events (for example floods, storms, and wildfires) or through long (such as precipitation frequency, weather instability and rise of sea levels). In considered, sustainability risks may have a negative impact on the market price of these investments and thus on the return o the portfolio, e.g., if issuers were to underestimate or fail to adequately assess sustain were to occur adversely affecting the market price of their securities. In addition, reputational risks, caused by unsustaina acts of an issuer, could also adversely affect the market price of its securities. Legal, regulatory and enforcement risk ich DIMA and its affiliates are regulated and supervised by banking and other regulatory authorities in those jurisdictions in wh they operate. In recent years, regulators and governmental bodies in certain countries have sought to subject investment advise rs to increasing regulation. ln light of an uncertain and evolving regulatory framework, legislative and regulatory reform may have a significant impact on DIMA’s investment advisory business. e Investment Company Act or because they are foreign funds not sponsored by a U.S. -U.S. Persons; these Advisory Accounts DIMA utilizes certain exemptions and exclusions under the Volcker Rule that allow it to continue its investment advisory business. For instance, under the asset management exemption, DIMA may sponsor and advise a covered fund but is prohibited from owning more than 3% of the outstanding ownership interests of such covered fund, among other conditions and restrictions. Moreover, certain of the Advisory Accounts are not covered funds because they would not be considered investment companies for purposes of th banking entity that were organized and offered in offshore transactions targeting non are generally considered beyond the scope of the Volcker Rule. r to do ed from -compliance could have A number of U.S. states and governmental pension plans have adopted laws, regulations or policies which prohibit, restrict, o require disclosure of payments to (and/or certain contacts with) state or local officials by individuals and entities seeking business with state or local entities, including those seeking investments by public retirement funds. The SEC has also adopt rules that, among other things, prohibit an investment adviser from providing advisory services for compensation to certain government affiliated investors for two years after the adviser or certain of its executives, employees or agents make a contribution to certain elected officials or candidates. Such laws, regulations or policies may inhibit an investment adviser provi ding advisory services for compensation to a governmental client. If DIMA or any of its employees or affiliates or any service provider acting on their behalf fails to comply with such laws, regulations or policies, such non an advers e effect on DIMA’s clients. nt -U.S. jurisdictions in which DIMA h ed -ranging piece of legislation that regulates firms which provide that DIMA and its investment Advisory Accounts may also be subject to regulation in jurisdictions where they engage in business. Recent legislative, tax, and regulatory reform may impact the activities of DIMA by requiring DIMA to provide additional clie acco unt information to the Internal Revenue Service or other taxing authorities. Other non operates are also in the process of developing more comprehensive regulation related to the financial services industry, whic could hav e a similar impact on DIMA and the broader markets. For example, foreign regulators have passed legislation that may affect certain clients, including the European Commission’s Alternative Investment Fund Managers Directive (“AIFMD”), which imposed certain requirements and restrictions on managers of alternative investment funds. Similarly, the European Union’s revised Markets in Financial Instruments Directive and Markets in Financial Instruments Regulation (collectively call “MiFID II”), which came into effect on January 3, 2018, is a wide services to clients relating to financial instruments and that has implications for asset managers located in the U.S. with business ties to the European Union. From time to time, DIMA may be subject to a higher standard with respect only to specific clients with particular regulatory requirements. For example, DIMA might be indirectly subject to MiFID II only to the extent DIMA (1) trades on European trading venues; (2) trades with European counterparties, or (3) provides investment management \ 58  Form ADV Part 2A DWS Investment Management Americas, Inc. d is services to EU clients or DWS legal entities in the EU or performs delegated activities for an EU DWS legal entity or fund an contractually required to adhere to the regulatory standards of the outsourcing/delegating EU entity. Where DIMA aggregates trades, however, it will apply the higher standard to all clients. -related risk Additionally, regulators in diverse global jurisdictions are developing various sustainable finance and climate management, disclosure and taxonomy frameworks for listed companies and financial institutions that will impact investment managers and advisers, including DIMA. As a result, DIMA may be subject to multiple risk and regulatory framework requirements imposed by various regional regulators. in icipate every possible current or future circumstance the DIMA’s business is dynamic, and the regulatory landscape can change significantly over time, thus subjecting investment Advisory Accounts to new or additional regulatory constraints in the future. Offering materials and other documents received connection with an investment advisory account cannot address or ant that may affect the investment advisory account, DIMA, or its businesses. A multitude of factors may significantly impact the business operati ons of DIMA , investors and/ or operational construct of an investment advisory account. For the avoidance of doubt, DIMA is not obligated to effect any transaction that it reasonably believes would violate federal or state law, or regulations of any regulatory body or self -regulatory body. \ 59  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 9 / Disciplinary Information of DIMA’s public statements about its ESG integration approach containing SEC did not find that any of these public statements was intentionally false. DIMA was censured -7 and 206(4) -8 On September 25, 2023, DIMA entered into a settlement with the SEC regarding DIMA’s ESG policies and procedures. The SEC found that DIMA did not adequately implement certain provisions of its global ESG integration policy for certain actively managed mutua l funds and retail separately managed account strategies. The SEC also found that DIMA had weaknesses in its marketing processes that resulted in certain material misstatements. The and ordered to cease and desist from violating Sections 206(2) and 206(4) of the Advisers Act and Rules 206(4) thereunder. DIMA agreed to pay a p enalty in the amount of $19 million. DIMA neither admitted nor denied the SEC’s findings. \ 60  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 10 / Other Financial Industry Activities and Affiliates -owner of DIMA and DIMA’s parent DWS Group. The Deutsche Bank Group Deutsche Bank Group is an indirect majority provides and/or engages in numerous financial services such as: commercial banking, insurance, brokerage, investment banking, financial advising, and broker -dealer activities (including sales and trading. DWS Group is a global asset manager providing services to institutions and individuals. r to or Deutsche Bank Group continues to exercise significant influence over DWS Group’s operations. The varied and complex financial services offered by Deutsche Bank Group can result in real, potential, or apparent conflicts of interest that appea prove d isadvantageous to some of DIMA’s advisory clients. . In Specifically, Deutsche Bank Group entities may act in their own interest, in the interest of third parties other than DIMA’s clients, for example when Deutsche Bank Group entities other than DIMA engage in advisory, transactional, and financial activities, or acquire or divest interests in assets that DIMA may directly or indirectly purchase or sell for its clients' Advisory Accounts. On occasion, other entities within the Deutsche Bank Group may have engagements and responsibilities that could give rise to the appearance of a conflict with DIMA's fiduciary obligation. Present and future activities of the Deutsche Bank Group in addition to those described herein may result in conflicts of interest that may be disadvantageous to DIMA's clients addition, D WS Group engages in global asset management activities, which could result in actual, potential, or apparent conflicts of interest between clients of DIMA and the interests of other DWS Group affiliates and their clients. in certain circumstances include revenue sharing or DIMA utilizes or recommends the services of its affiliates to clients, which joint compensation arrangements that create a conflict of interest. A number of factors mitigate these conflicts: — DIMA personnel involved in decision -making for Advisory Accounts are required to act in the best interests of their advisory clients. DIMA acts as a fiduciary with respect to its asset management activities and owes its clients a duty of utmost care and lo yalty. — DWS has implemented policies, procedures, and controls to identify and address actual, potential, or perceived conflicts of interest, whether with respect to Deutsche Bank Group or other DWS Group businesses interests. — Contacts between DIMA employees associated with the investment process, including portfolio managers, research analysts, and traders, and employees of the Deutsche Bank Group as it pertains to specific clients, business matters, or initiatives is governed by internal procedures or approved by DWS Group’s Compliance. — DIMA personnel generally, but not exclusively, act without knowledge of specific business goals or positions of Deutsche – Code of Ethics, Participation or Interest in Bank Group. When advisory personnel have knowledge of actual or potential conflicts among Advisory Accounts or between Advisory Account s and the Deutsche Bank Group, applicable policies require mitigation of the conflicts. A discussion about additional conflicts of interest that involve related persons is set out in Item 11 Client Transaction s, and Personal Trading. \ 61  Form ADV Part 2A DWS Investment Management Americas, Inc. Material Relationships or Arrangements with Financial Industry d -making for Advisory the best interests of their advisory clients and generally (but not exclusively) without knowledge of the do know of conflicts or potential conflicts among Advisory Accounts or between Advisory f conflicts involving related persons that may arise through this Form ADV. A – Code of Ethics, DIMA may utilize, suggest, or recommend other services of any of its affiliates to DIMA’s clients, which may involve revenue sharing or joint compensation, thus creating a conflict of interest. DWS has established a variety of policies, procedures an disc losures designed to address conflicts of interest arising between its employees, vendors, Advisory Accounts, and the Deutsche Bank Group's businesses. Pursuant to DWS's policies, DIMA personnel involved in decision Accounts must act in interests of proprietary trading and other operations of the Deutsche Bank Group and/or personnel of the Deutsche Bank Group. Where advisory personnel Accounts and the Deutsche Bank Group and/or personnel of the Deutsche Bank Group, it is DIMA's policy to mitigate such conflicts, and generally to disclose the types o discussion concerning additional conflicts of interest involving related persons is set out in Item 11 Participation or Interest in Client Transactions, and Per sonal Trading. U.S. and foreign affiliates and third -party service -office and other services on behalf of, and relating to, Advisory -U.S. ju risdictions. Accordingly, certain -party service providers in connection with DIMA has entered into and may in the future enter into arrangements with providers to perform various compliance, administrative, back Accounts. Such affiliates and service providers may be located in the U.S. or in non information about Advisory Accounts may be shared with such affiliates and third these fun ctions. Moreover, upon client request, DIMA will share information about its clients with affiliates with whom the clients wish to enter into a business arrangement. Deutsche CIB Centre Private Limited; DBOI Global Services Private Limited, Deutsche Bank Securities Inc., and Deutsche Knowledge Services Pte, Ltd provide certain near sourced financial services to DIMA including but not limited to trade processing, client account management, FX sell off activities and conduct period end substantiation of cost related accounts. Broker -Dealers — DIMA has arrangements with the following related persons that are broker -dealers: — Deutsche Bank Securities Inc. ("DBSI"), New York, NY, is a registered broker dealer under the U.S. Securities Exchange Act of 1934 (the "Securities Exchange Act") and is registered as a Futures Commission Merchant with the U.S. Commodity Futures Trading Co mmission (“CFTC”). It is a member of the New York Stock Exchange and other principal exchanges in the U.S., the National Futures Association (“NFA”), as well as the Financial Industry Regulatory Authority (“FINRA”). DBSI also serves as distributor for cert ain funds of DIMA. DIMA may also utilize DBSI’s services to effect securities transactions for clients. — DWS Distributors, Inc. is a wholly owned subsidiary of DIMA, which is registered as a limited purpose broker -dealer in the U.S. It serves as the principal underwriter for the DIMA -advised mutual funds, and proprietary private funds (or private placements) . Certain management persons of DIMA may be designated as registered representatives of DWS Distributors, Inc., a registered broker -dealer, as necessary or appropriate to perform their responsibilities. Investment Companies and Other Pooled Vehicles -advisory capacity to a variety of U.S. investment companies and U.S and non -U.S. pooled -adviser, manager, or distributor. DIMA also acts in an administrator some of or officers. These arrangements are disclosed in each fund's These fees will be in addition to any advisory fees or other fees agreed between the DIMA acts in an advisory or sub vehicles for which an affiliate may act as adviser, sub capacity to a variety of closed -end investment companies for which an affiliate acts as adviser. In connection with these funds, certain DIMA employees serve as directors prospectus or offering docu ment in accordance with any disclosure requirements. DIMA and its affiliates will receive management or advisory fees with respect to these services. Although such fees are generally paid by the entities, the costs are ultimately borne by their investors. investors in their capacities as clients and DIMA and its affiliates for investment advisory, brokerage, or other services. \ 62  Form ADV Part 2A DWS Investment Management Americas, Inc. A When DIMA recommends or invests advisory account assets in DIMA Advised Funds conflict of interests arise where the Adviser and/or its Affiliates may benefit from increased allocations to the DIMA Advised Funds, and certain Affiliates of DIM may receive a dvisory or other fees for services provided to such funds. Please refer to Item 11, Participation, or interest in client transactions for a more complete discussion regarding conflicts of interest. Fees, and Compensation for a more complete discussion As described in Item 5, DIMA generally does not receive advisory fees from both the advisory account and the DIMA Advised Fund in which the advisory account is invested. Please refer to Item 5, regarding fees and compensation. Investment Advisers y, DIMA has investment advisory affiliates around the globe, including, without limitation, in Australia, United Kingdom, German Hong Kong, Japan, Singapore, Luxembourg, Switzerland and the U.S. The following DIMA investment advisory affiliates are register ed with the SEC as investment advisers: DBSI, DWS International GmbH, DWS Investments Australia Limited, DWS Investments Hong Kong Limited, RREEF America L.L.C., DWS Alternatives Global Limited, and DBX Advisors LLC. A number of DIMA’s non -U.S. investment advisory affiliates are not registered with the SEC, including without limitation, DWS Investments UK Limited and DWS Investments (Japan) Limited. DWS Investments SA is an exempt reporting adviser. dviser, gates of -advisory, co -advisory or Apart from furnishing investment advice to clients, DIMA also provides various investment advisory, consulting, trading, administrative, and research support services to its affiliates pursuant to intercompany agreements. With respect to certain non - U.S. strategies, or otherwise as it determines, DIMA may, in its discretion, delegate all or a portion of its advisory or other functions (including placing trades on behalf of clients) to any affiliate that is registered with the SEC as an investment a in the U.S. or outside the U.S., or to any Participating Affiliate, or otherwise as permitted by law. To the extent DIMA dele its advisory or other functions to affiliates that are registered with the SEC as investment advisers, a copy of the brochure each such affiliate is available on the SEC’s website (http://www.adviserinfo.sec.gov) and will be provided to clients or prospective clients upon request. Certain services may be performed for affiliates by DIMA employees who are also employees of such affiliates or through delegation or other arrangements. In addition, DIMA may participate in sub other joint projects related to pooled investment vehicles with unaffiliated entities. earch h . DBSI’s research Services do not include any securities trading activity on a DIMA’s affiliates, including DBSI, offer investment views to their clients through the provision of proprietary published res pertaining to investment securities, including debt and equity securities and access to the research analysts who prepare suc research (collectively, “DB Research Services”) discretionary basis or otherwise and are not specially tailored for particular clients. DB Research Services are developed indep endently of DIMA. While DIMA may, from time to time, consider DB Research Services in providing advisory service to Advised Accounts, DIMA is not bound by the views expressed in these DB Research Services, which could differ from DIMA developed research . There is no sharing of information by DIMA related to development or provision of the DB Research Services. Commodity Pool Operator, Commodity Trading Advisor and Futures Commission Merchant DIMA is registered with the CFTC as a commodity pool operator (“CPO”) and a commodity trading advisor (“CTA”). Certain management persons of DIMA are registered with the National Futures Association (“NFA”) as associated persons and swap associated persons to the extent necessary or appropriate to perform their responsibilities. \ 63  Form ADV Part 2A DWS Investment Management Americas, Inc. DIMA may have related persons that are registered with the CFTC as either a CPO, CTA, or futures commission merchant ("FCM") including but not limited to the following: Affiliates Licenses RREEF America L.L.C. CTA/Exempt CPO Deutsche Bank Securities Inc. FCM/ SEC broker -dealer y To the extent permitted by law and applicable regulations, DIMA may utilize the foregoing or other affiliates as FCM, Exempt CPO or CTA in connection with DIMA's purchase or sale of futures, on behalf of certain of its clients or may delegate advisor serv ices to an affiliate as a CTA, FCM, Exempt CPO or CTA affiliates which may receive remuneration for such services. Banking Institutions The following banking institutions are related persons of DIMA: TC also provides trustee and/or custodial services to various individual retirement accounts — DWS Trust Company ("DWS TC") is a New Hampshire trust company. DWS TC is the trustee as well as sponsor and/or investment adviser to privately offered investment funds, including various funds exempt from registration under the Investment Company Act. DWS (“IRAs”), profit sharing plans, pension plans and other retirement plan clients of DIMA. — Deutsche Bank AG is a publicly traded international commercial and investment banking concern listed on the Frankfurt and -custodians in certain jurisdictions. Any of DBAG’s -custodian by a U.S. global custodian, acting as custodian for Advisory Accounts t to ERISA. In these circumstances, DIMA affiliates may execute certain transactions on behalf of create conflicts of interest. -financial New York Stock Exchanges and is the indirect parent of DIMA and its affiliates. DIMA’s clients may utilize custodians unaffiliated wit h DIMA who may, in turn, hire affiliates of DIMA as sub branches may be selected as a foreign sub including an account subjec DIMA’s clients (e.g., foreign exchange transactions, corporate actions). These circumstances DIMA has developed policies and procedures to monitor such circumstances. DBAG may also provide various non services to DIMA. Sponsor or Syndicator of Limited Partnerships also -adviser. Absent specific authority, rther From time to time, DIMA’s affiliates may act as placement agent, sponsor, general partner, managing member or other controlling entity in private investment vehicles in which DIMA's clients may be solicited to invest, and DIMA’s clients may be solicit ed to invest in private investment vehicles for which DIMA acts as adviser or sub DIMA does not exercise any discretionary authority with respect to client decisions to invest in such vehicles. Please see fu discuss ion under the above section “Investment Companies and Other Pooled Vehicles.” Management persons; policies and procedures g Certain of DIMA's management persons may also hold positions with DIMA’s affiliates. In these positions, those management persons of DIMA may have certain responsibilities with respect to the business of these affiliates and the compensation of these manag ement persons may be based, in part, upon the profitability of these affiliates. Consequently, in carrying out their roles at DIMA and these other entities, the management persons of DIMA may be subject to the same or similar potential conflicts of interes t that exist between DIMA and these affiliates. DIMA has established a variety of restrictions, policies, procedures, and disclosures designed to address potential conflicts that may arise between DIMA, its management persons, and its affiliates. These pol icies and procedures include; information barriers designed to prevent the flow of information between DIMA, personnel of DIMA and certain other affiliates; policies and procedures relating to brokerage selection, tradin with affiliates, or investing in p roducts managed or sponsored by affiliates; and allocation and trade sequencing policies applicable to clients. \ 64  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 11 / Code of Ethics, Participation, or Interest in Client Transactions, and Personal Trading Code of Ethics – DWS Group (the "Code") under Rule 204A -1 of the Advisers Act and Rule 17j -1 of ns in and DIMA has adopted the DWS Code of Ethics the Investment Company Act, designed to provide that DIMA employees, which are all considered Access Persons under the Code, comply wit h applicable federal securities laws and place the interests of clients first in conducting personal securities transactions and act solely in the interest of DIMA’s clients. The Code imposes certain restrictions on securities transactio the personal accounts of covered persons to help avoid conflicts of interest. These restrictions may include but are not limited to requiring Access Persons to hold positions in securities and DWS advised/sponsored funds for a minimum of 30 calendar days and not knowin gly or otherwise effect the purchase of sale of a security on a day during which any DWS client account has an open buy or sell order, subject to limited exceptions. Subject to the limitations of the Code, Access Persons may buy sell securities or othe r investments for their personal accounts, including investments in pooled investment vehicles that are sponsored, managed, or advised by DWS, and may also take positions that are the same as, different from, or made at different times than, positions take n (directly or indirectly) for accounts. -clear all of their personal securities transactions in securities that are Pursuant to the Code, Access Persons are required to pre not exempt from the Code. Additionally, employees must also receive prior approval before purchasing any securities in a private placement. Finally, Access Persons may not purchase a security pursuant to an initial public offering. transaction of that security in a client account if he/she manages or provides advice to that The Code further classifies Access Persons based on whether they are Investment Personnel. Investment Personnel are those employees involved in the investment management and trading activity of clients' assets (including portfolio managers, research analys ts and traders) and imposes additional personal trading restrictions on those most centrally involved in the investment management process. For example, Investment Personnel may not knowingly purchase or sell a security within five days before and after a client account. which e to their securities holdings that they have All Access Persons are subject to reporting obligations, including filing quarterly personal securities transaction reports ( provides information with regard to all securities and certain DWS advised/sponsored fund transactions that are required to b reported, if any, effected during the previous quarter for their own accounts and any accounts over which they have direct or indirect beneficial interest, influence and/or control). All Access Persons are required to disclose their security accounts DIMA upon hire. Additionally, Access Persons are required to acknowledge annually received, read, understood, and had the opportunity to ask questions regarding the Code. y -term trading or trading during blackout periods, may . All violations are reported to the Chief Compliance Officer on a monthly basis. Violations Any Access Person who violates the Code may be subject to disciplinary actions, including possible dismissal. In addition, an securities transactions executed in violation of the Code, such as short sub ject the employee to sanctions and suspected violations of criminal laws will be reported to the appropriate authorities as required by applicable laws and regulati ons. A copy of the Code will be provided to any client and/or prospective client upon request. Outside Business Activities DIMA has policies and procedures in place which requires DIMA employees to obtain approval before engaging in any outside activities, including serving on the board of a publicly traded company, so that DIMA has the opportunity to consider whether such act ivities create actual or potential conflicts of interest. The Code and other DWS policies are intended to identify activities that have the potential to conflict with DWS and/or DWS activities. \ 65  Form ADV Part 2A DWS Investment Management Americas, Inc. Gifts and Entertainment licies DIMA has policies and procedures in place which limit and prohibit DIMA employees from accepting gifts, entertainment and other things of material value that create a conflict of interest or give the appearance of a conflict of interest. Additionally, Access Persons are prohibited from offering gifts, entertainment or other things of material value that could be viewed as attempting to unduly influence the decision making or objectivity of any client or other business partner. In general, the po prohi bit giving and receiving gifts or participating in entertainment cannot occur if the value and/or the frequency of the gift or entertainment is excessive or extravagant. The policies impose specific restrictions and require DWS Compliance approval of gifts and entertainment . d. In general, the policy permits employees to accept gifts having a nominal value (e.g., promotional items) which must be logge Reporting and approval requirements and restrictions apply in the case of entertainment offered to or to be provided by DIMA. DWS’ Policy also sets forth parameters with respect to entertainment -related expenses. Additional restrictions regarding gifts and entertainment apply to Access Persons who are registered representatives or other associates of DIMA's affiliated broker -dealers. Participation or Interest in Client Transactions nd ervices from entities for which Deutsche Bank Group performs or seeks to perform in herwise has direct or indirect interests. DIMA makes decisions for its clients – Other Financial ies of Deutsche Bank Group may have a negative or detrimental effect on Deutsche Bank Group is a major participant in global financial markets, and it acts as an investor, investment banker, investment manager, financer, advisor, market maker, trader, prime broker, lender, agent and principal in the global fixed income, curren cy, commodity, equity, and other markets in which DIMA's Advisory Accounts directly and indirectly invest. In those and other capacities, Deutsche Bank Group advises clients in all markets and transaction and purchases, sells, holds, a recommends a broad array of investments, including securities, derivatives, loans, commodities, currencies, swaps, indices, and other financial instruments and products for its own account and for the accounts of clients and of is personnel, through Advisory Accounts and th e relationships and products it sponsors, manages, and advises. As permitted by and in conformity with applicable laws and regulations, DIMA's Advisory Accounts will invest in, engage in transactions with, make voting decisions with respect to, or obtain s banking or other services. Additionally, it is likely that DIMA's Advisory Accounts will undertake transactions in securities which Deutsche Bank Group makes a market or ot in accordance with its fiduciary obligations as manager of its Advisory Accounts. As disclosed in Item 10 Industry Activities and Affiliations, certain activit Advisory Accounts managed by DIMA. h ry rom DIMA may take investment positions in securities of the same issuer that are different parts of the capital structure in whic other clients or related persons within the Firm have different investment positions. There may be instances in which DIMA is purchasing or selling for its Advisory Accounts or pursuing an outcome in the context of a workout or restructuring with respect to, securities in which Deutsche Bank Group is undertaking the same or differing strategy in other businesses or other Adviso Ac counts. Prices, availability, liquidity, and terms of the investments may be negatively impacted by the Firm's activities and the transactions for DIMA's clients may, as result, be less favorable. The investment results for DIMA's clients may differ f the results achieved by Deutsche Bank Group and other clients of Deutsche Bank Group. In addition, results among DIMA clients may differ. With respect to certain managed investment strategies, trading services including counterparty selection as well as certain “downstream” functions including, but not limited to, trade matching and settlement, investment accounting, reconciliations, corpora te actions, and performance measurement are provided through DIMA and its global affiliates. In providing these services, DIMA and its affiliated entities will have access to certain information about Advisory Accounts, including not limited to, client ide ntities, portfolio transactions, open order, and positions. ts As noted, DIMA makes decisions for its clients in accordance with its fiduciary obligations as manager of its Advisory Accoun independent of decisions made by Deutsche Bank Group. When conflicts of interest arise between decisions that are in the \ 66  Form ADV Part 2A DWS Investment Management Americas, Inc. erest best interests of DIMA's advisory clients and decisions that benefit parts of the Deutsche Bank Group, such conflicts of int are managed by the use of information barriers that control the sharing of information among the different businesses of the Deutsche Bank Group. For a summary of the restriction of the flow of certain information between DIMA and Deutsche Bank Group, please see "Information Barriers" below. The DWS Americas Investment Risk Oversight Committee (“IROC”) is responsible for monitor ing investment performance of Advisory Accounts on a regular basis and performing an annual product review. See Item 12 – Brokerage Practices for more details. This are imposed on the aggregate amount of investment by affiliated investors. DIMA may or The investment activities of Deutsche Bank Group may limit the investment opportunities for DIMA's Advisory Accounts. occurs in certain regulated industries, private equity markets, emerging markets, and in certain futures and derivative transactions where restrictions voluntarily limit transactions for Advisory Accounts or limit the amount of voting securities purchased for Advisory Accounts waive voting rights for certain securities held in Advisory Accounts, which may limit positions, in order to avoid circumstances which, in the view of DIMA, would require aggregation of such Advisory Account positions with investments in Deutsche Bank Group that would approach or exceed certain ownership thresholds. -only accounts. For example, DIMA may DIMA may have portfolio managers who manage long/short accounts alongside long buy on behalf of an Advisory Account a security for which DIMA may establish a short position on behalf of another Advisory Account. The sub sequent short sale may result in impairment of the price of the security held long in the Advisory Account. Conversely, DIMA may on behalf of an Advisory Account establish a short position in the same security which it may purchase on behalf of another Adv isory Account. The subsequent purchase may result in an increase of the price of the underlying position in the short sale exposure. T rading with these brokers raise conflict s of DIMA may engage in security transactions with brokers who may also sell shares of DIMA Advised Funds advised by DIMA, provided that it reasonably believes that the broker will provide best execution. interest ; however, there are no quid pro quo arrangements or agreements in place with these brokers. Furthermore, DIMA has implemented policies and procedures reasonably designed to prevent its traders from considering sales of DWS Fund shares as a factor in the selection of broker-dealers to execute portfolio transactions for each DWS Fund. This may affect potential returns on Advisory Accounts, and a client not advised by DIMA may not be subject to some of these restrictions. A DIMA may recommend and invest an Advisory Account in DIMA Advised Funds, which creates a conflict of interest because the Adviser and/or its Affiliates may benefit from increased allocations to the DIMA Advised Funds, and certain Affiliates of DIM may rec eive advisory or other fees for services provided to such funds. In accordance with a client’s investment guidelines, when selecting DIMA Advised Funds for Advisory Accounts, DIMA must conduct independent due diligence and document the rationale for its selection of DIMA Advised Funds. DIMA has policies and controls in place to govern and monitor its activities and processes for identifying and managing conflicts of interest. Information Barriers non-public information in connection with its commercial and investment y Deutsche Bank Group obtains confidential, material banking activities. Deutsche Bank Group and DWS, have internal procedures in place intended to limit the potential flow of an such non -public information. -public information, DIMA has procedures that prohibit trading activities -public information decisions for its clients. These procedures and prohibitions may preclude Advisory Accounts from If DIMA come s into possession of any material, non based on such information by DIMA for its clients and by DIMA employees. DIMA may not use material, non when making investment purchasing or selling certain securities, which could have a detrimental effect on one or more Advisory Accounts. are privy to material, There may be instances in which senior management of DIMA, not involved in the investment process, non -public information about transactions or securities due to discussions with senior personnel from other departments within \ 67  Form ADV Part 2A DWS Investment Management Americas, Inc. -public information, senior management may not hin Deutsche Bank Group . However, when in possession of material, non participate or use that information to influence trading decisions; nor may they pass that information along to personnel wit DWS involved in the investmen t process (e.g., portfolio managers, research analysts and traders) for use in investment activities. DIMA has developed policies and procedures to monitor such circumstances. ies that There may also be periods during which DIMA may not initiate or recommend certain types of transactions, disseminate research, or may otherwise restrict or limit its advice given to clients in certain securities issued by or related to compan Deuts che Bank Group is performing banking or other services, or companies in which Deutsche Bank Group has a proprietary position. As a result, Advisory Accounts may be precluded from purchasing or selling certain securities, which could have a detrimental effe ct on one or more Advisory Accounts. Principal Trading ces, . to DIMA generally does not cause its clients to enter into principal transactions with related persons. Under limited circumstan DIMA may enter into a principal transaction provided the transaction is in accordance with Section 206(3) of the Advisers Act All such transactions must receive client consent for each transaction, are affected on arms' length terms and, with respect commissions paid, are competitive with those paid to non -related broker dealers. s of -financial soft dollar The only compensation received by DIMA for effecting securities transactions for clients is its advisory fees. Related person DIMA will receive brokerage commissions, commission equivalents, fees associated with acting as an issuer’s paying agent, spread and other fees in connection with brokerage services provided. DIMA may also receive certain non benefits, as described in “Research and Soft Dollars,” below. See Item 12 – Brokerage Practices for more details. . In these cases, the purchase eriencing difficulty in DIMA may purchase, on behalf of its clients (other than ERISA plans), securities in which an affiliate of DIMA serves as lead underwriter or co -manager of an underwriting syndicate or member of an underwriting syndicate is generally made from a party unaffiliated with any DWS company, but DIMA’s affiliate may nevertheless benefit from such transactions, including in circumstances where the syndicate of which DIMA’s affiliate is a member is exp effectuatin g the distribution of the new issues. - create conflicts of interest. DIMA has DIMA’s clients may utilize custodians unaffiliated with DIMA and such custodians may, in turn, hire affiliates of DIMA as sub custodians in certain jurisdictions. In such circumstances, DIMA affiliates may affect certain transactions on behalf of DIMA clients (e.g., foreign exchange transactions, corporate actions). These circumstances developed policies and procedures to monitor such circumstances. fiduciary clients, these circumstances create a conflict of interest, even able to DIMA’s -going While DIMA acts solely in the best interests of its though the transactions are effectuated in compliance with applicable regulations (see "Agency Transactions," "Investment Companies," and “Cross Trades” below). Additionally, regulatory, or other government requirements applic related persons may restrict DIMA from investing in or disposing of certain securities for its clients on a temporary or on basis. Agency Transactions -dealers through which it may affect agency transactions . (other than ERISA Plans) -dealers er- -dealers would charge their own customers. As a general matter, -dealers only if DIMA has determined in good resent conflicts of interest, including that DIMA affiliates will earn fees with regard to such DIMA is a related person of various broker DIMA has procedures reasonably designed to ensure that agency transactions executed with these related broker acting as agent comply with applicable law and regulations. If any client portfolio transaction is executed with related brok dealers, the broker -dealers may charge a commission in connection with these transactions; however, the commissions do not exceed the usual a nd customary commission that the broker DIMA can execute agency transactions on behalf of clients with related broker faith that the client will rece ive best execution in the transaction, and only in compliance with applicable law and regulations, DWS's policies and procedures, and in accordance with the consent of clients to these kinds of transactions. Executing transactions with affiliates of DIMA p transactions. See Item 12 – Brokerage Practices for a discussion of “Trading and Restricted Brokerage.” \ 68  Form ADV Part 2A DWS Investment Management Americas, Inc. Investment Companies -dealers will be executed only -1 and Rule 10f -3 an In addition, Rule 10f -3 under the Investment Company Act provides an exception to the prohibition on ter of such security is an affiliate of the DIMA Advised Funds as long as certain conditions For DIMA Advised Fund clients, agency and underwriting transactions with affiliated broker pursuant to procedures adopted by the Boards of Trustees or Directors of such companies under Rule 17e under the Inves tment Company Act. Rule 17e -1 under the Investment Company Act provides that, when purchasing or selling securities as agent, an affiliate of the DIMA Advised Funds may not accept any compensation, except in that person’s role as underwriter or broker. DIMA Advised Funds from knowingly purchasing or acquiring securities during the existence of an underwriting or selling syndicate when a principal underwri are met. Cross trades a-7 tions with affiliated persons)); are, in the view of the respective portfolio managers, DIMA from time to time effects cross transactions directly between Advisory Accounts, provided that: such transactions are consistent with the investment objectives and policies of such accounts (for mutual funds, consistent with the funds’ Rule 17 procedures (procedures for transac favorable to both sides of transactions; and are otherwise executed in accordance with applicable laws, rules and regulation. ired DIMA will only consider engaging in cross transactions to the extent permitted by applicable law and will, to the extent requ by law, obtain the necessary client consent . Clients may revoke their consent for agency cross transactions at any time. Portfolio Holdings Disclosure Policy -adviser have a responsibility to their clients and investors not to disclose non - As investment advisers, DIMA and each sub public portfolio holdings information unless such disclosure is consistent with relevant laws and regulations and with the fiduciary duties DIMA and each sub -adviser owe to their clients. third parties including DIMA affiliates, sub -advisers, custodians, ing agencies or a fund's shareholders in connection with DIMA provides non-public portfolio holdings information to independent registered accounting firms, a DWS Fund's officers and trustees/directors, securities lending agents, financial printers, proxy voting firms, mutual fund analysts and rating and track in-kind redemptions in , each case, in accordance with DIMA’s portfolio holdings disclosure policy. Proprietary Account Trading and Hedging Activities s of interest or could potentially In accordance with DWS policy, DIMA may invest and manage its own proprietary capital by investing in a variety of securities and other instruments that is also subject to Volcker compliance. Proprietary capital investments will include investing in certai n products and strategies managed by DIMA for its clients. The market risks of these investments may be hedged, while market risks of client assets may not be so hedged. Hedging activities may include purchasing instruments or using investment strategies s uch as short selling, futures (or options on futures) trading or employing other derivative techniques. Portfolio management and trading of the proprietary capital as well as any associated hedging activity is undertaken in accordance with DWS policies and procedures. Proprietary capital may not perform the same as similarly managed Advisory Accounts for a variety of reasons, including, but not limited to regulatory restrictions on the type and amount of securities in which the proprietary capital may be in vested, differential credit and financing terms, as well as any hedging transactions. While DIMA acts solely in the best interests of its clients, these circumstances may give rise to conflict disadvantage its clients. \ 69  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 12 / Brokerage Practices Broker Dealer Selection In general, the execution strategy and associated execution methods, including where and how to execute an order, are made based on the functional and economic merits e.g., liquidity, appropriateness, certainty, and settlement infrastructure of a broker or a venue. The selection of a particular broker to execute client orders is based on a number of criteria, including, but not limited to , their: — Price — Inventory or risk appetite (i.e., size available) — Market and security familiarity — Access to liquidity or willingness to commit risk to principal trade — Financial stability and certainty of settlement — Reliability and Integrity of maintaining confidentiality — Soundness of technological infrastructure and operational capabilities — In case of new Issues: The broker´s capability to provide subscription facility in the primary market — Safeguards and compliance controls to protect Clients — Pricing and costs for execution -only services — Ability to provide transaction cost analysis (TCA) — Access to Centralized Risk Book (CRB) — Ability to provide analysis of speed of execution — Level of control over interactions with internal and external Systematic Internalisers (SIs) — Approach to double caps and new large -in-size (LIS) venues — Smart order routing (SOR) logic and Algorithmic trading strategies — Ability to produce customized reports, trade related performance data, performance attribution, — risk reports (including breach violations and rejection) on a periodic basis — Ability to provide assisted trade reporting — Connectivity to OMS and FIX confirmation capabilities \ 70  Form ADV Part 2A DWS Investment Management Americas, Inc. Allocation of Investments DWS has policies and procedures, which DIMA has adopted, reasonably designed to ensure that all clients are treated fairly and equitably. -dealers or other counterparties for alloca te -rata fashion amongst the participating Advisory Accounts, based on the When DIMA aggregates orders for its clients, the order is placed with one or more broker execution. When an aggregated order is completely filled, or if partially filled, at the end of the day, DIMA will generally the securities or the proceeds from the sale in a pro accounts’ relative order size. In accordance with DWS Trading’s Allocation Methodology, adjustments or changes to an allocation may be made under certain circumstances. Such examples may include, but are not limited to, avoiding odd lots or small allocations, ensuring minimum lot size requirements are met or satisfying cash flows and guidelines. Best Execution DIMA places orders for the execution of transactions for Advisory Accounts according to its best execution policies and proce dures. When selecting brokers for order execution, DIMA will seek to obtain the best possible results taking into account price, cos speed, likelihood of execution and settlement, size, nature, or any other consideration relevant to the execution of the orde ts, r. The relative importance of these execution factors will be determined based on the following criteria: — The characteristics of the order — The financial instruments that are the subject of the order — The characteristics of the execution venues to which the order can be directed — The current market circumstances — Specifically, for Funds: the objectives, investment policy and risks of the Fund as indicated in the prospectus, articles of association or offering documents of the Fund Generally, DIMA will regard price and cost as the important factors for Best Execution, however there may be circumstances when DIMA determines that other execution factors have a greater influence in achieving the best possible result. Brokerage Practices Fiduciary Oversight Sub -Committee (“BPSC”) , The BPSC, which is directed by IROC, is the fiduciary oversight committee for brokerage practices, including broker selection best execution and new commission sharing and soft dollar arrangements for DWS in the Americas. The responsibilities of the BPSC include, but are not limited to, the following: 1. Reviewing — Best execution practices including, but not limited to broker selection, new soft dollar arrangements, approval of standard commission schedules, etc. 2. Reviewing best execution determinations from each trading desk, including where applicable — Trading volume and commission by broker — Broker rank — Trends and market color as it related to execution \ 71  Form ADV Part 2A DWS Investment Management Americas, Inc. — Cross trading activity 3. Reviewing list of approved counterparties. 4. Reviewing trading errors Commission Rates -dealer by country and by types of trades. -dealers approved by DWS Group. The A trade may DIMA utilizes a schedule of commission rates that have been negotiated with the broker schedule delineates the commission rates negotiated with the broker deviate from the schedule in limited instances. Counterparty Risk al e f extended settlements, the CPRM team is heavily involved in the negotiation of Counterparty risk is the risk that a counterparty will not be able to complete a client's transaction, whether due to financi difficulties or otherwise, which may result in opportunity cost and/or loss of principal. While DWS Group cannot guarantee th creditworthiness of counterparties, DWS Group has a Counterparty Risk Management (CPRM) team within its Chief Control Office (“CCO”), which is responsible for assessing and managing counterparty risk for all transactions undertaken on behalf o DIMA’s clien ts and across all businesses globally within DWS Group. The CPRM team has developed policies and procedures which are used to assess credit worthiness and levels of credit exposure of all counterparties, to approve or decline counterparty limits and exposu res, and to measure and monitor counterparty exposure to ensure that there is no undue concentration of exposure, within levels that, in DIMA’s judgment, are prudent with regard to the counterparty's financial resources. For certain transactions involving special agreements with certain counterparties. s and In less -developed markets, there may well be a higher level of counterparty risk because counterparties may not be as well capitalized. In addition, there is often limited and less reliable information about counterparties' financial condition, les regula tory supervision of securities markets, market policies that may require payment before delivery of securities, less automated clearance and settlement conditions, the uncertain enforceability of legal obligations, greater market volatility, increased levels of sovereign and currency risk. In these markets, the effort to attain best execution may also increase counterparty risk, and DIMA will attempt to balance these factors when selecting a counterparty to execute client transaction s. , Alternative Trading Systems (ATS) , or Similar Execution or Trading Systems or Electronic Communication Network (ECN) Venues. , ATS, or similar execution or trading system venues to execute trades. DIMA’s affiliates may MA DIMA may elect to utilize ECNs maintain an ownership interest in one or more ECNs, which creates a conflict of interest. In no case does such interest by DI or any U.S. affiliate currently exceed 10%. Electronic Trading Platforms DIMA may enter into agreements with various vendors who provide platforms for DIMA to gain electronic access to various participating broker -dealers. DIMA aims to make use of electronic venues wherever possible. This means that the order will be made avail able on the venues (i.e., request for quote submitted) on a best effort basis to avoid market movements adversely impacting execution. When determining the execution venue for order execution in respect of a particular order, DIMA takes the following factors into consideration: — The instrument types mainly traded on the particular venue where the competitive prices are available — The depth of liquidity and the relative volatility of the market — The speed and likelihood of execution \ 72  Form ADV Part 2A DWS Investment Management Americas, Inc. — The creditworthiness of the counterparty on the venue — The quality, cost, and arrangements supporting clearing and settlement — Impact to price/position leakage DIMA has identified the brokers and execution venues on which we place significant reliance in meeting our best execution obligations on a consistent basis. There may, however, be occasions when achieving the best possible result in carrying out a client o rder will require executing the order outside trading venues. Errors and Corrections des a rade ed on a regular basis to DIMA management and/or DIMA Compliance. Trade error a Trading Errors : A trading error is defined as an error in the placement, execution, or settlement of a client’s trade. Trade errors include improper trades resulting from incorrect information being given to, and fully accepted by, the executing broker; tra that are in consistent with a client’s or fund client’s investment guidelines, DWS Group policy or procedure, applicable laws and regulations, and operational errors that cause trading or guideline breaches. A trading error does not include, for example, situation w here DIMA invests in a particular investment that does not perform as expected. Operational mistakes which can be promptly reversed so as not to affect the client account also are not considered errors. In accordance with its policy, any t error that a ffects a DIMA client account must be resolved promptly and fairly, and in accordance with legal/regulatory restrictions and guidelines. All trade errors caused by DIMA which result in a loss to a client account must be reimbursed regardless of the amount. With respect to certain trade errors, DIMA may determine the amount of such reimbursement by offsetting losses against gains resulting from such errors to the extent permitted by DWS's policies and procedures and applicable law. All trade errors are report incidents resulting from the mistakes of brokers, custodians or other third parties are generally not compensable by DIMA to client. third party service h our loss to that client. Not all Errors result in client harm or a compensable management parameters to support our processes. These internal parameters mandated restrictions, and deviations from them, in and of themselves, do Other Errors : We seek to perform our advisory services diligently and in accordance with our fiduciary obligations. However, investment management involves complex processes that rely on people, technology, data inputs, and providers. As a result, operational, administrative, or other errors (collectively, “Errors”) may occur from time to time. We maintain policies and procedures reasonably designed to identify, review, and remediate Errors in a manner consistent wit duty to act in clients’ best interests. When an Error is identified, we assess the nature of the Error, its materiality, its cause, and its direct impact on the client. Corrective actions may vary depending on the circumstances and may include making a client whole when the Error causes a direct and quantifiable loss. Certain Errors —such as those that do not negatively affect a client’s account value, that are offset by market movements, or that ot herwise are noncompensable Errors —may not require financial remediation. We also use internal investment guidelines, thresholds, monitoring tools, and risk are for internal oversight purposes, are not client not constitute Errors or give rise to any compensable claim. Investment and Brokerage Discretion Generally, DIMA is retained on a discretionary basis for Advisory Accounts and DIMA determines which securities should be bought or sold, the total amount to be bought or sold for the account, the broker or dealer through which the securities are executed, and the commission rates, if any, at which transactions are affected for those accounts. From time to time, a client may also retain DIMA on a non -discretionary basis, explicitly requiring that portfolio transactions be discussed in advance. Model Portfolio Programs s non-discretionary and sory As noted above in “Item 4 – Advisory Business,” DIMA , for certain investment strategies, provide discretionary investment advice in the form of model portfolios to model portfolio program sponsors (each a “Sponsor,” and collectively, “Sponsors”) who may utilize such recommendations in connection with the management of their Advi Accounts. \ 73  Form ADV Part 2A DWS Investment Management Americas, Inc. With respect to model portfolios, DIMA normally intends to follow the general trading approach outlined below: For discretionary model portfolios provided by DIMA to unaffiliated Sponsors (each a “Discretionary Model Portfolio Account,” and collectively, the “Discretionary Model Portfolio Accounts”) and for affiliated Sponsors, DIMA will generally communicate information regarding model portfolios, or updates thereto, to such Sponsors at approximately the same time as it communicates to its trade desk the corresponding transactions for its Advisory Accounts within the same investment strategy. -Discretionary Model Portfolio -Discretionary Model Portfolio Accounts,” and together with Discretionary Model Portfolio y, with model portfolio changes normally being communicated to the Sponsor that is first in line in -Discretionary Model Portfolio Account Sponsors utilizing the same investment sign such Sponsor their spot in the trading sequence for that day. Once DIMA nce (the “Initial Trade Date”). DIMA intends to release model portfolio changes to all , systematically favor or disadvantage any For non -discretionary model portfolios provided by DIMA to unaffiliated Sponsors (each a “Non Account,” and collectively, the “Non Accoun ts, the “Model Portfolio Accounts”), DIMA will normally seek to communicate information regarding model portfolios to such Sponsors at approximately the same time as it communicates to its trade desk the corresponding transactions for its Advisory Accounts within the same investment strategy; provided that for situations where more than one such Sponsor is using the same investment strategy, DIMA intends to follow a trade rotation policy where it provides model portfolio changes to such Sponsors sequentiall the sequence at approximately the same time corresponding advisory client account trade orders are communicated to DIMA’s trading desk. In an effort to trea t the Non -Discretionary Model Portfolio Accounts on a fair and equitable basis over time, on each day where there is trading for multiple Non strategy, DIMA intends to randomly as determines the trading sequence for a particular day for a particular investment strategy, it will normally follow that seque for all trades that are initiated during that day Non - Discretionary Model Portfolio Accounts in a manner that does not intentionally particular Non -Discretionary Model Portfolio Account over time. ical into account other relevant factors, including the time of day the investment decision is initiated. In the case of -Discretionary Model Portfolio Account in line in the trade sequence for that day. Once it completes the Market Moving Trade and any and ry then sequentially communicate all of the corresponding model portfolio changes to the On any given day, if DIMA determines, in its discretion, that an advisory client account trade and a corresponding change to Non - Discretionary Model Portfolio Accounts are likely to be market moving (a “Market Moving Trade”), DIMA will seek to implement a trading approach that it deems fair and equitable under the circumstances. When determining whether a trade is or is not likely to be market moving, DIMA may base its determination on a number of factors, including the current or histor context and de pth of the market, the average trading volume of the security, the total size or value of the trade, minimum lot size, the current float, shares outstanding and/or issue size of the security. In addition to these factors, DIMA may, in its discretion, take a Market Moving Trade involving an investment strategy being utilized by multiple Non Sponsors, DIMA w ill normally seek to communicate the advisory client account trade order to its trading desk at approximately the same time that it communicates the corresponding model portfolio change to the Non -Discretionary Model Portfolio Account Sponsor that is first all other related trades for its Advisory Accounts and any affiliated Sponsors that trade in the aggregate with DIMA’s Adviso Accounts, DIMA will normally remaining Non -Discretionary Model Portfolio Account Sponsors in accordance with the trade sequence established on the Initial Trade Date. ll -Discretionary Model Portfolio Accounts after it completes all If DIMA determines that the trading approach described above is not appropriate for a particular investment strategy, DIMA wi normally release recommended model portfolio changes for Non of th e corresponding trades for its Advisory Accounts within the same investment strategy. Under the above -described circumstances, DIMA may or may not complete its trading for its Advisory Accounts and any affiliated Sponsors before providing the model portfolio changes to all of the Model Portfolio Accounts. Under certain circumstances, such a s when DIMA, in its discretion, determines that abnormal market conditions exist, DIMA reserves the right to modify its general trading approach in a manner that it deems fair and equitable over time to similarly situated cli ents. As a result of DIMA’s above -described trading activity on behalf of its Advisory Accounts and affiliated Sponsors, corresponding model portfolio related trades placed by Sponsors for their Model Portfolio Accounts may, as a general matter, be subject to \ 74  Form ADV Part 2A DWS Investment Management Americas, Inc. for ir e less that price movements, particularly for orders that are large in relation to a security's average daily trading volume. This could potentially result in the Model Portfolio Accounts receiving prices that are less favorable than the prices obtained by DIMA its Advisory Accounts and affiliated Sponsors. Similarly, model portfolio related trading activity by Sponsors on behalf of the Model Portfolio Accounts could potentially result in DIMA’s advisory clients and affiliated Sponsors receiving prices that ar favorable than prices that might otherwise have been obtained absent the Sponsors’ trading activity, particularly for orders are large in relation to a security's average daily trading volume. ’ In addition, it is possible that the communication of the model portfolios to Sponsors may be delayed because of the Sponsors administrative requirements or implementation practices. In such circumstances, Sponsors, including affiliated Sponsors, who make decisions for Model Portfolio Accounts, will not have had the chance to evaluate or act upon the model portfolio recommendations prior to the time at which other Advisory Accounts received such model portfolio and had the opportunity to act upon it. It is also possible that Sponsors, including affiliated Sponsors, who make execution decisions for Model Portfolio Accounts, may act upon such information before other Advisory Accounts have commenced trading. n For Sponsors participating in a trading sequence, particularly Sponsors that are not “first in line,” trades placed by such Sponsors for their clients may be subject to price movements due to the trading activity of other Sponsors. This may result i adver se price impacts for the affected Sponsors’ clients. ponsors are in the best position to take steps to address trading issues in furtherance of their time DIMA intends to take reasonable steps to minimize the market impact on Advisory Accounts and affiliated Sponsors of orders associated with model portfolio recommendations provided to all Sponsors. Because DIMA does not control the Sponsors’ execution of tr ansactions for the Model Portfolio Accounts, DIMA cannot minimize the potential market impact of such transactions on Model Portfolio Accounts to the same extent that it may be able to for its Advisory Accounts and affiliated Sponsors. DIMA believes that S best execution obligations to their clients. DIMA endeavors to treat its similarly situated clients fairly and equitably over with respect to trade sequen cing and allocation, recognizing that DIMA generally has different levels of responsibility with respect to its discretionary clients as compared to its non -discretionary clients. New Issue Allocation block When allocating Initial Public Offerings (“IPOs”), Secondary Public Offerings (“SPOs”) (collectively “new issues”) and other trades, DWS must treat all Advisory Accounts in a fair and equitable manner. WS l When an order has been entered by the portfolio manager into the execution management system and sent to the responsible dealing desk, DIMA will aggregate all orders in relation to a new issue and submit an aggregated indication of interest for D to the broker. Communication to the broker should only reflect actual interest of the respective funds and clients of DWS. Participation in new issues is limited to those Advisory Accounts that meet applicable FINRA eligibility requirements. Not al Advisory Acco unts or funds will be eligible for investment in new issues. Any deviations to the applicable allocation methodologies must be approved by DIMA Compliance. Non -Discretionary Accounts - DIMA provides non -discretionary investment advice to certain clients (including affiliates), requiring client consent prior to trading on behalf of such clients. In certain cases, depending on the time elapsed between DIMA seeking and receiving consent to purchase or dispose of an investment, such clients may not participate or receive the benefits of trading in the aggregate with other DIMA clients or may lose an investment or disposition opportunity altogether. In cases where clients receive non discreti onary advice and do not participate in an aggregated trade order, such clients’ order may be traded after the aggregated order is completed. Order Aggregation DIMA may, to the extent appropriate, permissible, and/or feasible, aggregate multiple client orders for the purchase or sell of the same security, placed at or around the same time, to achieve best execution with respect to all transactions being affect ed \ 75  Form ADV Part 2A DWS Investment Management Americas, Inc. t on behalf of Advisory Accounts. To the extent possible, the aggregation of orders shall be performed in a way that it does no disadvantage any client account or client whose orders are to be aggregated. e f an ally arch services (i.e., those accounts subject to MiFID II). Accounts that do not use commissions -only” rates which would be below DIMA will generally execute aggregated orders across all applicable accounts. Orders of the same security and transaction typ should, to the extent possible, be aggregated. Any subsequent orders that the trading desk receives prior to full execution o aggregated order will generally be added to the unfilled portion. In addition, to the extent that aggregated orders are parti unfilled following execution, the unfilled amounts are to be combined with subsequent orders for future execution. When an ag gregated order is executed at more than one price over the course of a day, the executed transactions are allocated so that each account pays (or receives) the weighted average execution price per broker and generally will pay the average commission, subje ct to odd lots or rounding. There may be instances in which not all accounts are charged the same commission or commission equivalent rates in an aggregated order, including restrictions under applicable law on the use of client commissions to pay for rese to pay for research services included in the aggregated order pay commissions at “execution the total commission rates paid by t hose Advisory Accounts that use commissions to pay for research services. DIMA does not always bunch or aggregate orders for different accounts if aggregating is not appropriate or practicable from DIMA’s operational or other perspectives or if doing so would not be appropriate in light of applicable regulatory considerations. F or example, trading instructions, cash flows, separate portfolio management processes, among other factors may result in orders in the same security not being bunched or aggregated. This may result in DIMA placing orders in the same instrument for differen t accounts at different times. s, th e y Certain orders may be auto -routed electronically for execution and as such may not be aggregated with other orders. There may be instances in which other DIMA client orders for the same security are being placed through a broker and, in those instance auto-routed and the direct orders may theoretically compete against each other in the market. Prices and availability of a securit may differ depending on whether an order was auto routed or aggregated, and this may result in certain Advisory Accounts receiving more or less favorable prices than the other Advisory Accounts in contemporaneous trades. rders. Certain affiliated advisers of DIMA may utilize DIMA’s trading desk to facilitate the routing and execution of their client o In such cases, DIMA’s trading desk will execute these client orders along with DIMA client orders in the manner described above. rs. In liate DIMA may also utilize the trading desks of certain affiliated advisers to facilitate the routing and execution of client orde such cases, consistent with its best execution obligations, the affiliate advisers will execute these orders along with affi orders in the manner described above so as to treat all Advisory Accounts in a fair and equitable manner. Research and Soft Dollar Benefits -dealer might charge for executing the same transaction in order -dealers that provide research and research and brokerage services itself. As a result, DIMA has an -dealer based on its interest in receiving the research and brokerage services from n receiving the best commission rate. As a result, DIMA must -dealers are reasonable in relation to the value of the DIMA is permitted by Section 28(e) of the Securities Exchange Act of 1934, as amended (such Act, the “1934 Act” and such Section, the “Sec. 28(e) Safe Harbor”) when placing securities transactions for an account, to cause the account to pay brokerage commi ssions in excess of that which another broker to obtain research and brokerage services if DIMA determines that such commissions are reasonable in relation to the overall services provided. DI MA may from time to time execute portfolio transactions with broker brokerage services to DIMA. When DIMA uses client commissions to obtain research and brokerage services, DIMA receives a benefit because it does not have to produce or pay for the incentive to select or recommend a broker that broker -dealer, rather than solely on its clients’ interest i determine in good faith that the non -execution costs paid to broker research and brokerage services received by DIMA. Research services provided by brokers to DIMA may include, but is not limited to, information on the economy, industries, groups of securities, individual companies, statistical information, accounting and tax law interpretations, political \ 76  Form ADV Part 2A DWS Investment Management Americas, Inc. dit parties if developments, legal developments affecting portfolio securities, technical market action, pricing and appraisal services, cre analysis, risk measurement analysis, performance analysis and measurement and analysis of corporate responsibility issues. Thes e research services are typically received in the form of written reports, telephone contacts and personal meetings with security analysts. Research services may also be provided in the form of market data services, and meetings arranged with corporate and industry representatives. Research and brokerage services may include products obtained from third DIMA determines that such product or service constitutes brokerage and research as defined in Section 28(e) and interpretations thereunder. -dealer ll - dealer -making process by, among other things, These research and brokerage services may be bundled with the trade execution services provided by a particular broker and subject to applicable law, DIMA may pay for such research and brokerage services with client commissions. Transactions wi not always be executed at the most favorable available commission and DIMA may cause clients to pay commissions higher than those charged by other broker -dealers as a result of the research and brokerage services received by DIMA to service its clients. DIMA participates in “commission sharing arrangements” under which DIMA may execute transactions through a broker and request that the broker -dealer allocate a portion of the commissions or commission credits to another firm that provides research to D IMA. DIMA believes such arrangements are useful in its investment decision ensuring access to a variety of research, access to individual analysts and availability of resources that DIMA might not be provided absent s uch arrangements . Due to European regulatory changes affecting DIMA and certain of its affiliates, beginning in January 20218, certain clients no longer participate in the client commission sharing arrangement described above. ts which Clients may differ with regard to whether and to what extent they pay for research and brokerage services through commissions. As a result, brokerage and research services may disproportionately benefit some clients relative to other clien based on the relative amount of commissions paid by the clients and in particular those clients that do not pay for research and brokerage services. DIMA has implemented certain controls and processes designed to oversee and secure to its satisfaction substantially eq uivalent outcomes by putting in place processes to establish maximum budgets for research costs and allocating research costs based on assets that are participating in the commission sharing arrangements. DIMA will switch to execution only commissions when m aximums are met and will pay for research services with its own assets. While DIMA seeks to estimate its research budget in good faith, the actual costs of such research may be higher or lower than budgeted, raises conflicts of interest in estimating such budgets. Trading and Broker Restrictions execut ed -dealer ("Designated Broker"); (ii) requiring trades or executing commissions to be s Clients may limit DIMA’s authority by prohibiting or by limiting the purchasing of certain securities or industry groups. In addition, a client may further limit DIMA’s authority by (i) requiring that all or a portion of the client's transactions be through the client's designated broker stepped out or given up to a client’s designated broker; and/or (ii) restricting DIMA from executing the client's transaction through a particular broker - dealer. client -dealers to execute Directed/Restricted Brokerage, DIMA may be unable to o btain ons, egated ve less In situations where a client directs or restricts brokerage for their accounts ("Directed/Restricted Brokerage"), because the has placed limitations on the selection of broker "best execution" for such trades. Similarly, where a client directs DIMA to use a particular counterparty for swaps, OTC opti etc., DIMA may be unable to obtain best execution for such trades. Furthermore, Directed/Restricted Brokerage may not be aggregated or "blocked" for execution with transactions in the same securities for other clients and may trade after the aggr trades and/or directed trades for other DIMA clients. As a result, such clients may have to pay higher commissions or recei favorable net prices than would be the case if the clients had participated in the aggregated trading order and DIMA were authorized to choose the broker through which to execute transactions for such Advisory Accounts. ands ed solely to In agreeing to satisfy a client's directions to execute transactions for its account through Designated Brokers, DIMA underst that it is the client's responsibility to ensure that: (i) all services provided by the Designated Brokers (a) will be provid the client's account and any beneficiaries of the account, (b) are proper and permissible expenses of the account, and may properly be provided in consideration for brokerage commissions or other remuneration paid to the Designated Brokers, (ii ) using \ 77  Form ADV Part 2A DWS Investment Management Americas, Inc. count, bligations ary and its on behalf and third parties the Designated Brokers in the manner directed is in the best interest of the client's account and any beneficiaries of the ac taking into consideration the services provided by the Designated Brokers, (iii) its directions will not conflict with any o persons acting for the client's account may have to the account, its beneficiaries or any third parties, including any fiduci obligations persons acting for the account may have to obtain the most favorable price and execution for the account beneficiaries; and (iv) persons acting for the client's account have requisite power and authority to provide the directions of the account and have obtained all consents, approvals or authorizations from any beneficiaries of the account that may be required under applicable law or instruments governing the account. \ 78  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 13 / Review of Accounts Regular reviews of accounts in each strategy vary in frequency and are tailored to the specific facts and circumstances applicable to the various investment strategies. Portfolio managers review accounts on an ongoing basis to ensure investments are approp riate and DWS’ Investment Guideline Management team uses both automated and manual processes to monitor portfolios in accordance with their stated portfolio investment guidelines, restrictions, and other regulatory requirements. Daily: Traders perform daily trade reviews to ensure that records are accurate and complete. Daily trade reviews are also completed by the portfolio managers who review and verify that orders were executed in accordance with the trading instructions. – Brokerage s on all trading errors . In addition , IROC monitors products/portfolio’s investment d Monthly: IROC is responsible for providing oversight of DIMA’s investment performance, investment risk, investment compliance, brokerage practices, composite change process, liquidity risk management, valuation process, proxy voting activities, sub - adviso ry oversight, derivatives trading oversight and any other areas they may be deemed appropriate. DIMA also has policies and procedures in place to address trade errors and the BPSC (as described under Item 12 Practices) receives monthly report risk profiles against defined limits, conducts annual product reviews, and reviews investment compliance violations identifie by DWS Compliance. by Annually: In addition to the aforementioned trade reviews, institutional account reviews are also performed at least annually DIMA Client Services. DIMA may actively participate in a client's Board and Investment Committee presentations as well as provi de regular performance reviews to the client. Reports to Clients ith holdings The nature and frequency of reports to clients is primarily determined by the particular needs of the client, as negotiated w the client. Written client account reports are generally sent to clients on at least a quarterly basis and generally include in the account with relevant transactions. Clients are also advised in writing or via telephone conversation of any material investment changes in their portfolio and per the individual client's requirements. Wrap fee and non -wrap fee advisory programs: -wrap fee advisory clients. Third -party program sponsors also typically issue performance -wrap fee Third -party program sponsors will receive market commentaries prepared by DIMA upon request and may send such commentaries onto wrap fee and non reports to clients on a quarterly basis. In addition, DIMA personnel who are knowledgeable about wrap fee and non advisory programs will be reasonably available to the third -party program sponsors for consultation. \ 79  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 14 / Client referrals and Other Compensation -affiliates for client referrals in accordance with Rule 206(4) -1 under the Advisers Act. The es of ivision. DIMA compensates affiliates or non compensation paid to any such entity will typically consist of a payment stated as a percentage of the advisory fee. Affiliat DIMA and/or third parties who refer or help solicit investment advisory clients may also be compensated based on a percentage of the investment advisory fee charged to that client. Employees of DIMA and/or related persons to DIMA may be compensated purs uant to the Firm’s approved compensation structure(s) which may take into account a variety of factors including profitability of DWS, profitability of the division, and contributions of that individual to the successes of the d For the avoidance of doubt, compensation structure is never exclusively driven by sales targets or acquisition of specific clients. When required under the law, the policies and procedures require regulatory disclosure of the compensation arrangement between DIMA and the re ferring party. . DIMA may be referred advisory clients by unaffiliated consultants that are retained by existing or prospective clients. These consultants may advise existing or prospective clients whether to engage or retain the services of DIMA as investment adviser Additionally, while payments are not made in connection with any advisory client referral such as these, DIMA may make payments to investment consultants in order to attend industry -wide conferences sponsored by these consultants. Client Testimonials and Surveys DIMA ’s From time to time, DIMA may include testimonials statements from current clients regarding their experience with our services in marketing materials, including information received in response to client satisfaction surveys . ary. . Clients are not compensated, directly or indirectly, for providing these testimonials, and participation in surveys is volunt Testimonials are not representative of the experience of all clients and are not a guarantee of future performance or success The experiences described in testimonials may not be indicative of future results. \ 80  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 15 / Custody . DIMA’s clients appoint their own qualified custodians who are unaffiliated with DIMA . DIMA DIMA does not hold client assets is not involved in the client’s selection or ongoing monitoring of client custodians. -party custodians selected by the client may appoint subsidiaries of the Deutsche -2 of the Advisers Act as a result of In the majority of cases, DIMA invoices its clients for fees. However, there may be instances where DIMA For example, with . As a result, DIMA has policies and procedures in place to address this -2 of the Advisers Act . In addition, DIMA’s clients receive statements from their qualified custodian at least on . Comparing statements may allow clients to determine whether account In certain limited circumstances, the third Bank Group as a sub -custodian, for example, for foreign stocks or currencies in jurisdictions where the client’s custodian does not operate. Subsidiaries of the Deutsche Bank Group that are not subsidiaries of the DWS Group are operationally independent of DIMA; as such, DIMA is not in custody of client assets under Rule 206(4) these arrangements. deducts a fee without invoici ng the client . In these limited instances DIMA may be deemed to have custody. respect to its dual contract retail SMA arrangements, DIMA may have limited authority to withdraw its advisory fee directly from a client’s account subject to various conditions under Rule 206(4) a quarterly basis . Clients are enco uraged to review these statements carefully and compare statements received from DIMA with statements received from the qualified custodian transactions are proper . DIMA also instructs clients to contact their client service representative at their qualified custodian if they are not receiving statements from their custodian at least on a quarterly basis. -party program sponsor, or a qualified . DIMA is not involved in the selection or ongoing monitoring of The assets of wrap account clients and Retail SMA accounts are custodied with the third custodian selected by the third -party program sponsor or client client custodians for wrap account clients and Retail SMA Accounts . \ 81  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 16 / Investment Discretion -discretionary basis. Such advisory services are . For discretionary clients, the IAA grants DIMA the authority Generally, DIMA offers investment advisory services on a discretionary or non governed by a written IAA established between a client and DIMA to make investment decisions and effect portfolio transactions on behalf of the client without prior notice, consultation, or consent. the -dealers, see Item 12 of this Brochure for more information) through . For DIMA Advised Funds, DIMA’s authority to trade securities may also be In making decisions as to which securities are to be bought or sold and the amounts thereof, DIMA is guided by a client’s investment guidelines, objectives, and any limitations (such as certain securities not to be bought or sold) as set forth in relevant IAA . In accordance with an applicable IAA, DIMA's authority could include the ability to select brokers and dealers (or may impose certain limitations on DIMA’s use of broker which to execute t ransactions on behalf of its clients limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Where permitted by applicable law and a relevant IAA, DIMA may delegate investment management authority for all or a portion of a client's accounts to an affiliate, including affiliates that may be outside the U.S. \ 82  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 17 / Voting Client Securities y. oted DIMA has proxy voting responsibility for an advisory account as indicated in the IAA, or pursuant to other delegated authorit DIMA has adopted a proxy voting policy and procedure that includes specific proxy voting guidelines (“Guidelines”) which set forth the general principles DIMA uses to determine how to vote proxies for issuers in Advisory Accounts for which DIMA has proxy voting responsibility. DIMA believes that the Guidelines are reasonably designed to ensure 1) that client proxies are v in th e best economic interests of clients and 2) that material conflicts of interest are avoided and/or resolved in a manner consistent with DIMA’s fiduciary duties under applicable law. The Guidelines set forth standard voting positions on a comprehensive list of common proxy voting matters. Guidelines are monitored and periodically updated based on considerations of current corporate governance principles, industry standards, client feed back, and the impact of the matter on issuers and the value of the investments, among other considerations. DIMA has engaged a third -party proxy voting service (the “Proxy Service”) to assist in the implementation of certain proxy voting - related functions, including, without limitation, operational, recordkeeping and reporting services. The Proxy Service also p repares recommendations for each proxy that reflects its application of the Guidelines to a particular proxy issue. The Proxy Service uses the Guidelines adopted by DIMA when providing proxy related services to DIMA. -Committee (“PVSC”) and voted in accordance with what the - ished within DIMA, monitors for potential material conflicts of interest in connection with proxy proposals . The information considered by the Conflicts of Interest Management Sub -Committee may the -Comm ittee or brought to the attention of that sub -committee; and (iii) any (or anyone participating or providing information to the PVSC) and any person an the event that the Conflicts of Interest Management Sub -Committee determines (i) obtain instructions as to how the proxies should be voted, if time s Under normal circumstances, DIMA will generally vote proxies in accordance with the Guidelines. Any proxy vote that is not covered by the Guidelines or is one in which DIMA believes that voting in accordance with the Guidelines may not be in the best inter ests of clients, will be evaluated by the Proxy Voting Sub PVSC, in good faith, determines to be the best economic interest of the clients. The Conflicts of Interest Management Sub Committee, establ that are to be evaluated by the PVSC include without limitation information regarding: (i) DIMA client relationships; (ii) any relevant personal conflict known by Conflicts of Interest Management Sub communications with members of the PVSC outside or within the organization (including Deutsche Bank Group and its affiliates) or any entity that identifies itself as Advisory Client regarding the vote at issue. In that there is a material conflict of interest, DIMA will either permits, from the affected clients; or (ii) vote the proxies in accordance with the standard Guidelines. It is possible that actual proxy voting decisions by DIMA in respect of a particular client may benefit DIMA’s other clients or businesses of DIMA or it affiliates, provided DIMA’s proxy voting decisions are made in accordance with its fiduciary responsib ilities and are independent of such considerations. e . In addition, if DIMA -end fund or business -4 of the Investment m feeder funds will be are voted in accordance with applicable provisions of DIMA may have voting discretion with respect to accounts that own securities issued by DWS, its affiliates (including Deutsch Bank Group itself) or pooled investment vehicles managed by DIMA or its affiliates. In circumstances in which DIMA has discretion to vote proxies with respect to such securities, DIMA will generally vote proxies pursuant to an echo voting arrangement under which shares are voted in the same manner and proportion as shares for which DIMA does not have voting discretion. For markets w here echo voting is not permitted, DIMA will abstain from voting such shares Advised Funds (including an ETF advised by DIMA or an affiliate together with Advisory Clients, in aggregate, (i) hold more than 25% of the outstanding voting securities of an investment company that is not a registered closed development company, or (ii) hold more than 10% of the outstanding voting securities of an investment company that is a registered closed -end fund or business develo pment company, then DIMA will vote its holdings in such DIMA Advised Fund’s securities in the same proportion as the vote of all other holders of such securities as required by Rule 12d1 Company Act and Master Fund proxies solicited fro Section 12 of Investment Company Act. Determinations by DIMA as to whether and how to vote proxies with respect to \ 83  Form ADV Part 2A DWS Investment Management Americas, Inc. create a conflict securities issued by DWS, its affiliates or pooled investment vehicles managed by DIMA or its affiliates between the interests of DWS and DIMA, on the one hand, and clients on the other hand. client r f For clients who have delegated proxy voting responsibilities to DIMA, it is the custodian’s fiduciary responsibility to send proxy materials to DIMA. Clients who have delegated proxy voting responsibilities to DIMA may from time to time contact thei client service representatives to direct as to how to vote certain proxies on behalf of their accounts. DIMA will use its commercially reasonable efforts to vote according to the client’s request in these circumstances. Clients can obtain a copy o the G uidelines, or information about how DIMA voted proxies with respect to securities held in their account(s), by calling their client service representative. ith -party proxy service provider, Institutional , If a client chooses not to delegate proxy voting authority to DIMA, the right to vote securities is retained by the client. W respect to certain discretionary model portfolio programs, where the underlying client of such program has delegated proxy voting authority to DIMA, DIMA has in turn, delegated proxy voting authority to a third Shareholder Services Inc. (“ISS”), who will vote such proxies in accordance with its own proxy voting guidelines. In so doing these proxies may not be voted in line with recommendations/votes that would be made in connection with other clients of DIMA. \ 84  Form ADV Part 2A DWS Investment Management Americas, Inc. Item 18 / Financial Information This section is not applicable. \ 85  Form ADV Part 2A DWS Investment Management Americas, Inc. Additional Disclosures Business Continuity DIMA is committed to protecting its staff and ensuring the continuity of critical DIMA businesses and functions in order to protect DWS. It is DIMA’s policy that every unit of DIMA develops, implements, tests, and maintains appropriate, comprehensive, and verifiable Business Continuity and Disaster Recovery strategies and plans in compliance with the goals and planning assumptions as define d by the policy. Legal Proceedings and Corporate Actions -advised accounts) in any Proceedings" include, but are not o such a ts trustee and/or designated custodia n of Legal Proc eedings: DIMA does not act on behalf of client separately managed accounts (including sub legal proceeding involving assets managed by DIMA (and/or transactions effected for). "Legal limited to, class actions, insolvency filings, SIPC filings and settlement filings. If DIMA receives documentation relating t legal proceeding, where practicable, DIMA will forward the documentation to the client, i record. DIMA, on behalf of the DIMA Advised Funds, will determine whether or not to participate in Legal Proceedings on behalf of the DIMA Advised Funds, subject, with respect to certain Legal Proceedings, to approval by the Board of Directors/Trustees of a DIMA Advised Fund that is a registered investment company. their behalf with respect to such actions. DIMA, Corporate preclude DIMA from Corporate Actions: With respect to corporate actions (“ Corporate Actions ”), as with all investment decisions, DIMA will seek approval from non -discretionary separately managed account clients to act on on behalf of the discretionary accounts and the DIMA Advised Funds, will determine whether or not to participate in Actions. Delays in receiving client consent, the length of time between notice of a Corporate Action and the deadline for required fili ngs in order to participate in the Corporate Action, time zone differences, or other factors could acting on behalf of a client or the DIMA Advised Funds in a Corporate Action. Know Your Customer (“KYC”) Policy h person To help the government fight the funding of terrorism and money laundering activities, U.S. laws require certain covered financial institutions to obtain, verify, and record information that identifies each person and verifies the identity of eac who opens an account. KYC duties also mandate the on -going monitoring of relevant customer information. -Money Laundering and Know Your Client Policy (the “ DB AML Program”) , which DWS Group is subject to the DB Group Anti appl ies to all DWS Group legal entities, including DIMA. In addition, DIMA has adopted the DWS U.S. Bank Secrecy Act and Anti -Money Laundering Compliance Program (the “DWS AML Program”). KYC and CIP Policies are significant components of the DB AML Program and the DWS AML Program. These Programs include: — Obtain ing at a minimum certain information such as an individual’s name, address, date of birth and social security number and a driver’s license, passport, or other identity verification document. For Legal entities, it would include their formation documents and tax identification number. Information about the beneficial owners of legal entities may also be obtained. — Based upon its assessment of the level of risk, DIMA collect ing as much information as it deems appropriate as well as request the source of funds and purpose of the investment. s — KYC includes screening new and existing customers against applicable sanctions lists published by the Office of Foreign Asset Control (“OFAC”), European Union, as well as the United Nations. In addition, screening is completed against lists of persons \ 86  Form ADV Part 2A DWS Investment Management Americas, Inc. ica and/or legal entities compiled by the U.S. Department of Treasury pursuant to Title III of the Uniting and Strengthening Amer by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (“U.S. Patriot Act”) — KYC includes identifying customers unlawfully engaged in the internet gambling business under Regulation GG, the Unlawful Internet Gambling Enforcement Act of 2006. — KYC requires periodic review and update of a customer’s KYC information and screening against appropriate lists. — A customer’s refusal to provide KYC information can result in a decision to decline entering into a new client relationship o r a decision to exit an existing customer relationship. Privacy Notice “GLBA ”), enacted in 19 89, imposes requirements on financial institutions to clearly disclose The Graham Leach Bliley Act (the how they collect, share and protect consumers nonpublic personal information and mandates privacy notices addressing such requirements. DIMA and its affiliates have created a privacy notice addressing GLBA which can be found at: Privacy Notice . , which became effective January 1,2020 , imposes privacy DWS California Consumer Privacy Disclosure and its affiliates have created a . Other states The California Consumer Privacy Act, as amended (the “CCPA”) compliance obligations with regard to the personal information of California residents. DIMA separate privacy notice addressing CCPA which can be found at: may, in the future, impose similar privacy compliance obligations. \ 87  The brand DWS represents DWS Group GmbH & Co KGaA and any of its subsidiaries such as DWS Investment Management Americas, Inc., which offers investment advisory services. © 202 6 DWS Group GmbH & Co. KGaA. All rights reserved.