Disclosure

is an interactive web-based investment tool developed by that permits an investment professional (generally a registered investment adviser or a sophisticated investor) to devise a desired investment strategy (“Strategy,” including any combination of such Strategies) for the professional’s client or such sophisticated investor. At all times, the investment professional, and not OSAM, is responsible for: maintaining the initial and ongoing relationship with the underlying client and rendering individualized investment advice to the client. In addition, the investment professional or self-managing sophisticated investor, as the case may be, and not OSAM, is responsible for (1) determining the initial and ongoing suitability of the Strategy for the client; (2) devising or determining the specific initial and ongoing desired Strategy; (3) monitoring performance of the Strategy; and (4) modifying and/or terminating the management of the client’s account using the Strategy. The client may not look to OSAM for, and OSAM shall not have any responsibility for: (1) providing individualized investment advice or making any determination as to the initial or ongoing suitability of any Strategy for any specific investor, including the professional’s client; (2) monitoring the Strategy; or (3) the performance of the Strategy. The use of the CANVAS tool does not serve as the receipt of, or as a substitute for, personalized investment advice from the client’s investment professional, for which the client must look solely to his or her investment professional. No guaranty of performance or suitability is made or may be inferred from materials at the CANVAS web site or the use of the CANVAS tool.

Past performance may not be indicative of future results. Different types of investments involve varying degrees of risk. It should not be assumed that future performance of any specific investment or investment strategy, including the investments and/or Strategy devised and/or managed by OSAM, and any investment or investment Strategy resulting from the use of CANVAS, will be profitable, equal any historical performance level(s), be suitable for any specific investor or individual situation, or prove successful. Historical performance results for investment indices, benchmarks, and/or categories have been provided for general informational/comparison purposes only, and generally do not reflect the deduction of transaction and/or custodial charges, the deduction of an investment management fee, nor the impact of taxes, the incurrence of any or which would have the effect of decreasing historical performance results. When the securities to be purchased and held using the CANVAS tool include ex-change-traded funds, including fixed-income funds, the investor will be subject to additional expenses imposed at the fund level; the CANVAS tool seeks to estimate these expenses but may not do so precisely. An investor’s account holdings will generally not correspond directly to any comparative indices or categories.

The CANVAS tool reports historical performance information for Strategies compiled by OSAM. These performance figures reflect hypothetical, back-tested results; thus, they represent the retroactive performance of simulated portfolios. As such, the corresponding results have inherent limitations, including that: (a) the results do not reflect actual trading using investor assets, but were achieved by means of the theoretical retroactive application of the devised Strategy, certain aspects of which may have been designed with the benefit of hindsight; (b) back-tested performance may not reflect the impact that any material market or economic factors might have had on the investment professional’s use of the hypothetical portfolio if the portfolio had been used during the period to manage actual investor assets; and (c) the back-tested performance of any Strategy does not reflect trading costs, investment management fees or taxes (although, as noted above, the expenses of exchange-traded funds included in any Strategy are sought to be taken into account). Such simulated theoretical returns are provided for informational purposes only to indicate historical performance had the Strategy’s portfolios been available over the relevant time period. OSAM did not offer the CANVAS tool until April 2019. Prior to 2007, OSAM did not manage client assets.

A copy of OSAM’s current written disclosure brochure is directly accessible via link at www.osam.com/legal

CANVAS is intended for use only by investment professionals and by certain other sophisticated investors with appropriate knowledge and experience who are able to bear the risks of loss associated with the use of the CANVAS tool.