CHILTON INVESTMENT COMPANY INC.

Chilton does not have fixed internal brokerage allocation procedures, prioritizing best execution in transactions for client accounts. They may direct brokerage to firms providing research products and services when permitted by law and when they believe those firms can provide best execution. Chilton recognizes the value of research products and services and may direct brokerage to firms providing them, consistent with their obligation to seek best execution. Chilton's investment staff is comprised of highly qualified and trained professionals integral to the success of the firm and client accounts. Attracting and retaining a qualified, motivated, and talented investment staff is crucial to Chilton's success. Failure to do so could negatively impact the performance of client accounts and Chilton's business overall.

Chilton's equity strategies are characterized as classic fundamental long/short equity strategies with a conservative approach focused on alpha generation and capital preservation. They invest in both growth and value companies that meet short-term and long-term fundamental criteria. The sector, market capitalization, or geographical allocations of a given Client Account's investment portfolio will depend upon the Client Account's mandate and Chilton's determination with respect to the best fundamental risk and reward opportunity set. The implementation of Chilton's investment strategies may include long-term purchases (securities held at least a year), short-term purchases (securities sold within a year), trading (securities sold within 30 days including same-day transactions), short sales and covers, and securities and obligations purchased on margin. The success of a Client Account's investment and trading activities will depend on Chilton's ability to identify undervalued investment opportunities within the relevant investment objective.

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