J.P. MORGAN SECURITIES LLC

A. Broker-Dealer Registrations ......................................................... 10 B. Futures/Commodities-Related Registrations ................................ 10 C. Material Relationships with Related Persons and Potential Conflicts of Interest ..................................................................................... 10 ITEM 11 — CODE OF ETHICS, PARTICIPATION, OR INTEREST IN FORM ADV PART 2A FIRM BROCHURE INSTITUTIONAL CONSULTING SERVICES PROGRAM CLIENT TRANSACTIONS AND PERSONAL TRADING ................... 11 A. Code of Ethics ............................................................................... 11 B. Securities in Which JPMS or a Related Person Has a Material J.P. Morgan Securities LLC Financial Interest .......................................................................... 11 February 5, 2026 C. When JPMS or a Related Person Invests in the Same Securities That It Recommends ..................................................................... 11 270 Park Avenue New York, NY 10017 (212) 270-6000 jpmorgan.com/adv This investment advisory brochure (Brochure) provides information about the qualifications and business practices of J.P. Morgan Securities LLC (JPMS or the Firm) and the Institutional Consulting Services program (the Program). If you have any questions about the contents of this Brochure, contact us at (212) 270-6000. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. D. When JPMS or a Related Person Buys/Sells Securities for Itself at or About the Same Time It Recommends the Same Securities to/for Clients................................................................................. 12 ITEM 12 — BROKERAGE PRACTICES .................................................. 12 ITEM 13 — REVIEW OF ACCOUNTS ..................................................... 12 ITEM 14 — CLIENT REFERRALS AND OTHER COMPENSATION .......... 12 A. Economic Benefits for Providing Services to Clients ..................... 12 B. Compensation to Non-Supervised Persons for Client Referrals .... 13 ITEM 15 — CUSTODY .......................................................................... 13 ITEM 16 — INVESTMENT DISCRETION ............................................... 13 ITEM 17 — VOTING CLIENT SECURITIES ............................................ 13 ITEM 18 — FINANCIAL INFORMATION ............................................... 13 ITEM 4 — ADVISORY BUSINESS Additional information about JPMS also is available on the SEC’s website at adviserinfo.sec.gov. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. A. Description of Advisory Firm ITEM 2 — MATERIAL CHANGES This is the initial Brochure for the Program and should be read in its entirety. ITEM 3 — TABLE OF CONTENTS JPMS is a subsidiary of J.P. Morgan Broker-Dealer Holdings Inc. and an indirect, wholly owned subsidiary of JPMorgan Chase & Co. (JPMC), a publicly held financial services holding company. JPMC and its affiliates (together, J.P. Morgan) are engaged in a large number of financial businesses worldwide, including banking, asset management, securities brokerage, and investment advisory services. JPMS is registered as a broker-dealer and investment adviser with the SEC and is a member of the Financial Industry Regulatory Authority (FINRA). JPMS and its affiliates’ investment advisory services include sponsoring a variety of advisory programs and providing certain consulting services to defined contribution plan sponsors and institutional clients. JPMS offers investment advisory services through several separate sales channels. ITEM 2 — MATERIAL CHANGES ............................................................. 1 ITEM 3 — TABLE OF CONTENTS ............................................................ 1 ITEM 4 — ADVISORY BUSINESS ............................................................ 1 A. Description of Advisory Firm ........................................................... 1 B. Description of Advisory Services ..................................................... 2 C. Availability of Customized Services ................................................. 3 D. Wrap Fee Program .......................................................................... 3 E. Limitation of the Services ............................................................... 3 F. Other Investment Advisory Programs ............................................. 3 G. Assets Under Management ............................................................. 3 ITEM 5 — FEES AND COMPENSATION .................................................. 4 A. JPMS Compensation and Fees ......................................................... 4 B. Billing of Fees ................................................................................. 4 C. Other Fees and Expenses ................................................................ 4 D. Advance Payment of Fee ................................................................. 4 E. Wealth Advisors Compensation ....................................................... 4 ITEM 6 — PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................................................. 4 ITEM 7 — TYPES OF CLIENTS ................................................................ 4 ITEM 8 — METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND This Brochure provides information about JPMS and the Program that is made available as a pilot program through a limited number of “Wealth Advisors” or “Wealth Partners” (collectively referred to herein as Wealth Advisors and each, a Wealth Advisor), each of whom is a representative of JPMS. Information about other investment advisory services that JPMS provides is contained in separate brochures, which can be obtained from your Wealth Advisor or at the SEC’s website at adviserinfo.sec.gov. JPMS chase.com/managed-account- also maintains a separate website, disclosures for clients of Private Client Advisors and jpmorgan.com/adv for Wealth Advisor clients, that contains the wrap fee program brochures and other important disclosures, including advisory brochures for J.P. Morgan Private Investments Inc. (JPMPI). For purposes of this Brochure, “Client” or “you” refers to the institutional client, as named in the Client Agreement (as defined below), and “we” and “our” refer to JPMS. RISK OF LOSS ............................................................................... 4 A. Methods of Analysis and Investment Strategies ............................. 4 B. Material, Significant, or Unusual Risks Associated with Certain Investments in the Program............................................................ 5 C. Risks Associated with Particular Types of Securities ....................... 8 ITEM 9 — DISCIPLINARY INFORMATION .............................................. 8 A. Criminal or Civil Proceedings .......................................................... 8 B. Administrative Proceedings Before Regulatory Authorities and Self-Regulatory Authorities ............................................................. 8 ITEM 10 — OTHER FINANCIAL INDUSTRY ACTIVITIES AND Investing in securities involves risk of loss that Clients should be prepared to bear. The investment performance and success of any particular investment cannot be predicted or guaranteed, and the value of a Client’s investments will fluctuate due to market conditions and other factors. Investments are subject to various risks, including, but not limited to, market, liquidity, currency, economic, and political risks, and will not necessarily be profitable. Past performance of investments is not indicative of future performance. AFFILIATIONS ............................................................................ 10 INVESTMENT AND INSURANCE PRODUCTS ARE: • NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, JPMORGAN CHASE BANK, N.A. OR ANY OF ITS AFFILIATES • SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED 33825_COL 02-05-2026 Page 1 of 13  B. Description of Advisory Services in this Program takes JPMS and its affiliates offer other managed products or wrap programs that provide asset allocation advice. The asset allocation advice provided to accounts in those programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program. This is due to, among other things, the fact that the asset allocation advice provided into consideration multiple accounts, including accounts that are held away from and/or not managed by JPMS and its affiliates. In contrast, the other managed products or wrap programs generally will only consider such external assets for purposes of determining the asset allocation of the particular account managed under those programs. Within the Program, JPMS provides a range of non-discretionary investment consulting services (Services) to institutional Clients, including (i) asset allocation advice; (ii) investment manager, strategy, private fund, mutual fund, and exchange traded fund (ETF, and together with private funds and mutual funds, Funds, or each, a Fund) product searches and recommendations; and (iii) performance reporting. These services will be delivered through a select group of Wealth Advisors located across the country that have significant experience serving the investment advisory needs of institutional Clients and are supported by a management team dedicated to institutional consulting. the JPMS Institutional Consulting Services Agreement • Investment Product Searches and Recommendations. Your Wealth Advisor will assist you in identifying, evaluating, and recommending investment managers, strategies, and Funds (collectively, Investment Products) that meet JPMS’ due diligence standards (Eligible Strategies). As a general matter, your Wealth Advisor recommends Eligible Strategies based on a variety of factors, including investment styles available in the marketplace, platform capacity, Client demand, and the outcome of due diligence reviews. The initial and periodic reviews of Eligible Strategies are performed through an investment review conducted by the manager solutions team of JPMPI or its affiliates (refer to Methods of Analysis, Investment Strategies, and Risk of Loss for further information). The specific Services being provided are agreed to by the Client and JPMS (Client in Agreement). JPMS’ relationship with Clients becomes effective as detailed in the applicable Client Agreement. Any preliminary discussions that take place before the Client Agreement is effective are not intended, and should not be relied upon, as investment or other fiduciary advice. By participating in the Program, you acknowledge that the Services we are providing in the Program are non-discretionary and that you have retained, and will exercise, final decision-making authority and responsibility for all matters concerning the investment portfolio (Portfolio) as well as for the selection of any investment manager or Fund and implementation of any investment strategy resulting from the Services provided under the Client Agreement. The Services do not include brokerage recommendations or execution services. JPMS and the Wealth Advisors are acting solely in their investment advisory capacity in connection with any advice or recommendations provided as part of the Services. 1. Institutional Consulting Services JPMS offers the following Services to its Clients: Your Wealth Advisor and JPMS will base their recommendations on your investment goals and objectives, as well as on information gathered from you, to recommend one or more Eligible Strategies (refer to Limitation of the Services). It is your responsibility to negotiate directly with independent third-party investment managers (not retained through any investment advisory program offered by JPMS and its affiliates) the terms of any investment manager agreement and applicable fees. You may select an Investment Product (or continue the use of an Investment Product) without receiving a recommendation from JPMS. Clients may select Investment Products that are not covered by JPMS or its affiliates. JPMS does not evaluate or make any representations concerning such Investment Products and does not assume any liability for any loss, claim, damage, or expense attributable to Client’s selection of Investment Products that are not covered by JPMS or its affiliates. • Asset Allocation Advice. Your Wealth Advisor will review your current asset allocation and will provide a written report that includes asset allocation recommendations in accordance with your investment goals and objectives. Under this service, sophisticated computer models are used to construct asset allocations and to project potential ranges of returns and market values over various time periods and using various cash flows. The modeling uses our forward-looking capital market assumptions of risk, return, and correlations for the different asset mixes (refer to Methods of Analysis, Investment Strategies, and Risk of Loss — Methods of Analysis and Investment Strategies - Asset Allocation Advice for further information). The asset allocation advice is provided as of the date stated on the written report. It is your responsibility to select the final asset allocation and to determine whether to implement any asset allocation strategy. After you select an asset allocation, it is important that you periodically review your Portfolio’s actual asset allocation to verify that it remains in line with your investment guidelines. JPMS and its affiliates offer other managed products or wrap programs. Recommendations provided to accounts in those programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including advice related to the recommendation of certain Investment Products. This is due to, among other things, the differing nature of the other investment advisory services and differing processes and criteria upon which the selection or recommendation of particular Investment Products are made. • Performance Reporting. JPMS provides Clients with customized performance reports that assess their Portfolio’s performance relative to benchmarks. The reports may include comparisons to recognized benchmarks and market segments. We will rely upon the data supplied by your custodian or third-party investment manager in preparing the report. JPMS will not be held responsible for the accuracy of the data provided by your custodian (if other than JPMS), or third-party investment manager. We also use outside information sources in preparing the report, including computer and data analysis firms. This information is obtained from sources believed to be reliable. We will also periodically report to you, in writing, the actual asset allocation of your Portfolio relative to the asset allocation you selected for your Portfolio. Your Portfolio’s actual asset allocation may deviate from the asset allocation you selected for many reasons, such as market movements, additions, and withdrawals of assets from your Portfolio, changes in investment managers and strategies, and the purchase and sale of certain securities within those investment strategies. Your Wealth Advisor will review your Portfolio’s actual asset allocation with you on a periodic basis (at least annually) and may recommend changes to the asset allocation based on that review. We will not monitor the asset allocation for your Portfolio on an ongoing basis or make any adjustments to that asset allocation strategy without your prior consent. You should notify JPMS of any change in your Portfolio’s investment goals, risk tolerance, guidelines, restrictions, or similar information as such change may change our asset allocation recommendation to you. Performance information from third-party sources or performance reports provided by JPMS for accounts enrolled in other JPMS investment advisory programs may differ from that shown in the report. These differences may be due to different methods of analysis, different pricing sources, treatment of accrued income or different 33825_COL 02-05-2026 Page 2 of 13  E. Limitation of the Services accounting procedures. For example, infrequently traded fixed- income securities may be priced according to yields calculated on a matrix system, which may vary among pricing sources. As another example, if sufficient data is available and the reports are prepared on a trade date basis, their performance information may differ from reports prepared on a settlement date or other basis. Universe of Investment Managers and Strategies. Investment managers, strategies, and Funds recommended for your Portfolio are limited to Eligible Strategies. Our recommendations therefore will not include every investment manager, investment strategy, or Investment Product option available in the industry, including investment strategies offered through other JPMS investment advisory programs. Legal, Tax, and Accounting Advice. JPMS and its affiliates do not provide legal, tax, or accounting advice. The Client is responsible for, and should consult with, its legal and tax professionals about those matters. You should use the report to evaluate your investments and progress towards your investment goals. Your Wealth Advisor will be available to assist you in understanding the format and content of the report, which includes graphic and tabular presentations of performance, and will assist you in reviewing and evaluating the reports. Performance reporting is not intended to replace written confirmation of securities transactions and account statements provided by the broker-dealer or custodian responsible for holding the relevant assets. JPMS. The alternative Information Provided by Clients. JPMS will rely on information provided by Clients without further verification. Clients are responsible for notifying JPMS promptly, in writing, of any changes to the information that the Client previously provided to JPMS and for providing JPMS with additional information as JPMS may request from time to time. Clients must notify JPMS promptly of any material changes in the Client’s financial condition, risk tolerance, needs, or objectives. JPMS has no liability for a Client’s failure to provide JPMS with accurate or complete information or to inform JPMS promptly of any change in information previously provided. information provided is based upon Third-Party Information. JPMS relies on third-party information, including publicly available information, in providing the Services. While JPMS believes the information is accurate, JPMS does not independently verify or guarantee the accuracy of the information. F. Other Investment Advisory Programs JPMS may provide Clients with alternative investments performance reporting. This may include periodic reports that provide historical performance reporting of alternative investments that were not purchased through JPMS, are not held in custody by JPMS and are not investment historical researched by performance information provided, directly or indirectly, to JPMS by the issuer of the alternative investment or by its sponsor, investment manager, or administrator (Performance Reporting AI). JPMS’ ability to provide historical or other performance reporting on alternative investments is dependent upon its ability to obtain such information from each Performance Reporting AI and is not independently verified by JPMS. JPMS is not liable for any misstatement or omission made by the Performance Reporting AI nor for any loss, liability, claim, damage, or expense arising out of such misstatement or omission. We offer other investment advisory programs as well as incidental advice as a broker-dealer. We also offer general information not directed to and not tailored to the specific needs of any individual or individual clients in the form of publications or research. More information about these programs and services is contained in the applicable JPMS disclosures and brochures (or the applicable JPMS Form ADV Part 2A) and is available upon request or through the SEC’s website at adviserinfo.sec.gov/. This reporting service does not constitute investment advice or a recommendation by JPMS of any alternative investment, and JPMS is not evaluating the appropriateness of the initial investment or the continued investment in the alternative investments reported on as part of this service. JPMS is not responsible for and will not provide tax reporting with respect to any alternative investment reported on under this service. 2. Termination The Client Agreement may be terminated at will by either party by giving notice as described in the Client Agreement. Termination of the Client Agreement will not affect the liabilities or obligations of the parties under the Client Agreement that arise prior to termination. Upon termination, JPMS has no further obligation to provide Services to the Client. 3. Wealth Advisors You may elect to engage an investment manager or strategy or purchase an Investment Product recommended by us or an affiliate through another investment advisory program or brokerage account offered by JPMS or its affiliates (Other J.P. Morgan Programs). Your Program Fee will not be applied to any portion of your Portfolio that is invested based on advice and/or recommendations provided through these Other J.P. Morgan Programs. Instead, you will be charged the advisory fees, brokerage commissions, or other expenses set forth in the agreements that govern your participation in the Other J.P. Morgan Programs. The services provided under the Other J.P. Morgan Programs, including the profiling process, guidelines, fee calculation, and billing methodology will differ from that of this Program. Further, the advice and/or recommendations provided in these Other J.P. Morgan Programs will be different from, or even conflict with, the advice and guidance provided in connection with this Program, including advice related to the recommendation of certain Investment Products. For more information about those programs, please review the applicable disclosures and brochures as described above. Wealth Advisors who provide Services are registered representatives and investment adviser representatives. Wealth Advisors who provide Services receive training on the Program, Program guidelines and policies, and other information essential to advising Program Clients. JPMS is not bound by the standards of conduct of any professional organizations of which its Wealth Advisors are members or entities that have authorized Wealth Advisors to use designations or certifications. C. Availability of Customized Services The Services are customized based on the individual needs of Clients and their Portfolios. D. Wrap Fee Program If you elect to engage or invest in an Investment Product recommended by us through an Other J.P. Morgan Program and hold assets in a brokerage account at JPMS, you must agree to terms and conditions of the applicable brokerage account agreement. The brokerage account agreement will include terms and conditions for an automatic cash sweep program. An automatic cash sweep program is a program provided as part of your brokerage account agreement whereby cash balances in your brokerage account are automatically swept into a cash sweep option available for your account type that you select (Cash Sweep Option). JPMS will not recommend a Cash Sweep Option as part of the Program. G. Assets Under Management JPMS is the sponsor of several wrap fee programs; however, the Program is not a wrap fee program. In a wrap fee program, Clients pay JPMS a single fee based on the assets they have invested with them. The fee covers investment advisory services and other account-related services, such as trade execution, clearing and settlement services, reporting, and custody services as well as financial planning, when applicable. As of December 31, 2025, JPMS managed $336,305,778,542 on a discretionary basis and $71,398,641,352 on a non-discretionary basis. 33825_COL 02-05-2026 Page 3 of 13  ITEM 5 — FEES AND COMPENSATION JPMS Compensation and Fees A. information for purposes of calculating the Fee. Upon request, JPMS will provide an annual statement that details the amount of Fees the Client has paid to JPMS. C. Other Fees and Expenses The Fee and the specific Services are agreed upon in the Client Agreement. Clients in the Program pay an asset-based fee calculated as a percentage of Portfolio assets for which JPMS provides Services (the Fee). The Fee is charged on total Portfolio assets (i.e., not on a tiered basis). The Fee for the Program are negotiable and are subject to a $25 million Portfolio minimum. The standard fee schedule for the Program is as follows: Portfolio Asset Value* Annual Fee $25 million but less than $50 million 0.30% $50 million but less $100 million 0.25% $100 million but less than $250 million 0.20% $250 million or more Negotiable The Fee does not cover transaction-based charges; commissions or other charges Clients may incur in implementing any investment advice that JPMS provides; certain costs or charges that may be imposed by JPMS or third parties, including custodian fees; or any other services, accounts, or products that JPMS provides to the Client apart from, or in addition to, the Services as agreed upon in the Client Agreement. JPMS may recommend that the Client invest in Funds that have various internal fees and expenses, which are paid by such Funds but ultimately are borne by the Client as a Fund shareholder. These internal fees and expenses are in addition to the Fee JPMS receives from the Client for the Services offered through the Program, and the Client is not entitled to any refund of the Funds’ internal fees and expenses ultimately borne by the Client or other offset against the Fee. D. Advance Payment of Fee Fees are not paid in advance. Refer to Item 5.B. above. *Assets managed by JPMS or its affiliates in a fee-based program or service, or recommended for purchase by JPMS as a broker-dealer, will not be considered Portfolio assets for purposes of the Fee. E. Wealth Advisors Compensation The Fee applicable to the delivery of Services will not be tied to or adjusted for any other services or investment programs the Client may be invested in with JPMS or its affiliates. If a Client has chosen to enter into another investment advisory agreement with JPMS or its affiliates, the fees for the services provided under that agreement will be separate and distinct from those offered through the Program. JPMS typically pays a portion of the Fee it receives from each Client in the Program to the Wealth Advisor for that Client. Certain Wealth Advisors who do not receive compensation based on annual revenue production receive an annual salary and bonus payment, whereas other Wealth Advisors receive a portion of the Fee paid to JPMS. For those Wealth Advisors that receive a portion of the Fee, the exact portion of the Fee paid to the Wealth Advisor varies among Wealth Advisors and can also depend upon the overall revenue production of each Wealth Advisor but is most commonly within a range from 22% to 50%. The type of compensation paid to Wealth Advisors does not result in a change to a Client’s Fee schedule. In its discretion, JPMS may negotiate the amount and calculation of the Fee, based on a number of factors, including (1) the type and size of the Client’s Portfolio, (2) the number and types of Services selected, (3) the scope of the engagement, (4) the complexity of the Services to be provided to the Client, (5) the nature and amount of Investment Products involved, and (6) the frequency with which certain Services are provided. We address conflicts from compensation described in this section and throughout the Brochure in a variety of ways, including the disclosure of the conflicts in this Brochure. Moreover, our Wealth Advisors are required to recommend investment advisory programs, Investment Products, and securities that are suitable for you and in your best interest based upon your investment goals, risk tolerance, financial situation and needs, and cost considerations. In addition, we have established a variety of restrictions, procedures, and disclosures designed to address actual and potential conflicts of interest – both those arising between and among accounts as well as between accounts and our business. CLIENTS ARE ABLE TO OBTAIN THE SAME OR SIMILAR SERVICES OR TYPES OF INVESTMENTS YOU ACCESS THROUGH THE PROGRAM THROUGH OTHER JPMS PROGRAMS, WHETHER INVESTMENT ADVISORY PROGRAMS OR BROKERAGE ACCOUNTS, AND AT FEES THAT ARE HIGHER OR LOWER THAN THE FEE CHARGED TO A CLIENT UNDER THIS PROGRAM. THE FEE CHARGED TO A CLIENT MAY BE HIGHER OR LOWER THAN THE FEE CHARGED TO OTHER CLIENTS FOR SIMILAR SERVICES AND THE COST OF SIMILAR SERVICES OFFERED THROUGH OTHER FINANCIAL FIRMS. THE FEE TO BE CHARGED TO EACH CLIENT IS SPECIFIED IN THE CLIENT AGREEMENT. ITEM 6 — PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT B. Billing of Fees Neither JPMS nor any of its supervised persons currently accepts performance-based fees in connection with the Program. ITEM 7 — TYPES OF CLIENTS JPMS invoices Clients or the Client’s custodian for the Services provided or receives payment directly from the custodian, as agreed to in the Client Agreement. JPMS makes the Program available to corporations, foundations, endowments, and other institutional Clients. Clients must have a minimum of $25 million in Portfolio assets to participate in the Program. ITEM 8 — METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS A. Methods of Analysis and Investment Strategies Set forth below is a general description of the primary methods of analysis that JPMS utilizes for the Program. Asset Allocation Advice. JPMS will assist you in identifying an appropriate long-term asset allocation for your Portfolio based upon your risk tolerance, investment goals and objectives, liquidity needs, tax status, time horizon, Portfolio initial investment value, and investment constraints. financial Fees are payable in arrears, no less frequently than on a calendar quarter basis, unless otherwise agreed to by JPMS. The Fee for the first billing period is prorated from either the date on which the Client Agreement becomes effective or as otherwise determined by JPMS. The Fee due for the billing period in which the Client Agreement is terminated will be prorated up until termination date or as otherwise determined by JPMS. The rate used for calculating the amount due is approximately one-fourth of the applicable annual rate based on the number of days in the quarter (or, if billed monthly, the rate used each month is approximately one-twelfth of the applicable annual rate based on the number of days in the month) and based on the net market value of the Portfolio on the last business day of the relevant billing period. If current valuation data is not available to JPMS, JPMS will calculate the Fee using the most recent valuations provided to JPMS by the Client, the Client’s custodian(s), or other professionals, or institutions through electronic connections provided by authorized by the Client, and JPMS is expressly authorized to rely upon such Research Process. JPMS uses research from the manager solutions team of JPMPI or any of its affiliates to research, select, and monitor Funds. The 33825_COL 02-05-2026 Page 4 of 13  prospectus, disclosures, laws, or regulations, or other matters within the investment’s control. The description of the method of analysis above is qualified in its entirety by the information included in the applicable investment’s prospectus or other relevant offering documentation. Each investment’s manager is solely responsible for the management of the investment. Neither JPMS nor its affiliates can ensure that a given investment’s investment objective will be attained. Clients are not obligated to implement any investment advice, suggestions, or recommendations that Wealth Advisors provide in the Program. Clients are solely responsible for determining if, and how, the investment advice provided should be implemented or otherwise followed. Clients should carefully consider all relevant factors, including an investment’s prospectus or other disclosures, in making these decisions. manager solutions team of JPMPI or any of its affiliates is comprised of employees of JPMorgan Chase Bank, N.A. (JPMCB) and other affiliates. Specialists on the manager solutions team of JPMPI or any of its affiliates are supervised persons of JPMPI. The manager solutions team of JPMPI or any of its affiliates conducts due diligence of the Funds that are available for use in the Program. The manager solutions team of JPMPI or any of its affiliates is responsible for researching and selecting Funds as well as for subjecting them to a review process. The due diligence process is designed to subject Funds to the same process; however, the manager solutions team of JPMPI or any of its affiliates applies its discretion and is not required to apply all factors equally to each Fund in the search universe. The manager solutions team of JPMPI or any of its affiliates will begin the search process by defining an applicable universe of Funds for a desired asset class. The manager solutions team of JPMPI or any of its affiliates utilizes both quantitative and qualitative assessments during its initial review process. The manager solutions team of JPMPI or any of its affiliates then recommends particular Funds to an internal governance forum, which is responsible for approving or rejecting them. The manager solutions team of JPMPI or any of its affiliates is also responsible for monitoring and re- evaluating approved Funds as part of its ongoing review process. Investing in securities involves risk of loss that Clients should be prepared to bear. The investment performance and success of any particular investment cannot be predicted or guaranteed, and the value of a particular investment option will fluctuate due to market conditions and other factors. Past performance of investments is not indicative of future performance. Clients receive no written or oral guarantees regarding performance. Any projections, analyses or other information regarding various investment outcomes are hypothetical in nature, do not reflect actual investment results, and are not guarantees of future investment results. You are assuming the risks involved in selecting Investment Products for the Portfolio, and the Portfolio could lose all or a portion of the amount held in those Investment Products. Typically, JPMS recommends that a Client seek a diversified portfolio in an effort to meet the Portfolio’s investment objectives and have investments diversified across multiple asset classes in order to reduce investment risk associated with concentrated investments. Diversification does not eliminate risk. For specific risks associated with the investments in your Portfolio, you should consult with the relevant investment managers you select to manage your Portfolio. B. Material, Significant, or Unusual Risks Associated with Certain Investments in the Program Set forth below are some of the material risk factors that are often associated with the investment options recommended by Wealth Advisors or JPMS, respectively. The information included below does not identify every potential risk associated with each investment option. The strategies followed by a particular investment option may be speculative and involve significant risk. Clients are urged to ask their Wealth Advisor or JPMS questions regarding risk factors applicable to a particular investment option, read all risk disclosures specific to particular investment options, and determine whether a particular investment option is suitable. Centralized Due Diligence. The manager solutions team of JPMPI or any of its affiliates provides two types of research on Funds and investment strategies (collectively referred to herein as Researched Products) on an ongoing basis. For certain investment advisory programs, the manager solutions team of JPMPI or any of its affiliates utilizes a qualitative analysis of the Researched Products by reviewing the organization, investment process, investment philosophy, and performance of the Researched Products on an ongoing basis (the Qualitative Research Process). Additionally, the manager solutions team of JPMPI or any of its affiliates uses an internally developed quantitative screening process to evaluate the Researched Products that do not go through the Qualitative Research Process by reviewing the organization, investment process, service, and performance of the Researched Products on an ongoing basis (the Systematic Research Process). Researched Products may be removed from an investment advisory program if it is determined that they do not meet the criteria set forth in the Systematic Research Process. However, in the event a Researched Product does not pass the Systematic Research Process, the manager solutions team of JPMPI or any of its affiliates can review the Research Product and apply the Qualitative Research Process to determine if the Researched Product is eligible. Additionally, if a Researched Product does not meet the criteria of the Qualitative Research Process, it is removed from investment advisory programs that utilize the Systematic Research Process. The Program utilizes the Systematic Research Process. As part of the due diligence process, the manager solutions team of JPMPI or any of its affiliates applies an ESG (as defined below) eligibility framework that establishes minimum criteria for determining the universe of Funds and strategies to be considered for inclusion in ESG strategies. Initial Fund and Investment Strategy Review and Approval. The internal governance forum approves or rejects new Funds to be made available for recommendation in the Program. There can be Funds that are not available in the Program but that are available in programs advised by JPMPI or its affiliates. The manager solutions and operational due diligence teams of JPMPI or any of its affiliates provide a formal presentation on prospective managed strategies to the governance forum for review. The internal governance forum is expected to consider factors in its review and approval process, including, but not limited to: (a) an analysis of the manager’s overall investment opportunity, (b) investment thesis, (c) track record, (d) performance, (e) terms of the vehicle, (f) reputational risk, (g) potential for conflicts of interest, and (h) regulatory issues. General Market Risk. Economies and financial markets throughout the world are becoming increasingly interconnected, which increases the likelihood that events or conditions in one country or region will adversely impact markets or issuers in other countries or regions. Securities in any one strategy may underperform in comparison to general financial markets, a particular financial market or other asset classes, due to a number of factors, including inflation (or expectations for inflation), deflation (or expectations for deflation), interest rates, global demand for particular products or resources, market instability, debt crises and downgrades, embargoes, tariffs, sanctions and other trade barriers, regulatory events, other governmental trade or market control programs, and related geopolitical events. In addition, the value of a strategy's investments may be negatively affected by the occurrence of global events such as war, terrorism, environmental disasters, natural disasters or events, country instability, and infectious disease epidemics, pandemics, or endemics. Infectious Disease Risk. The effects of any future pandemic or other global event to business and market conditions may have a significant negative impact on the performance of investments; increase separately managed Investment Risk of Loss. The particular investment options recommended by JPMS entail varying degrees of risk. There is no assurance that recommended investment options will be successful or that Clients will not suffer losses. Neither JPMS nor its affiliates are responsible for the performance of any investment or for any investment’s compliance with its 33825_COL 02-05-2026 Page 5 of 13  clients. While measures have been developed that are designed to reduce the risks associated with cyber-security, there is no guarantee that those measures will be effective, particularly since J.P. Morgan does not directly control the cyber-security defenses or plans of its service providers, financial intermediaries, and companies in which they invest or with which they do business. Use of AI Tools may lead to increased risks of cyber- attacks or data breaches and the ability to launch more automated, targeted, and coordinated attacks due to the vulnerability of AI technology to cyber-security threats. account and fund volatility; exacerbate preexisting political, social, and economic risks; and negatively impact broad segments of businesses and populations. In addition, governments, regulatory agencies, or self- regulatory organizations have taken or may take actions in response to a pandemic or other global event that affect the instruments in which a Client invests or the issuers of such instruments, in ways that could have a significant negative impact on such Client’s investment performance. The ultimate impact of any pandemic or other global event, and the extent to which the associated conditions and governmental responses impact investments, will also depend on future developments, which are highly uncertain, difficult to accurately predict, and subject to frequent changes. Intellectual Property and Technology Risks Involved in International Operations. There can be risks to technology and intellectual property that can result from conducting business outside the United States. This is particularly true in jurisdictions that do not have comparable levels of protection of corporate proprietary information and assets such as intellectual property, trademarks, trade secrets, know-how, and customer information and records. As a result, JPMS and its funds can be more susceptible to potential theft or compromise of data, technology, and intellectual property from a myriad of sources, including direct cyber intrusions or more indirect routes, such as companies being required to compromise protections or yield rights to technology, data, or intellectual property in order to conduct business in a foreign jurisdiction. Risks Associated with the Use of Artificial Intelligence (AI) Tools. J.P. Morgan may rely on programs and systems that utilize AI, machine learning, probabilistic modeling, and other data science technologies (AI Tools). AI Tools are highly complex and may be flawed, hallucinate, reflect biases included in the data on which such tools are trained, be of poor quality, or be otherwise harmful. J.P. Morgan typically incorporates human oversight to reduce the risk of acting on potentially defective outputs. AI Tools present Data Sources Risks and Cyber-security Risks (as further described below). The U.S. and global legal and regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving and could require changes in JPMPI’s implementation of such tools. Furthermore, J.P. Morgan may rely on AI Tools developed by third parties, and J.P. Morgan may have limited visibility over the accuracy and completeness of such AI Tools. Data Source Risk. Although J.P. Morgan obtains data, including alternative data, and information from third-party sources that it considers to be reliable, J.P. Morgan does not warrant or guarantee the accuracy and/or completeness of any data or information provided by these sources. J.P. Morgan has controls for certain data that, among other things, consider the representations of such third parties with regard to the provision of the data to J.P. Morgan in compliance with applicable laws. J.P. Morgan does not make any express or implied warranties of any kind with respect to such third-party data. J.P. Morgan shall not have any liability for any errors or omissions in connection with any data obtained from third-party sources. Risks That Apply Primarily to ESG/Sustainable Investing Strategies. Investment approaches that incorporate environmental, social, and governance (ESG) considerations or sustainable investing can include additional risks. ESG or sustainable investing strategies (together, ESG Strategies), including mutual funds and ETFs, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. ESG Strategies may invest in securities or industry sectors that underperform the market as a whole or underperform other strategies screened for ESG standards. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries that share common characteristics and can be subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized or the determinations made by JPMS or JPMPI will align with the beliefs or values of a client. Additionally, investment managers, including affiliates, can have a different approach to ESG or sustainable investing and can offer ESG Strategies that differ from the ESG Strategies offered by J.P. Morgan with respect to the same theme or topic. AI Tools often use data feeds from a number of sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool will be unable to properly function or their operation may be adversely impacted. The tools’ ability to use the data may also be adversely impacted by any change in the format of data delivered or acquired by the tool. The timeliness and quality of a third party’s data may be compromised for a variety of reasons, some of which are outside of the control of J.P. Morgan and the third-party data provider. A tool’s ability to process data may also be adversely affected if J.P. Morgan experiences any disruptions to its computing resources or network connections, including disruption of cloud-based computing resources. When evaluating investments, an investment manager is dependent upon information and data that might be incomplete, inaccurate, or unavailable, which could cause the manager to incorrectly assess an investment’s ESG or sustainable attributes. In making investment decisions, J.P. Morgan will use data and information, including, but not limited to, industry classifications, industry grouping, ratings, scores, and issuer screening provided by third-party data providers or by a J.P. Morgan affiliated service provider. J.P. Morgan does not review, guarantee, or validate any third-party data, ratings, screenings, or processes. Such data and information will not have been validated by J.P. Morgan and can therefore be incomplete or erroneous. Cyber-security Risk. As the use of technology has become more prevalent in the course of business, J.P. Morgan has become more susceptible to operational and financial risks associated with cyber-security, including: theft; loss; misuse; improper release; corruption and destruction of, or unauthorized access to, confidential or highly restricted data relating to J.P. Morgan and its clients; and compromises or failures to systems, networks, devices, and applications, including, but not limited to, AI Tools and cloud-based computing resources relating to the operations of J.P. Morgan and its service providers. Cyber-security risks may result in financial losses to J.P. Morgan and its clients; the inability of J.P. Morgan to transact business with its clients; delays or mistakes in materials provided to clients; the inability to process transactions with clients or other parties; violations of privacy and other laws; regulatory fines, penalties, and reputational damage; and compliance and remediation costs, legal fees, and other expenses. J.P. Morgan’s service providers and parties with which J.P. Morgan engages may be adversely impacted by cyber-security risks in their own businesses, which could result in losses to J.P. Morgan or its ESG and sustainable investing are not uniformly defined concepts, and scores or ratings may vary across third-party data providers that use similar or different screens based on their process for evaluating ESG characteristics. Companies identified by as demonstrating positive ESG characteristics might not be the same companies identified by other investment managers in the market that use similar ESG screens or methodologies. In addition, companies identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region, and industry and are constantly evolving. As a result, a company’s ESG or sustainable investing practices and the investment manager’s assessment of such practices can change over time. 33825_COL 02-05-2026 Page 6 of 13  J.P. Morgan takes a global approach to ESG or sustainable investing, and the solutions offered through our sustainable investing platform meet our internally developed criteria for inclusion in our sustainable investing platform and, where applicable, take into account ESG or sustainable investing regulations. As part of the due diligence process, the manager solutions team of JPMPI or any of its affiliates applies an ESG eligibility framework that establishes minimum criteria for determining the universe of funds and strategies to be considered for inclusion in the ESG Strategies offered to our clients. The evolving nature of sustainable finance regulations and the development of jurisdiction-specific legislation setting out the regulatory criteria for a “sustainable investment” or “ESG” investment mean that there is likely to be a degree of divergence as to the regulatory meaning of such terms. This is already the case in the European Union where, for example, under the Sustainable Finance Disclosure Regulation (EU) (2019/2088) (SFDR), certain criteria must be satisfied in order for a product to be classified as a “sustainable investment.” Any references to “sustainable investing” or “ESG” in this material are intended as references to our internally developed criteria only and not to any jurisdiction-specific regulatory definition. Category Restrictions and Exclusions Risks. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from a portfolio. longer be representative of the underlying markets. New or alternative references rates have since been used in place of LIBOR. Replacement rates that have been identified include the Secured Overnight Financing Rate (SOFR, which is intended to replace U.S. dollar LIBOR and measures the cost of U.S. dollar overnight borrowings collateralized by treasuries) and the Sterling Overnight Index Average rate (SONIA, which is intended to replace pound sterling LIBOR and measures the overnight interest rate paid by banks in the sterling market). Markets are slowly developing in response to these new rates. As a result of the benchmark reforms, publication of all LIBOR settings has ceased, and the investment managers and the funds and accounts they manage have generally transitioned to successor or alternative reference rates as necessary. Although the transition process away from IBORs for most instruments has been completed, there is no assurance that any such alternative reference rate will be similar to or produce the same value or economic equivalence as LIBOR or that it will have the same volume or liquidity as did LIBOR prior to its discontinuance. This may affect the value, volatility, liquidity, or return on certain of a fund’s or other client account’s loans, notes, derivatives, and other instruments or investments comprising some or all of a fund’s or other client account’s portfolio and result in costs incurred in connection with changing reference rates used for positions, closing out positions, and entering into new trades. The transition from LIBOR to alternative reference rates may result in operational issues for a fund or a client account or their investments. Moreover, certain aspects of the transition from IBORs will rely on the actions of third-party market participants, such as clearing houses, trustees, administrative agents, asset servicers, and certain service providers. No assurances can be given as to the impact of the transition away from LIBOR on a fund or other client account or their investments. These risks may also apply with respect to changes in connection with other IBORs (e.g., Euribor) and a wide range of other index levels, rates, and values that are treated as “benchmarks” and are the subject of recent regulatory reform. Restrictions and exclusions can affect the investment manager’s ability to make investments or take advantage of opportunities that may be available to clients that do not choose similar restrictions. As a result, investment performance could suffer. In order to implement category restrictions, JPMS and JPMPI may rely on information about a company, industry classification, issuer screening industry grouping, and/or provided by J. P. Morgan, an affiliate, or a third party. Category restrictions aim to screen companies that engage in certain behaviors or with revenue derived from a restricted category; however, they do not exclude all companies with any tie or revenue derived from such restricted category. Mutual Funds. Mutual funds are sold by prospectus. Clients should review the prospectus to determine whether the fund is an appropriate investment by considering the investment’s objectives, risk, charges, and expenses. A fund’s net asset value will change with changes in the international equity and fixed income markets and the value of the mutual funds in which it invests. The investment performance of funds that implement their strategies by investing in underlying funds is directly related to the performance and risks of the underlying funds. There is no assurance that the underlying funds will achieve their investment objectives. In addition, a fund indirectly pays a portion of the expenses incurred by the underlying funds. As the underlying funds or the fund’s allocations among the underlying funds change from time to time, or to the extent that the expense ratio of the underlying funds changes, the weighted average operating expenses borne by the fund may increase or decrease. In addition, a fund may hold a significant percentage of the shares of an underlying fund. As a result, the fund’s investments in an underlying fund may create a conflict of interest because a situation could occur where an action for the fund could be adverse to the interest of an underlying fund or vice versa. If a fund invests in closed-end investment companies, it may incur added expenses such as additional management fees and trading costs. Third-party managers may apply category restrictions differently than J.P. Morgan or its affiliates and use different data and methodologies; therefore, the selection of restricted securities and the number of restricted securities may differ in the same category. Category restrictions require assumptions, opinions, and the subjective judgement of the data provider that might not reflect J.P. Morgan’s views or values and/or the views or values of a client. Furthermore, use of a particular data source from an organization does not mean that J.P. Morgan endorses all the activities of that organization. Additionally, data providers will have conflicts of interest when receiving compensation from or providing services to companies that use or obtain their ratings. J.P. Morgan does not review, guarantee, or validate any third-party data, ratings, screenings, or processes. Moreover, issuer screenings and processes to implement category restrictions are not absolute and may change at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations, and estimations, which could result in the Portfolio holding investments in companies that derive revenue from the restricted category. Any faith-based restrictions will exclude multiple categories selected by a third-party provider based generally on the values and norms of such groups; however, such restrictions will not completely represent or fully align with a client’s values or religious beliefs. Exchange Traded Funds (ETFs) and Index Mutual Funds. ETFs and index mutual funds are marketable securities that are interests in registered funds and are designed to track, before fees and expenses, the performance or returns of a relevant basket of assets, usually an underlying index. The index may be published or calculated by affiliates of JPMS. Unlike mutual funds, ETFs trade like common stock on a stock exchange. ETFs experience price changes throughout the day as they are bought and sold. ETFs typically have higher daily liquidity and lower fees than mutual fund shares. LIBOR Discontinuance Risk. The London Interbank Offering Rate (LIBOR) was intended to represent the rate at which contributing banks may obtain short-term borrowings from each other in the London interbank market. After the global financial crisis, regulators globally determined that existing interest rate benchmarks should be reformed based on a number of factors, including that LIBOR and other interbank offering rates (IBORs) may no Physical replication and synthetic replication are two of the most common structures used in the construction of ETFs and index mutual funds. index mutual funds buy all or a Physically replicated ETFs and 33825_COL 02-05-2026 Page 7 of 13  representative portion of the underlying securities in the index that they track. In contrast, some ETFs and index mutual funds do not purchase the underlying assets but gain exposure to them by use of swaps or other derivative instruments. In addition to the general risks of investing in mutual funds, there are specific risks to consider with respect to an investment in these passive investment vehicles including, but not limited to: • Variance from Benchmark Index. ETF and index mutual fund performance will differ from the performance of the applicable index for a variety of reasons. For example, ETFs and index mutual funds incur operating expenses and portfolio transaction costs not incurred by the benchmark index, may not be fully invested in the securities of their indices at all times, or may hold securities not included in their indices. In addition, corporate actions with respect to the equity securities underlying ETFs and index mutual funds (such as mergers and spin-offs) may impact the variance between the performances of the funds and applicable indices. For example, client accounts that track the same indexes used by the ETFs and index mutual funds may engage in purchases and sales of securities relating to index changes prior to the implementation of index updates or at the time as the ETFs and index mutual funds engage in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the ETFs’ and index mutual funds’ portfolios are only rebalanced on a periodic basis corresponding with the rebalancing of an index. These differences may result in the client accounts having more favorable performance relative to that of the index and the ETFs and index mutual funds or other client accounts that track the index. Other potential conflicts include the potential for unauthorized access to index information, allowing index changes that benefit JPMPI or other client accounts and not the investors in the ETFs and index mutual funds. J.P. Morgan has established certain information barriers and other policies to address the sharing of information between different businesses within J.P. Morgan, including with respect to personnel responsible for maintaining the indexes and those involved in decision-making for the ETFs and index mutual funds. Risks Associated with Particular Types of Securities C. Refer to response to Item 8.B. ITEM 9 — DISCIPLINARY INFORMATION A. Criminal or Civil Proceedings JPMS has no material civil or criminal actions to report. • Passive Investing Risk. Passive investing differs from active investing in that ETF and index mutual fund managers are not seeking to outperform their benchmark. As a result, managers may hold securities that are components of their underlying index, regardless of the current or projected performance of the specific security or market sector. Passive managers do not attempt to take defensive positions based upon market conditions, including declining markets. This approach could cause a passive vehicle’s performance to be lower than if it employed an active strategy. B. Administrative Proceedings Before Regulatory Authorities and Self- Regulatory Authorities JPMS has been involved in the following material legal or disciplinary events during the last 10 years. • Secondary Market Risk. With respect to ETFs, shares are bought and sold in the secondary market at market prices. Although ETFs are required to calculate their net asset values (NAV) on a daily basis, at times the market price of an ETF’s shares may be more than the NAV (trading at a premium) or less than the NAV (trading at a discount). Given the differing nature of the relevant secondary markets for ETFs, certain ETFs may trade at a larger premium or discount to NAV than other ETFs, depending on the markets where such ETFs are traded. The risk of deviation from NAV for ETFs generally is heightened in times of market volatility or periods of steep market declines. For example, during periods of market volatility, securities underlying ETFs may be unavailable in the secondary market, market participants may be unable to calculate accurately the NAV per share of such ETFs, and the liquidity of such ETFs may be adversely affected. This kind of market volatility may also disrupt the ability of market participants to create and redeem shares in ETFs. Further, market volatility may adversely affect, sometimes materially, the prices at which market participants are willing to buy and sell shares of ETFs. As a result, under these circumstances, the market value of shares of an ETF may vary substantially from the NAV per share of such ETF, and the client may incur significant losses from the sale of ETF shares. 1) On December 18, 2015, JPMS and JPMCB (together, Respondents) entered into a settlement with the SEC resulting in the SEC issuing an order (Order). The Respondents consented to the entry of the Order that finds that JPMS violated Sections 206(2), 206(4), and 207 of the Advisers Act and Rule 206(4)-7, and JPMCB violated Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The Order finds that JPMCB negligently failed to adequately disclose (a) from February 2011 to January 2014, a preference for affiliated mutual funds in certain discretionary investment portfolios (the Discretionary Portfolios) managed by JPMCB and offered through J.P. Morgan’s U.S. Private Bank (the U.S. Private Bank) and the Chase Private Client lines of business; (b) from 2008 to 2014, a preference for affiliated hedge funds in certain of those portfolios offered through the U.S. Private Bank; and (c) from 2008 to August 2015, a preference for retrocession-paying third-party hedge funds in certain of those portfolios offered through the U.S. Private Bank. With respect to JPMS, the Order finds that, from May 2008 to 2013, JPMS negligently failed to adequately disclose, including in documents filed with the SEC, conflicts of interest associated with its use of affiliated mutual funds in the Chase Strategic Portfolio (CSP) program, specifically, a preference for affiliated mutual funds, the relationship between the discounted pricing of certain services provided by an affiliate and the amount of CSP assets invested in affiliated products, and that certain affiliated mutual funds offered a lower-cost share class than the share class purchased for CSP. In addition, the Order finds that JPMS failed to implement written policies and procedures adequate to ensure disclosure of these conflicts of interest. Solely for the purpose of settling these proceedings, the Respondents consented to the Order, admitted to the certain facts set forth in the Order, and acknowledged that certain conduct set forth in the Order violated the federal securities laws. The Order censures JPMS and directs the Respondents to cease-and-desist from committing or causing any violations and any future violations of the above- enumerated statutory provisions. Additionally, the Order requires the • Tracking the Index. Certain funds track financial indexes in which J.P. Morgan retains various intellectual property rights. As a result, J.P. Morgan may be entitled to receive index licensing fees from unaffiliated licensees of these indexes. Affiliates of JPMPI may develop or own and operate stock market and other indexes based on investment and trading strategies developed by such affiliates. Affiliates of JPMPI may also assist unaffiliated entities in creating indexes that are tracked by certain ETFs and index mutual funds utilized by JPMPI. Some ETFs and index mutual funds seek to track the performance of these indexes. J.P. Morgan may, from time to time, manage client accounts that invest in the ETFs and index mutual funds. In addition, J.P. Morgan may manage strategies that track the same indexes used by the ETFs and index mutual funds or that may be based on the same, or substantially similar, strategies that are used in the operation of the indexes and the ETFs and index mutual funds. The operation of the indexes, the ETFs and index mutual funds and client accounts in this manner may give rise to potential conflicts of interest. 33825_COL 02-05-2026 Page 8 of 13  Respondents to pay a total of $266,815,000 in disgorgement, interest, and civil penalty. reasonably designed to monitor and evaluate the performance of the vendor that handled certain functions on behalf of the Firm. Concurrently, on December 18, 2015, JPMCB reached a settlement agreement with the Commodity Futures Trading Commission (CFTC) to resolve its investigation of JPMCB’s disclosure of certain conflicts of interest to discretionary account clients of J.P. Morgan Private Bank’s U.S.-based wealth management business. In connection with the settlement, the CFTC issued an order (Order) finding that JPMCB violated Section 4o(1)(B) of the Commodity Exchange Act (CEA) and Regulation 4.41(a)(2) by failing to fully disclose to certain clients its preferences for investing certain discretionary portfolio assets in certain commodity pools or exempt pools, namely (a) investment funds operated by J.P. Morgan Asset Management and (b) third-party managed hedge funds that shared management and/or performance fees with an affiliate of JPMCB. The Order directs JPMCB to cease-and- desist from violating Section 4o(1)(B) of the CEA and Regulation 4.41(a)(2). Additionally, JPMCB shall pay $40 million as a civil penalty to the CFTC and disgorgement of $60 million satisfied by disgorgement to be paid to the SEC by JPMCB and an affiliate in a related and concurrent settlement with the SEC. the 4) On January 9, 2020, JPMS entered into a settlement with the SEC resulting in the SEC issuing an administrative order (the 2020 Order). JPMS consented to the entry of the 2020 Order, which found that JPMS violated Section 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The 2020 Order found that JPMS negligently omitted to state from at least January 2010 through December 2015 that (a) it received greater compensation from eligible customers’ purchases of more expensive mutual fund share classes, resulting in eligible customers not having sufficient information to understand that JPMS had a conflict of interest from sales of the more expensive share classes; and (b) the purchase of the more expensive share classes, when the customers were otherwise eligible for less expensive share classes, would negatively impact the overall return on the eligible customers’ investments, in light of the different fee structures for the different fund share classes. The 2020 Order also found that JPMS did not have adequate systems and controls in place to determine whether eligible customers were eligible to purchase the less expensive share classes. Solely for the purpose of settling this proceeding, JPMS consented to the 2020 Order, without admitting or denying the findings set forth in the 2020 Order. The 2020 Order censured JPMS and directed JPMS to cease-and-desist from committing or causing any violations and any future violations of Securities Act Sections 17(a)(2) and 17(a)(3). Additionally, the 2020 Order required JPMS to pay a total of $1,822,438 in disgorgement, pre- judgment interest, and civil penalty. 5) On March 9, 2020, JPMS entered into an Agreed Order (the March 2020 Order) with the Kentucky Department of Financial Institutions (KDFI). JPMS consented to the entry of the March 2020 Order that alleged that JPMS failed to disclose conflicts of interest arising from preferences for J.P. Morgan-managed mutual funds (Proprietary in violation of KRS 292.320 and 808 KAR Mutual Funds), 10:450§2(8)(c) and (11)(a). Specifically, the March 2020 Order alleged that, between 2008 and 2013, JPMS failed to disclose to Kentucky investors that (i) CSP was designed and operated with a preference for Proprietary Mutual Funds; (ii) there was an economic incentive to invest CSP assets in Proprietary Mutual Funds as a result of discounted pricing for services provided to JPMS for CSP by a JPMS affiliate; and (iii) until November 2013, JPMS failed to disclose to CSP clients the availability of certain less expensive Proprietary Mutual Fund share classes. Solely for the purpose of settling these proceedings, JPMS consented to the March 2020 Order, with no admissions as to liability. In the agreement, JPMS agreed to pay a total of $325,000 to resolve the KDFI investigation. 2) On July 27, 2016, JPMS and JPMCB entered into a Consent Agreement (Agreement) with Indiana Securities Division (ISD). The Respondents consented to the entry of the Agreement that alleged that certain conduct of the Respondents was outside the standards of honesty and ethics generally accepted in the securities trade and industry, in violation of 710 Ind. Admin. Code § 4-10-1(23) (2016). Specifically, the Agreement alleged that, between 2008 and 2013, JPMS failed to disclose to Indiana investors that certain proprietary mutual funds purchased for CSP clients offered institutional shares that were less expensive than the institutional shares JPMS chose for CSP clients. In addition, the Agreement alleged that, from February 2011 to January 2014, no account opening document or marketing materials disclosed to Indiana investment management account clients or Indiana J.P. Morgan Investment Portfolio clients that JPMCB preferred to invest client assets in proprietary mutual funds, and that between 2008 and January 2014, JPMCB did not disclose its preference for investing certain investment management account assets in certain proprietary hedge funds to Indiana clients. Lastly, the Agreement alleged that JPMCB did not disclose its preference for placement-agent-fee-paying third-party hedge fund managers in certain investment management accounts to Indiana clients until August 2015. Solely for the purpose of settling these proceedings, the Respondents consented to the Agreement, with no admissions as to liability. In the Agreement, the Respondents agreed to pay a total of $950,000 to resolve the ISD’s investigation, which was paid on August 1, 2016. 3) In October 2018, JPMS submitted an Acceptance, Waiver, and Consent (AWC) to FINRA pursuant to which JPMS was censured and required to certify in writing to FINRA that it had engaged in a risk-based review of Chase Wealth Management (CWM) client-facing third-party vendors, that it had corrected any issues detected, and that JPMS had established and implemented systems and policies and procedures (written or otherwise) reasonably designed to achieve compliance with applicable FINRA and NASD rules. JPMS had discovered and self- reported to FINRA that a vendor responsible for the automated realignment of portfolio assets (“rebalancing”) and the calculation of fees was not rebalancing certain accounts due to technology upgrades by the vendor. Similarly, the vendor had converted to a new billing platform that caused billing errors that went undetected. JPMS paid total restitution of $4,620,140 to impacted customers and provided substantial assistance to FINRA by proactively undertaking an extensive lookback concerning its complex and systemic failures and reporting related findings on an ongoing basis. Without admitting or denying the findings, JPMS consented to the sanctions and to the entry of findings that it failed to establish and maintain a system and procedures 6) In September 2020, JPMS, together with JPMC and JPMCB (collectively, J.P. Morgan), agreed to an administrative resolution with the CFTC for violations of the CEA and CFTC regulations related to manipulation, attempted manipulation, and spoofing, as well as a charge against JPMS for failure to supervise. As described in the CFTC’s Order, from at least 2008 through 2016, former J.P. Morgan traders placed hundreds of thousands of spoof orders of precious metals futures and U.S. treasuries (UST) futures on exchanges, and, on occasion, engaged in manipulation related to precious metals barrier options. The CFTC Order further states that JPMS failed to identify, adequately investigate, and put a stop to misconduct, despite red flags, including internal surveillance alerts, inquiries from CME and the CFTC, and internal allegations of misconduct. J.P. Morgan consented to the entry of the CFTC Order without admitting or denying the findings contained therein, except to the extent that admissions were made in the related resolutions, described below, with the United States Department of Justice, Criminal Division, Fraud Section, and the United States Attorney’s Office for the District of Connecticut (together, DOJ) and the SEC. JPMS also agreed to an administrative resolution with the SEC for violations of Section 17(a)(3) of the Securities Act of 1933. Pursuant to the SEC Order, JPMS admitted to hundreds of manipulative trading 33825_COL 02-05-2026 Page 9 of 13  B. Futures/Commodities-Related Registrations In addition, JPMS is registered with the CFTC as a futures commission merchant and also acts as a commodity pool operator exempt from registration as such with the CFTC. Some of JPMS’ management personnel, and a small number of the Wealth Advisors and/or their supervisors in the Program, are registered with the CFTC as associated persons of JPMS in its capacity as a futures commission merchant. C. Material Relationships with Related Persons and Potential Conflicts of Interest to certain cooperation, remediation, and events involving spoofing by certain former J.P. Morgan traders in the UST cash securities secondary market between April 2015 and January 2016. JPMC separately entered into a deferred prosecution agreement (DPA) with the DOJ with respect to a criminal information, charging JPMC with two counts of wire fraud (the Information) related to the same conduct underlying the CFTC and SEC Orders. JPMS and JPMCB also agreed to certain terms and obligations of the DPA. J.P. Morgan admitted, accepted, and acknowledged responsibility for the acts of its officers, directors, employees, and agents as described in the Information and the Statement of Facts accompanying the DPA and that the allegations described therein are true and accurate. In resolving these three actions, J.P. Morgan agreed to pay a total of $920,203,609 to the DOJ, CFTC, and SEC, consisting of civil and criminal monetary penalties, restitution, and disgorgement. J.P. Morgan agreed to cease and desist from any further violations and also agreed, among other things, reporting requirements. JPMS has several relationships or arrangements with related persons that are material to its advisory business. Affiliates of JPMS are the sponsors, managers, and/or general partners of certain open-end mutual funds (including money market funds), closed-end funds, ETFs, and other pooled investment vehicles (J.P. Morgan Funds) that may be recommended to a client. JPMS and its affiliates may provide investment management, distribution, and other services to the J.P. Morgan Funds and may receive compensation based on the value of the assets invested in those funds. Accordingly, JPMS and its affiliates will receive more total revenue when a client invests in J.P. Morgan Funds than when it invests in third-party funds. In addition to the J.P. Morgan Funds, JPMS’ ultimate parent company, JPMorgan Chase & Co., is a publicly traded corporation the common stock of which is listed and trades on the NYSE. Other affiliates of JPMS also may issue securities through public or private distributions. All or substantially all registered representatives also are employees of JPMCB. In their capacities as employees of JPMCB and outside of the Program, Wealth Advisors may market and sell products and services of JPMCB to clients and be compensated in connection with such sales. Additional information about these relationships or arrangements can be found in the brochures for the other investment advisory programs JPMS or its affiliates offers, which can be obtained upon request or at the SEC’s website adviserinfo.sec.gov. Revenue Sharing Arrangements with Affiliates 7) On January 16, 2024, JPMS entered into a settlement with the SEC resulting in the SEC issuing an administrative order (the Order). JPMS consented to the entry of the Order, which found that JPMS willfully violated Rule 21F-17(a) under the Securities Exchange Act of 1934 (the Exchange Act). The Order arose out of JPMS, from 2020 through July 2023, asking certain clients and customers to whom it had issued a credit or settlement over $1000 in value to sign a confidential release agreement that required the clients to keep confidential the release agreement and all information relating to the specified account at JPMS. The confidential release agreement neither prohibited nor restricted clients from responding to any inquiry about the confidential release agreement or its underlying facts from FINRA, the SEC, or any other government entity or self-regulatory organization, or as required by law, but did not permit voluntary communications with such regulators. The Order censured JPMS and directed JPMS to cease-and- desist from committing or causing any violations and any future violations of Rule 21F-17(a) under the Exchange Act. Additionally, the Order required JPMS to pay a civil money penalty in the amount of $18,000,000. JPMS has paid the civil monetary penalty in accordance with the terms of the Order. • JPMS is a party to certain revenue sharing arrangements pursuant to which it may receive compensation from certain affiliates. This compensation is related to referrals or introductions of investors by registered representatives in JPMS (including Wealth Advisors in the Program) to those affiliates for the provision by the affiliates of products and services to the investors. The investors referred may be existing investment advisory clients, including Clients in the Program. When JPMS make such a referral of one of its existing investment advisory clients to an affiliate, the revenue sharing arrangement creates a conflict of interest with the client because: • JPMS has a financial incentive to make the referral because it will be entitled to compensation from the affiliate if the referred client becomes a client or customer of the affiliate; • JPMS does not necessarily base such referrals on any review or due diligence of the affiliate or its personnel, products, or services; • JPMS does not necessarily conduct an assessment of the suitability of the affiliate’s products or services for referred clients; and • It may not be in the referred client’s best interest to become a client or customer of the affiliate. 8) On October 31, 2024, JPMS entered into a settlement with the SEC resulting in the SEC issuing an administrative order (the Order). JPMS consented to the entry of the Order, which found that JPMS willfully violated Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The Order arose out of JPMS, from at least July 2017 until October 11, 2024, failing to fully and fairly disclose the financial incentive of itself and certain of its Wealth Advisors to recommend a certain advisory program—the Portfolio Manager Program—over other advisory programs offered by JPMS that use third- party managers. The Order also found that JPMS failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with the disclosure of conflicts of interest presented by the fee structure of the advisory programs for itself and its Wealth Advisors. The Order censured JPMS and directed JPMS to cease-and-desist from committing or causing any violations and any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. Additionally, the Order required JPMS to pay a civil money penalty in the amount of $45,000,000. JPMS has paid the civil monetary penalty in accordance with the terms of the Order. JPMS believes that this conflict is addressed in the following ways: ITEM 10 — OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. Broker-Dealer Registrations • Typically, the referred client is not charged more for the product or service provided by the affiliate by virtue of the fact that the affiliate will compensate JPMS for the referral. • Clients referred to affiliates by JPMS have no obligation to become clients or customers of those affiliates. If they decline to do business JPMS is registered with the SEC as a broker-dealer as well as an investment adviser. Some of JPMS’ management personnel and all of the Wealth Advisors and their supervisors in the Program are registered with the FINRA as registered representatives of JPMS in its capacity as a broker- dealer. 33825_COL 02-05-2026 Page 10 of 13  with the affiliate to which they were referred, it will not affect their relationship with JPMS. Recommendation or Selection of Other Investment Advisers valuable brokerage relationships with the Funds. Assuming that a Program Client’s Wealth Advisor is aware of which Funds execute through JPMS or an affiliate or other related person and which do not, JPMS believes that this conflict is addressed in the following ways: JPMS may recommend other investment advisers, including affiliated investment advisers, for Clients. JPMS has a conflict of interest in recommending affiliated investment advisers because if a Client chooses to invest with them, JPMS’ affiliate will receive the investment advisory fee. Thus, JPMS and its affiliates will receive in the aggregate greater compensation when a Client selects an investment adviser affiliated with JPMS. ITEM 11 — CODE OF ETHICS, PARTICIPATION, OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. Code of Ethics • Unless the Wealth Advisor is individually involved in the execution of portfolio transactions for a Fund, they do not receive any direct financial benefit (such as additional compensation) from the purchase or sale by a Client of Funds that execute transactions through JPMS or an affiliate or other related person rather than Funds that do not. Moreover, because Wealth Advisors are compensated in the Program through the receipt of a portion of the Fee, which is typically tied to the market value of a Client’s assets, Wealth Advisors are to that extent incentivized to recommend Funds they believe will increase in value, regardless of whether or not the Funds execute transactions through JPMS or an affiliate or other related person. Wealth Advisors in the Program are bound by the JPMS Investment Adviser Code of Ethics (Code of Ethics), adopted by JPMS in accordance with Rule 204A-1 under the Advisers Act. • Wealth Advisors are subject to supervision JPMS believes is reasonably designed to ensure that any investment advice, suggestions, or recommendations provided are in accordance with criteria and other information provided by the Client and that, when acting in a fiduciary capacity, Wealth Advisors are acting in accordance with their duty to place the interests of Program Clients before their own and those of JPMS. The Code of Ethics describes the general standards of business conduct applicable to JPMS’ Wealth Advisors, including Wealth Advisors in the Program, and the fiduciary obligations owed by JPMS and its Wealth Advisors to clients in its investment advisory programs. More specifically, the Code of Ethics addresses the following subjects: • The maintenance of personal securities accounts by JPMS’ investment Wealth Advisors; • The reporting to JPMS Compliance personnel of certain personal securities holdings and transactions by certain of JPMS’ Wealth Advisors, including all Wealth Advisors in the Program; • Certain trading restrictions and holding periods applicable to personal JPMS and its affiliates (including JPMorgan Distribution Services, Inc.) and other related persons also may receive other forms of compensation in connection with the operation and/or sale of shares of affiliated or unaffiliated Funds. Such compensation may include distribution fees paid by certain Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940 and non-Rule 12b-1 compensation (including revenue sharing, shareholder servicing fees, and licensing fees for the use by a fund of a J.P. Morgan index), to the extent permitted by applicable law. JPMS addresses this conflict by disclosing it to Clients. securities transactions of certain of JPMS’ Wealth Advisors; • Trading by Wealth Advisors while in possession of material non-public information; • Periodic certification by certain of JPMS’ Wealth Advisors, including all Wealth Advisors in the Program, of their review, understanding, and compliance with the Code of Ethics; • JPMS’ administration and enforcement of the Code of Ethics; and • The keeping of certain records relating to the Code of Ethics and its administration and enforcement by JPMS. A copy of the Code of Ethics is available free of charge to any Client or prospective Client upon request by contacting your Wealth Advisor. B. Securities in Which JPMS or a Related Person Has a Material Financial Interest In some cases, JPMS or a related person recommends to investment advisory clients, including Clients in the Program, securities in which JPMS or a related person has a material financial interest. Certain asset management firms (each, an asset manager) through their funds and separately managed accounts currently hold a 5% or more ownership interest in J.P. Morgan publicly traded stock. This ownership interest presents a conflict of interest when JPMCB, JPMS, JPMPI, and J.P. Morgan (collectively, J.P. Morgan) recommends or purchases the publicly traded security of the asset manager or the separately managed accounts or funds that are managed or advised by the asset manager. J.P. Morgan addresses this conflict by disclosing the ownership interest of the asset manager and by subjecting the asset manager’s separately managed accounts and funds to a research process. Additionally, the financial advisers and portfolio managers who may purchase or recommend securities, separately managed accounts, and funds of an asset manager that has an ownership interest in J.P. Morgan do not receive any additional compensation for that purchase or recommendation. A fund ownership interest in J.P. Morgan can cause the fund and its affiliates to determine that they are unable to pursue a transaction or the transaction will be limited or the timing altered. J.P. Morgan monitors ownership interests in J.P. Morgan for regulatory purposes and to identify and mitigate actual and perceived conflicts of interest. As of February 26, 2025, the Vanguard Group, Inc. and BlackRock, Inc. hold more than a 5% interest in J.P. Morgan. C. When JPMS or a Related Person Invests in the Same Securities That It Recommends JPMS and its related persons (including Wealth Advisors) may recommend that Clients in the Program make investments that JPMS or a related person buys or sells for itself. In such circumstances, the interests of JPMS and its related persons conflict with those of Clients in the Program in several respects: • JPMS or a related person may benefit from (1) Clients buying securities that JPMS or the related person then sells (because purchases may increase the market price of a security JPMS or the Certain unaffiliated Funds that Wealth Advisors recommend to Clients may execute transactions for their portfolios through JPMS or an affiliate as broker-dealer, and JPMS or an affiliate or other related person (including Wealth Advisors acting in their capacity as registered representatives of JPMS as broker-dealer) may receive compensation from the Funds in connection with these transactions. Such compensation presents a conflict of interest between JPMS and Program Clients because JPMS and/or Wealth Advisors may have a financial incentive to recommend such Funds available to Clients. This incentive may arise: (1) from the hope or expectation that increasing the amount of assets invested with the Funds will increase the number and/or size of transactions placed by the Funds for execution by JPMS or an affiliate or other related person, thereby resulting in increased compensation to JPMS and its affiliates and other related persons in the aggregate; and (2) to benefit the Funds and thereby preserve and foster 33825_COL 02-05-2026 Page 11 of 13  ITEM 13 — REVIEW OF ACCOUNTS A. Frequency and Nature of Review of Client Accounts related person owns or borrows and then sells), or (2) Clients selling securities that JPMS or the related person then buys (because sales may reduce the market price of a security JPMS or the related person then buys). An important part of the Program relationship involves providing you with the opportunity to engage in periodic reviews with your Wealth Advisor. These reviews provide updates on the progress of your Portfolio towards your goals and other important information about your Portfolio. Because these reviews provide you with important and necessary information relating to your Portfolio, you are strongly encouraged to take advantage of these opportunities to participate in these reviews. • JPMS or a related person may benefit from (1) buying securities that Clients will later buy (because the subsequent purchases may increase the market price of the security JPMS or the related person already bought and owns) or (2) selling securities that Clients will later sell (because subsequent sales may decrease the market price of the security JPMS or the related person already sold). JPMS addresses these conflicts in the following ways: Any review we perform does not substitute for your continued review of your reports or accounts. B. Factors Prompting Review of Client Accounts Other than a Periodic Review • The maintenance of policies (including in the Code of Ethics) prohibiting JPMS employees from engaging in conduct intended to manipulate the price of securities and procedures designed to prevent and/or detect such conduct; JPMS reviews the Program on an ongoing and periodic basis and has policies and procedures to supervise the Program in accordance with the Advisers Act and other rules and regulations. C. Content and Frequency of Account Reports to Clients • The maintenance of information barrier procedures designed to control the flow of information between JPMS’ and its affiliates’ proprietary trading operations and other business units; Each Wealth Advisor is responsible for reviewing the Clients advised by them on an ongoing basis. Responsibility for the ongoing supervision of each Wealth Advisor’s activity in the Program lies with the supervisor designated by JPMS as being responsible for supervising that Wealth Advisor generally. • The supervision of Wealth Advisors in providing investment advice in the Program that JPMS believes to be reasonably designed to ensure that any investment advice provided is consistent with the criteria and other information provided by Clients in accordance with their duty to place the interests of Clients in the Program before their own and those of JPMS; ITEM 14 — CLIENT REFERRALS AND OTHER COMPENSATION A. Economic Benefits for Providing Services to Clients JPMS does not receive economic benefits from non-clients for providing investment advice or other advisory services to Program Clients. • The imposition of trading restrictions with respect to certain time periods and/or lists of issuers that are designed to prevent investment personnel (including Wealth Advisors) from unfairly benefiting from unreleased research reports and recommendations; and • The requirement in the Code of Ethics that Wealth Advisors in the Program periodically report personal securities holdings and transactions to JPMS Compliance personnel. JPMS and its affiliates do receive economic benefits from certain mutual funds and other pooled investment vehicles when Clients invest in them. Although these benefits are attributable to sales of the Funds and the investment of Client’s assets in the Funds, they are not benefits the Funds provide to JPMS or its affiliates in exchange for JPMS’ provision of investment advisory services to Program Clients. Clients should understand that Wealth Advisors typically are not required, except in certain limited circumstances, to follow or otherwise consider or adhere to research reports, analyses, and opinions published or otherwise communicated by other employees of JPMS or its affiliates, including J.P. Morgan investment committees, due diligence personnel, research analysts, economists, and market strategists, and the advice of Wealth Advisors to Clients in the Program may differ from (and be diametrically opposed to) the content of such reports, analyses, and opinions. D. When JPMS or a Related Person Buys/Sells Securities for Itself at or About the Same Time It Recommends the Same Securities to/for Clients In addition, JPMS and its affiliates may from time to time enter into joint marketing activities with portfolio managers and/or sponsors of mutual funds recommended to Clients in the Program. These managers and/or sponsors may pay some or all of the cost of the marketing activities, which payment may take the form of reimbursement of JPMS. Because of the willingness of these managers and/or sponsors to provide financial support for such activities, JPMS has an incentive to allow these managers and/or sponsors (as opposed to other portfolio managers and/or sponsors who are unwilling to provide such financial support) to participate in such joint marketing activities. However, the payments by the fund managers and/or sponsors are not made in exchange for JPMS’ provision of investment advisory services to its Clients. JPMS and its related persons (including Wealth Advisors) may recommend that Clients in the Program make investments at or about the same time that JPMS or a related person buys or sells the same securities for its (or a related person’s) own account. In such circumstances, the interests of JPMS and its related persons conflict with those of JPMS’ clients, including Clients in the Program, in all of the respects described in the preceding section, each of which typically involves not only trading in the same securities that clients do but also trading in them at or about the same time that clients do. Refer to Item 10 for a discussion of revenue sharing arrangements between JPMS and certain of its affiliates pursuant to which JPMS may receive compensation from the affiliates in connection with referrals or introductions of clients by JPMS to the affiliates for the provision by the affiliates of products and services to the clients. In such cases, the compensation is in exchange for JPMS’ referral of clients to other affiliated financial service providers, not for JPMS’ own provision of investment advisory services to its clients. ITEM 12 — BROKERAGE PRACTICES JPMS does not recommend or select broker-dealers for Client transactions in the Program and does not engage in securities transactions in connection with the Program. As such, the Services do not include the review or recommendation of broker-dealers for Client transactions. The investment products recommended to Clients participating in the Program are limited to those made available through JPMS. Third-party providers (such as investment managers), may participate in JPMS-sponsored internal training and educational conferences and meetings, and they may make payments to, or for the benefit of, JPMS or its Wealth Advisors to reimburse for certain expenses incurred for these events. Providers may also sponsor their own educational conferences or due diligence meetings and pay certain expenses of Wealth Advisors attending these events. JPMS’ policies require that the training or 33825_COL 02-05-2026 Page 12 of 13  educational portion of these conferences comprises substantially all of the event, and such conferences and meetings are subject to review and approval. Further, JPMS may provide sponsorship opportunities and access to its branch offices and Wealth Advisors to such providers for educational, marketing, and other promotional efforts. Any payments made by providers could lead Wealth Advisors to focus on products managed by these providers when recommending products to Clients instead of those from other providers that do not commit similar resources to educational, marketing, and other promotional efforts. J.P. Morgan has implemented policies and procedures intended to ensure that J.P. Morgan and its employees avoid actual or perceived conflicts of interest when giving or receiving non-monetary compensation from relevant parties and comply with all applicable laws and regulations. To that end, the J.P. Morgan Code of Conduct and other gift-related policies generally restrict or prohibit acceptance of gifts, entertainment, or other nonmonetary compensation in connection with the services provided to any Client or in return for any business of J.P. Morgan. Exceptions may be made, including for certain non-cash gifts or promotional items valued at $100 or less. The J.P. Morgan Code of Conduct and other gift-related policies set conditions for each of these types of payments and do not permit any gifts or promotional items unless it is clear that the gift-giving person is not trying to influence or reward the JPMS employee inappropriately in connection with any business decision or transaction and that the gift is unsolicited. Providers participating in JPMS programs or otherwise utilized by J.P. Morgan are not required to make any of these types of payments. B. Compensation to Non-Supervised Persons for Client Referrals Neither JPMS nor any related person of JPMS directly or indirectly compensates any person who is not its supervised person for Client referrals to the Program. ITEM 15 — CUSTODY JPMS does not have custody of Client funds and securities in connection with the Program. ITEM 16 — INVESTMENT DISCRETION JPMS does not accept discretionary authority in connection with the Program. ITEM 17 — VOTING CLIENT SECURITIES JPMS will not vote proxies (or give advice about how to vote proxies) relating to securities or other property currently or formerly held by a Client. JPMS and its affiliates will not be responsible for notifying Clients of proxies or of sending Clients proxy materials. Clients are responsible for voting proxies or any securities or other property in their Portfolio. ITEM 18 — FINANCIAL INFORMATION JPMS does not require or solicit prepayment of more than $1,200 in fees per Client 6 months or more in advance and, thus, has not included a balance sheet or its most recent fiscal year. JPMS is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to its Clients, nor has JPMS been the subject of a bankruptcy petition at any time during the past 10 years. 33825_COL 02-05-2026 Page 13 of 13