pg. 1

"We believe that given the nature of the services that we offer that the risk of our involvement in modern slavery and human trafficking throughout our operations, and supply chains is low, as (i) we and our suppliers generally operate in lower risk jurisdictions, (ii) we have in place robust money laundering controls to mitigate against the risk of financing modern slavery or bonded labor, and (iii) our business partners in the financial services sector present a low risk of modern slavery. To assess, monitor, and mitigate our risk we have formed and empowered an ESG Committee; a Diversity, Equity, and Inclusion (“DEI”) Committee; and a Vendor Committee, each charged with reviewing our business conduct, including potential exposure to modern slavery and human trafficking in all its forms."

...

"In terms of our approach to due diligence, we evaluate company modern slavery disclosures, policies, and procedures and proactively engage management to understand how they think about these risks. This applies to new positions and existing positions in the portfolio where an allegation of modern slavery may appear during the course of ownership. As appropriate and where necessary, we engage management to understand the nature of the allegations and advocate for changes to a company’s actions.

Finally, some manifestations of ESG risk may not have a clear financial impact on earnings but are deemed material societal risks. In these cases, we approach the issues as we would material financial risks. We consider child labor and/or involvement in human trafficking as such a risk regardless of the impact on company earnings and therefore will engage management if instances or allegations of these activities exist. We plan to continually evaluate whether we should add additional issues to this list in the future."

pg. 2

"We respect the rights of our employees to enjoy just and favorable work conditions, including health and safety protections, and are committed to providing adequate information and training on health, safety and wellbeing issues.

We also promote diversity, equity, and inclusion and have formed a DEI Committee to spearhead our efforts to prohibit all forms of discrimination based on age, race, nationality, ethnic origin, gender, sexual orientation, religion, marital status, or disability. Pzena is committed to a work environment in which all individuals are treated with respect and dignity.

In addition, all employees are made aware of the important role that they play in upholding our high standards of conduct and integrity in all we do through our Code of Business Conduct and Ethics, Employee Handbook, whistleblowing policy and other policies."