BNY MELLON SECURITIES CORPORATION

BNY Mellon Securities Corporation 240 Greenwich Street, New York, NY 10286 Form ADV Part 2A Disclosure Statement BNY Mellon Securities Corporation Firm Brochure March 31, 2025 This brochure (“Brochure”) provides information about the qualifications and business practices of BNY Mellon Securities Corporation (“BNYSC”). If you have any questions about the contents of this Brochure, please contact your program sponsor or us at 212- 635-8827. 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. Registration with the SEC does not imply a certain level of skill or training. Additional information about BNYSC and its affiliated investment advisers is also available on the SEC’s website at www.adviserinfo.sec.gov. Clients of wrap fee programs should also review the wrap fee program Brochure provided by the program sponsor.  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Item 2. Material Changes We may update this document at any time but are required to promptly send clients a copy of any material changes to our disclosures upon doing so. In addition, we will also deliver an annual summary of all material changes that occur to this Brochure along with an offer to provide you with a copy of the updated Brochure. BNYMSC’s last annual update of this Brochure was on March 30, 2024. As of August 29, 2024, we updated Item 9 to reflect a settlement we entered into with the SEC regarding the sending and receipt of business-related text message communications via platforms that were not approved for business purposes. 2  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Item 3. Table of Contents Item Page 1- Cover Page 1 2- Material Changes 2 3- Table of Contents 3 4- Advisory Business 4 5- Fees and Compensation 9 6- Performance-Based Fees and Side-by-Side Management 11 7- Types of Clients 13 8- Methods of Analysis, Investment Strategies and Risk of Loss 14 9- Disciplinary Information 22 10- Other Financial Industry Activities and Affiliations 22 11- Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 29 12- Brokerage Practices 34 13- Review of Accounts 38 14- Client Referrals and Other Compensation 38 15- Custody 39 16- Investment Discretion 40 17- Voting Client Securities 40 18- Financial Information 45 Appendix A 46 3  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Item 4. Advisory Business Introduction BNY Mellon Securities Corporation (“BNYSC,” “Firm,” “We,” “Our” or “Us”) is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”) and as a broker-dealer under the Securities Exchange Act of 1934 (the “1934 Act”); is a member of the Financial Industry Regulatory Authority (FINRA); and is registered with the National Futures Association (NFA) as an introducing broker. BNYSC is a corporation organized under the laws of the State of New York. BNYSC is a wholly owned subsidiary of BNY Mellon Investment Adviser, Inc. (“BNYIA”) and an indirect subsidiary of The Bank of New York Mellon Corporation (“BNY”). BNYSC has been providing investment advisory services to individuals and institutions since 2001. We provide investment advisory services to wrap programs sponsored by non-affiliated banks, broker-dealers, investment advisers and other financial intermediaries (“Program Sponsors”) by: (i) sub-advising separate account portfolios (“Traditional Wrap Program(s)”); (ii) providing model portfolios (“Model Delivery Program(s)”); or (iii) directly advising on investors’ separate account portfolios (“Dual-Contract Program(s)”). In Traditional Wrap Programs and Dual-Contract Programs, BNYSC executes discretionary securities transactions in an account in the name of the wrap program client (“Wrap Client(s)”), subject to any investment restrictions specified by the Wrap Client. With respect to Model Delivery Programs, BNYSC provides model portfolios to the Program Sponsor, who then executes securities transactions on behalf of the Wrap Clients. Investment advisory services are provided to Model Delivery Programs on a non-discretionary basis. We do not have discretionary investment authority with respect to any Wrap Client accounts in Model Delivery Programs (although we may, depending upon our contractual arrangement with the Program Sponsor, be granted authority over proxy voting, regulatory reporting or similar non- investment functions). For purposes of this Brochure, we will collectively refer to Traditional Wrap Programs, Model Delivery Programs and Dual Contract Programs as “Wrap Programs.” BNYSC provides portfolio management services to Traditional Wrap Program and Model Delivery Program Wrap Clients pursuant to an agreement with the Program Sponsor and, with respect to Dual-Contract Programs, pursuant to an investment advisory agreement with the Wrap Client. In connection with these Wrap Programs, BNYSC may engage affiliated or non-affiliated investment managers (each a “Delegated Manager”) to perform certain investment advisory services on BNYSC’s behalf, including providing investment recommendations to BNYSC based 4  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 on a particular investment strategy (the “Strategy(ies)”). The Delegated Manager is responsible for monitoring, evaluating and adjusting the investment recommendations based on the Delegated Manager’s investment research, experience and judgment. Currently, BNY Mellon Advisors, Inc. (“BNY Advisors”), Newton Investment Management North America LLC (“NIMNA”), Newton Investment Management Limited (“NIM”) and Walter Scott & Partners Limited (“Walter Scott”), all of which are affiliated investment managers, serve as Delegated Managers to BNYSC. We, BNY Advisors, NIMNA, NIM and Walter Scott are registered investment advisers and BNY Investments firms. BNY Investments is one of the world’s leading investment management organizations and one of the top U.S. wealth managers, encompassing BNY’s affiliated investment management and global distribution firms. BNY is the corporate brand of The Bank of New York Mellon Corporation. BNYSC may also give advice to a municipal entity or obligated person regarding the investment of proceeds of a municipal security, and this will be done in our investment adviser capacity. Please see Item 7 of this Brochure for more information on these types of clients. As described in more detail below, we also offer advisory services not described in this Brochure, in particular as the sponsor of a wrap fee investment program (the BNY Managed Asset Program). If you would like more information, please consult our Form ADV Part 2A, Appendix 1 – Wrap Fee Program Brochure, which is available at www.adviserinfo.sec.gov. Third-Party Wrap Programs Traditional Wrap Programs In a Traditional Wrap Program, a Wrap Client enters into an advisory agreement with the Program Sponsor and the Program Sponsor enters into a sub-advisory agreement with BNYSC. Under a Traditional Wrap Program, BNYSC is retained by the Program Sponsor, and Wrap Clients select BNYSC from among the investment advisers that the Program Sponsor presents to them. Upon accepting management of a Wrap Client’s account (“Wrap Account”), BNYSC provides investment advisory services to the Wrap Account in accordance with the investment guidelines applicable to the investment strategy selected by the Wrap Client; the investment guidelines, if any, specified by the Program Sponsor with respect to the applicable Wrap Program; and the investment restrictions, if any, specified by the Wrap Client. In connection with Traditional Wrap Programs, BNYMSC may perform some or all of the following services: 5  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 - providing investment advisory services for Wrap Accounts; - facilitating trading for Wrap Accounts with Program Sponsors and other broker-dealers; - managing Wrap Accounts and implementing the Delegated Manager’s investment strategy recommendations; - monitoring the Delegated Manager’s strategy guidelines, the Program Sponsor’s Wrap Program guidelines and the Wrap Clients’ investment guidelines; - participating in consultations with financial advisors of the Program Sponsors regarding administration of Wrap Accounts; facilitating the instructing of corporate actions; conducting proxy voting on a Wrap Client’s behalf, if so directed; and - undertaking secondary suitability reviews; - - - filing certain regulatory reports. Portfolio transactions for Wrap Clients of Traditional Wrap Programs are generally directed by BNYSC to the Program Sponsor for execution but may also, in certain circumstances, be directed to a non-sponsoring broker-dealer in an effort to seek best execution. Please see Item 12 of this Brochure for more information about the selection of broker-dealers when executing securities trades on behalf of Wrap Clients. Model Delivery Programs In Model Delivery Programs, BNYSC is retained by the Wrap Program Sponsor to provide non- discretionary portfolio recommendations, which take the form of a portfolio model related to a particular strategy and not tailored to any specific Wrap Client. The Program Sponsor retains full discretion to accept, modify or reject such recommendations and the Program Sponsor (or a third party retained by the Program Sponsor to perform services for the Wrap Program, such as an overlay manager) is generally responsible for implementing the ultimate investment decisions. BNYSC does not know the identity of, or any other pertinent information about, the Wrap Clients for whom the Program Sponsor has elected to use BNYSC’s portfolio model. Unlike Traditional Wrap Programs or Dual-Contract Programs, BNYSC does not have discretionary investment authority with respect to any Wrap Client accounts in Model Delivery Programs. In connection with Model Delivery Programs, BNYSC may perform some or all of the following services: - facilitating model delivery to the Program Sponsor; 6  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 facilitating the instructing of corporate actions; conducting proxy voting on a Wrap Client’s behalf, if so directed; and - - - filing certain regulatory reports. Dual-Contract Programs In Dual-Contract Programs, a Wrap Client enters into an investment advisory agreement directly with BNYSC and a separate agreement with the Program Sponsor. Upon accepting management of a Wrap Account, BNYSC directly advises and manages the Wrap Account in accordance with the investment guidelines applicable to the investment strategy selected by the Wrap Client; the investment guidelines, if any, specified by the Program Sponsor with respect to the applicable Wrap Program; and the investment restrictions, if any, specified by the Wrap Client. As of the date of this Brochure, we do not advise any Dual-Contract Program Wrap Accounts but do offer discretionary investment advisory services to Wrap Programs that accept Dual-Contract Program Wrap Clients. In connection with Dual-Contract Programs, BNYSC may perform some or all of the following services: - providing investment advisory services for Wrap Accounts; - undertaking suitability and Know Your Customer reviews; - facilitating trading with Program Sponsors (where available) and other broker-dealers; - managing Wrap Accounts and implementing the Delegated Manager’s investment strategy recommendations; - monitoring the Delegated Manager’s strategy guidelines, the Program Sponsor’s Wrap Program guidelines and the Wrap Clients’ investment guidelines; - participating in consultations with financial advisors of the Program Sponsors regarding administration of Wrap Accounts; facilitating the instructing of corporate actions; facilitating billing of Wrap Accounts; conducting proxy voting on a Wrap Client’s behalf, if so directed; and - - - - filing certain regulatory reports. Portfolio transactions for Wrap Clients of Dual-Contract Programs are generally directed by BNYSC to the Program Sponsor for execution (where available) but may also, in certain 7  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 circumstances, be directed to a non-sponsoring broker-dealer in an effort to seek best execution. Please see Item 12 of this Brochure for more information about the selection of broker-dealers when executing securities trades on behalf of Wrap Clients. BNYMSC has the right, at its discretion, to decline to provide investment advisory services, on a case-by-case basis, to new Wrap Clients of Program Sponsors. In addition to providing investment advisory and related services for Wrap Programs, BNYSC may be retained by affiliated and non-affiliated investment managers to provide administrative and support services (“Administrative Services”) in connection with the investment advisory services that such managers have agreed to perform for wrap accounts of financial services firms who sponsor wrap fee investment programs. Wrap Clients of these Wrap Programs should also review the Brochures of the Delegated Manager and Program Sponsor, which will contain additional information about each of those firm’s investment advisory services. Other Accounts BNYSC’s Role as a Program Sponsor to a Wrap Fee Investment Program: BNY Managed Asset Program BNYSC also offers a proprietary wrap fee investment program, the BNY Managed Asset Program (“BNY MAP”), for which BNYSC serves as the program sponsor. BNY MAP clients may invest in (i) mutual funds sponsored or managed by our affiliates (“BNY Mutual Funds”) or a combination of BNY Mutual Funds and selected mutual funds from third party mutual fund families, (ii) equity investment strategies through one or more separately managed accounts managed by professional investment advisory firms, including BNYSC, (iii) municipal bonds through a separately managed account managed by an affiliate, Insight North America LLC (“INA”), (iv) a fixed income decumulation strategy managed by INA, or (v) a combination of these products. For more detail with respect to BNY MAP, please refer to BNYSC’s Form ADV Part 2A, Appendix 1 - Wrap Fee Program Brochure, available at www.adviserinfo.sec.gov. 8  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Assets Under Management As of December 31, 2024, we managed $7.139 billion for clients, of which $0.701 billion was on a discretionary basis and $6.438 billion was on a non-discretionary basis. Class Actions; Litigation: It is our policy that we do not advise, initiate or take any other action on behalf of clients relating to securities held in the client’s account managed by us in any legal proceeding (including, without limitation, class actions, class action settlements and bankruptcies). We do not file proofs of claims relating to securities held in your account and do not notify you or your custodian of class action settlements or bankruptcies relating in any way to such account. Typically, custodians submit filings in connection with class action settlements and may also handle bankruptcy filings. You should consult with your custodian and other service providers to ensure such coverage. Item 5. Fees and Compensation Fees for BNYSC’s investment advisory services are described in the sections below. As a dually registered investment adviser and broker-dealer, the investment advisory services that we perform are separate and distinct from the brokerage services we perform, and each is governed by different laws and contractual arrangements. While there may be certain similarities between the brokerage and advisory services we provide depending on the capacity in which we act, our contractual relationship and legal duties, including the fees we charge to clients, are subject to a number of important differences. Wrap Programs Generally, in a Wrap Program, the Program Sponsor charges the Wrap Client an inclusive (“wrap”) fee that covers various costs relating to the management of the Wrap Client’s account. This wrap fee typically includes brokerage transaction and clearing charges, custodian fees, investment advisory fees, and any other applicable fees for related services. Typically, the Wrap Client is introduced to the Strategy by the Wrap Client’s financial professional, who is employed by the Program Sponsor. Some Wrap Programs may not charge a wrap fee and may, instead, bill separately for each service provided. With respect to Dual-Contract Programs, the investment advisory fee typically is not included in the Program Sponsor’s wrap fee and, therefore, the investment advisory fee would be an additional fee paid by the Wrap Client either directly or collected by the Program Sponsor from the Wrap Client on our behalf. Wrap Clients should consult their Program Sponsor’s Wrap Fee Program Brochure for additional information about the 9  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 services provided through their program by the Program Sponsor and related fees and expenses associated with the Wrap Program. Except with respect to certain Dual-Contract Programs, the Program Sponsor’s Wrap Clients generally do not pay a fee directly to BNYSC and have limited direct contact with BNYSC. The Program Sponsor typically pays BNYSC a portion of the total managed account program fee paid to the Program Sponsor by the Wrap Client. This typically ranges from 0.00% to 0.50% annually, depending on the Program Sponsor, the type of account, the level of support provided by BNYSC and the size of the Wrap Client’s assets in the specific Strategy. In addition, and as described above, BNYSC may be retained by affiliated and non-affiliated investment managers to provide administrative and support services in connection with the investment advisory services that such managers have agreed to perform for wrap accounts of financial services firms who sponsor wrap fee programs. In such cases, BNYSC is paid a fee by those investment managers for providing such administrative and support services, which are unrelated to BNYSC’s provision of investment advisory services to Wrap Clients. In Traditional Wrap Programs, trade execution is generally conducted through the Program Sponsor unless trade execution with a non-sponsoring firm may result in more favorable execution for the Wrap Client. With respect to Dual-Contract Programs, depending upon the structure of the Program, trade execution may either be generally conducted through the Program Sponsor, unless trade execution with a non-sponsoring firm may result in more favorable execution, or all trading may occur away from the Program Sponsor. Trade execution with a non-sponsoring firm may result in additional fees to the Program Sponsor’s Wrap Clients. Please refer to Item 12 of this Brochure (Brokerage Practices) for more information about trade execution with non-sponsoring firms. Depending on the amount of activity in an account, the fees for a Wrap Program may result in higher costs than a Wrap Client might otherwise incur by establishing separate arrangements for trade execution, custody, investment advice and other account-related services. Wrap Clients may wish to periodically evaluate whether the total fee for a particular Wrap Program is appropriate to their needs. Conflicts of Interest Related to Wrap Programs BNYSC has certain representatives who, among other things, market the Strategies advised by the Delegated Managers to Program Sponsors. Program Sponsors may then recommend the Strategies to their Wrap Clients. BNYSC may compensate its representatives more for successfully marketing certain Strategies over others. The compensation paid by BNYSC to its representatives 10  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 for marketing the Strategies is made solely by BNYSC out of its own assets. These payments present a conflict of interest because the BNYSC representatives have an incentive to promote Strategies to Program Sponsors based on the potential for compensation rather than the needs of a Program Sponsor’s Wrap Clients. For more information on fees and compensation, please see the Wrap Program Brochure you receive from your Program Sponsor. Item 6. Performance-Based Fees and Side-by-Side Management Performance-based fee arrangements and side-by-side management activities entail inherent conflicts that are described in this Item 6. We have not entered into performance-based fee arrangements with our clients. However, our Delegated Managers may enter into performance-based fee arrangements with their clients. For more detailed information about such arrangements, including how our Delegated Managers’ performance fees are calculated, please see the respective Delegated Manager’s firm brochure. “Side-by-side management” refers to our simultaneous management of multiple types of client accounts/investment products. For example, we or our Delegated Managers may simultaneously manage separate accounts, managed accounts and pooled investment vehicles for clients. Our clients have a variety of investment objectives, policies, strategies, limitations and restrictions. Our affiliates likewise manage a variety of separate accounts, managed accounts, and pooled investment vehicles. Side-by-side management gives rise to a variety of potential and actual conflicts of interest for us, our employees and our supervised persons. Below we discuss the conflicts that we and our employees and supervised persons face when engaging in side-by-side management and how we deal with them. Note that certain of our affiliated Delegated Managers’ employees are also officers or employees of one or more BNY affiliates (“dual officers” or “dual employees”). These dual officers or dual employees undertake administrative or investment management duties for the affiliates of which they are such officers or employees. Please see Dual Officers and Dual Employees in Item 10 of this Brochure (Other Financial Industry Activities and Affiliations) for more information on our dual officer and dual employee arrangements. When our affiliates concurrently manage client accounts/ investment products, and particularly when dual officers or dual employees are involved, this presents the same conflicts as described below. 11  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 To address these conflicts of interest, we manage our accounts consistent with applicable law, and we and our Delegated Managers follow procedures that are reasonably designed to treat our clients fairly and to prevent any client or group of clients from being systematically favored or disadvantaged. For example, we and our Delegated Managers have trading policies and procedures, such as trade allocation and best execution procedures, which are designed and implemented to help ensure that all clients are treated fairly and equally, and to prevent these conflicts from influencing the allocation of investment opportunities between and among clients. Please see Item 12 of this Brochure (Brokerage Practices) (and Item 12 of our Delegated Managers’ firm Brochures) for more information. Conflicts of Interest Relating to Accounts with Different Strategies We and our Delegated Managers manage numerous accounts with a variety of strategies, which presents conflicts of interest relating to the allocation of investment opportunities and the aggregation and allocation of trades. For example, a long/short position in two client accounts simultaneously can result in a loss to one client based on a decision to take a gain in the other. Taking concurrent conflicting positions in certain derivative instruments can likewise cause a loss to one client and a gain to another. Conflicts of Interest Relating to the Management of Multiple Client Accounts We and our Delegated Managers perform investment advisory services for various clients. In many instances, we give advice and take action in the performance of our duties with respect to certain of our clients which differs from the advice given, or the timing or nature of action taken, with respect to other clients. We have no obligation to purchase or sell for a client any security or other property which we purchase or sell for our own account or for the account of any other client, if it is undesirable or impracticable to take such action. Conflicts of Interest Relating to Investment in Affiliated Accounts To the extent permissible under applicable law, we may decide to invest some or all of our corporate temporary investments in money market accounts advised or managed by a BNY affiliate. We have an incentive to allocate our own investments to these types of affiliated accounts to generate additional fees for us or our affiliates. Conflicts of Interest Relating to “Proprietary Accounts” We, our affiliates, and/or our existing and future employees will from time to time invest in products managed by us or our affiliates (“Proprietary Accounts”). Investment by us, our affiliates, 12  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 or our employees in Proprietary Accounts creates conflicts of interest because we or our affiliates have an incentive to favor these Proprietary Accounts by, for example, directing the best investment ideas to these accounts or allocating, aggregating or sequencing trades in favor of such accounts, to the disadvantage of other accounts. We and our affiliates also have an incentive to dedicate more time and attention to our Proprietary Accounts and to give them better execution and brokerage commissions than our other client accounts. Other Conflicts of Interest As noted previously, we and our affiliates manage numerous accounts with a variety of interests. This necessarily creates conflicts of interest for us. For example, we or our Delegated Managers may cause multiple accounts to invest in the same investment. Such accounts may have conflicting interests and objectives in connection with such investment, including differing views on the operations or activities of the portfolio company, the targeted returns for the transaction and the timeframe for and method of exiting the investment. Conflicts also arise in cases where multiple BNYSC and/or affiliate client accounts are invested in different parts of an issuer’s capital structure. For example, one of our client accounts could acquire debt obligations of a company while an affiliate’s client account acquires an equity investment. In negotiating the terms and conditions of any such investments, we could conclude that the interests of the debt-holding client accounts and the equity holding client accounts conflict. If that issuer encounters financial problems, decisions over the terms of any workout could raise conflicts of interest (including, for example, conflicts over proposed waivers and amendments to debt covenants). For example, debt holding accounts may be better served by a liquidation of an issuer in which it could be paid in full, whereas equity holding accounts might prefer a reorganization of the issuer that would have the potential to retain value for the equity holders. As another example, holders of an issuer’s senior securities could potentially direct cash flows away from junior security holders, and both the junior and senior security holders could be BNYSC client accounts. It is important to note that, when we act as your broker-dealer, we are not held to the same legal standards that apply when we are providing investment advisory services. Item 7. Types of Clients and Account Requirements Types of Clients As discussed in Item 4 (Advisory Business) above, we provide an array of investment advisory services to individual investors and other clients of Program Sponsors of Wrap Programs. To the extent that we are providing advice to a municipal entity or obligated person regarding the investment of proceeds of a municipal security, this will be done in our investment adviser 13  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 capacity. Please review the wrap fee program brochure from your Program Sponsor for more information on types of clients and account requirements for the Program Sponsor’s Wrap Programs. For information regarding BNY MAP, please refer to our Form ADV Part 2A, Appendix 1 - Wrap Fee Program Brochure, available at www.adviserinfo.sec.gov. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Wrap Programs We offer a variety of investment strategies which, as described in Item 4, are referred to in this Brochure as “Strategies” and which are listed below in this Item 8. Please also refer to Item 8 of our Delegated Managers’ Brochures for detailed descriptions of the Strategies for which each Delegated Manager performs investment advisory services on our behalf, and for each Delegated Manager’s methods of analysis. Each Strategy involves risk of loss, which Wrap Clients should be prepared to bear. Please refer to the Summary of Material Risks in this Item 8 below, and to Item 8 of our Delegated Managers’ Brochures, for descriptions of the primary risks relating to the Strategies we offer. In addition, with respect to the ETF-based model Strategies described below, please refer to the particular ETF prospectus for more information about the risks applicable for a particular ETF. If you would like a copy of a particular BNY Mellon ETF prospectus, you may obtain one at bny.com/investments or by calling us at 1-800-373-9387. To obtain non-BNY Mellon ETF prospectuses, please contact the Program Sponsor or the direct website of the ETF in question. For all Strategies, there is no assurance or guarantee that a Strategy’s or a Wrap Client’s investment objectives will be met. Investment Strategies The Strategies we may currently make available to Program Sponsors are listed below, along with the name of the Delegated Manager providing investment advisory services to us. Wrap Clients should additionally check with representatives of their Program Sponsors for actual availability of a given Strategy with respect to a particular Wrap Program. 14  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025  BNY Advisors BNY Advisors provides the following core model Strategies to us for use in Model Delivery Programs: o BNY Mellon Growth ETF Model - seeks to provide investors with exposure to a growth-oriented portfolio focused on capital return. o BNY Mellon Growth & Income ETF Model - seeks to provide investors with growth through capital return and income. o BNY Mellon Balanced ETF Model - seeks to provide investors with a balance of growth, income, and principal preservation. o BNY Mellon Stable Growth ETF Model - seeks to provide investors with principal preservation and growth. o BNY Mellon Income ETF Model - seeks to provide investors with a stream of current income primarily through bonds. o BNY Mellon Stability ETF Model - seeks to provide investors with principal preservation and an “anchor” to their overall portfolio. o BNY Mellon Stable Income ETF Model - seeks to provide investors with principal preservation and income. Each of these seven ETF-based model Strategies is available in Wrap Account form in both taxable and tax-aware versions. Each model Strategy is comprised of a blend of Exchange Traded Funds (ETFs) sponsored or managed by our affiliates (“BNY Mellon ETFs”) and by unaffiliated investment managers (“Third Party ETFs”) and is designed to seek a particular investment objective (as expressed in each model Strategy’s name). The tax-aware versions, while each retaining the same investment objective described above and the same sector allocations as the corresponding taxable version, include exposure to a Municipal Bond ETF to potentially generate tax-free income; please refer to the BNY Advisors brochure for more information concerning BNY Advisors’ investment processes and associated risks. Information about the specific ETFs comprising each model strategy may be found in each ETF’s prospectus, available as described above. 15  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 In addition to the core ETF-based model Strategies described above, BNY Advisors may create on our behalf customized variations of these core model Strategies or new model Strategies for use in Model Delivery Programs, focused on specific investment goals or objectives and may, for example, be keyed to particular asset allocations and investment styles, depending on the specific requirements of the Program Sponsors who have engaged us as model providers. As of the date of this Brochure, BNY Advisors has created a number of such custom variations on our behalf in response to specific product requests we have received from various Program Sponsors. Such customized variations of the core model Strategies and new model Strategies will include allocations to one of more of the following: (i) BNY Mellon ETFs and/or BNY Mellon Mutual funds sponsored or managed by our affiliates (collectively, the “BNY Funds”), (ii) Third Party ETFs and/or mutual funds sponsored or managed by unaffiliated investment managers (collectively, “Third Party Funds” and together with the BNY Funds, the “Funds”), and (iii) other model Strategies of the Delegated Managers as described in this Item 8 (the “SMA Strategies”). As general matter, BNY Funds and SMA Strategies provided by the affiliated Delegated Managers (the “Affiliated SMA Strategies” and together with the BNY Funds, the “BNY Products”) are preferred in these model Strategies and the proportion of BNY Products included can be high (in fact up to 100%); however, the proportion and types of BNY Products (as well as Third Party Funds and third party SMA Strategies) recommended will vary depending on the specific goals and objectives of the model Strategies, as well as any particular requirements imposed by Program Sponsors. This also means that the universe of mutual funds, ETFs and SMA Strategies considered in constructing the model Strategies is limited and, as discussed below, BNYSC and its affiliates will receive more overall compensation when BNY Products are included. When constructing these model Strategies, we will however seek to include the lowest cost share classes of the constituent Funds in our model recommendations that we reasonably believe Wrap Clients would be eligible to purchase, subject to any limitations that may be imposed by the Program Sponsor. Wrap Clients who invest in our ETF-based core model Strategies, as well as the customized variations and new model Strategies described above, will bear a proportionate share of each Fund’s fees and expenses, including, as applicable, investment management fees and fees for administrative, distribution, transfer agency, custody, legal and audit services and other fees and expenses customarily paid by funds to persons who provide services to them. These fees will be in addition to the wrap fee charged by the Program Sponsor and are described in each Fund’s prospectus or statement of additional information (“SAI”). Clients should review all applicable prospectuses and SAIs for additional information about these fees and expenses. In addition, clients who invest in a model Strategy that includes a SMA Strategy component will be subject to the applicable advisory fee for that SMA strategy. 16  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 With respect to BNY Funds, BNYSC and its affiliates provide services to such BNY Funds and receive fees for those services from the applicable BNY Fund or one or more of its other service providers. In addition, BNYSC’s affiliates may also provide services to Third Party Funds and receive fees for those services from the applicable Third -Party Fund or one or more of its other service providers. Typically, these fees will be based on the value of a Fund’s total assets. In particular, BNYSC serves as the distributor of the BNY Mellon Family of Funds, the BNY Mellon Funds Trust and the BNY Mellon ETF Trusts, and may be compensated through distribution and/or shareholder service fees. In addition, our affiliates provide a variety of other services to the BNY Funds and their shareholders, such as investment advisory, transfer agency, custodial and other administrative services (including securities lending services). With respect to the Affiliated SMA Strategies and as described in Item 5 above, BNYSC receives a fee from the Program Sponsor and, in turn, compensates the applicable Delegated Manager for its investment advisory services. The compensation received by BNYSC and its affiliates varies by Fund and by Affiliated SMA Strategy, which means that BNYSC and its affiliates benefit more when Wrap Clients invest in BNY Funds and Affiliated SMA Strategies where the compensation is higher, as described in general terms in each Fund’s prospectus or SAI (for the Funds) and as described in Item 5 above and in a Program Sponsor’s Wrap Fee Program Brochure (for the Affiliated SMA Strategies). BNYSC and its affiliates receive significantly higher compensation from BNY Funds and Affiliated SMA Strategies than from Third Party Funds and unaffiliated SMA Strategies, respectively. Accordingly, a financial incentive exists when constructing these model Strategies to select Funds (and BNY Funds in particular) and Affiliated SMA Strategies that result in additional compensation to BNYSC and its affiliates, and to weight higher compensating BNY Funds and Affiliated SMA Strategies more heavily. However, as discussed above, the Funds and SMA Strategies selected for the model Strategies are designed to meet particular investment goals and objectives, including any particular requirements of the Program Sponsors. In addition, as an investment adviser, we are obligated to act in the best interest of Program Sponsors when making non-discretionary model recommendations, and we maintain policies, procedures and supervisory controls designed to meet this obligation.  NIMNA o BNYM Newton Dynamic Value o BNYM Newton Dynamic US Equity o BNYM Newton Global Natural Resources 17  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 o BNYM Newton Large Cap Growth o BNYM Newton Small Mid Cap Growth The Strategies above correspond to, respectively, the Large Cap Value, Domestic Asset Allocation, Thematic Equity, Global Equity and Small Cap Growth strategies described in Item 8 of NIMNA’s brochure.  NIM o BNYM Newton International Equity o BNYM Newton International Equity ADR (no longer offered) o BNYM Newton Global Equity o BNYM Newton Global Equity Income ADR The Strategies above correspond to, respectively, the International Equity, International Equity, Global Equity and Global Equity Income strategies described in Item 8 of NIM’s Brochure.  Walter Scott o BNYM Walter Scott International Stock ADR The Strategy above corresponds to the EAFE strategy described in Item 8 of Walter Scott’s Brochure. Working with a Program Sponsor representative, the Wrap Client typically determines his or her investment strategy based on personal circumstances and objectives and selects one or more Strategies. Wrap Clients are responsible for asset allocation decisions when selecting portfolios. We and our Delegated Managers do not provide asset allocation advice with respect to the Strategies we offer. 18  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Risk of Loss Each investment strategy we offer invests in a variety of securities and employs a number of investment techniques that involve certain risks. Investment involves risk of loss that clients and investors should be prepared to bear. Summary of Material Risks The table below and Appendix A of this Brochure set forth information concerning the material risks involved with each Strategy. An “X” in the table indicates that the Strategy involves the corresponding risk. An empty box indicates that the Strategy does not involve the corresponding risk in a material way. However, an empty box does not guarantee that the Strategy will not be subject to the corresponding risk. BNY Advisors Strategies NIMNA Strategies NIM Strategies Walter Scott Strategies Risk Type ADR / GDR Risk X X X X Allocation Risk X X X X Banking Industry Risk X X X X X X X X Clearance and Settlement Risk Concentration Risk X X X X Correlation Risk X X X X Counterparty Risk X X X X X X X X Country, Industry and Market Sector Risk X X X X Disease/Epidemics Risk Cybersecurity Risk X X X X 19  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 BNY Advisors Strategies NIMNA Strategies NIM Strategies Walter Scott Strategies Risk Type Emerging Market Risk X X X Equity Securities Risk X X X X ESG Investment Risk X ETF Risk X X X X X Fixed Income Securities Risk X X X X Foreign Investment Risk General Risks X X X X X X X X Growth and Value Stock Risk Growth Stock Risk X X X X Healthcare Sector Risk X X X X X X X X Investment Strategy Risk Issuer Risk X X X X Large Cap Stock Risk X X X X Liquidity Risk X X X X Market Risk X X X X Market Sector Risk X X X X X X Micro Cap Company Risk 20  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 BNY Advisors Strategies NIMNA Strategies NIM Strategies Walter Scott Strategies Risk Type X X X Non-Diversification Risk Performance Risk X X X X X X X X Portfolio Turnover Risk Preferred Stock Risk X X Quantitative Model Risk X X X X Real Estate Sector Risk X X X X Small and Midsize Company Risk Stock Investing Risk X X X X Stock Selection Risk X X X X Systemic Risk X X X X X X X X Technology Company Risk Value Stock Risk X X X X Valuation Risk X X X X Please also refer to Item 8 of our Delegated Managers’ Brochures, Appendix A of this Brochure and the prospectuses of the ETFs for further descriptions of these material risks relating to the Strategies. 21  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Item 9. Disciplinary Information On August 14, 2024, the Securities and Exchange Commission (“SEC”) entered a settled administrative order against BNYSC and Pershing LLC (“Pershing”) that found that BNYSC and Pershing willfully violated Section 17(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) and Rule 17a-4(b) thereunder. The order also found that BNYSC and Pershing failed to reasonably supervise their employees within the meaning of Exchange Act Section 15(b)(4)(E). Specifically, the order found that from at least January 2020 to August 14, 2024, BNYSC and Pershing personnel sent and received text message communications on platforms that were not approved for business purposes, many of which were not preserved by BNYSC or Pershing. In numerous instances, BNYSC and Pershing supervisors themselves communicated using these unapproved communication platforms. In determining to accept BNYSC’s and Pershing’s offers of settlement, the SEC considered remedial acts promptly undertaken by BNYSC and Pershing and cooperation afforded the Commission staff. In connection with the order, BNYSC and Pershing admitted the facts alleged in the order and acknowledged that their conduct violated the federal securities laws. Both entities were (i) censured; (ii) ordered to cease and desist from committing or causing any violations and any future violations of Exchange Act Section 17(a) and Rule 17a-4 thereunder; (iii) ordered to pay a penalty of $40 million; and (iv) ordered to comply with certain undertakings, including the retention of an independent compliance consultant to review their policies and procedures related to electronic communications. Item 10. Other Financial Industry Activities and Affiliations In addition to being registered as an investment adviser under the Advisers Act, BNYSC is also registered as a broker-dealer under the Securities Exchange Act of 1934, is a member of FINRA, and is registered with the NFA as an introducing broker. BNY is a Global Financial Services Company BNY is a global financial services company providing a comprehensive array of financial services (including asset management, wealth management, asset servicing, clearing and execution services, issuer services and treasury services) through a world-wide client focused team that enables institutions and individuals to manage and service their financial assets. BNY Investments and Wealth is the umbrella designation for BNY’s affiliated investment management firms, wealth management business and global distribution companies and is responsible, through various subsidiaries, for U.S. and non-U.S. retail, intermediary and institutional distribution of investment management and related services. 22  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 We enter into transactions with unaffiliated counterparties or third-party service providers who can be using affiliates of ours to execute such transactions. Additionally, when we effect transactions in American Depositary Receipts (“ADRs”) or other securities, the involved issuers or their service providers could be using affiliates for support services. Services provided by our affiliates to such unaffiliated counterparties, third party service providers and/or issuers include, for example, clearance of trades, purchases or sales of securities, serving as depositary bank to issuers of ADRs, providing foreign exchange services in connection with dividends and other distributions from foreign issuers to owners of ADRs, or other transactions not contemplated by us. Although one of our affiliates receives compensation for engaging in these transactions and/or providing services, the decision to use or not use an affiliate of ours is made by the unaffiliated counterparty, third party service provider or issuer. Further, we will likely be unaware that the affiliate is being used to enter into such transaction or service. BNY and/or its affiliates may gather data from BNYSC about our investment activities, including information about holdings within client portfolios, which is required for regulatory filings to be made by BNYSC or BNY or their affiliates (e.g., reporting beneficial ownership of equity securities) or for other compliance, legal or risk management purposes, pursuant to policies and procedures of BNY or its affiliates. This data is deemed confidential and procedures are followed to help ensure that any information is utilized solely for the purposes intended. BNY’s Status as a Bank Holding Company BNY and its direct and indirect subsidiaries, including us, are subject to (1) certain U.S. banking laws, including the Bank Holding Company Act of 1956, as amended (the “BHCA”), (2) regulation and supervision by the Board of Governors of the Federal Reserve System (the “Federal Reserve”) and (3) the provisions of, and regulations under, the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The BHCA, the Dodd-Frank Act, other applicable banking laws and the regulatory agencies, including the Federal Reserve, that interpret and administer these laws may restrict (1) the transactions and relationships among BNY, its affiliates (including us) and our clients and (2) our investments, transactions and operations. For example, the BHCA regulations applicable to BNY and us may restrict our ability to make certain investments or the size of certain investments, impose a maximum holding period on some or all of our investments and restrict our ability to participate in the management and operations of the companies in which we invest. In addition, certain BHCA regulations may require aggregation of the positions owned, held or controlled by related entities. Thus, in certain circumstances, positions held by BNY and its affiliates (including us) for client and proprietary accounts may need to be aggregated and may be subject to a limitation on the amount of a position that may be 23  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 held. These limitations may have an adverse effect on our ability to manage clients’ investment portfolios. For example, depending on the percentage of a company that we and our affiliates (in the aggregate) control at any given time, the limits may (1) restrict our ability to invest in that company for certain clients or (2) require us to sell certain client holdings of that company when it may be undesirable to take such action. Additionally, in the future BNY may, in its sole discretion and without notice, engage in activities affecting us in order to comply with the BHCA, the Dodd-Frank Act or other legal requirements applicable to (or reduce or eliminate the impact or applicability of any bank regulatory or other restrictions on) us and accounts that we and our affiliates manage. The Volcker Rule The Dodd-Frank Act includes provisions that have become known as the “Volcker Rule,” which restrict bank holding companies, such as BNY and its subsidiaries (including us) from (i) sponsoring or investing in a private equity fund, hedge fund or otherwise “covered fund”, with the exception, in some instances, of maintaining a de minimis investment, subject to certain other conditions and/or exceptions, (ii) engaging in proprietary trading, and (iii) entering into certain transactions involving with affiliated covered funds. The Volcker Rule generally prohibits certain transactions involving an extension of credit or other type of transaction as set forth in applicable regulations between BNY and its affiliates, on the one hand, and “covered funds” managed or sponsored by BNY and/or its affiliates (including us), on the other hand. BNY affiliates provide securities clearance and settlement services to broker- dealers on a global basis. The operational mechanics of the securities clearance and settlement process can result in an incidental or unintended intraday extension of credit between the securities clearance firm and a “covered fund.” As a result, we may be restricted from using a BNY affiliate as custodian or in other capacities for covered funds as well as be restricted in executing transactions for certain funds through broker-dealers that utilize a BNY affiliate as their securities clearance firm. Such restrictions could limit the covered fund’s selection of service providers and prevent us from executing transactions through broker-dealers we would otherwise use in fulfilling our duty to seek best execution. The Volcker Rule was amended in 2020 to include exemptions that permit a broader range of transactions between BNY and its affiliates and relevant covered funds. BNY intends to rely on such exemptions to the extent it deems appropriate. Dual Officers and Dual Employees Certain employees of our Delegated Managers act as officers or employees of one or more of our affiliates (“dual officers” or “dual employees”), including The Bank of New York Mellon, an affiliated New York chartered bank (the “Bank”), and BNYIA, an affiliated registered investment 24  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 adviser, for the purpose of performing administrative or investment management and related functions. In their capacities as dual officers or dual employees, they provide administrative or discretionary investment advisory services to certain clients and also to certain collective investment funds of the Bank and the applicable Delegated Manager receives a fee for such services. In their capacities as dual employees of BNYIA, these Delegated Manager personnel provide investment advisory services to certain affiliated registered investment companies. In these capacities, they may also provide non-discretionary investment advisory services to unaffiliated managed account/wrap-fee accounts. The Delegated Managers receive a portion of the investment management fee received by BNYIA for such services. The Delegated Managers may also provide sub-advisory services to certain affiliated registered investment companies by serving as a sub-adviser to BNYIA. For such services, the Delegated Managers receive a portion of the investment management fee received by BNYIA from each investment company to which it renders advice. Other Relationships In addition, BNY personnel, including certain of our employees, may have board, advisory, or other relationships with issuers, distributors, consultants and others that may have investments in a private fund and/or related funds or that may recommend investments in a private fund or distribute interests in a private fund. To the extent permitted by applicable law, BNY and its affiliates, including us and our personnel, may make charitable contributions to institutions, including those that have relationships with investors or personnel of investors. As a result of the relationships and arrangements described in this paragraph, placement agents, consultants, distributors and other parties would have conflicts associated with their promotion of a private fund, or other dealings with a private fund, that create incentives for them to promote a private fund. BNY maintains, and we have adopted, a Code of Conduct that addresses these types of relationships and the conflicts of interest they present, including the provision and receipt of gifts and entertainment. BNY, among several other leading investment management firms, has a minority equity interest in Kezar Markets, LLC (f/k/a Titan Parent Company, LLC), which owns Kezar Trading, LLC (f/k/a Luminex Trading and Analytics LLC) (“Kezar”), a registered broker-dealer under the Exchange Act that operates two alternative trading systems for securities (the “Alternative Trading Systems”). Transactions for clients for which we serve as adviser or sub-adviser may be executed 25  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 through the Alternative Trading Systems. We and BNY disclaim that either is an affiliate of Kezar. Affiliated Broker-Dealers and Investment Advisers BNYSC is affiliated with a significant number of advisers and broker/dealers. Please see our Form ADV, Part 1A - Schedule D, Section 7.A for a list of our affiliated advisers and broker-dealers. Several of our investment adviser affiliates have, collectively, a significant number of investment- related private funds for which a related person serves as sponsor, general partner or managing member (or equivalent), respectively. Please refer to the Form ADV, Part IA – Schedule D, Section 7.B for each of our affiliated investment advisers for information regarding such firm’s private funds (if applicable) and such firm’s Form ADV, Part IA – Schedule D, Section 7.A for information regarding related persons that serve in a sponsor, general partner or managing member capacity (if applicable). Except with respect to BNY MAP where our affiliate, Pershing LLC, provides certain execution, clearing and custodial services, we limit our selection of brokers for effecting purchases or sales of securities for client accounts to unaffiliated brokers only. Please refer to our Wrap Fee Program Brochure for more information concerning Pershing LLC’s role with respect to BNY MAP. We have broker selection policies in place that require our selection of a broker-dealer to be consistent with our duties of best execution, and subject to any client and regulatory proscriptions. Please also see Item 12 of our Delegated Managers’ firm Brochures for more information. We may be prohibited or limited from effecting transactions for you because of rules in the marketplace, foreign laws or our own policies and procedures. In certain cases, we may face further limitations because of aggregation issues due to our relationship with affiliated investment management firms. Due to local market rules associated with aggregation of security ownership with our affiliates we may be prevented from owning more of a particular security that we would otherwise want to own for client accounts. Please also refer to Item 12 of our Delegated Managers’ Brochures for a discussion of trade aggregation issues. Affiliated Underwriters Our broker-dealer affiliates occasionally act as underwriter or as a member of the underwriting syndicate for certain new issue securities, which presents a conflict of interest because it creates an incentive for us to purchase these new issue securities in an effort to provide additional fees to the broker-dealer affiliate. As a matter of policy, however, we do not purchase new issue securities for discretionary client accounts. 26  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 BNY has established a policy regarding purchases of securities in an offering in which an affiliate acts as an underwriter or as a member of the underwriting syndicate. In compliance with applicable banking, securities and ERISA regulations, we may purchase on behalf of our clients securities in an offering in which an affiliate is acting as an underwriter or as a member of the underwriting syndicate during the syndication period, so long as requirements of the policy, including written approval and compliance with certain investment criteria, are met. The policy prohibits direct purchases from an affiliate for any fiduciary account under any circumstances. Affiliated Banking Institutions BNY engages in trust and investment business through various banking institutions, including the Bank and BNY Mellon, National Association. These affiliated banking institutions may provide certain services to us, such as recordkeeping, accounting, marketing services, and/or referrals of clients. We may provide the affiliated banking institutions with sales and marketing materials regarding our investment management services that may be distributed under the name of certain marketing “umbrella designations” such as BNY, BNY Investments, BNY Wealth, BNY EMEA and BNY APAC. Certain clients may have established custodial or sub-custodial arrangements with the Bank and other financial institutions that are affiliated with us. Furthermore, the Bank and other financial institutions that are affiliated with us may provide services (such as trustee, custodial or administrative services) to issuers of securities. Because of their affiliation with us, our ability to purchase securities of such issuers and to take advantage of certain market opportunities may be subject to certain restrictions and in some cases, prohibited. Other Business Activities of BNYSC and its Affiliates As a BNY company, BNYSC may, from time to time, use the research staff, products, services and libraries of its affiliates and may consult with their portfolio managers. BNYSC’s affiliates are engaged in a broad range of financial services activities in the United States and abroad, and include banks, trust companies, broker-dealers, investment advisers, stock transfer agents, commodity pool operators, commodity trading advisers, municipal securities dealers and pension consultants, among other businesses. Certain of BNYSC’s affiliates serve as investment advisers of and provide other services to mutual funds and other investment companies, including the BNY Funds that are used as options in BNY MAP. BNYSC’s arrangements with the BNY Funds and their service providers are material to BNYSC’s business as an investment adviser. In addition, from time to time, BNYSC and certain of its affiliates may refer investment advisory clients or 27  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 other business to each other, as permitted by applicable law and rules, and these arrangements may become material to BNYSC’s investment advisory business. The client should be aware that BNYSC and its affiliated entities maintain various types of financial and other relationships with financial or other institutions, entities and persons. Services provided by BNYSC, BNYIA and their affiliates for the BNY Funds include investment advice, administration, distribution and transfer agency services. Although it is not possible to determine accurately the amount of time that BNYSC devotes to any one of the wide range of financial activities in which it is engaged, BNYSC’s principal business is the sale of mutual funds, ETFs and private funds advised by its affiliates. BNYSC and its representatives may give advice and take action in the performance of their duties for a client that differs from advice given, or the timing and nature of action taken, with respect to other clients or for themselves. Personal trading by BNYSC employees must be conducted in compliance with all applicable laws and the BNY Personal Securities Trading Policy that governs BNY and its subsidiaries, including BNYSC. As described in Item 4 above, we may be retained by affiliated and non-affiliated investment managers to provide administrative and support services (“Administrative Services”) in connection with the investment advisory services that such managers have agreed to perform for wrap accounts of financial services firms who sponsor wrap fee investment programs. In that capacity, we have a business relationship with an unaffiliated investment manager (the “Unaffiliated Investment Manager”) pursuant to which we may be retained and compensated by such manager in order to: (i) provide administrative and support services in connection with third party wrap programs where the Unaffiliated Investment Manager directly contracts with the third party wrap program sponsors to provide investment advisory services and (ii) solicit potential wrap program sponsors to offer the strategies and/or models of such Unaffiliated Investment Manager as part of these wrap programs. These arrangements, in turn, create a conflict because to the extent we are successful in soliciting a wrap program sponsor to offer an Unaffiliated Investment Manager’s strategies and/or models, then we will not only receive a solicitation fee, but will also be compensated for providing the resulting administrative services. 28  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Item 11. Code of Ethics, Participation or Interest in Client Transactions, Personal Trading Code of Ethics, Participation or Interest in Client Transactions, Personal Trading We have adopted a Code of Ethics that is made up of two parts: 1. BNY Code of Conduct (the “BNY Code”); and 2. BNY Personal Securities Trading Policy (the “PSTP”). The BNY Code of Conduct sets expectations for business conduct for employees and provides guidance on important legal and ethical issues. In addition, it clarifies the Firm’s responsibilities to clients, suppliers, government officials, competitors and the communities we serve. BNY’s Code of Conduct covers the following key principles: 1. Respecting Others: We are committed to fostering an inclusive workplace where talented people want to stay and develop their careers. Supporting a diverse, engaged workforce allows us to be successful in building trust, empowering teams, serving our clients and outperforming our peers. We give equal employment opportunity to all individuals in compliance with legal requirements and because it’s the right thing to do. 2. Avoiding Conflicts: We make our business decisions free from conflicting outside influences. Our business decisions are based on our duty to BNY and our clients and are not driven by any personal interest or gain. We are to remain alert to any and all potential conflicts of interest and ensure that we identify, mitigate or eliminate any such conflicts. 3. Conducting Business: We secure business based on honest competition in the marketplace. This contributes to the success of our company, our clients and our shareholders. We compete in full compliance with all applicable laws and regulations. We support crime. worldwide efforts to combat financial corruption and financial 4. Working with Governments: We follow all requirements that apply to doing business with governments. We recognize that practices for dealing with private and government clients are different from a legal perspective. 29  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 5. Protecting Company Assets: We ensure all entries made in the company’s books and records are complete and accurate and comply with established accounting and record- keeping procedures. We maintain confidentiality of all forms of data and information entrusted to us and prevent the misuse of information belonging to the company or any client. 6. Supporting Our Communities: We take an active part in our communities around the world, both as individuals and as a company. Our long-term success is linked to the strength of the global economy and the strength of our industry. We are honest, fair and transparent in our interactions with our communities and the public at large. As a global financial institution, BNY and its subsidiaries are subject to certain laws and/or regulations governing the personal trading of securities. In order to ensure that all employees’ personal investments are conducted in compliance with the applicable rules and regulations and are free from conflicts of interest, the Company has established limitations on personal trading, as reflected in the PTSP. The PSTP sets forth procedures and limitations that govern the personal securities transactions of our employees in accounts held in their own names as well as accounts in which they have indirect ownership. We, and our related persons and employees, may, under certain circumstances and consistent with the PSTP, purchase or sell for their own accounts securities that we also recommend to clients. The PSTP imposes different requirements and limitations on employees based on the nature of their business activities. Each of our employees is classified as one of the following: 1. Investment/Public Employee (“IE”): IE is an employee who, in the normal conduct of his/her job responsibilities, is on the “public side” of the Information Barrier in accordance with BNY’s Information Barrier Policy and has access (or is likely to be perceived to have access) to nonpublic information regarding any advisory client’s purchase or sale of securities or nonpublic information regarding the portfolio holdings of any Proprietary Fund (defined as a fund sponsored, managed or subadvised by BNY or any of its affiliates), is involved in making securities recommendations to advisory clients, or has access to such recommendations before they are public. 2. Access Decision Maker (“ADM”): Generally, employees are considered to be ADM Employees if they are portfolio managers or research analysts and make or participate in recommendations or decisions regarding the purchase or sale of securities for mutual funds or managed accounts. Portfolio managers of broad-based index funds and traders 30  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 are not typically classified as ADM Employees. 3. Insider Risk Employee (“IR”): IR is an employee who in the normal course of business is likely to receive material non-public information regarding issuer clients. These employees are on the “private side” of the Information Barrier in accordance with BNY’s Information Barrier Policy. 4. Non-Classified Employee: Our employees are considered non-classified if they are not an IE, IR or ADM. PSTP Overview: 1. IE, ADM, and IR employees are subject to preclearance and personal securities reporting requirements, with respect to discretionary accounts in which they have direct or indirect ownership. 2. Transaction reporting is not required for non-discretionary accounts, transactions in exempt securities or certain other transactions that are not deemed to present any potential conflicts of interest. 3. Preclearance is not required for transactions involving certain exempt securities (such as ETFs and open-end investment company securities that are not Proprietary Funds or money market funds and short-term instruments, non-financial commodities; transactions in non-discretionary accounts (approved accounts over which the employee has no direct or indirect influence or control over the investment decision- making process); transactions done pursuant to automatic investment plans; and certain other transactions detailed in the PSTP which are either involuntary or deemed not to present any potential conflict of interest. 4. We have a “Preclearance Compliance Officer” who maintains a “restricted list” of companies whose securities are subject to trading restrictions. This list is used by the PTA System to determine whether or not to grant trading authorization. 5. The acquisition of any securities in a private placement requires prior written approval. 6. With respect to transactions involving BNY securities, all employees are also prohibited from engaging in short sales, purchases on margin, option transactions (other than employee option plans), and short-term trading (i.e., purchasing and selling, or selling and purchasing BNY securities within any 60-calendar day period). 7. For IE, ADM, and IR employees, with respect to non-BNY securities, purchasing and 31  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 selling, or selling and purchasing the same or equivalent security within 30 calendar days is prohibited, and any profits must be disgorged. 8. No covered employee should knowingly participate in or facilitate late trading, market timing or any other activity with respect to any fund in violation of applicable law or the provisions of such fund’s disclosure documents. A copy of our Code of Ethics will be provided upon request. Interest in Client Transactions Note that while each of the following types of transactions present conflicts of interest for us, as described below, we manage our accounts consistent with applicable law, and we follow procedures that are reasonably designed to treat our clients fairly and to prevent any client or group of clients from being systematically favored or disadvantaged. Wrap Program clients should also review the Brochures of the Delegated Managers and/or Program Sponsors, as applicable, which will contain additional information about those firms’ investment advisory Services. Principal Transactions “Principal transactions” are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys any security from or sells any security to any client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated pooled investment vehicle and another client account. We do not engage in principal transactions. While we do not engage in principal transactions, we are part of a large diversified financial organization, which includes banks and broker-dealers. As a result, it is possible that an affiliate may, as principal, purchase securities from, or sell securities to, our clients. Cross Transactions We do not engage in cross transactions. 32  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Transactions in Same Securities We or our affiliates may invest in the same securities that we or our affiliates recommend to clients. When we or an affiliate currently holds for our own benefit the same securities as a client, we have a conflict of interest. For example, we or our affiliate could be seen as harming the performance of the client’s account for our own benefit if we short sell the securities in our own account while holding the same securities long in the client account, causing the market value of the securities to move lower. Interests in Recommended Securities/Products We or our affiliates may recommend securities to clients, or buy or sell securities for client accounts, at or about the same time that we or one of our affiliates buys or sells the same securities for our (or the affiliate’s) own account. This practice gives rise to a variety of conflicts of interest, particularly with respect to aggregating, allocating and sequencing securities being purchased on both our (or our affiliate’s) behalf and our clients’ behalf. For example, we have an incentive to cause a client or clients to participate in an offering because we desire to participate in the offering on our own behalf and would otherwise be unable to meet the minimum purchase requirements. Likewise, we have an incentive to cause our clients to participate in an offering to increase our overall allocation of securities in that offering, or to increase our ability to participate in future offerings by the same underwriter or issuer. On the other hand, we have an incentive to cause our clients to minimize their participation in an offering that has limited availability so that we do not have to share a proportionately greater amount of the offering to the client. Allocations of aggregated trades likewise raise a conflict of interest as we have an incentive to allocate securities that are expected to increase in value to ourselves. See Item 12 for a discussion of our brokerage and allocations practices and policies. Further, a conflict of interest could arise if a transaction in our own account closely precedes a transaction in related securities in a client account, such as when a subsequent purchase by a client account increases the value of securities that were previously purchased for ourselves. We or a related person may recommend the purchase of securities in certain private funds which BNYIA or our affiliates manage and for which BNYIA or our affiliate may serve as sole director or managing member or collective investment funds maintained by the Bank (which are managed by personnel of BNYIA or one of our affiliates in their roles as dual officers of the Bank and for which BNYIA or our affiliate, as applicable, receive a fee and the Bank may receive a custodial fee for custody services). BNY, or certain of its employees, or related persons, may currently invest in certain private funds or collective funds that also include client assets managed by BNY, 33  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 BNYIA, or their affiliates, and they and such related persons will receive proportional returns associated with such investment. Additionally, in many instances we receive an investment management fee in our capacity as investment adviser or sub-adviser and related persons (including affiliated broker-dealers) receive certain amounts associated with placement agent fees, custodial fees, administrative fees, loads, or sales charges. Investments by Related Persons and Employees We and our existing and future employees, our board members, and our affiliates and their employees may from time to time invest in products managed by us. We have developed policies and procedures to address any conflicts of interest created by such investment. We are part of a large diversified financial organization that includes banks and broker-dealers. As a result, it is possible that a related person may, as principal, purchase securities or sell securities for itself that we also recommend to clients. We do permit our employees to invest for their own account within the guidelines and restrictions of the Code of Ethics, as described above. For more information, please see “Interests in Recommended Securities/Products” in this Item 11, and “Dual Officers and Dual Employees” in Item 10 of this Brochure. Agency Transactions Involving Affiliated Brokers Neither we, nor any of our officers or directors, acting as broker or agent, effects securities transactions for compensation for any client. We are part of a large diversified financial organization that includes broker-dealers. As a result, it is possible that a related person, other than our officers and directors, may, as agent, effect securities transactions for our clients for compensation. Please also see additional information relating to affiliate arrangements and with regard to purchases of securities in an offering where an affiliate acts as underwriter or a member of the underwriting. Please also see Schedule D, Section 7A of our Form ADV Part 1 for a list of broker-dealers which are our affiliates. Item 12. Brokerage Practices Wrap Programs With respect to Model Delivery Programs, BNYSC provides the model portfolios to the Program Sponsor, who then executes securities transactions on behalf of the Wrap Clients. 34  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 With respect to Traditional Wrap Programs, BNYSC executes transactions in Wrap Accounts generally through the Program Sponsor unless executing trades with a non-sponsoring firm may result in more favorable execution to the Wrap Client. Accordingly, to facilitate obtaining best execution for Wrap Clients, BNYSC may, at its discretion, facilitate trade execution for Wrap Client transactions with a non-sponsoring firm. We may do so for a variety of reasons, including the type or liquidity of the securities we are buying or selling, or because we are aggregating trades for Wrap Clients of one Program Sponsor with trades for Wrap Clients of other Program Sponsors. The corresponding brokerage commissions and associated transaction costs for such “trading away” activity will not be included in the wrap fee paid by the Wrap Client to the Program Sponsor and instead will represent additional costs borne by the Wrap Client; however, this will not increase the advisory fee paid to or billed by BNYSC. Wrap Clients should also note that such brokerage commissions and associated transaction costs may be built into the net price of the investment, as reflected on trade confirmations, as opposed to being separately itemized. In connection with the Strategies for Traditional Wrap Programs currently offered by BNYSC and which were available and contained Wrap Client assets during calendar year 2024 – BNYM Newton Dynamic Value; BNYM Newton International Equity, BNYM Newton Global Equity, BNYM Newton Global Equity Income ADR, BNYM Newton Small Mid Cap Growth and BNYM Walter Scott International Stock ADR - the average dollar-weighted percentage of transactions traded away by BNYSC during the twelve months through December 31, 2024 across the Wrap Client accounts in each Strategy was 0.00%, 55.35%, 28.85%, 0.00%, 0.00% and 18.44%, respectively. With respect to all five Strategies, the additional cost incurred by Wrap Clients with respect to each such transaction ranged from 0 - 4 cents per share (or, for commissions charged on a percentage rather than per share basis, approximately 0 - 10 basis points of the value of each trade). In addition to the fees and expenses described above, certain routine trading costs associated with the day-to-day investment management of a Wrap Account may, depending upon the provisions of a particular Wrap Program, not be included in a Wrap Client’s wrap fee and may therefore represent additional costs to the Wrap Client. In general, these may include (but are not necessarily limited to) the SEC fee imposed on sales of US securities and the transaction taxes imposed by certain non-US countries with respect to the purchase and sale of securities of certain issuers domiciled in those countries. With respect to trading away activity in the BNYM Newton International Equity, BNYM Newton Global Equity, BNYM Newton Global Equity Income ADR and BNYM Walter Scott International Stock ADR Strategies, additional trading-related costs, such as non-US local market transaction taxes and ADR conversion charges, may also apply. 35  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 For the reasons described above, with respect to both Traditional Wrap and Model Delivery Programs it is not always possible for us to aggregate client transactions pursuant to our trade aggregation procedures except when we direct transactions in a Traditional Wrap Program to a non-sponsoring broker-dealer in an effort to seek best execution. To help ensure fair and equitable treatment of all clients, changes to our investment strategy models are disseminated to us when implemented by the Delegated Manager. Upon completion of our initial order preparation, we in turn communicate such model revisions to all Program Sponsors for the same strategy at or near the same time. As a result, there may be instances in which a Delegated Manager and one or more Program Sponsors are executing trades for their clients at the same time that we are executing trades in the same securities. This could lead to competing orders for the same securities, potentially harming execution quality. In an effort to mitigate this adverse consequence and help ensure fair and equitable treatment across the respective clients of the Delegated Manager, BNYSC and the Program Sponsors, BNYC may seek to communicate with the applicable Delegated Manager, and to coordinate trading proportionally to assets under management with the Program Sponsors, when the combined order size in that security is anticipated to exceed certain trading volume thresholds. While, as described under Third-Party Wrap Programs in Item 4 of this Brochure, we do not currently advise any Dual-Contract Program Wrap Accounts, our brokerage selection and coordinated trading processes as described in this Item 12 with respect to Traditional Wrap Programs would also apply to Dual-Contract Programs. Other Brokerage Practices The following describes our policies when we facilitate non-mutual fund client transactions with a broker-dealer other than the Program Sponsor: Broker Selection: We have the authority to direct securities transactions on behalf of our discretionary clients to broker-dealers we select from the BNY Approved Broker List. In doing so, we seek best execution of such transactions. When seeking best execution, we consider the full range and quality of a broker-dealer’s services including, among other things, commission rates/trading costs, a broker’s trading expertise, reputation and integrity, willingness and ability to commit capital, reliability both in executing and settling trades, fairness in resolving disputes, value provided in a market, execution capability, financial responsibility and responsiveness to the Firm. Please also see the discussion concerning the Volcker Rule and its possible implications concerning our broker-dealer selection practices in Item 10 above. 36  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Soft Dollars: We do not use/receive research or other products or services other than execution from a broker-dealer or third party in connection with client securities transactions. Affiliated Broker/Dealers: Except with respect to the wrap fee investment program we sponsor, described on Page 5 of this Brochure, we do not direct securities transactions to any affiliated broker-dealer unless directed to by the Program Sponsor. Certain unaffiliated broker-dealers used by us to execute trades may use a broker-dealer who is our affiliate to clear those trades. In such cases, the clearing broker receives a clearance fee negotiated and paid by the executing broker- dealer. The decision to use one of our affiliates in these circumstances is made by the unaffiliated executing broker-dealer, and we have no influence over whether a broker-dealer we select for execution of client trades clears through one of our affiliates, or if so the financial arrangement between them. Affiliated Depository Agent: From time to time, we will use an unaffiliated broker-dealer to convert local shares of a foreign security into an American Depository Receipt (“ADR”) shares or ADR shares into local shares. In certain cases, the unaffiliated broker-dealer may use BNY as a depository agent. Brokerage/Compensation for Client Referrals: We do not direct securities transactions to, or otherwise compensate, any broker-dealer in exchange for referral of investment management clients. Directed Brokerage: We will participate in directed brokerage only if directed by the Program Sponsor and a contractual arrangement is in place. In the event that such direction occurs, we may have limited capability to negotiate commission rates or obtain volume discounts. As a result, the net price paid or received by the directed account may be different than the price paid or received by our other accounts. Overall, any instruction that we use a certain broker-dealer or restrict trading with a particular broker-dealer may cause a client to pay higher commissions, receive less favorable net prices or investment results, or incur additional custodial or other external administrative charges than would be the case if we were authorized to choose the broker-dealers through which to execute transactions. Trade Aggregation: We will aggregate certain client transactions (i.e., the purchase or sale of securities of the same issuer with purchases or sales on behalf of other client accounts trading in the same security on the same day) when we determine that it is in the best interest of all clients. Each client participating in an aggregated transaction within a trading day will do so at the same 37  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 average price where possible. Trade Allocation: Allocation of an aggregated order is prepared prior to the execution of the aggregated trade. If an aggregated order is filled in its entirety, the order must be allocated in accordance with the allocation specified. Aggregated trades are allocated at the average price of the aggregated order. Generally, if an aggregated order is partially filled, the order will be allocated among the participating accounts on a pro-rata basis in proportion to the intended allocation. We may, however, if required in our judgment, deviate from pro rata allocation on partially filled orders to help prevent odd lot position sizes or similar outcomes that may not be desirable for clients’ accounts. New Issue Allocation: BNYSC does not currently purchase new issues for client accounts. To the extent we seek to purchase new issues in the future, we will adopt policies and procedures designed to help ensure fair and equitable treatment of clients. Trade Errors: Our policy is to correct trading and operational errors we make and to reimburse client accounts to the extent that any such error, in aggregate across the participating client accounts, results in a loss of $25 or more. Item 13. Review of Accounts In addition to the account review activities that may be performed by Program Sponsors, we perform various oversight activities with respect to the discretionary client accounts we manage in Traditional Wrap and Dual-Contract Programs and the model portfolios we provide to Model Delivery Programs. These include, where applicable, verifying compliance with Strategy, Wrap Program and Wrap Client investment restrictions; monitoring best execution efforts and investment performance dispersion; conducting Wrap Account-level position reconciliations; performing oversight of Delegated Managers; and conducting similar supervisory and oversight-related functions. We monitor investments in Traditional Wrap Programs on a daily, weekly and quarterly basis by monitoring cash positions, verifying compliance with investment restrictions, monitoring account position drift vs. the investment strategy model and monitoring account investment performance. Item 14. Client Referrals and Other Compensation Our ultimate parent, BNY, has organized its lines of business into two groups: BNY Investments and Wealth and BNY Investment Services (collectively “Groups”). We are part of the BNY Investments and Wealth Group. A sales force has been created to focus on developing new 38  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 customer relationships and developing and coordinating large complex existing customer relationships within those Groups. In certain circumstances, BNY Investments and Wealth sales representatives are paid fees for sales. The fees may be based on revenues and may be a one-time payment or paid out over a number of years. In particular, members of this sales force: (i) acting as representatives of BNYSC in our capacity as investment adviser, may solicit prospective clients with respect to the institutional separate account products and strategies of our affiliates, including the Delegated Managers and (ii) acting as registered representatives of BNYSC in our capacity as broker-dealer, may sell alternative investment products (such as private funds) managed by our affiliates, including products managed by the Delegated Managers. We receive compensation from these affiliates in connection with successful referrals or sales, respectively, typically as a percentage of the revenue received by the manager attributable to the client. We, in turn, compensate these salespeople from the compensation we receive. These arrangements create a conflict of interest for us in recommending the affiliated Delegated Managers because we have a financial incentive to do business with these affiliates generally. We address this conflict by disclosing it to you and through oversight of the Delegated Managers. However, we do not currently compensate any affiliates or third parties for referring clients to us, nor do we direct securities transactions to any broker-dealer in exchange for referral of investment management clients. Item 15. Custody Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) defines “custody” to include a situation in which an adviser or a related person holds, directly or indirectly, client funds or securities or has any authority to obtain possession of them, in connection with advisory services provided by the adviser. BNYSC does not have “custody” of Wrap Client assets in the Wrap Programs for purposes of the Custody Rule. With respect to the BNY Managed Asset Program we sponsor, we are subject to certain provisions of the Custody Rule since our affiliate, Pershing LLC, maintains custody of assets for such clients; please refer to our Form ADV Part 2A, Appendix 1 – Wrap Fee Program Brochure for more information. 39  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Item 16. Investment Discretion For Wrap Accounts where we have investment discretion, we will exercise any such investment discretion that has been granted to us in a manner consistent with the stated investment guidelines and restrictions for the particular Wrap Client's account and the terms and conditions of our agreement with the Program Sponsor and/or the Wrap Client. If we are unable to accommodate any Wrap Client's guidelines or restrictions, we will inform the Program Sponsor and determine how to proceed in consultation with such Program Sponsor. BNYSC does not have discretionary investment authority over any Wrap Accounts with respect to Model Delivery Programs Item 17. Voting Client Securities With respect to client accounts for which we have investment discretion or are otherwise contractually required, we exercise the voting rights delegated to us by clients or the Program Sponsor. Voting rights are most commonly exercised by casting votes by proxy at shareholder meetings on matters that have been submitted to shareholders for approval. Consistent with applicable rules under the Advisers Act, we have adopted and implemented written proxy voting policies and procedures (the “Proxy Policies”) that are reasonably designed: (1) to vote proxies, consistent with our fiduciary obligations, in the best interests of clients; and (2) to prevent conflicts of interest from influencing proxy voting decisions made on behalf of clients. We provide these proxy voting services as part of our investment management service to client accounts and do not separately charge a fee for this service. If presented with a proxy voting opportunity, we will seek to make voting decisions that are in the best interest of the client and have adopted detailed, pre-determined, written proxy voting guidelines for specific types of proposals and matters commonly submitted to shareholders by U.S. and non-U.S. companies (collectively, the “Voting Guidelines”). These Voting Guidelines are designed to assist with voting decisions which over time seek to maximize the economic value of the securities of companies held in client accounts (viewed collectively and not individually) as determined in our discretion. We believe that this approach is consistent with our fiduciary obligations and with the published positions of applicable regulators with an interest in such matters (e.g., the U.S. Securities and Exchange Commission and the U.S. Department of Labor). Clients who have granted us voting authority are not permitted to direct us on how to vote in a particular solicitation. With respect to clients that have not granted us voting authority over 40  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 securities held in their accounts and choose either to retain proxy voting authority or to delegate proxy voting authority to another firm (whether such retention or delegation applies to all or only a portion of the securities within the client’s account), either the client’s or such other entity’s chosen proxy voting guidelines will apply to those securities. We generally do not provide proxy voting recommendations to clients who have not granted us voting authority over their securities. If we receive a proxy from a non-U.S. company, we will seek to effect a vote decision through the application of the Voting Guidelines. However, corporate governance practices, disclosure requirements and voting operations vary significantly among the various non-U.S. markets in which our clients may invest. In these markets, we may face regulatory, compliance, legal or logistical limits with respect to voting securities held in client accounts which can affect our ability to vote such proxies, as well as the desirability of voting such proxies. Non-U.S. regulatory restrictions or company-specific ownership limits, as well as legal matters related to consolidated groups, may restrict the total percentage of an issuer’s voting securities that we can hold for clients and the nature of our voting in such securities. Our ability to vote proxies may also be affected by, among other things: (1) late receipt of meeting notices; (2) requirements to vote proxies in person: (3) restrictions on a foreigner’s ability to exercise votes; (4) potential difficulties in translating the proxy; (5) requirements to provide local agents with unrestricted powers of attorney to facilitate voting instructions; and (6) requirements that investors who exercise their voting rights surrender the right to dispose of their holdings for some specified period in proximity to the shareholder meeting. Absent an issue that is likely to impact clients’ economic interest in a company, we generally will not subject clients to the costs (which may include a loss of liquidity) that could be imposed by these requirements. In these markets, we will weigh the associative costs against the benefit of voting and may refrain from voting certain non-U.S. securities in instances where the items presented are not likely, in our view, to have a material impact on shareholder value. Process With respect to U.S.-based and Japan-based issuers and companies, we utilize internally developed Voting Guidelines. With respect to issuers and companies domiciled in other jurisdictions, our Voting Guidelines consist of standardized guidelines for those jurisdictions provided by an independent, third-party proxy advisor (the “Proxy Advisor). The Voting Guidelines in all instances are intended to address routine, non-controversial proxy proposals. We have also engaged the Proxy Advisor to serve as our proxy agent to administer the mechanical, non-discretionary elements of proxy voting and reporting for clients. The Proxy Advisor is directed, in an administrative role, to follow the specified Voting Guideline and apply it to each 41  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 applicable proxy proposal or matter where a shareholder vote is sought. Accordingly, proxy items that can be appropriately categorized and matched either will be voted in accordance with the applicable Voting Guideline or will be referred to us if the Voting Guideline so requires. The Voting Guidelines require referral to us of all proxy proposals or shareholder voting matters for which there is not an established applicable Voting Guideline, and generally for those proxy proposals or shareholder voting matters that are contested or similarly controversial. We will, in turn, refer such proxy proposals to the relevant Delegated Manager for the purpose of obtaining non-binding proxy voting recommendations in respect of such matters. In cases where we are unable to obtain, or to timely obtain, such proxy voting recommendations directly from the applicable Delegated Manager, we will seek to apply the Proxy Advisor’s applicable standardized guideline for the proposal and jurisdiction in question, where available. Clients may receive a copy of the Voting Guidelines, as well as our Proxy Voting Policy, upon request. Clients may also receive information on the proxy voting history for their managed accounts upon request. Please contact us for more information. Managing Conflicts: It is our policy to make proxy voting decisions that are solely in the best long-term economic interests of clients. We are aware that, from time to time, voting on a particular proposal or with regard to a particular issuer may present a potential conflict of interest for us. For example, potential conflicts of interest may arise when: (1) a public company or a proponent of a proxy proposal has a business relationship with a BNY affiliated company; and/or (2) an employee, officer or director of BNY or one of its affiliated companies has a personal interest in the outcome of a particular proxy proposal. Aware of the potential for conflicts to influence the voting process, we have consciously developed the Voting Guidelines and their application with several layers of controls that are designed to ensure that our voting decisions are not influenced by interests other than those of our clients. For example, we developed the Voting Guidelines with the assistance of internal and external research and recommendations provided by third party vendors but without consideration of any BNY client relationship factors. We have directed our Proxy Advisor to apply the Voting Guidelines to individual proxy items in an objective and consistent manner across client accounts. When proxies are voted in accordance with these pre-determined Voting Guidelines, it is our view that these votes do not present the potential for a material conflict of interest and no additional safeguards are needed. For those proposals that are referred to us in accordance with the Voting Guidelines or our 42  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 direction, we seek to make voting decisions based upon the principle of maximizing the economic value of the securities held in client accounts. In this context we seek to address the potential for conflicts presented by such “referred” items through utilization of the independent expertise of our Delegated Managers. With respect to the potential for personal conflicts of interest, BNY’s Code of Conduct requires that all employees make business decisions free from conflicting outside influences. Under this Code, BNY employees’ business decisions are to be based on their duty to BNY and to their clients, and not driven by any personal interest or gain. All employees are to be alert to any potential for conflict and to identify and mitigate or eliminate any such conflict. Accordingly, employees with a personal conflict of interest regarding a particular public company or proposal that is being voted upon must recuse themselves from participation in the discussion and decision- making process with respect to that matter. Additionally, as described below, we have developed specific protocols for instances involving actual or potential conflicts of interest involving ourselves or our ultimate corporate parent, BNY. Conflicts involving BNYSC typically arise due to relationships between proxy issuers (or companies) and BNYSC and/or its employees, executives, officers or directors (“BNYSC Conflicts”). BNYSC Conflicts may include proxies issued by a company for which a BNYSC employee, executive, officer or director serves as a Board member; proxies issued by a company that is a current client of BNYSC (such as a wrap fee program sponsor) and that contributed materially to BNYSC’s total revenue as of the end of the last fiscal quarter; and other proxies deemed to present an actual, potential or perceived material conflict because of a relationship between a proxy issuer and BNYSC and/or its executive officers or directors. In addition, BNY has established a Proxy Voting Conflicts Policy (“BNY Policy”) that establishes the required actions and reporting protocols for business units that have discretionary authority to vote proxies on behalf of clients (each, a “Voting Firm”) when actual or potential conflicts of interest involving BNY itself arise. The BNY Policy identifies several specific types of proxy solicitations that are considered “Primary Conflicts” for all Voting Firms (including BNYSC) and directs the manner in which such Primary Conflicts are to be addressed (e.g., application of written guidelines, delegation to independent fiduciary, abstention, client consent, etc.). The BNY Policy also identifies those situations that, while not identified as a Primary Conflict, may present an actual, potential or perceived material conflict because of a relationship between a proxy issuer and BNY or its executive officers or Board of Directors (a “Secondary Conflict”). The BNY Policy has further established the BNY Proxy Voting Conflicts Committee (the “PCC”) with responsibility (among others) to (1) maintain and approve changes to the BNY Policy; (2) 43  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 confirm whether a “Primary Conflict” or “Secondary Conflict” exists if unclear; (3) provide interpretive guidance and/or determine how certain actual or potential conflicts should be addressed; and (4) periodically review proxy conflict decisions as reported by the Voting Firms. The BNY Policy requires each BNY investment adviser to establish a proxy voting conflicts committee or, alternatively, to delegate that function to the PCC. BNYSC has adopted the latter approach and accordingly will present to the PCC for consideration and direction any need for guidance (1) to determine whether a certain situation should be treated as a BNYSC Conflict, Primary Conflict or Secondary Conflict, and (2) the manner in which such actual or potential conflicts should be addressed. The PCC will have sole discretion to determine how a BNYSC Conflict, Primary Conflict or Secondary Conflict is to be addressed -- to the extent a situation is not addressed sufficiently under the applicable policy or if BNYSC deems the applicable policy to be unclear and PCC guidance is needed. Depending on the circumstances, the PCC may determine that the situation: (1) does not rise to the level of a material conflict of interest and will not prohibit BNYSC from voting the proxy; or (2) does present a material conflict of interest requiring some form of mitigation by BNYSC. The PCC may direct any conflict mitigation approach it deems necessary and appropriate (e.g., voting in accordance with the guidance of an independent fiduciary; voting in proportion to other shareholders (“mirror voting”); abstaining from voting; erecting informational barriers around, or recusal from the vote decision making process by, the person or persons making voting decisions; obtaining client consent; or voting in other ways that are consistent with our obligation to vote in our clients’ best interest. Controls and Oversight: We currently apply our proxy voting policies and procedures uniformly across client accounts, without distinction based on investment strategy or client type, but maintain processes designed to periodically re-evaluate this approach and determine its ongoing appropriateness. In addition, we, or the PGT on our behalf, perform a variety of qualitative and quantitative evaluations and maintain processes designed to: i) incorporate additional information that may become available about a pending proxy proposal that would reasonably be expected to affect our voting decision; ii) conduct monitoring to verify that proxy votes have been cast in accordance with the Voting Guidelines or our specific direction, as applicable, and that the number of proxies voted falls within our reconciliation tolerances; iii) verify the continued efficacy and applicability of the Voting Guidelines; iv) help ensure the adequacy, transparency and sufficiently broad dissemination of our proxy voting disclosures; v) periodically review the adequacy of our proxy 44  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 voting policies and procedures to ensure that they have been reasonably formulated and effectively implemented and are reasonably designed to ensure that we continue to cast proxy votes in the best interest of our clients; and vi) conduct due diligence oversight of the Proxy Advisor and qualitatively determine whether continued engagement of the Proxy Advisor is warranted. (This due diligence oversight includes, but is not limited to, annual completion of a comprehensive due diligence questionnaire and provision of a detailed policy and procedure inventory by the Proxy Advisor; annual provision by the Proxy Advisor of a detailed control evaluation performed by an independent auditor; submission of an annual compliance, regulatory and conflicts-related attestation by the Proxy Advisor’s Chief Compliance Officer; and periodic due diligence meetings and on-site visits conducted by the PGT.) Item 18. Financial Information In certain circumstances, registered investment advisers are required to provide you with financial information or disclosures about their financial condition in this Item. BNYSC has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has never been the subject of a bankruptcy proceeding. 45  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Appendix A American Depository Receipts and Global Depository Receipts risk. American depository receipts ("ADRs") are receipts issued by a U.S. bank or trust company evidencing ownership of underlying securities issued by non-U.S. issuers. ADRs may be listed on a national securities exchange or may be traded in the over-the-counter market. Global depository receipts ("GDRs") are receipts issued by either a U.S. or non-U.S. banking institution representing ownership in a non-U.S. company's publicly traded securities that are traded on non-U.S. stock exchanges or non- U.S. over-the-counter markets. Holders of unsponsored ADRs or GDRs generally bear all the costs of such facilities. The depository of an unsponsored facility frequently is under no obligation to distribute investor communications received from the issuer of the deposited security or to pass through voting rights to the holders of depository receipts in respect of the deposited securities. Investments in ADRs and GDRs pose, to the extent not hedged, currency exchange risks (including blockage, devaluation and non-exchangeability), as well as a range of other potential risks relating to the underlying shares, which could include expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains, other income or gross sales or disposition proceeds, political or social instability or diplomatic developments that could affect investments in those countries, illiquidity, price volatility and market manipulation. In addition, less information may be available regarding the underlying shares of ADRs and GDRs, and non- U.S. companies may not be subject to accounting, auditing and financial reporting standards and requirements comparable to, or as uniform as, those of U.S. companies. Such risks may have a material adverse effect on the performance of such investments and could result in substantial losses. Allocation risk. The asset classes in which a strategy seeks investment exposure can perform differently from each other at any given time (as well as over the long term), so a strategy will be affected by its allocation among the various asset classes. If the strategy favors exposure to an asset class during a period when that class underperforms, performance may be hurt. Banking industry risk. The risks generally associated with concentrating investments in the banking industry, such as interest rate risk, credit risk and regulatory developments relating to the banking industry. Clearance and settlement risk. Many emerging market countries have different clearance and settlement procedures from developed countries. There may be no central clearing mechanism for settling trades and no central depository or custodian for the safekeeping of securities. The registration, record-keeping and transfer of instruments may be carried out manually, which may cause delays in the recording of ownership. Increased settlement risk may increase counterparty 46  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 and other risk. Certain markets have experienced periods when settlement dates are extended, and during the interim, the market value of an instrument may change. Moreover, certain markets have experienced periods when settlements did not keep pace with the volume of transactions resulting in settlement difficulties. Because of the lack of standardized settlement procedures, settlement risk in emerging markets is more prominent than in more mature markets. Concentration risk. A strategy may have a concentrated portfolio due to investment in a limited number of securities, giving rise to concentration risk. A fall in the value of a single security may have a greater impact on the strategy’s value than if the strategy had a more diversified portfolio. Correlation risk. Although the prices of equity securities and fixed income securities, as well as other asset classes, often rise and fall at different times so that a fall in the price of one may be offset by a rise in the price of the other, in down markets the prices of these securities and asset classes can also fall in tandem. Additionally, where a strategy seeks to deliver returns that are not typically representative of the broad market by allocating its assets among satellite asset categories or investment strategies, there can be no guarantee that the performance of the underlying funds or the fund will have a low correlation to that of traditional asset classes under all market conditions. Counterparty risk. Under certain conditions, a counterparty to a transaction, including repurchase agreements and derivative instruments, could fail to honor the terms of the agreement, default and the market for certain securities or financial instruments in which the counterparty deals may become illiquid. Country, industry and market sector allocation risk. A strategy may be overweighted or underweighted, relative to the benchmark index, in companies in certain countries, industries or market sectors, which may cause the strategy’s performance to be more or less sensitive to positive or negative developments affecting these countries, industries or sectors. In addition, a strategy may, from time to time, invest a significant portion (more than 25%) of its total assets in securities of companies located in particular countries, such as the United Kingdom and Japan, depending on such country’s representation within the benchmark index. Cybersecurity risk. In addition to the risks described above that primarily relate to the value of investments, there are various operational, systems, information security and related risks involved in investing, including but not limited to “cybersecurity risk”. In general, cybersecurity incidents can result from deliberate attacks or unintentional events. Cybersecurity attacks include electronic and non- electronic attacks that include but are not limited to gaining unauthorized access to digital systems (e.g., through "hacking" or malicious software coding) for purposes of misappropriating assets or 47  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 sensitive information, corrupting data or causing operational disruption. Cybersecurity attacks also may be carried out in a manner that does not require gaining unauthorized access, such as causing denial of service attacks on websites (i.e., efforts to make services unavailable to intended users). As the use of technology has become more prevalent, we and the client accounts we manage have become potentially more susceptible to operational risks through cybersecurity attacks. These attacks in turn could cause us and client accounts (including funds) we manage to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. Similar adverse consequences could result from cybersecurity incidents affecting issuers of securities in which we invest, counterparties with which we engage in transactions, third-party service providers (e.g., a client account’s custodian), governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers and other financial institutions and other parties. While cybersecurity risk management systems and business continuity plans have been developed and are designed to reduce the risks associated with these attacks, there are inherent limitations in any cybersecurity risk management system or business continuity plan, including the possibility that certain risks have not been identified. Accordingly, there is no guarantee that such efforts will succeed, especially since we do not directly control the cybersecurity systems of issuers or third-party service providers. Disease/Epidemic risk. Investments could be materially adversely affected by the widespread outbreak of infectious disease or other public health crises, including the COVID-19 pandemic. Public health crises such as the COVID-19 pandemic, together with any containment or other remedial measures undertaken or imposed, could have a material and adverse effect on various investments. Emerging market risk. Emerging markets tend to be more volatile and less liquid than the markets of more mature economies and generally have less diverse and less mature economic structures and less stable political systems than those of developed countries. The securities of issuers located or doing substantial business in emerging markets are often subject to rapid and large changes in price. In particular, emerging markets may have relatively unstable governments, present the risk of sudden adverse government or regulatory action and even nationalization of businesses, have restrictions on foreign ownership or prohibitions on repatriation of assets and impose less protection of property rights than more developed countries. The economies of emerging market countries may be based predominantly on only a few industries and may be highly vulnerable to changes in local or global trade conditions and may suffer from extreme debt burdens or volatile inflation rates. Local securities markets may trade a small number of securities and may be unable to respond effectively to increases in trading volume, potentially making prompt liquidation of substantial holdings difficult. Transaction settlement and dividend collection procedures also may be less reliable in emerging markets than in developed markets. The fixed income securities of issuers located in emerging markets can be more volatile and less liquid than 48  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 those of issuers in more mature economies. In addition, such securities often are considered to be below investment grade credit quality and predominantly speculative. The imposition of sanctions, confiscations, trade restrictions (including tariffs) and other government restrictions by the United States and other governments, or problems in share registration, settlement or custody, may also result in losses. Equity securities risk. The value of equity securities of public and private, listed and unlisted companies and equity derivatives generally varies with the performance of the issuer and movements in the equity markets. As a result, an account may suffer losses if it invests in equity instruments of issuers whose performance diverges from expectations or if equity markets generally move in a single direction. Accounts may also be exposed to risks that issuers will not fulfill contractual obligations such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering restricted securities for public resale. ESG investment approach risk. A strategy’s investment approach may cause it to perform differently than strategies that invest in securities of companies but that do not integrate consideration of environmental, social and governance (“ESG”) issues when selecting investments. An investment approach that systematically integrates the consideration of ESG issues in the securities selection process may result in such strategy forgoing opportunities to buy certain securities when it might otherwise be advantageous to do so or selling securities when it might be disadvantageous for such strategy to do so. Exchange-traded fund (“ETF”) risk. Exchange Traded Funds ("ETFs") are shares of publicly traded unit investment trusts, open-end funds or depository receipts that seek to track the performance and dividend yield of specific indexes or companies in related industries. These indexes may be either broad-based, sector or international. However, ETF shareholders are generally subject to the same risk as holders of the underlying financial instruments they are designed to track. ETFs are also subject to certain additional risks, including, without limitation, the risk that their prices may not correlate perfectly with changes in the prices of the underlying financial instruments they are designed to track and the risk of trading in an ETF halting due to market conditions or other reasons, based on the policies of the exchange upon which the ETF trades. ETFs in which the strategy may invest involve certain inherent risks generally associated with investments in a portfolio of common stocks and/or bonds, including the risk that the general level of stock prices may decline, thereby adversely affecting the value of each unit of the ETF. Moreover, an ETF may not fully replicate the performance of its benchmark index because of the temporary unavailability of certain index securities in the secondary market or discrepancies between the ETF and the index with respect to the weighting of securities or the 49  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 number of securities held. In addition, legal, tax and regulatory changes, such as certain sanctions imposed by governments, may occur which may restrict an ETF’s ability to purchase, hold or sell certain constituents of the relevant index in their appropriate proportions or otherwise adversely affect the ability of the ETF to pursue its indexing strategy. If you invest in the ETF-based model strategies we offer, you will bear a proportionate share of each ETF’s fees and expenses. These fees are described in each ETF’s prospectus. Clients should review all applicable prospectuses for additional information about these fees and expenses. Accordingly, investing in ETFs, which are investment companies, may involve duplication of advisory fees and certain other expenses. Fixed-Income Securities risk. Certain underlying ETFs in the ETF-based model strategies we offer may invest in fixed income securities. The value of fixed-income securities in which such funds invest will change in response to fluctuations in interest rates. In addition, the value of certain fixed-income securities can fluctuate in response to perceptions of credit worthiness, political stability or soundness of economic policies. Valuations of other fixed-income instruments, such as mortgage-backed securities, may fluctuate in response to changes in the economic environment that may affect future cash flows. Except to the extent that values are independently affected by currency exchange rate fluctuations, when interest rates decline, the value of fixed-rate, fixed-income securities generally can be expected to rise. Conversely, when interest rates rise, the value of the same fixed-income securities generally can be expected to decline. Underlying funds may invest in U.S. and non-U.S. issuers of fixed- income securities and may invest in both investment grade and non-investment grade debt securities, including "high-yield" or "junk bonds" and "distressed securities." Foreign investment risk. Special risks associated with investments in foreign companies include exposure to currency fluctuations, less liquidity, less developed or less efficient trading markets, lack of comprehensive company information, political or economic instability, seizure or nationalization of assets, imposition of taxes or repatriation restrictions and differing auditing and legal standards. The securities of issuers located in emerging markets can be more volatile and less liquid than those of issuers in more mature economies. The imposition of sanctions, confiscations, trade restrictions (including tariffs) and other government restrictions by the United States and other governments, or problems in share registration, settlement or custody, may also result in losses. General risks: Investing in securities involves risk of loss that you should be prepared to bear. We do not guarantee or represent that our investment program will be successful. Our past results are not necessarily indicative of our future performance and our investment results may vary over 50  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 time. We cannot assure you that our investments of your money will be profitable, and in fact, you could incur substantial losses. Your investments with us are not bank deposits and are not insured or guaranteed by the FDIC or any other government agency. Growth and value stock risk. Investors often expect growth companies to increase their earnings at a certain rate. If these expectations are not met, investors can punish the stocks inordinately, even if earnings do increase. In addition, growth stocks typically lack the dividend yield that can cushion stock prices in market downturns. Value stocks involve the risk that they may never reach their expected full market value, either because the market fails to recognize the stock’s intrinsic worth, or the expected value was misgauged. They also may decline in price even though in theory they are already undervalued. Growth stock risk. Investors often expect growth companies to increase their earnings at a certain rate. If these expectations are not met, investors can punish the stocks inordinately, even if earnings do increase. In addition, growth stocks may lack the dividend yield that may cushion stock prices in market downturns. Health care sector risk. When a strategy’s investments are concentrated in the health care and related sectors, the value of your investment will be affected by factors particular to those sectors and may fluctuate more widely than that of a strategy which invests in a broad range of industries. Health care companies are subject to government regulation and approval of their products and services, which can have a significant effect on their market price. The types of products or services produced or provided by these companies may quickly become obsolete. Moreover, liability for products that are later alleged to be harmful or unsafe may be substantial and may have a significant impact on the health care company’s market value and/or share price. Biotechnology and related companies are affected by patent considerations, intense competition, rapid technology change and obsolescence and regulatory requirements of various federal and state agencies. In addition, some of these companies are relatively small and have thinly traded securities, may not yet offer products or may offer a single product and may have persistent losses during a new product’s transition from development to production, or erratic revenue patterns. The stock prices of these companies are very volatile, particularly when their products are up for regulatory approval and/or under regulatory scrutiny. Securities of companies within specific health care sectors can perform differently than the overall market. This may be due to changes in such things as the regulatory or competitive environment, or to changes in investor perceptions regarding a sector. Because the strategy may allocate relatively more assets to certain health care sectors than others, the strategy’s performance may be more sensitive to developments which affect those sectors emphasized by the strategy. 51  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Investment strategy risk. A strategy’s investment criteria (for example, sustainability) may limit the number of investment opportunities available to the strategy, and, as a result, at times the strategy’s returns may be lower than those of strategies that are not subject to such special investment considerations. Issuer risk. The value of a security may decline for a number of reasons which directly relate to the issuer, such as management performance, financial leverage and reduced demand for the issuer’s products or services. Large cap stock risk. To the extent a strategy invests in large capitalization stocks, the strategy may underperform strategies that invest primarily in the stocks of lower quality, smaller capitalization companies during periods when the stocks of such companies are in favor. Liquidity risk. When there is little or no active trading market for specific types of securities, it can become more difficult to sell the securities at or near their perceived value. In such a market, the value of such securities and the value of your investment may fall dramatically, even during periods of declining interest rates. Liquidity risk also exists when a particular derivative instrument is difficult to purchase or sell. If a derivative transaction is particularly large or if the relevant market is illiquid (as is the case with many privately negotiated derivatives), it may not be possible to initiate a transaction or liquidate a position at an advantageous time or price. The secondary market for certain municipal bonds tends to be less well developed or liquid than many other securities markets, which may adversely affect the strategy’s ability to sell such municipal bonds at attractive prices. Trading limits (such as “daily price fluctuation limits” or “speculative position limits”) on futures trading imposed by regulators and exchanges could prevent the prompt liquidation of unfavorable futures positions and result in substantial losses. In addition, the ability to execute futures contract trades at favorable prices if trading volume in such contracts is low may be limited. It is also possible that an exchange or a regulator may suspend trading in a particular contract, order immediate liquidation and settlement of a particular contract or order that trading in a particular contract be conducted for liquidation only. Therefore, in some cases, the execution of trades to invest or divest cash flows may be postponed, which could adversely affect the withdrawal of assets and/or performance. Market risk. The market value of a security may decline due to general market conditions that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates, outbreaks of an infectious disease, or adverse investor sentiment generally. A security’s market value also may decline because of factors that affect a particular industry or industries, such as labor shortages or increased production costs and competitive conditions within an 52  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 industry. Global economies and financial markets are becoming increasingly interconnected, and conditions and events in one country, region or financial market may adversely impact issuers in a different country, region or financial market. These risks may be magnified if certain events or developments adversely interrupt the global supply chain; in these and other circumstances, such risks might affect companies worldwide. Market Sector risk. Certain underlying funds in the ETF-based model strategies we offer may significantly overweight or underweight certain companies, industries or market sectors, which may cause a separate account’s performance to be more or less sensitive to developments affecting those companies, industries or sectors. Micro-cap company risk. Micro-cap stocks may offer greater opportunity for capital appreciation than the stocks of larger and more established companies; however, they also involve substantially greater risks of loss and price fluctuations. Micro-cap companies carry additional risks because their earnings and revenues tend to be less predictable (and some companies may be experiencing significant losses) and their share prices tend to be more volatile and their markets less liquid than companies with larger market capitalizations. Micro-cap companies may be newly formed or in the early stages of development, with limited product lines, markets or financial resources, and may lack management depth. In addition, there may be less public information available about these companies. The shares of micro-cap companies tend to trade less frequently than those of larger, more established companies, which can adversely affect the pricing of these securities and our ability to sell these securities. Also, it may take a long time before the value of your investment realizes a gain, if any, on an investment in a micro-cap company. Non-diversification risk. A non-diversified strategy may invest a relatively high percentage of its assets in a limited number of issuers. Therefore, the strategy’s performance may be more vulnerable to changes in the market value of a single issuer or group of issuers and more susceptible to risks associated with a single economic, political or regulatory occurrence than a diversified strategy. Performance risk. Investors often expect growth companies to increase their earnings at a certain rate. If we do not meet our clients’ performance expectations this is considered a material risk. Portfolio turnover risk. A strategy may engage in short-term trading, which could produce higher transaction costs and taxable distributions and lower the strategy’s after-tax performance. Preferred stock risk. Preferred stock is a class of capital stock that typically pays dividends at a specified rate. Preferred stock is generally senior to common stock, but subordinate to debt securities, with respect to the payment of dividends and on liquidation of the issuer. The market 53  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 value of preferred stock generally decreases when interest rates rise and is also affected by the issuer’s ability to make payments on the preferred stock. Quantitative model risk. For certain strategies, we rely on quantitative models that utilize mathematical and statistical formulas designed to select a combination of positions that reflect forward-looking estimates of return and risk. There can be no assurance that a particular quantitative model has been designed to appropriately account for all variables that may affect the performance of a particular investment strategy. Any errors in the design, input or implementation of the quantitative models used by us could have a material adverse effect on the performance of a particular investment strategy. Due to the foregoing risks and the inherent complexities in quantitative models, it may be very difficult or impossible to detect the source of any weakness or failing in a quantitative model before any losses are incurred. Real estate sector risk. When a strategy’s investments are concentrated in the securities of companies principally engaged in the real estate sector, the value of your investment will be affected by factors particular to the real estate sector and may fluctuate more widely than that of a strategy which invests in a broader range of industries. The securities of issuers that are principally engaged in the real estate sector may be subject to risks similar to those associated with the direct ownership of real estate. These include: declines in real estate values, defaults by mortgagors or other borrowers and tenants, increases in property taxes and operating expenses, overbuilding, fluctuations in rental income, changes in interest rates, possible lack of availability of mortgage funds or financing, extended vacancies of properties, changes in tax and regulatory requirements (including zoning laws and environmental restrictions), losses due to costs resulting from the clean-up of environmental problems, liability to third parties for damages resulting from environmental problems and casualty or condemnation losses. In addition, the performance of the economy in each of the regions and countries in which the real estate owned by a portfolio company is located affects occupancy, market rental rates and expenses and, consequently, has an impact on the income from such properties and their underlying values. In addition to the risks which are linked to the real estate sector in general, Real Estate Investment Trusts (“REITs”) are subject to additional risks. Equity REITs, which invest a majority of their assets directly in real property and derive income primarily from the collection of rents and lease payments, may be affected by changes in the value of the underlying property owned by the trust, while mortgage REITs, which invest the majority of their assets in real estate mortgages and derive income primarily from the collection of interest payments, may be affected by the quality of any credit extended. Further, REITs are highly dependent upon management skill and often are not diversified. REITs also are subject to heavy cash flow dependency and to defaults by borrowers or lessees. In addition, REITs possibly could fail to qualify for favorable tax treatment under applicable U.S. or foreign law and/or to maintain exempt status under the Investment Company 54  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 Act of 1940, as amended. Certain REITs provide for a specified term of existence in their trust documents. Such REITs run the risk of liquidating at an economically disadvantageous time. Small and mid-size company risk. Small and mid-size companies carry additional risks because the operating histories of these companies tend to be more limited, their earnings and revenues less predictable (and some companies may be experiencing significant losses) and their share prices more volatile than those of larger, more established companies. The shares of smaller companies tend to trade less frequently than those of larger, more established companies, which can adversely affect the pricing of these securities and the strategy’s ability to sell these securities. These companies may have limited product lines, markets or financial resources, or may depend on a limited management group. Some of the strategy’s investments will rise and fall based on investor perception rather than economic factors. Other investments are made in anticipation of future products, services or events whose delay or cancellation could cause the stock price to drop. Stock investing risk. Stocks generally fluctuate more in value than bonds and may decline significantly over short time periods. There is the chance that stock prices overall will decline because stock markets tend to move in cycles, with periods of rising prices and falling prices. The market value of a stock may decline due to general market conditions that are not related to the particular company, such as real or perceived adverse economic conditions, changes in the outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. A security’s market value also may decline because of factors that affect a particular industry, such as labor shortages or increased production costs and competitive conditions within an industry or factors that affect a particular company, such as management performance, financial leverage and reduced demand for the company’s products or services. Stock selection risk. The stocks selected for implementing a given investment strategy may not perform as well as anticipated or in relation to available stock alternatives, negatively impacting account performance. Systemic risk. World events and/or the activities of one or more large participants in the financial markets and/or other events or activities of others could result in a temporary systemic breakdown in the normal operation of financial markets. Such events could result in a portfolio losing substantial value caused predominantly by liquidity and counterparty issues which could result in a portfolio incurring substantial losses. Technology company risk. The technology sector has been among the most volatile sectors of the stock market. If the strategy’s investments are concentrated in the technology sector, its performance can be significantly affected by developments in that sector. Technology companies, especially small-cap technology companies, involve greater risk because their revenue and/or 55  BNY Mellon Securities Corporation Form ADV Part 2A March 31, 2025 earnings tend to be less predictable (and some companies may be experiencing significant losses) and their share prices tend to be more volatile. Certain technology companies may have limited product lines, markets or financial resources, or may depend on a limited management group. In addition, these companies are strongly affected by worldwide technological developments and their products and services may not be economically successful or may quickly become outdated. Investor perception may play a greater role in determining the day-to-day value of tech stocks than it does in other sectors. Investments made in anticipation of future products and services may decline dramatically in value if the anticipated products or services are delayed or cancelled. The risks associated with technology companies are magnified in the case of small-cap technology companies. The shares of smaller technology companies tend to trade less frequently than those of larger, more established companies, which can have an adverse effect on the pricing of these securities and on a strategy’s ability to sell these securities. Valuation risk. Certain securities in which the underlying funds in the ETF-based model strategies we offer may invest may not have a readily ascertainable market price. Such securities are nevertheless generally valued by the fund managers, their appointed administrators, or third- party pricing agents. Valuation is ordinarily conclusive with respect to a separate account or pooled investment vehicle, even though fund managers generally face a conflict of interest in valuing such securities because the value of the securities may affect the compensation they receive. Value stock risk. Value stocks involve the risk that they may never reach their expected market value, either because the market fails to recognize the stock’s intrinsic worth or the expected value was misgauged. They also may decline in price even though in theory they are already undervalued. 56 

BNY Mellon Securities Corporation 240 Greenwich Street, New York, NY 10286 Form ADV Part 2A, Appendix 1 Wrap Fee Program Brochure As of March 31, 2025 This wrap fee program Brochure provides information about the qualifications and business practices of BNY Mellon Securities Corporation (BNYSC). If you have any questions about the contents of this Brochure, please contact us at 212-635-8827. 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. Registration with the SEC does not imply a certain level of skill or training. Additional information about BNYSC and its affiliated investment advisers is also available on the SEC’s website at www.adviserinfo.sec.gov. Clients of the Customized Investment Series or the Municipal Bond Series should also review the Brochures of any firms acting as Portfolio Managers or Delegated Subadvisers, which accompany this Brochure when an account is first opened, and which may also be found at the SEC’s website at www.adviserinfo.sec.gov.  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Item 2. Material Changes We may update this document at any time but are required to promptly send clients a copy of any material changes to our disclosures upon doing so. We may, at our discretion, either provide you with an updated copy of this Brochure, or an annual summary of all material changes that have occurred to this Brochure along with an offer to provide you with the updated Brochure. BNYSC’s last annual update of this Brochure was on March 30, 2024. As of August 29, 2024, we updated the Disciplinary Information section of Item 9 to reflect a settlement we entered into with the SEC regarding the sending and receipt of business-related text message communications via platforms that were not approved for business purposes. As of February 3, 2025, we updated Items 4, 5, 6 and 9 to reflect the addition of the Personal Bond Strategy to our product offering. 2  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Item 3. Table of Contents Item Page 1 - Cover Page 1 2 - Material Changes 2 3 – Table of Contents 3 4 – Services, Fees and Compensation Our Firm BNY Managed Asset Program Fees and Expenses 5 5 5 14 5 – Account Requirements and Types of Clients 27 Participation in the Program; Minimum Investments and Additional Deposits Types of Clients 27 28 6 – Portfolio Manager Selection and Evaluation Selection and Evaluation BNYSC and Affiliates as Portfolio Managers / Delegated Subadvisers Advisory Business Performance-Based Fees and Side-By-Side Management Methods of Analysis, Investment Strategies and Risk of Loss 29 29 31 32 32 34 7 - Client Information Provided to Portfolio Managers 37 8 – Client Contact with Portfolio Managers 38 9 – Additional Information 38 38 39 Disciplinary Information Other Financial Industry Activities and Affiliations Code of Ethics, Participation or Interest in Client Transactions, Personal Trading 46 3  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Interest in Client Transactions Review of Accounts Nature and Frequency of Reports Client Referrals and Other Compensation Voting Client Securities Financial Information 49 51 52 53 54 59 Appendix A 59 4  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Item 4. Services, Fees and Compensation Our Firm BNY Mellon Securities Corporation (“BNYSC,” “Firm,” “We,” “Our” or “Us”) is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”) and as a broker-dealer under the Securities Exchange Act of 1934 (the “1934 Act”); is a member of the Financial Industry Regulatory Authority (FINRA); and is registered with the National Futures Association (NFA) as an introducing broker. BNYSC is a wholly owned subsidiary of BNY Mellon Investment Adviser, Inc. (“BNYIA”) and an indirect, wholly owned subsidiary of The Bank of New York Mellon Corporation (“BNY”). BNY Managed Asset Program BNYSC, as an investment adviser, offers a wrap fee investment program through its BNY Advisor Services division called the BNY Managed Asset Program (“MAP” or the “Program”) to individuals and other clients (each a “Client” and collectively, the “Clients”) that may include trusts, estates, charitable organizations, individual retirement accounts, corporations, or other business entities. The Program has three currently available components (the “Program Components”): (1) a Mutual Fund Series (the “Mutual Fund Series”) that enables Clients to invest in a wide array of mutual funds (“Funds”) from an approved group of fund families, including Funds that are managed and administered by BNYIA and distributed by BNYSC (“BNY Funds”) and unaffiliated third-party Funds (“Third Party Funds”); (2) a Customized Investment Series (the “Customized Investment Series”) that enables a Client to either invest in (a) equity investment strategies or (b) a specialized fixed income strategy (“Personal Bond Strategy”) through one or more separately managed accounts managed by professional investment advisory firms, which currently consist of Fayez Sarofim & Co. (“Sarofim”), an unaffiliated investment adviser; Insight North America LLC (“Insight”), an affiliate of BNYSC; and BNYSC; and (3) a Municipal Bond Series (the “Municipal Bond Series”) that enables a Client to invest in national or state specific separately managed accounts managed by Insight. 5  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 The Municipal Bond Series and the equity strategies within the Customized Investment Series are not available for retirement account Clients, including Individual Retirement Account (“IRA”) Clients or Simplified Employee Pension IRA (“SEP IRA”) Clients. Please also refer to the discussion under In General in Item 4 of this Brochure for more information about the types of retirement accounts the Program may accept. In addition to the three currently available Program Components, there are three legacy components which are no longer available to new Clients, but that remain open for activity by existing Clients who are currently invested in those components. These legacy components are the Mutual Fund Series – Retirement Accounts (the “Retirement Series”); Mutual Fund Series – Index Portfolio (the “Index Portfolio”); and the Combined Series (the “Combined Series”). The Retirement Series enables such existing Clients who are IRA Clients to invest in an array of BNY Funds. Existing Retirement Series Clients may at their option also obtain access in their Retirement Series account to the Third-Party Funds currently available through the Mutual Fund Series. The Index Portfolio enables such existing Clients to invest in a mutual fund portfolio comprised of BNY Funds that are index funds. The Combined Series enables such existing Clients to invest in a combination of Funds in the Mutual Fund Series, and one or more separate accounts in the Customized Investment Series and/or the Municipal Bond Series. The separate accounts available through the Customized Investment Series, the Municipal Bond Series or the Combined Series are referred to in this Brochure individually as a “Separate Account” and collectively as the “Separate Accounts.” Subject to a Client meeting certain minimum investment requirements as described below, the Client may open one or more accounts in the Program (each a “Program Account”) with respect to the Mutual Fund Series, the Customized Investment Series or the Municipal Bond Series. The Program includes: (i) monitoring of the Funds and automatic rebalancing and performance reporting for Clients in the Mutual Fund Series; (ii) monitoring and performance reporting for Clients in the Customized Investment Series (except with respect to the Personal Bond Strategy, whose Representatives will receive customized cashflow experience reporting from Insight); and (iii) credit surveillance for the Municipal Bond Series. In addition to serving as Program sponsor, BNYSC may serve as one of the available Portfolio Managers (as defined below) within the Customized Investment Series with respect to one or more investment strategies offered to Clients and, in such capacity, will retain affiliated investment management firms as subadvisers (each a “Delegated Subadviser”). Such Delegated Subadvisers will perform certain investment advisory services on BNYSC’s behalf, including providing 6  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 investment recommendations to BNYSC based on a particular investment strategy (the “Strategy” or “Strategies”). Pursuant to BNYSC’s engagement of a Delegated Subadviser, BNYSC may delegate all or a portion of its investment strategy discretion to a Delegated Subadviser while retaining trading discretion over the Client’s Program Account. The Delegated Subadviser is responsible for monitoring, evaluating and adjusting the investment recommendations based on the Delegated Subadviser’s investment research, experience and judgment. Currently, Newton Investment Management Limited (“Newton”), an affiliated investment manager, has been engaged by BNYSC as a Delegated Subadviser with respect to the Global Equity Income ADR Strategy (the “GEI Strategy”) offered within the Customized Investment Series. Though selection of BNYSC or an affiliate as a Portfolio Manager (and BNYSC’s use of affiliates as Delegated Subadvisers) does not increase the Advisory Fee payable by a Client, this may present certain actual or potential conflicts of interest for BNYSC and such affiliates. Please refer to Item 6 (Portfolio Manager Selection and Evaluation) and Item 9 (Additional Information) of this Brochure for a detailed description and discussion of these topics. Separate Account Investment Strategies Municipal Bond Series The Insight strategy we offer in the Municipal Bond Series is a tailored version of Insight’s Municipal Bond Fixed Income strategy, designed to generate predictable levels of income rather than total return, and is available as US national, as well as California, New Jersey and New York state-specific portfolios. These portfolios are structured using a 10-year laddered-maturity, buy- and-hold investment approach. Each Client’s portfolio is divided into ten approximately equal portions, with the holdings in each portion (or “rung” of the maturity “ladder”) successively maturing in one-year intervals, currently from three years through twelve years. As the shortest (three year) rung matures, the proceeds are reinvested in bonds having twelve-year maturities, and this investment cycle continues on an ongoing basis. Securities are otherwise generally not purchased or sold, except to accommodate initial portfolio investment, subsequent Client-directed deposits or withdrawals, security dispositions related to credit quality oversight, and account terminations. The strategy is limited to US municipal bonds and does not utilize securitized investments, derivatives or leverage. As Portfolio Manager, Insight may periodically, in its discretion, to accommodate changing market conditions on behalf of Program Accounts, adjust the starting and ending points of the rungs of 7  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 the maturity ladder, while still maintaining an overall ten-year span. In such cases, one or more rungs may remain wholly or partially vacant until such time as the new maturity structure may be fully implemented. Please also refer to Item 8 and Appendix A of this Brochure for additional information, including a discussion of the material risks associated with this strategy. Customized Investment Series The Sarofim strategy we offer in the Customized Investment Series, for which Sarofim acts as Portfolio Manager, represents Sarofim’s Large Capitalization Equity Product. This strategy is focused on domestically traded common stocks with large market capitalizations and high daily trading volumes. American Depositary Receipts, preferred stocks and foreign stocks may also be included. Sarofim invests in the stocks of companies that it believes are high quality, financially sound industry leaders that have an expanding global presence. Sarofim generally maintains an investment perspective of at least three to five years, which tends to result in lower portfolio turnover. The strategy does not utilize derivatives, options, short-selling, leverage, initial public offerings or market timing. Please also refer to Item 8 and Appendix A of this Brochure for additional information, including a discussion of the material risks associated with this strategy. The Newton strategy we offer in the Customized Investment Series, for which BNYSC acts as Portfolio Manager, represents an American Depositary Receipts (“ADRs”)-focused version of Newton’s Global Equity Income strategy. Securities are selected using a bottom-up process within a global thematic framework. The strategy typically holds securities that have a yield premium to the strategy’s benchmark, the MSCI World Index, and is limited to Depository Trust and Clearing Corporation (DTCC)-eligible securities of global companies and index-based exchange-traded funds. The strategy invests predominantly (typically at least 80%) in securities of developed markets, such as the US, Canada, Japan, Australia, Hong Kong and Western Europe, but may also invest up to 30% in securities of emerging markets. The strategy is typically comprised of approximately 50% ADRs and 50% stocks, and does not utilize derivatives, options, short-selling, leverage, initial public offerings or market timing. Please also refer to Item 8 and Appendix A of this Brochure for additional information, including a discussion of the material risks associated with this strategy. 8  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 The Insight strategy we offer in the Customized Investment Series, for which Insight acts as the Portfolio Manager, represents Insight’s “Personal Bond Strategy” – an individually personalized, fixed income decumulation strategy designed to generate pre-defined monthly or annual payouts, over a specific time period, from an accumulated savings base. The strategy is intended primarily for investors who are entering into or already are in retirement and interested in creating a predictable, income stream while avoiding the capital lock-up requirements typically associated with annuity products. The Strategy is invested primarily in US investment-grade corporate bonds and US Treasury securities, and seeks to provide an optimized, individually tailored portfolio based on the cashflow and time period requirements specified by the client. Please note that, as a decumulation strategy, the income stream paid to the client will consist of both investment income and return of principal, such that the Client’s Personal Bond Strategy Program Account balance, under expected interest rate and other market factors, will be reduced to zero ($0) as of the end of the time period specified by the Client. Please also refer to Item 8 and Appendix A of this Brochure for additional information, including a discussion of the material risks associated with this Strategy. Additional Information About the Program The Program is comprised of the following elements: 1. Client Questionnaire and Investment Guidelines The Client will complete a confidential Program Client Questionnaire (the “Questionnaire”), designed to help the Client identify and provide BNYSC information about the Client’s current investments, financial circumstances and investment objectives. In addition, the Mutual Fund Series Questionnaire contains an integral Risk Tolerance Assessment (the “Risk Assessment”) further designed to assist BNYSC with recommending an Asset Allocation Plan, specific to the Mutual Fund Series, as described in the following section titled Asset Allocation Plan. Customized Investment Series and Municipal Bond Series Clients may on their Questionnaire specify reasonable investment restrictions related to individual securities, groups of securities or security sectors with respect to the management of their Separate Account. With respect to the Personal Bond Strategy, such investment restrictions will generally be limited to a maximum of 9  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 three issuer-specific restrictions and three security sectors each. Such investment restrictions, if any, are referred to in this Brochure as the “Investment Guidelines.” The Client agrees to promptly notify BNYSC in writing of any change in, as applicable, the Risk Assessment, the Investment Guidelines or the Client’s financial condition that may affect the manner in which the Program Account assets are to be invested under the Program. With respect to Customized Investment Series and Municipal Bond Series Clients, BNYSC will promptly convey Investment Guidelines revisions to the applicable portfolio manager or managers selected by the Client in accordance with Item 6 of this Brochure (each a “Portfolio Manager”). In general, based on such written notification from the Client, BNYSC may reevaluate the suitability of a particular Fund or Separate Account for the Client, or recommend a change in the investments to be made under the Program. Any changes to the Investment Guidelines will become effective as soon as practicable following their delivery in writing to BNYSC and their acceptance by BNYSC and the applicable Portfolio Manager(s). 2. Asset Allocation Plan For Clients who participate in the Mutual Fund Series, BNYSC, in consultation with the Client and based on the Client’s responses to the Questionnaire and Risk Assessment, will recommend, from among a suite of available model-based options, an asset allocation plan (“Asset Allocation Plan”). BNYSC has retained an affiliate, BNY Mellon Advisors, Inc. (“BNY Advisors”), to provide, maintain and periodically update the model-based Asset Allocation Plan options offered in the Mutual Fund Series, and pays BNY Advisors a fee for this service. Please note that this fee is borne directly by BNYSC and has no impact on any fee charged to a Client who participates in the Program. To participate in the Mutual Fund Series, the Client must either accept the Asset Allocation Plan recommended by BNYSC or, at the Client’s discretion, select an alternate Asset Allocation Plan from among the available options, and instruct BNYSC to invest Program Account assets pursuant to such accepted or alternate Asset Allocation Plan. As more broadly described under In General, below, we reserve the right, at our discretion, not to accept a Program Account in cases where we believe an alternate Asset Allocation Plan selected by the Client may not be consistent with the Client’s financial situation or desired investment guidelines. 10  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 The current asset classes that are available under the Mutual Fund Series (“Asset Classes”) include: • US Large Capitalization Equities • US Small and Mid-Capitalization Equities • Global Income Equities • US Taxable Fixed Income • US Tax-Free Fixed Income • International Equities – Developed Markets • International Equities – Emerging Markets • Cash Equivalents BNYSC will offer the Asset Allocation Plan for Mutual Fund Series Clients, as described above, based on the Client’s individual investment needs and objectives as described in the Questionnaire and Risk Assessment provided by the Client. The Asset Allocation Plan will designate a combination of Asset Classes into which Program Account assets will be invested and the percentage of Program Account assets to be invested in each Asset Class. The Asset Classes that are available through the Mutual Fund Series and the percentage of Program Account assets to be invested in each Asset Class are subject to change at any time, and the Client understands that the Asset Allocation Plan designed for the Client may need to be adjusted on occasion to reflect the addition or removal of certain Asset Classes from the Program. Pursuant to the Asset Allocation Plan, if applicable, the Client, in consultation with a BNYSC Investment Advisory Representative (“Representative”), will choose one or more Funds for each Asset Class selected. Upon opening a Program Account, the Client will designate a money market Fund managed by BNYIA (a “Sweep Fund”) for the cash equivalents asset class (with respect to the Mutual Fund Series only) and for uninvested cash balances (with respect to all three Program Components). BNYSC and its affiliates (including BNYIA) provide services to the Sweep Funds and receive fees for those services and, therefore, BNYSC and its affiliates benefit financially when assets are invested in a Sweep Fund. 3. Client Agreement Mutual Fund Series If a Client, in consultation with a Representative, chooses to participate in the Mutual Fund Series, the Client will sign an investment advisory agreement (the “Investment Advisory Agreement”) 11  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 that sets forth the terms and conditions for participation in the Program and that governs the operation of the Program Account. In particular, pursuant to the Investment Advisory Agreement, the Client engages BNYSC to provide non-discretionary investment advisory and other services under the Program. Moreover, by signing the Investment Advisory Agreement, the Client instructs BNYSC to rebalance the Program Account on a semi-annual basis based upon balances in the Program Account on the last business day of the quarter preceding each rebalancing date (unless the Client and BNYSC agree to a different time frame for rebalancing) by liquidating shares of certain Funds and purchasing shares of other Funds to realign Program Account investments with the percentage of Program Account assets to be invested in each Asset Class as specified in the Asset Allocation Plan; provided, however, that BNYSC will not perform any rebalancing trade that would be for less than $100. For rebalancing purposes, BNYSC will only purchase shares of the selected Funds in proportion to the Asset Allocation Plan. Rebalancing involves the purchase and redemption of Fund shares over a period of one or more business days and, therefore, involves certain investment risks and the possible loss of dividend earnings during the rebalancing period. BNYSC will not execute investment transactions for the Mutual Fund Series except for purchase, redemption and rebalancing transactions in Fund shares made in accordance with the Client’s instructions as set forth in the Investment Advisory Agreement and the Asset Allocation Plan accepted by the Client. Customized Investment Series If a Client, in consultation with a Representative, chooses to participate in the Customized Investment Series, the Client will sign a client services agreement (“Client Services Agreement”) that sets forth the terms and conditions for participation in the Customized Investment Series and governs the operation of the corresponding Customized Investment Series Separate Account. Under the Client Services Agreement, the Portfolio Manager selected by the Client will direct the investment and reinvestment of the assets in the Separate Account corresponding to the investment strategy selected. The Portfolio Manager will manage the Separate Account on a discretionary basis in accordance with the investment style listed adjacent to the Portfolio Manager’s name in the Client Services Agreement. As described above, BNYSC may serve as one of the available Portfolio Managers within the Customized Investment Series, and, in such capacity, will retain affiliated Delegated Sub-advisers with respect to certain investment strategies offered to Clients. In such cases, BNYSC will execute securities transactions on a discretionary basis for the applicable Separate Accounts, utilizing specific investment strategy guidance from the corresponding affiliated Delegated Sub-adviser(s). 12  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 The Portfolio Manager will manage such corresponding Separate Account on a discretionary basis in accordance with the selected investment strategy and consistent with the Investment Guidelines. Municipal Bond Series If a Client, in consultation with his, her or its Representative, chooses to participate in the Municipal Bond Series, the Client will sign a client services agreement (the “Municipal Bond Series Client Services Agreement”) that sets forth the terms and conditions for participation in the Municipal Bond Series and governs the operation of the Separate Account. Under the Municipal Bond Series Client Services Agreement, the Portfolio Manager appointed by the Client will direct the investment and reinvestment of the assets in the Separate Account corresponding to the investment strategy provided by the Portfolio Manager and selected by the Client. The Portfolio Manager will manage such corresponding Separate Account on a discretionary basis in accordance with the selected investment strategy and consistent with the Investment Guidelines. In General Except as otherwise provided in the following paragraph, the Program will not accept as a Client a retirement or other employee benefit plan that is subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) nor any other type of retirement account. The Mutual Fund Series will accept IRA Program Accounts that are not subject to ERISA and will also accept SEP IRA Program Accounts. The Municipal Bond Series and the equity strategies within the Customized Investment Series do not accept Program Accounts that would be subject to ERISA or retirement Program Accounts of any other type, including IRA Program Accounts. The Personal Bond Strategy within the Customized Investment Series will however accept IRA Program Accounts that are not subject to ERISA. In addition, BNYSC reserves the right, at its discretion, not to accept any Program Account prior to the signing of an Investment Advisory Agreement, Client Services Agreement or Municipal Bond Series Client Services Agreement by the Client. Program Account assets will be invested without regard to potential tax consequences. BNYSC does not provide any tax advice. Purchases and sales of securities may have tax consequences that the Client should discuss with an independent tax professional. 13  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 In the event a Client opens more than one Program Account in the Program, each Program Account will be governed by the separate client agreement described above corresponding to the Program Component selected by the Client. There can be no assurance that the Client’s investment objectives can be achieved by this Program or any other investment strategy. Fees and Expenses Advisory Fee The Client will pay an annual fee with respect to each Program Component (the “Advisory Fee”) that includes fees and expenses for the investment advisory, custodial, clearing and other services provided under the Program, as well as all brokerage commissions and associated transaction costs, except that the Client will pay certain fees and expenses in addition to the Advisory Fee as described below in Additional Fees and Expenses Not Included in Advisory Fee. Each Client’s Advisory Fee is set forth in the applicable Investment Advisory Agreement, Client Services Agreement or Municipal Bond Series Client Services Agreement (collectively and individually referred to as the “Client Agreement”). Mutual Fund Series; Mutual Fund Series – Retirement Accounts; Mutual Fund Series – Index Portfolio; Combined Series (Mutual Fund portion) The standard Advisory Fee schedule for the Mutual Fund Series, Mutual Fund Series – Retirement Accounts, Mutual Fund Series – Index Portfolio and Mutual Fund Series portion of the Combined Series is set out below. The Client’s annual Advisory Fee is reduced by a credit amount (“Credit Amount”). The purpose of this Credit Amount is to reduce the Client’s annual Advisory Fee by the amount of the fees or other compensation, if any, received from the BNY Funds and Third-Party Funds for investment management and/or certain other services provided by us or our affiliates. This Credit Amount is applied quarterly. To the extent applicable, a Credit Amount is calculated for each Fund held in the Program Account as follows: 14  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 1. For the BNY Funds, the Credit Amount will equal the investment management fees, distribution and shareholder servicing fees (as applicable), and certain other fees (net of any expense waivers or reimbursement) paid to us or our affiliates by the Funds less any fees paid to non-affiliated sub-advisers. 2. For the Third-Party Funds, the Credit Amount will equal the distribution and shareholder servicing fees (as applicable), and certain other fees paid to us or our affiliates by the Funds. These are added together to arrive at the total Credit Amount. The total Credit Amount is applied against the annual Advisory Fee to arrive at the annual net Advisory Fee. ANNUAL ADVISORY FEE SCHEDULE Annual Net Advisory Fee Account Asset Tier Annual Advisory Fee – Mutual Fund Series - Index Portfolio First $100,000 Annual Advisory Fee – Mutual Fund Series and Mutual Fund Series – Retirement Accounts 1.50% 0.85% Annual Advisory Fee Less Credit Amount Next $400,000 1.15% 0.60% = Next $500,000 1.00% 0.50% Annual Net Advisory Fee Assets above $1,000,000 0.90% 0.35% Fund shares purchased through the Program are generally comprised of share classes that do not assess distribution or “12b-1” fees (“Non-12b-1 Shares”). BNYSC seeks to make available the lowest cost share class of a Fund that Program Clients are eligible to purchase that is not subject to transaction fees when Program Clients purchase and sell Fund shares in their Program Accounts. If Program Clients do not meet the eligibility criteria set forth in a Fund’s prospectus for a particular class of shares, then BNYSC will seek to make available the lowest cost share class from among the remaining choices that is not subject to transaction fees when Program Clients purchase and sell Fund shares in their Program Accounts. This means that any share class of a Fund that subjects Program Clients to transaction fees will not be made available, even if such share class 15  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 has the lowest stated expense ratio as reflected in a Fund’s prospectus. For a description of all available share classes for a given Fund, please refer to the Fund’s prospectus. BNYSC periodically reviews the share classes offered by the Funds, but also relies on the Fund families to inform BNYSC when and if share classes will be made available. Please contact your Representative for information about any limitations on the share classes available through the Program. Subject to the eligibility criteria constraints discussed above, if BNYSC makes available a share class for a Fund with a lower fee structure than the share class previously made available for that Fund, to the extent allowed, BNYSC will effectuate for Clients a share class exchange of current (i.e., previously purchased) shares of the Fund for the lower fee share class of the same Fund. Such conversion of shares of a Fund can take time, including several days or more, to complete. BNYSC and its affiliates generally receive significantly higher fees from BNY Funds than from Third Party Funds. Neither BNYSC nor its affiliates will receive any sales commissions or charges, fees, discounts, penalties or adjustments in connection with the purchase, holding, exchange, termination or sale of any shares of BNY Funds. The Client may be able to avoid the Advisory Fee by investing in the Funds directly instead of through the Program. However, the Client may pay sales charges on Funds purchased outside of the Program and may not be eligible to purchase the same share classes that are available through the Program. Certain Clients, including those who began participating in the Program before adoption of the above Advisory Fee schedule and/or for whom the Advisory Fee was separately agreed to, may pay lower or higher fees. Customized Investment Series The standard Advisory Fee schedule for the Customized Investment Series (except with respect to the Personal Bond Strategy) is as follows: Account Asset Tier Annual Advisory Fee First $1,000,000 All assets above $1,000,000 1.50% 1.25% The standard Advisory Fee for the Personal Bond Strategy is a fixed, non-tiered rate of 0.70%. 16  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Municipal Bond Series The standard Advisory Fee schedule for the Municipal Bond Series is as follows: Account Asset Tier Annual Advisory Fee First $500,000 Next $500,000 Next $4,000,000 All assets above $5,000,000 0.70% 0.65% 0.60% 0.50% With respect to the Customized Investment Series, the portion of the Advisory Fee that is paid to Portfolio Managers for providing investment advice can range from 0.20% – 0.60% of assets under management. With respect to the Municipal Bond Series, the portion of the Advisory Fee that is paid to Portfolio Managers for providing investment advice can range from 0.25% – 0.50% of assets under management. Combined Series The Advisory Fee for the services provided to Clients in the Combined Series is calculated separately with respect to Program Account assets that are held in the Mutual Fund Series and Program Account assets that are held in the Customized Investment Series and/or the Municipal Bond Series, in accordance with the foregoing Advisory Fee schedules (each as applicable). Fee Discount for Multiple Program Accounts Members of the same family – defined as Client; Client’s spouse or legal domestic partner; and Client’s children residing at the same address as Client, and businesses with the same ownership who own multiple Program Accounts in the Mutual Fund Series, Mutual Fund Series – Retirement Accounts or Mutual Fund Series - Index Portfolio (“Linked Accounts”), may be eligible for a discount on the Advisory Fee on such Linked Accounts. Clients must request the fee discount by completing a MAP Mutual Fund Series Discount Linkage Form. The discount will be applied at the beginning of the next quarter after the form is accepted by BNYSC. Except with respect to the Personal Bond Strategy, members of the same family (as defined above) and businesses with the same ownership who own multiple Customized Investment Series Program Accounts may link these Program Accounts to qualify for a discount on the Advisory 17  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Fee. Likewise, members of the same family (as defined above) and businesses with the same ownership who own multiple Municipal Bond Series Program Accounts may link these Program Accounts to qualify for a discount on the Advisory Fee. Clients must request that their Customized Investment Series or Municipal Bond Series Program Accounts be linked for fee purposes by completing and signing a Customized Investment Series or Municipal Bond Series Discount Linkage Form. The discount can also be applied to a business account owned by a sole proprietor and an individual or joint account owned by the same person. Please note that a Customized Investment Series Program Account cannot be linked to a Municipal Bond Series Program Account for fee discount purposes. In addition, Program Accounts within the Mutual Fund Series, Mutual Fund Series – Retirement Accounts or Mutual Fund Series – Index Portfolio cannot be linked to a Customized Investment Series Program Account or Municipal Bond Series Program Account for fee discount purposes. Personal Bond Strategy Program Accounts are not eligible for the multiple-Program Account fee discount described above. Payment of Advisory Fees With respect to all current Program Components and legacy components, the Advisory Fee is automatically deducted from the Program Account within approximately the first ten calendar days of each quarter. The Advisory Fee for the Mutual Fund Series, Mutual Fund Series – Retirement Accounts, Mutual Fund Series - Index Portfolio, and Mutual Fund Series portion of the Combined Series is calculated on a quarterly basis based on the average daily assets of the previous quarter and billed in arrears. The Advisory Fee for the Separate Account portion of the Combined Series, the Customized Investment Series, and the Municipal Bond Series is calculated and payable in advance based on the value of Program Account assets in the Program on the last business day of the previous quarter. The initial Advisory Fee will be calculated based on the value of the initial assets deposited into the Program Account and will cover the initial quarter (or, with respect to a partial quarter, will be prorated based on the number of days remaining in such quarter). The initial Advisory Fee will be automatically deducted from the Client’s deposited assets on the effective date of the applicable Client Agreement. If the Client Agreement is terminated before the last day of a quarter, a prorated portion, based on the number of days remaining in the quarter, of the Advisory Fee paid in advance will be refunded to the Client. All Advisory Fee deductions from the Program Account will be made first from any uninvested cash balance and then by redeeming available shares of the Sweep Fund. If sufficient Sweep Fund balances are not available, BNYSC 18  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 will redeem sufficient shares of Funds or securities (if applicable, in the same manner that redemptions are to be made in connection with the rebalancing of the Program Account) to pay such Advisory Fee. At our discretion, the Advisory Fee charged to a Client for participation in the Program may be negotiated and, in such circumstances, this negotiated Advisory Fee may differ from the standard Advisory Fees outlined above. Note that no Credit Amount is applicable or payable with respect to Customized Investment Series or Municipal Bond Series Program Accounts, nor with respect to the portions of any Combined Series Program Account held outside of the Mutual Fund Series. Additional Fees and Expenses Not Included in Advisory Fee Brokerage Account Fees and Expenses The securities transactions necessary for day-to-day investment management of a Client’s Program Account are effected through a brokerage account (“Brokerage Account”) that the Client is required to establish with BNYSC and which is governed by a separate BNY Managed Asset Program Brokerage Account Client Agreement (“Brokerage Account Client Agreement”). Any applicable Brokerage Account fees and expenses incurred by Client, as detailed in the Brokerage Account Client Agreement, will be in addition to, and not included in, the Advisory Fee payable by the Client. A Client may open one or more Program Accounts in the Program; however, each Program Account requires establishment of a separate Brokerage Account and completion of a separate Client Agreement, and each Program Account will be assigned a separate and distinct Program Account number. Trading Away Fees and Expenses BNYSC will introduce the Client’s Brokerage Account to Pershing LLC (“Pershing”), a BNYSC affiliate and BNY subsidiary, for execution and clearance of the securities transactions placed by BNYSC or the Portfolio Managers. To facilitate obtaining best execution on behalf of Customized Investment Series Clients, however, Portfolio Managers may, in their sole discretion, execute securities transactions through broker/dealers other than Pershing. A Portfolio Manager may trade away for a variety of reasons, including the type of securities that the Portfolio Manager is buying or selling, or because the Portfolio Manager is aggregating Client trades with trades for other, non- 19  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Program clients. The corresponding brokerage commissions and associated transaction costs for such “trading away” activity will not be included in the Advisory Fee paid by the Client and instead will represent additional costs borne by the Client. Clients should also note that such brokerage commissions and associated transaction costs may be built into the net price of the investment reflected on trade confirmations as opposed to being separately itemized. Please also refer to the discussion below under Execution, Clearance, Administrative and Custodial Services by Pershing. In connection with the GEI Strategy offered in the Customized Investment Series for which BNYSC serves as the Portfolio Manager (and which is described in more detail under Separate Account Investment Strategies in Item 4 above), all trades for the period from January 1 through December 31, 2024, were executed with Pershing. This trading away information reflects historical data and may not be indicative of our current or future trading away practices. With respect to the Sarofim Strategy offered in the Customized Investment Series (and which is described in more detail under Separate Account Investment Strategies in Item 4 above), for the period from January 1 through December 31, 2024, all trades executed by Sarofim on behalf of client accounts were executed with Pershing. With respect to the Insight Personal Bond Strategy offered in the Customized Investment Series, the majority of trades will be executed with broker/dealers specializing in fixed income securities, rather than with Pershing. Unlike exchange-traded equity securities, such trades are typically executed on a principal, rather than agency, basis, for which markups, markdowns, and spreads are assessed in lieu of an explicit commission. Such markups, markdowns or spreads are reflected in the price the Client pays or receives for such securities as opposed to being separately itemized, and apply to fixed income securities transactions either executed with, or traded away from, Pershing. With respect to the Municipal Bond Series, the majority of trades are executed with broker/dealers specializing in municipal securities, rather than with Pershing. Unlike exchange-traded equity securities, municipal bond trades are typically executed on a principal, rather than agency, basis, for which markups, markdowns, and spreads are assessed in lieu of an explicit commission. Such markups, markdowns or spreads are reflected in the price the Client pays or receives for such securities as opposed to being separately itemized, and apply to municipal securities transactions either executed with, or traded away from, Pershing. 20  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Underlying Fund Fees and Expenses Clients in the Mutual Fund Series, Mutual Fund Series – Retirement Accounts, Mutual Fund Series - Index Portfolio or Combined Series (with respect to the portion of their assets invested in the Mutual Fund Series) will bear a proportionate share of each Fund’s fees and expenses, including investment management fees and fees for administrative, distribution, transfer agency, custody, legal and audit services and other fees and expenses customarily paid by mutual funds to persons who provide services to them. These fees will be in addition to the Advisory Fee and are described in each Fund’s prospectus or statement of additional information (“SAI”). Clients should review all applicable prospectuses and SAIs for additional information about these fees and expenses. BNYSC and its affiliates provide services to Funds in the Program and receive fees for those services from such Funds or one of their other service providers. Typically, these fees will be based on the value of a Fund’s total assets or the amount of Program Account assets invested in a Fund through the Program. In particular, BNYSC or an affiliate will receive: (i) distribution or “12b-1” fees and/or (ii) shareholder servicing fees from a Fund except that no 12b-1 fees will be received when Clients are invested in Non-12b-1 Shares. The compensation received by BNYSC and its affiliates varies from Fund to Fund, which means that BNYSC and its affiliates benefit more when the compensation is higher, and is described in general terms in each Fund’s prospectus or SAI. BNYSC and its affiliates receive significantly higher compensation from BNY Funds than from Third Party Funds. This creates a conflict of interest because BNYSC and its affiliates have a financial incentive for Clients to invest in the Funds generally and to invest in Funds that result in higher compensation to BNYSC and its affiliates. However, as discussed above, the Credit Amount offsets certain fees paid, with respect to the Mutual Fund Series, the Mutual Fund Series – Retirement Accounts, the Mutual Fund Series – Index Portfolio and the Mutual Fund Series portion, if any, of Combined Series Program Accounts, by a Fund to BNYSC or an affiliate, including any applicable 12b-1 and shareholder servicing fees. Please review the description as to how the Credit Amount is calculated. The size of the total Credit Amount applied against a Client’s Advisory Fee will depend on the mix of Funds held in that Client’s Program Account. In addition, the manner in which our Representatives are compensated does not create a financial incentive for them to recommend one Fund over another. Other Fees and Expenses In addition to the fees and expenses described above, certain routine trading costs associated with the day-to-day investment management of a Program Account will not be included in a Client’s 21  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Advisory Fee and therefore represent additional costs to the Client. In general, these may include (but are not necessarily limited to) the SEC fee imposed on sales of US securities and the transaction taxes imposed by certain non-US countries with respect to the purchase and sale of securities of certain issuers domiciled in those countries. Markups, markdowns, and spreads assessed in principal transactions (which are more typical of fixed income securities) will not be included in the Client’s Advisory Fee. Such costs are reflected in the price the Client pays or receives for such securities. Similarly, the purchase price for initial public offerings of securities typically includes a markup received by the underwriters or dealers involved in the distribution, rather than an explicit commission. Such markups will not be included in the Client’s Advisory Fee but will be reflected in the price the Client pays for such securities. With respect to trading away activity in the GEI Strategy, additional trading-related costs, such as non-US local market transaction taxes and ADR conversion charges, may also apply. Clients should carefully consider all fees and expenses, including the additional costs and expenses associated with trading away, before selecting a particular Portfolio Manager and investment strategy. Termination Mutual Fund Series; Mutual Fund Series – Retirement Accounts; Mutual Fund Series – Index Portfolio With respect to a Client’s participation in the Mutual Fund Series, Mutual Fund Series – Retirement Accounts or Mutual Fund Series – Index Portfolio, the Investment Advisory Agreement may be terminated (i) by BNYSC upon not less than 30 days written notice to the Client, and (ii) by the Client upon written notice to BNYSC, effective on the actual receipt of such notice by BNYSC. Upon termination by BNYSC, BNYSC will place orders to redeem the shares of all Funds held in the Program Account as promptly as is practicable and will deliver the redemption proceeds to the Client, unless the Client notifies BNYSC in writing to transfer such shares to another account designated by the Client (and provided such transfer is not contrary to any restrictions on mutual fund shares that may be specified in a Fund’s prospectus). Upon termination by the Client, (i) the Client may, at the Client’s discretion, instruct BNYSC to redeem the Fund shares held in the Program Account and pay the Client the cash proceeds received therefrom, or (ii) the Client may, at the Client’s discretion, instruct BNYSC to transfer any or all 22  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 of the Fund shares held in the Program Account to another account designated by the Client (and provided such transfer is not contrary to restrictions on mutual fund shares outlined in the Fund’s prospectus), and to redeem any Fund shares held in the Program Account that are not transferrable and pay the Client the cash proceeds received therefrom. In cases where the Investment Advisory Agreement is terminated by BNYSC, if BNYSC receives no response from the Client within the 30-day written notice period as to the Client’s desired disposition preference with respect to the Program Account, BNYSC will place orders to redeem the shares of all Funds held in the Program Account and will deliver the redemption proceeds to the Client. Redemption of Fund shares in either event can result in a taxable event and the Client should be aware of the potential tax implications. In the event of termination by BNYSC or the Client, it may take longer than three business days for the client to receive the proceeds from the redemption of shares of Funds other than the Sweep Fund. Customized Investment Series; Municipal Bond Series Similarly, with respect to a Client’s participation in the Customized Investment Series or the Municipal Bond Series, the Client Agreement may be terminated (i) by BNYSC upon not less than 30 days written notice to the Client, and (ii) by the Client upon written notice to BNYSC, effective on the actual receipt of such notice by BNYSC. In the event that the Client terminates the Client Services Agreement, the Client may, except with respect to the Personal Bond Strategy, at his, her or its discretion, instruct the Portfolio Manager(s) and BNYSC to: (i) liquidate all of the securities held in the Separate Account and pay the Client the cash proceeds received therefrom, or (ii) transfer, where permitted by the receiving account, any or all of the cash or securities held in the Separate Account to another account designated by the Client, and to liquidate any securities held in the Program Account that are not transferable and pay the Client the cash proceeds received therefrom. In cases where the Client Agreement is terminated by BNYSC, if BNYSC receives no response from the Client within the 30-day written notice period as to the Client’s desired disposition preference with respect to the Program Account, BNYSC will liquidate all of the securities held in the Program Account and pay Client the cash proceeds received therefrom. In the event of the termination of a Personal Bond Strategy Program Account, all securities held in the Program Account will be liquidated and the resulting cash proceeds will be paid to the Client. 23  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 If a Program Account is liquidated as the result of a termination notice, the Portfolio Manager may take up to 21 calendar days to effect such liquidation following the date the liquidation request was received by the Portfolio Manager, and proceeds will be payable to Client within ten (10) calendar days of such liquidation. With respect to Municipal Bond Series Accounts, if the Client closes such Program Account within the first three calendar quarters after opening the Program Account, an additional fee of $2,000 will be charged to the Program Account. This fee is designed to reimburse BNYSC for the particular expenses associated with establishing and maintaining a Program Account which holds solely municipal fixed-income securities. Combined Series With respect to a Client’s participation in the Combined Series, the Client Services Agreement and the Investment Advisory Agreement may be terminated (i) by BNYSC upon not less than 30 days written notice to the Client, and (ii) by the Client at any time upon written notice to BNYSC, effective on the actual receipt of such notice by BNYSC. In the event that the Client terminates the Client Services Agreement, the Client may, at his, her or its discretion, instruct the Portfolio Manager(s) and BNYSC to: (i) liquidate all of the securities held in the Program Account and pay the Client the cash proceeds received therefrom, or (ii) transfer, where permitted by the receiving account (and provided such transfer is not contrary to restrictions on outlined in the Fund’s prospectus where mutual fund positions are included in the Program Account), any or all of the cash or securities held in the Program Account to another account designated by the Client, and to liquidate any securities held in the Program Account that are not transferable and pay the Client the cash proceeds received therefrom. In cases where the Client Services Agreement and Investment Advisory Agreement are terminated by BNYSC, if BNYSC receives no response from the Client within the 30-day written notice period as to the Client’s desired disposition preference with respect to the Program Account, BNYSC will liquidate all of the securities held in the Program Account and pay Client the cash proceeds received therefrom. If the Program Account is to be liquidated as the result of a termination notice, the Client understands that the Portfolio Manager(s) may take up to five (5) trading days to effect such liquidation following the date that the liquidation request was received by the Portfolio Manager(s). Proceeds will be payable to the Client within 10 days of liquidation. 24  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Other Termination Provisions Following termination of any Program Account in the Program, BNYSC will be under no obligation whatsoever to recommend any further action with regard to the shares of any Fund or Separate Account or to provide any further investment advice to the Client. BNYSC retains the right to complete any transactions open as of the termination date and to retain amounts in the Program Account sufficient to effect such completion. In addition, other Program Account termination provisions may apply with respect to Clients who are deceased, incapacitated, or unavailable for contact for an extended period of time; please refer to your Investment Advisory Agreement, Client Services Agreement or Municipal Bond Series Client Services Agreement, as applicable, for more information. Execution, Clearance, Administrative and Custodial Services by Pershing As described above, all securities transactions for the Client’s Program Account will be effected through the Client’s Brokerage Account. BNYSC will introduce such Brokerage Accounts to Pershing. Pershing will execute all purchase and sale orders directed to it by BNYSC or the Portfolio Manager, if and as applicable, and perform the associated clearing services. A Portfolio Manager for the Customized Investment Series, Combined Series, or Municipal Bond Series may at its discretion select brokers and dealers other than Pershing to effect and execute transactions for such Program Accounts. To the extent such other brokers and dealers effect and execute transactions for Program Accounts, the corresponding brokerage commissions and associated transaction costs, if applicable, would not be included in the Advisory Fee paid by the Client and would represent additional costs incurred by the Client’s Program Account. Pershing will in all cases maintain custody of all Program Account assets and perform custodial functions, including crediting of interest and dividends on Program Account assets and crediting of principal on called or matured securities in the Program Account, as well as such other custodial functions that are customarily performed with respect to securities brokerage accounts. Pershing will also forward confirmations of each purchase and sale to Client and Portfolio Manager. Additionally, Program Account statements will be forwarded by Pershing to the Client, BNYSC, and, if requested by the Portfolio Manager, to the Portfolio Manager for each month in which activity occurs in a Program Account. Pershing will also act as general administrator of Program Accounts, and as such, pursuant to BNYSC’s instructions, will process the charging and collection of Program Account fees, and process deposits to and withdrawals from Program Accounts. 25  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Other Information Regarding the Program In the Program, we charge a Client an Advisory Fee that covers, except where otherwise described in this Brochure, various costs relating to the management of the Client’s Program Account. Depending on the amount of activity in a Program Account, the fees for the Program may result in higher costs than a Client might otherwise incur by paying a sponsor’s or adviser’s standard fees and negotiating separate arrangements for trade execution, custodial and other services. Clients may therefore wish to periodically reevaluate their participation in the Program to consider whether the total fees and expenses of the Program remain appropriate for their needs. Representatives may recommend the Program to current or prospective Clients. All or a portion of the Advisory Fees charged by BNYSC will be paid to certain Representatives for introducing Clients to the Program or for providing supplemental and other Client-related services. These payments will be made for the duration of each Client’s participation in the Program. In addition, other Representatives who introduce clients to the Program and provide these other services may receive annual discretionary compensation based on a variety of factors, such as achievement of overall corporate/business unit and individual performance goals, including actual sales production. While this type of award is discretionary, it creates a financial incentive to make recommendations generally. The amount of compensation received by Representatives with respect to Clients who participate in the Program may be more than that received if such Clients participated in other investment advisory programs or paid separately for the investment advice, brokerage and other services provided as part of the Program. As a result, Representatives have a financial incentive to recommend the Program and have you remain invested. A limited number of high-performing Representatives may also receive an annual, discretionary incentive award that is determined based on achievement of specific individual and team-based performance goals, including, but not limited to, full year sales production. This incentive award may be granted in the form of restricted stock or restricted stock units that vest over time. While this type of award is discretionary, it creates a financial incentive to make recommendations generally. In addition, certain Representatives who serve in positions with supervisory responsibility over other Representatives may receive annual discretionary compensation based on a variety of factors, such as achievement of overall corporate/business unit and individual performance goals, including consideration of the performance of the Representatives they supervise. While this type of award is discretionary, it creates a financial incentive for the supervising Representative to encourage other Advisors to make recommendations generally since this can potentially increase the total compensation of the supervisor. 26  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 While the Representatives may have the financial incentives described above, it is our fiduciary duty (and the duty of our Representatives) to make recommendations about the Program that are in a Client’s best interest. We maintain policies, procedures and supervisory controls designed to meet this duty to Clients. Item 5. Account Requirements and Types of Clients Participation in the Program; Minimum Investments and Additional Deposits The minimum initial investment required to participate in the Mutual Fund Series is $25,000, except that, with respect to Clients who select an Asset Allocation Plan that is limited to US equity Asset Classes only, the minimum initial investment is $75,000. The minimum initial investment is $100,000 to participate in the Customized Investment Series, $300,000 to participate in the national portfolios of the Municipal Bond Series, and $500,000 to participate in the state specific portfolios of the Municipal Bond Series. With respect to the Mutual Fund Series only, the Client may satisfy the required minimum initial investment by making a deposit in the form of a check, wire transfer or electronic check (no cash or securities will be accepted). In addition, the Client may transfer in shares of any Fund that is included in the Series at that time. Such shares will be subject to conversion if they are of a share class not offered in the Series at that time. Investment of the Client’s Program Account will commence only upon completion of all required share class conversions. No other securities will be accepted. With respect to the Customized Investment Series (excluding the Personal Bond Strategy) and the Municipal Bond Series , the Client initially may satisfy the minimum initial investment by making a deposit in the form of a check, wire transfer or electronic check (no cash will be accepted) and/or a deposit in the form of securities deemed acceptable to the Portfolio Manager (at the Portfolio Manager’s sole discretion) that have a combined market value at the time of deposit equal to or greater than the required minimum initial investment described above. Personal Bond Strategy Program Accounts may only be funded by making a deposit in the form of a check, bank wire or electronic check. Except with respect to the Personal Bond Strategy, for which no minimum asset maintenance level will apply, separate and apart from the minimum initial investment amounts described above, BNYSC (with respect to the Mutual Fund Series) or a Portfolio Manager (with respect to the Customized Investment Series or Municipal Bond Series) may, at their discretion, establish a minimum asset maintenance level to facilitate effective ongoing implementation of the strategy 27  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 chosen by the Client. In the event that market fluctuations or Client withdrawals cause the asset value of a Program Account to fall below the required minimum maintenance level, BNYSC or the Portfolio Manager, as applicable, may, at their discretion, require that subsequent deposits be made by the Client to restore the asset value of the Program Account to the required minimum maintenance level. If the Client does not take appropriate action to satisfy the required minimum asset level after being requested to do so, then BNYSC or the Portfolio Manager, as applicable, may terminate its agreement with the Client and close the Program Account, subject to the provisions described above under the Termination section of this Brochure. After opening the Program Account, the Client may deposit additional money into the Program Account at any time, subject to a minimum amount of $1,000 per deposit. For the Mutual Fund Series there is a $1,000 trade minimum for subsequent deposits and a $100 trade minimum for scheduled rebalances. BNYSC will accept subsequent deposits for a Program Account only in the form of checks, bank wires and electronic checks. No cash will be accepted; however, with respect to the Customized Investment Series (excluding the Personal Bond Strategy) and the Municipal Bond Series only, the Client may deposit acceptable securities rather than cash if the Portfolio Manager expressly allows the Client to do so. BNYSC will automatically invest at the end of each day any uninvested cash balance in the Program Account into the selected Sweep Fund. With respect to the Mutual Fund Series, if a subsequent deposit raises the total value of Program Account assets to a level that permits investment in a larger number of Funds per Asset Class, the Client may instruct BNYSC to invest the assets into additional Funds in such Asset Class. In the absence of such instructions, BNYSC will invest the additional assets in accordance with the Asset Allocation Plan without increasing the number of selected Funds. All subsequent deposits are subject to a $1,000 trade minimum, except that, with respect to Personal Bond Strategy Program Accounts, the Portfolio Manager may in its discretion accumulate additional deposits in the Sweep Fund pending identification of a desired incremental investment on behalf of the Client’s Program Account. Types of Clients BNYSC offers the Program to individuals and other clients (each a “Client,” or collectively, the “Clients”) that may include trusts, estates, charitable organizations, IRAs, corporations, partnerships or other business or governmental entities. 28  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Except as otherwise provided for under the “In General” section of Item 4, above, the Program will not accept as a Client a retirement or other employee benefit plan that is subject to ERISA nor any other type of retirement account. Program Account assets will be invested without regard to potential tax consequences. BNYSC does not provide any tax advice. Purchases and sales of securities may have tax consequences that the Client should discuss with an independent tax professional. There can be no assurance that the Client’s investment objectives can be achieved by this Program or by any other investment strategy. Please also refer to the “In General” section in Item 4 of this Brochure. Item 6. Portfolio Manager Selection and Evaluation Selection and Evaluation In selecting and evaluating Portfolio Managers (other than BNYSC) to be offered through the Customized Investment Series and the Municipal Bond Series, BNYSC utilizes various quantitative and/or qualitative measures, such as (but not limited to) centralized, formalized due diligence metrics and reviews, to identify a group of Portfolio Managers characterized by consistent management style and long-term returns for their relevant strategies. Portfolio Managers may initially be classified into Asset Classes according to their investment objectives or guidelines, performance behavior, investment adviser style and actual portfolio holdings. Once assigned to Asset Classes, as applicable, the Portfolio Managers are evaluated on the basis of their overall returns, taking into consideration the level of risk experienced by each Portfolio Manager, the investment discipline of the Portfolio Manager, and the consistency of the Portfolio Manager’s performance. BNYSC continually monitors and evaluates the performance of the Portfolio Managers offered through the Program. Based on this ongoing review and evaluation, BNYSC may add to or remove from the Program any Asset Class or Portfolio Manager or change the Asset Class category of any Portfolio Manager in the Program. A Portfolio Manager may also decide to discontinue its participation in the Program. 29  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 BNYSC may provide descriptive profiles of the Portfolio Managers available in the Program that include past performance information. While BNYSC believes such information is accurate, BNYSC does not independently verify or guarantee such information. Please note that BNYSC cannot assure you that any past performance information provided has been calculated on a uniform or consistent basis. The prior performance of a Portfolio Manager available in the Program may not be indicative of the Portfolio Manager’s future results. From time to time, the Client may instruct BNYSC to review the Client’s overall Program investments or Portfolio Manager selection for potential revision. One or more of the following factors may cause the Client to instruct BNYSC to conduct such a review: (i) a change in the Client’s investment objectives or financial status as identified in discussion between the Client and a Representative and as disclosed in writing to BNYSC through a revised Questionnaire, or (ii) a change in the Funds and/or Portfolio Managers that are available through the Program. In performing services and developing recommendations for Clients, BNYSC may utilize information provided by BNYIA as well as other third parties to, among other things, evaluate, monitor and assign Portfolio Managers to particular Asset Classes, and make decisions regarding which Portfolio Managers will be included in the Program. BNYSC, of course, remains responsible to the Client for all Program services provided. With respect to Portfolio Managers of Separate Accounts in which Clients may be invested through the Customized Investment Series, the Municipal Bond Series and/or the Combined Series, BNYSC’s evaluation will include review of the efficacy of certain of the Portfolio Managers’ trading practices, such as the application of their best execution or similar procedures. With respect to the Delegated Subadvisers that BNYSC may retain in its role as a Customized Investment Series Portfolio Manager, BNYSC will perform the same selection and evaluation processes as described above. With respect to BNYSC’s own participation as a Customized Investment Series Portfolio Manager, BNYSC is not subject to this selection and ongoing evaluation process; however, BNYSC has implemented a series of policies, procedures and supervisory controls to provide oversight of its investment and business activities, including to ensure that in its role as Portfolio Manager, BNYSC provides Clients with investment advisory services that are consistent with its duties as a registered investment adviser. 30  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 BNYSC and Affiliates as Portfolio Managers/Delegated Subadvisers We may serve as a Portfolio Manager in the Customized Investment Series and, in that capacity, retain Delegated Subadvisers. We may also utilize our affiliates as Portfolio Managers in the Program. Such arrangements create conflicts of interest because we have an incentive to direct Clients to Program Accounts for which we or our affiliate is the Portfolio Manager or Delegated Subadviser in order to generate additional fees for us or our affiliates rather than on the basis of expertise, performance or the Client’s needs. We address this conflict for affiliated Portfolio Managers and Delegated Subadvisers by utilizing the same selection and ongoing evaluation processes for affiliates as for non-affiliates described above in Selection and Evaluation and by monitoring Program Accounts in the same manner, regardless of whether the Portfolio Manager or Delegated Subadviser is an affiliate. We address this conflict when BNYSC is the Portfolio Manager by following the policies, procedures and supervisory controls described above in Selection and Evaluation. Our affiliated Portfolio Managers and Delegated Subadvisers may have an incentive to favor other accounts they manage directly by, for example, directing their best investment ideas to those accounts or allocating, aggregating or sequencing trades in favor of such accounts, to the disadvantage of our client accounts. They also may have an incentive to dedicate more time and attention to their direct client accounts and to give them better execution and brokerage commissions than our client accounts. They address these conflicts by establishing policies and procedures to treat all of their clients (including our clients) fairly. Before selecting an affiliate as a Portfolio Manager or Delegated Subadviser, we evaluate the adequacy of our affiliate’s policies, procedures and internal controls. We also monitor our affiliate’s compliance with those policies and procedures on an ongoing basis. Currently, Insight acts as the Portfolio Manager of the Municipal Bond Series and is the Portfolio Manager of the Personal Bond Strategy within the Customized Investment Series. Insight also manages certain BNY Funds in a sub-advisory capacity and is subject to investment, operational and compliance oversight by BNYSC’s direct parent, BNYIA. Similarly, our affiliate Newton currently acts as a Delegated Subadviser to BNYSC in connection with BNYSC’s role as a Customized Investment Series Portfolio Manager. Newton and its affiliated companies also subadvise certain BNY Funds and are likewise subject to investment, operational and compliance oversight by BNYIA. 31  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Advisory Business In addition to the investment advisory services provided by BNYSC in connection with the Program, which are described in this Brochure, BNYSC provides other investment advisory services, including, but not limited to, sub-advising separate account portfolios or providing model portfolios in wrap programs sponsored by banks, broker-dealers and other financial institutions. Please consult our Form ADV Part 2A (Firm Brochure”) for more information about the investment advisory and other services that BNYSC provides outside of the Program. Performance-Based Fees and Side-By-Side Management We do not enter into performance-based fee arrangements with any of our clients, including Clients of the Customized Investment Series where we act as a Portfolio Manager and retain Delegated Subadvisers. However, our Delegated Subadvisers may enter into performance-based fee arrangements with their own clients. For more information about such arrangements, including how the performance fees are calculated, please see the applicable Delegated Subadviser’s Firm Brochure, available at www.adviserinfo.sec.gov. “Side-by-side management” refers to the simultaneous management of multiple types of client accounts/investment products. For example, we or our Delegated Subadvisers may simultaneously manage separate accounts, managed accounts and pooled investment vehicles for our respective clients. Our respective clients have a variety of investment objectives, policies, strategies, limitations and restrictions. Our affiliates likewise manage a variety of separate accounts, managed accounts, and pooled investment vehicles. Side-by-side management gives rise to a variety of potential and actual conflicts of interest for us, our employees and our supervised persons. Below we discuss the conflicts that we and our employees and supervised persons face when engaging in side-by-side management and how we deal with them. Note that certain of our affiliated Delegated Subadvisers’ employees are also officers of one or more BNY affiliates (“dual officers”). These dual officers undertake administrative or investment management duties for the affiliates of which they are officers. When our affiliates concurrently manage client accounts/ investment products, and particularly when dual officers are involved, this presents the same conflicts as described below. To address these conflicts of interest, we manage our accounts consistent with applicable law, and we and our Delegated Subadvisers follow procedures that are reasonably designed to treat our clients fairly and to prevent any client or group of clients from being systematically favored or 32  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 disadvantaged. For example, we and our Delegated Subadvisers have trading policies and procedures, such as trade allocation and best execution procedures, which are designed and implemented to help ensure that all clients are treated fairly and equally, and to prevent these conflicts from influencing the allocation of investment opportunities between and among clients. Please see Item 12 of our Delegated Subadvisers’ Firm Brochures for more information. Conflicts of Interest Relating to Accounts with Different Strategies We and our Delegated Subadvisers manage numerous accounts with a variety of strategies, which presents conflicts of interest. For example, a long/short position in two client accounts simultaneously can result in a loss to one client based on a decision to take a gain in the other. Taking concurrent conflicting positions in certain derivative instruments can likewise cause a loss to one client and a gain to another. Conflicts of Interest Relating to the Management of Multiple Client Accounts We and our affiliates perform investment advisory services for various clients. In many instances, we give advice and take action in the performance of our duties with respect to certain of our clients which differs from the advice given, or the timing or nature of action taken, with respect to other clients. We have no obligation to purchase or sell for a client any security or other property which we purchase or sell for our own account or for the account of any other client if it is undesirable or impracticable to take such action. Conflicts of Interest Relating to Investment in Affiliated Accounts To the extent permissible under applicable law, we invest some or all of our corporate temporary investments in money market accounts advised or managed by a BNY affiliate. We have an incentive to allocate our own investments to these types of affiliated accounts in order to generate additional fees for us or our affiliates. Conflicts of Interest Relating to “Proprietary Accounts” We, our Delegated Subadvisers, and our existing and future employees from time to time manage and/or invest in products managed by BNYSC and its affiliates (“Proprietary Accounts”). Investment by BNYSC, our affiliates, or our employees in Proprietary Accounts creates conflicts of interest. We have an incentive to favor these Proprietary Accounts by, for example, directing our best investment ideas to these accounts or allocating, aggregating or sequencing trades in favor of such accounts, to the disadvantage of other accounts. We also have an incentive to dedicate 33  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 more time and attention to our Proprietary Accounts and to give them better execution and brokerage commissions than our other client accounts. Other Conflicts of Interest As noted previously, we and our affiliates manage numerous accounts with a variety of interests. This necessarily creates conflicts of interest for us. For example, we or an affiliate may cause multiple accounts to invest in the same investment. Such accounts could have conflicting interests and objectives in connection with such investment, including differing views on the operations or activities of the portfolio company, the targeted returns for the transaction and the timeframe for and method of exiting the investment. Conflicts also arise in cases where multiple BNYSC and/or affiliate client accounts are invested in different parts of an issuer’s capital structure. For example, one of our client accounts could acquire debt obligations of a company while an affiliate’s client account acquires an equity investment. In negotiating the terms and conditions of any such investments, we could conclude that the interests of the debt-holding client accounts and the equity holding client accounts conflict. If that issuer encounters financial problems, decisions over the terms of any workout could raise conflicts of interest (including, for example, conflicts over proposed waivers and amendments to debt covenants). For example, debt holding accounts may be better served by a liquidation of an issuer in which it could be paid in full, whereas equity holding accounts might prefer a reorganization of the issuer that would have the potential to retain value for the equity holders. As another example, holders of an issuer’s senior securities could potentially direct cash flows away from junior security holders, and both the junior and senior security holders could be client accounts of one or more of our affiliates. It is important to note that when we act as your broker-dealer, we are not held to the same legal standards that apply when we are providing investment advisory services. Methods of Analysis, Investment Strategies and Risk of Loss Each investment strategy offered in the Program invests in a variety of securities and employs a number of investment techniques that involve certain risks. Investing in securities involves risk of loss that you should be prepared to bear. With respect to the Funds offered in the Mutual Fund Series, the applicable investment strategies and processes and associated risks are described in each Fund’s Prospectus and/or Statement of Additional Information, which are available at www.bny.com/investments (for BNY Funds) or by calling our Service Desk at 1-800-843-5466 (for both BNY Funds and Third-Party Funds). 34  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 With respect to the Separate Account strategies (including those for which BNYSC acts as Portfolio Manager) offered in the Customized Investment Series and Municipal Bond Series, the applicable investment strategies and processes and generally associated risks are described in Item 8 of each Portfolio Manager’s or Delegated Subadviser’s Firm Brochure, available at www.adviserinfo.sec.gov. Please also refer to Item 4 of this Brochure for more detailed information concerning the Separate Account strategies we offer. As indicated in Item 4 (and within the limitations described in Item 4): i) the Municipal Bond Series strategy we offer corresponds to the Municipal Bond Fixed Income strategy described in Insight’s Firm Brochure; ii) the Sarofim equity strategy we offer in the Customized Investment Series corresponds to the Large Capitalization Equity Product described in Sarofim’s Firm Brochure; iii) the Newton strategy we offer in the Customized Investment Series corresponds to the Global Equity Income strategy described in Newton’s Firm Brochure; and the Personal Bond Strategy we offer in the Customized Investment Series corresponds to the Personal Bond Strategy described in Insight’s Firm Brochure. In addition, the table below sets forth information concerning the material risks involved with each Separate Account strategy. An “X” in the table indicates that the strategy involves the corresponding risk. An empty box indicates that the strategy does not involve the corresponding risk in a material way. However, an empty box does not guarantee that the strategy will not be subject to the corresponding risk. The risks set forth below represent a general summary of the material risks involved in the Separate Account strategies we offer. Please also refer to Appendix A of this Brochure for further descriptions of these material risks. 35  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Municipal Bond Series Customized Investment Series Customized Investment Series Risk Type Newton Global Equity Income ADR Strategy Sarofim Large Cap Equity Strategy Insight Municipal Bond Fixed Income Strategy Customized Investment Series Insight Personal Bond Strategy X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X ADR / GDR Risk Allocation Risk Banking Industry Risk Call Risk Clearance and Settlement Risk Concentration Risk Counterparty Risk Country, Industry and Market Sector Risk Credit Risk Cybersecurity Risk Disease/Epidemics Risk Emerging Market Risk Equity Securities Risk ESG Investment Risk ETF Risk Foreign Currency Risk Foreign Investment Risk General Risks Growth and Value Stock Risk Healthcare Sector Risk Inflation Risk Interest Rate Risk Investment Strategy Risk 36  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Municipal Bond Series Customized Investment Series Customized Investment Series Risk Type Newton Global Equity Income ADR Strategy Sarofim Large Cap Equity Strategy Insight Municipal Bond Fixed Income Strategy X Customized Investment Series Insight Personal Bond Strategy X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Issuer Risk Large Cap Stock Risk Liquidity Risk Market Risk Municipal Lease Risk Municipal Securities Risk Non-Diversification Risk Portfolio Turnover Risk Preferred Stock Risk Pre-Payment and Extension Risk Real Estate Sector Risk Small and Midsize Company Risk State-Specific Risk Stock Investing Risk Stock Selection Risk Style Risk Systemic Risk Tax Risk Technology Company Risk Value Stock Risk Item 7. Client Information Provided to Portfolio Managers Representatives obtain certain Client personal and financial information that is either required or necessary to communicate to a Portfolio Manager. This may include the Client profile information including Client name, address, date of birth, and other profile data that is obtained upon Program 37  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Account opening. Also, Client suitability and risk tolerance information will be obtained upon Program Account opening and made available to the applicable Portfolio Managers at that time. Any portfolio investment restrictions specified by the Client on the Questionnaire or Investment Guidelines are also communicated to the applicable Portfolio Managers upon Program Account opening, as well as Client’s Program Account holdings and balances. As updates to a Client’s profile information, suitability, risk tolerance or portfolio investment restrictions are made on BNYSC’s records, such updates will similarly be transmitted to the applicable Portfolio Managers accordingly. All Program Account holding and balance information is made available to the relevant Portfolio Managers daily. Item 8. Client Contact with Portfolio Managers Representatives are readily available to Clients on an ongoing basis. Representatives will either coordinate Client contact or consult directly with the applicable Portfolio Manager. Item 9. Additional Information Disciplinary Information On August 14, 2024, the Securities and Exchange Commission (“SEC”) entered a settled administrative order against BNY Mellon Securities Corporation (“BNYSC”) and Pershing LLC (“Pershing”) that found that BNYSC and Pershing willfully violated Section 17(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) and Rule 17a-4(b) thereunder. The order also found that BNYSC and Pershing failed to reasonably supervise their employees within the meaning of Exchange Act Section 15(b)(4)(E). Specifically, the order found that from at least January 2020 to August 14, 2024, BNYSC and Pershing personnel sent and received text message communications on platforms that were not approved for business purposes, many of which were not preserved by BNYSC or Pershing. In numerous instances, BNYSC and Pershing supervisors themselves communicated using these unapproved communication platforms. In determining to accept BNYSC’s and Pershing’s offers of settlement, the SEC considered remedial acts promptly undertaken by BNYSC and Pershing and cooperation afforded the Commission staff. In connection with the order, BNYSC and Pershing admitted the facts alleged in the order and acknowledged that their conduct violated the federal securities laws. Both entities were (i) censured; (ii) ordered to cease and desist from committing or causing any violations and any future violations of Exchange Act Section 17(a) and Rule 17a-4 thereunder; (iii) ordered to pay a penalty 38  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 of $40 million; and (iv) ordered to comply with certain undertakings, including the retention of an independent compliance consultant to review their policies and procedures related to electronic communications. Other Financial Industry Activities and Affiliations BNYSC is registered with the SEC as both an investment adviser and broker-dealer; is a member of FINRA; and is registered with the NFA as an introducing broker. BNY is a Global Financial Services Company BNY is a global financial services company providing a comprehensive array of financial services (including asset management, wealth management, asset servicing, clearing and execution services, issuer services and treasury services) through a world-wide client focused team that enables institutions and individuals to manage and service their financial assets. BNY Investments is the umbrella designation for BNY’s affiliated investment management firms and global distribution companies, and is responsible, through various subsidiaries, for U.S. and non-U.S. retail, intermediary and institutional distribution of investment management and related services. We enter into transactions with unaffiliated counterparties or third-party service providers who can be using affiliates of ours to execute such transactions. Additionally, when we effect transactions in American Depositary Receipts (“ADRs”) or other securities, the involved issuers or their service providers could be using affiliates for support services. Services provided by our affiliates to such unaffiliated counterparties, third party service providers and/or issuers include, for example, clearance of trades, purchases or sales of securities, serving as depositary bank to issuers of ADRs, providing foreign exchange services in connection with dividends and other distributions from foreign issuers to owners of ADRs, or other transactions not contemplated by us. Although one of our affiliates receives compensation for engaging in these transactions and/or providing services, the decision to use or not use an affiliate of ours is made by the unaffiliated counterparty, third party service provider or issuer. Further, we will likely be unaware that the affiliate is being used to enter into such transaction or service. BNY and/or its other affiliates may gather data from BNYSC about our investment activities, including information about holdings within client portfolios, which is required for regulatory filings to be made by BNYSC or BNY or other affiliates (e.g., reporting beneficial ownership of 39  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 equity securities) or for other compliance, legal or risk management purposes, pursuant to policies and procedures of BNYSC, BNY or other affiliates. This data is deemed confidential, and procedures are followed to help ensure that any information is utilized solely for the purposes intended. BNY’s Status as a Bank Holding Company BNY and its direct and indirect subsidiaries, including us, are subject to (1) certain U.S. banking laws, including the Bank Holding Company Act of 1956, as amended (the “BHCA”), (2) regulation and supervision by the Board of Governors of the Federal Reserve System (the “Federal Reserve”) and (3) the provisions of, and regulations under, the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The BHCA, the Dodd-Frank Act, other applicable banking laws and the regulatory agencies, including the Federal Reserve, which interpret and administer these laws may restrict (1) the transactions and relationships among BNY, its affiliates (including us) and our clients and (2) our investments, transactions and operations. For example, the BHCA regulations applicable to BNY and us may restrict our ability to make certain investments or the size of certain investments, impose a maximum holding period on some or all of our investments and restrict our ability to participate in the management and operations of the companies in which we invest. In addition, certain BHCA regulations may require aggregation of the positions owned, held or controlled by related entities. Thus, in certain circumstances, positions held by BNY and its affiliates (including us) for client and proprietary accounts may need to be aggregated and may be subject to a limitation on the amount of a position that may be held. These limitations may have an adverse effect on our ability to manage clients’ investment portfolios. For example, depending on the percentage of a company that we and our affiliates (in the aggregate) control at any given time, the limits may (1) restrict our ability to invest in that company for certain clients or (2) require us to sell certain client holdings of that company when it may be undesirable to take such action. Additionally, in the future BNY may, in its sole discretion and without notice, engage in activities affecting us in order to comply with the BHCA, the Dodd-Frank Act or other legal requirements applicable to (or reduce or eliminate the impact or applicability of any bank regulatory or other restrictions on) us and accounts that we and our affiliates manage. The Volcker Rule The Dodd-Frank Act includes provisions that have become known as the “Volcker Rule,” which restrict bank holding companies, such as BNY and its subsidiaries (including us) from (i) 40  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 sponsoring or investing in a private equity fund, hedge fund or otherwise “covered fund”, with the exception, in some instances, of maintaining a de minimis investment, subject to certain other conditions and/or exceptions, (ii) engaging in proprietary trading, and (iii) entering into certain transactions involving with affiliated covered funds. The Volcker Rule generally prohibits certain transactions involving an extension of credit or other type of transaction as set forth in applicable regulations between BNY and its affiliates, on the one hand, and “covered funds” managed or sponsored by BNY and/or its affiliates (including us), on the other hand. BNY affiliates provide securities clearance and settlement services to broker- dealers on a global basis. The operational mechanics of the securities clearance and settlement process can result in an incidental or unintended intraday extension of credit between the securities clearance firm and a “covered fund.” As a result, we may be restricted from using a BNY affiliate as custodian or in other capacities for covered funds as well as be restricted in executing transactions for certain funds through broker-dealers that utilize a BNY affiliate as their securities clearance firm. Such restrictions could limit the covered fund’s selection of service providers and prevent us from executing transactions through broker-dealers we would otherwise use in fulfilling our duty to seek best execution. The Volcker Rule was amended in 2020 to include exemptions that permit a broader range of transactions between BNY and its affiliates and relevant covered funds. BNY intends to rely on such exemptions to the extent it deems appropriate. Affiliated Custodian Our affiliate, Pershing LLC, provides execution and custodial services to certain of our clients in the Program. Clients in the Program do not pay additional fees for custodial services. In addition, other of our clients may select other affiliates, including BNY, to provide custodial services. Those clients may pay additional fees to BNY or other affiliates for those services. Other Relationships In addition, BNY personnel, including certain BNYSC employees, may have board, advisory or other relationships with affiliated and unaffiliated issuers, distributors, consultants and others. To the extent permitted by applicable law, BNY and its affiliates, including BNYSC and our personnel, may make charitable contributions to institutions, including those that have relationships with investors or personnel of investors. 41  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 BNY maintains, and we have adopted, a Code of Conduct that addresses these types of relationships and the potential conflicts of interest they may present, including the provision and receipt of gifts and entertainment. BNY, among several other leading investment management firms, has a minority equity interest in Kezar Markets, LLC (f/k/a Titan Parent Company, LLC), which owns Kezar Trading, LLC (f/k/a Luminex Trading and Analytics LLC) (“Kezar”), a registered broker-dealer under the Exchange Act that operates two alternative trading systems for securities (the “Alternative Trading Systems”). Transactions for clients for which we serve as adviser or sub-adviser may be executed through the Alternative Trading Systems. We and BNY disclaim that either is an affiliate of Kezar. Affiliated Broker-Dealers and Investment Advisers BNYSC is affiliated with a significant number of advisers and broker/dealers. Please see our Form ADV, Part IA - Schedule D, Section 7.A for a list of our affiliated advisers and broker-dealers. Several of our investment adviser affiliates have, collectively, a significant number of investment- related private funds for which a related person serves as sponsor, general partner or managing member (or equivalent), respectively. Please refer to the Form ADV, Part IA – Schedule D, Section 7.B for each of our affiliated investment advisers for information regarding such firms’ private funds (if applicable) and such firms’ Form ADV, Part IA – Schedule D, Section 7.A for information regarding related persons that serve in a sponsor, general partner or managing member capacity (if applicable). Except with respect our affiliate, Pershing LLC, who provides certain execution, clearing and custodial services as described above with respect to the Program, we limit our selection of brokers for effecting purchases or sales of securities for client accounts to unaffiliated brokers only. BNYSC has broker selection policies in place that require our selection of a broker-dealer to be consistent with our duties of best execution, and subject to any client and regulatory proscriptions. Please also refer to Item 12 of the relevant Portfolio Manager’s or Delegated Subadviser’s Brochure (including, when BNYSC is acting as Portfolio Manager, BNYSC’s Brochure) for more information. BNYSC may be prohibited or limited from effecting transactions for you because of rules in the marketplace, foreign laws or our own policies and procedures. In certain cases, we may face further limitations because of aggregation issues due to our relationship with affiliated investment 42  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 management firms. Please also refer to Item 12 of the relevant Portfolio Manager’s or Delegated Subadviser’s Brochure (including, when BNYSC is acting as Portfolio Manager, BNYSC’s Brochure) for a discussion of trade aggregation issues. Affiliated Banking Institutions BNY engages in trust and investment business through various banking institutions, including the Bank and BNY Mellon, National Association. These affiliated banking institutions may provide certain services to us, such as recordkeeping, accounting, marketing services, and/or referrals of clients. We may provide the affiliated banking institutions with sales and marketing materials regarding our investment management services that may be distributed under the name of certain marketing “umbrella designations” such as BNY, BNY Wealth, BNY Investments and BNY EMEA. Certain clients may have established custodial or sub-custodial arrangements with the Bank and other financial institutions that are affiliated with us. Furthermore, the Bank and other financial institutions that are affiliated with us may provide services (such as trustee, custodial or administrative services) to issuers of securities. Because of their affiliation with us, our ability to purchase securities of such issuers and to take advantage of certain market opportunities may be subject to certain restrictions and in some cases, prohibited. Other Business Activities of BNYSC and its Affiliates As a BNY company, BNYSC may, from time to time, use the research staff, products, services and libraries of its affiliates and may consult with their portfolio managers. BNYSC’s affiliates are engaged in a broad range of financial services activities in the United States and abroad, and include banks, trust companies, broker-dealers, investment advisers, stock transfer agents, commodity pool operators and commodity trading advisers, municipal securities dealers and pension consultants, among other businesses. Certain of BNYSC’s affiliates serve as investment advisers of and provide other services to mutual funds and other investment companies, including the BNY Funds. Certain of these BNY Funds are used as Sweep Funds in the Program. BNYSC’s arrangements with these funds and their service providers are material to BNYSC’s business as an investment adviser. In addition, from time to time, BNYSC and certain of its affiliates may refer investment advisory clients or other business to each other, as permitted by applicable law and rules, and these arrangements may become material to BNYSC’s investment advisory business. 43  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 The Client should be aware that BNYSC and its affiliated entities maintain various types of financial and other relationships with financial or other institutions, entities and persons. BNYSC, and BNYSC-affiliated Portfolio Managers, are available to the Client through the Program and may be recommended to the Client by Representatives in connection with the implementation of an Asset Allocation Plan and/or in connection with Separate Account recommendations. BNYSC or an affiliate will receive fees for the services they provide to the BNYSC-affiliated Separate Accounts. BNYSC or its affiliates also may provide services to and receive fees from third party Portfolio Managers that participate in the Program. Services provided by BNYSC and its affiliates for the BNYSC affiliated Separate Accounts include investment advice, administration, distribution and transfer agency services. For example, BNYSC uses only money market funds that are managed, administered or distributed by its affiliates as Sweep Funds. The compensation paid to BNYSC or an affiliate for these services is described in general terms in the Sweep Fund’s prospectus and statement of additional information. If the Client’s participation in the Program is terminated, but the Client still maintains a brokerage account with BNYSC, the particular Sweep Fund(s) utilized by the Client through the Program may no longer be available to the Client or the shares held by the Client in specially created series of such Sweep Funds may be converted into shares of another series of those Funds. The Client will bear his, her or its proportionate share of fees applicable to such other series, which may be higher than the fees that apply to the series available through the Program. Services provided by BNYSC, BNYIA and their affiliates for the BNY Funds include investment advice, administration, distribution and transfer agency services. Although it is not possible to determine accurately the amount of time that BNYSC devotes to any one of the wide ranges of financial activities in which it is engaged, BNYSC’s principal business is the sale of mutual funds advised by its affiliates. BNYSC and its Representatives also may buy or sell for themselves securities that they recommend to the Client for purchase and sale. They also may give advice and take action in the performance of their duties for the Client that differ from advice given, or the timing and nature of action taken, with respect to other Clients or for themselves. Personal trading by BNYSC employees must be conducted in compliance with all applicable laws and the Confidential Information and Personal Securities Trading Policy that governs BNY and its subsidiaries, including BNYSC. 44  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Representatives may recommend the Program to current or prospective Clients. All or a portion of the Advisory Fees charged by BNYSC may be paid to Representatives for introducing Clients to the Program or for providing supplemental and other Client-related services. These payments may be made for the duration of each Client’s participation in the Program. The amount of compensation received by Representatives with respect to the Clients who participate in the Program may be more than that received if the Clients participated in other investment advisory programs or paid separately for the investment advice, brokerage and other services provided as part of the Program. As a result, Representatives have a financial incentive to recommend the Program and to have you remain invested. Clients participating in the Program may have brokerage or other investment advisory accounts with BNYSC or its affiliates, and may pay commissions, sales charges or other fees to BNYSC or its affiliates for services provided to these other accounts. Where permitted by applicable laws and rules, BNYSC or an affiliate may engage in principal trades or agency cross transactions with Clients for accounts that are not part of the Program; however, it is BNYSC’s current policy not to engage in principal transactions or agency cross transactions. BNYSC may from time to time enter into solicitation agreements under which it receives cash compensation for referring Clients to other investment advisers, including one or more of its affiliates, or arrangements with other investment advisers whereby BNYSC agrees to provide certain services to clients of the investment adviser, in exchange for a portion of the investment advisory fee paid to the investment advisers by these clients. These arrangements will be conducted in accordance with the applicable rules under the Advisers Act. BNYSC or its affiliates may from time to time enter into joint marketing activities with investment managers or sponsors of Funds that participate in the Program. These managers or sponsors may pay a portion, or all, of the cost of the activities, including reimbursement to BNYSC or its affiliates for out-of-pocket expenses or may pay fees to BNYSC based on Client assets held in the Program. BNYSC has a business relationship with Sarofim pursuant to which we may be retained and compensated by Sarofim to: (i) provide administrative and support services in connection with third party wrap programs where Sarofim directly contracts with the third-party wrap program sponsors to provide investment advisory services and (ii) solicit potential wrap program sponsors to offer the strategies and/or models of Sarofim as part of these wrap programs. These arrangements, in turn, create a potential conflict because to the extent we are successful in 45  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 soliciting a wrap program sponsor to offer Sarofim’s strategies and/or models, then we will not only receive a solicitation fee, but will also be compensated for providing the resulting administrative services. Code of Ethics, Participation or Interest in Client Transactions, Personal Trading We have adopted a Code of Ethics that is made up of two parts: 1. BNY Code of Conduct (the “BNY Code”); and 2. BNY Personal Securities Trading Policy (the “PSTP”). The BNY Code of Conduct sets expectations for business conduct for employees and provides guidance on important legal and ethical issues. In addition, it clarifies the Firm’s responsibilities to clients, suppliers, government officials, competitors and the communities we serve. BNY’s Code of Conduct covers the following key principles: 1. Respecting Others: We are committed to fostering an inclusive workplace where talented people want to stay and develop their careers. Supporting a diverse, engaged workforce allows us to be successful in building trust, empowering teams, serving our clients and outperforming our peers. We give equal employment opportunity to all individuals in compliance with legal requirements and because it’s the right thing to do. 2. Avoiding Conflicts: We make our business decisions free from conflicting outside influences. Our business decisions are based on our duty to BNY and our clients and are not driven by any personal interest or gain. We are to remain alert to any and all potential conflicts of interest and ensure that we identify, mitigate or eliminate any such conflicts. 3. Conducting Business: We secure business based on honest competition in the marketplace. This contributes to the success of our company, our clients and our shareholders. We compete in full compliance with all applicable laws and regulations. We support worldwide crime. efforts to combat financial corruption and financial 4. Working with Governments: We follow all requirements that apply to doing business with governments. We recognize that practices for dealing with private and government clients are different from a legal perspective. 46  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 5. Protecting Company Assets: We ensure all entries made in the company’s books and records are complete and accurate and comply with established accounting and record- keeping procedures. We maintain confidentiality of all forms of data and information entrusted to us and prevent the misuse of information belonging to the company or any client. 6. Supporting Our Communities: We take an active part in our communities around the world, both as individuals and as a company. Our long-term success is linked to the strength of the global economy and the strength of our industry. We are honest, fair and transparent in our interactions with our communities and the public at large. As a global financial institution, BNY and its subsidiaries (the “Firm”) are subject to certain laws and/or regulations governing the personal trading of securities. In order to ensure that all employees’ personal investments are conducted in compliance with the applicable rules and regulations and are free from conflicts of interest, the Company has established limitations on personal trading, as reflected in the PTSP. The PSTP sets forth procedures and limitations that govern the personal securities transactions of our employees in accounts held in their own names as well as accounts in which they have indirect ownership. We, and our related persons and employees, may, under certain circumstances and consistent with the PSTP, purchase or sell securities for their own accounts that we also recommend to clients. The PSTP imposes different requirements and limitations on employees based on the nature of their business activities. Each of our employees is classified as one of the following: 1. Investment/Public Employee (“IE”): IE is an employee who, in the normal conduct of his/her job responsibilities, is on the “public side” of the Information Barrier in accordance with BNY’s Information Barrier Policy and has access (or is likely to be perceived to have access) to nonpublic information regarding any advisory client’s purchase or sale of securities or nonpublic information regarding the portfolio holdings of any Proprietary Fund (defined as a fund sponsored, managed or subadvised by BNY or any of its affiliates), is involved in making securities recommendations to advisory clients, or has access to such recommendations before they are public. 2. Access Decision Maker (“ADM”): Generally, employees are considered to be ADM Employees if they are portfolio managers or research analysts and make or participate in recommendations or decisions regarding the purchase or sale of securities for mutual 47  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 funds or managed accounts. Portfolio managers of broad-based index funds and traders are not typically classified as ADM Employees. 3. Insider Risk Employee (“IR”): IR is an employee who in the normal course of business is likely to receive material non-public information regarding issuer clients. These employees are on the “private side” of the Information Barrier in accordance with BNY’s Information Barrier Policy. 4. Non-Classified Employee: Our employees are considered non-classified if they are not an IE, IR or ADM. PSTP Overview: 1. IE, ADM, and IR employees are subject to preclearance and personal securities reporting requirements, with respect to discretionary accounts in which they have direct or indirect ownership. 2. Transaction reporting is not required for non-discretionary accounts, transactions in exempt securities or certain other transactions that are not deemed to present any potential conflicts of interest. 3. Preclearance is not required for transactions involving certain exempt securities (such as ETFs and open-end investment company securities that are not Proprietary Funds or money market funds and short-term instruments, non-financial commodities; transactions in non-discretionary accounts (approved accounts over which the employee has no direct or indirect influence or control over the investment decision- making process); transactions done pursuant to automatic investment plans; and certain other transactions detailed in the PSTP which are either involuntary or deemed not to present any potential conflict of interest. 4. We have a “Preclearance Compliance Officer” who maintains a “restricted list” of companies whose securities are subject to trading restrictions. This list is used by the PTA System to determine whether or not to grant trading authorization. 5. The acquisition of any securities in a private placement requires prior written approval. 6. With respect to transactions involving BNY securities, all employees are also prohibited from engaging in short sales, purchases on margin, option transactions (other 48  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 than employee option plans), and short-term trading (i.e., purchasing and selling, or selling and purchasing BNY securities within any 60-calendar day period). 7. For IE, ADM, and IR employees, with respect to non-BNY securities, purchasing and selling, or selling and purchasing the same or equivalent security within 30 calendar days is prohibited, and any profits must be disgorged. 8. No covered employee should knowingly participate in or facilitate late trading, market timing or any other activity with respect to any fund in violation of applicable law or the provisions of such fund’s disclosure documents. A copy of our Code of Ethics will be provided upon request. Interest in Client Transactions Note that while each of the following types of transactions present conflicts of interest for us, as described below, we manage our accounts consistent with applicable law, and we follow procedures that are reasonably designed to treat our clients fairly and to prevent any client or group of clients from being systematically favored or disadvantaged. Clients should also review the Firm Brochure of the relevant Portfolio Manager or Delegated Subadviser which will contain additional information about that firm’s investment advisory services. Principal Transactions “Principal transactions” are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys any security from or sells any security to any client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated pooled investment vehicle and another client account. We do not engage in principal transactions. Cross Transactions We do not engage in cross transactions. 49  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Transactions in Same Securities We or our affiliates may invest in the same securities that we or our affiliates recommend to clients. When we or an affiliate currently holds for our own benefit the same securities as a client, we have a conflict of interest. For example, we or our affiliate could be seen as harming the performance of the client’s account for our own benefit if we short sell the securities in our own account while holding the same securities long in the client account, causing the market value of the securities to move lower. Interests in Recommended Securities/Products We or our affiliates may recommend securities to clients, or buy or sell securities for client accounts, at or about the same time that we or one of our affiliates buys or sells the same securities for our (or the affiliate’s) own account. This practice gives rise to a variety of conflicts of interest, particularly with respect to aggregating, allocating and sequencing securities being purchased on both our (or our affiliate’s) behalf and our clients’ behalf. For example, we have an incentive to cause a client or clients to participate in an offering because we desire to participate in the offering on our own behalf and would otherwise be unable to meet the minimum purchase requirements. Likewise, we have an incentive to cause our clients to participate in an offering to increase our overall allocation of securities in that offering, or to increase our ability to participate in future offerings by the same underwriter or issuer. On the other hand, we have an incentive to cause our clients to minimize their participation in an offering that has limited availability so that we do not have to share a proportionately greater amount of the offering to the client. Allocations of aggregated trades likewise raise a conflict of interest as we have an incentive to allocate securities that are expected to increase in value to ourselves. Further, a conflict of interest could arise if a transaction in our own account closely precedes a transaction in related securities in a client account, such as when a subsequent purchase by a client account increases the value of securities that were previously purchased for ourselves. Please also refer to Item 12 of the relevant Portfolio Manager’s or Delegated Subadviser’s Brochure (including, when BNYSC is acting as Portfolio Manager, BNYSC’s Brochure) for information about their brokerage and allocation policies and procedures. We or a related person may recommend the purchase of securities in certain private funds which BNYIA or our affiliates manage and/or for which BNYIA or our affiliate may serve as a partner, sole director or managing member or collective investment funds maintained by the Bank (which are managed by personnel of BNYIA or one of our affiliates in their roles as dual officers of the 50  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Bank and for which BNYIA or our affiliate, as applicable, receive a fee and the Bank may receive a custodial fee for custody services). BNY, or certain of its employees, or related persons, may currently invest in certain private funds or collective funds that also include client assets managed by BNY, BNYIA, or their affiliates, and they and such related persons will receive proportional returns associated with such investment. Additionally, our affiliates, as applicable, may receive an investment management fee in their capacity as investment adviser or sub-adviser and related persons (including affiliated broker-dealers) may receive certain amounts associated with placement agent fees, custodial fees, administrative fees, loads, or sales charges. Investments by Related Persons and Employees We and our existing and future employees, our board members, and our affiliates and their employees from time to time invest in products managed by us. We have developed policies and procedures to address any conflicts of interest created by such investment. We are part of a large diversified financial organization that includes banks and broker-dealers. As a result, it is possible that a related person may, as principal, purchase securities or sell securities for itself that we also recommend to clients. We do permit our employees to invest for their own account within the guidelines and restrictions of the Code of Ethics, as described above. For more information, please see “Interests in Recommended Securities/Products” with regard to purchases of securities in an offering where an affiliate acts as underwriter or a member of the underwriting syndicate. Agency Transactions Involving Affiliated Brokers Neither we nor any of our officers or directors, acting as broker or agent, effect securities transactions for compensation for any client. We are part of a large diversified financial organization that includes broker-dealers. As a result, it is possible that a related person, other than our officers and directors, may, as agent, effect securities transactions for our clients for compensation. Please also see Schedule D, Section 7A of our Form ADV Part 1 for a list of broker- dealers which are our affiliates. Review of Accounts Program Accounts and Asset Allocation Plans are reviewed regularly by the Manager of Trading and Service and the Director of Sales. Reviews are triggered by contributions to or withdrawals from the Program Accounts. In addition, quantitative reviews are conducted regularly to determine if asset allocation changes are needed. Also, reviews of each proposed new Client’s investment 51  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 objectives are conducted, and a determination is made of whether our investment strategy as selected by the Client could reasonably be expected to meet such Client’s objectives. We also monitor client investments at daily, quarterly and/or annual intervals, which frequency will vary based on the strategy you have chosen (i.e., Mutual Fund Series, Customized Investment Series or Municipal Bond Series). Representatives also review asset allocations and holdings on a periodic basis. Reviews of Program Accounts are also performed in connection with periodic rebalancing that is executed in accordance with a Client’s Asset Allocation Plan, where applicable. We review all proposed Program Accounts to determine whether the financial information of the Client and the investment objectives reflected by the Client are reasonable for equity, balanced or fixed income account management. We consider the Client’s age and net worth, the portion of Client’s investment portfolio proposed to be managed, and the Client’s stated objectives, risk tolerance and restrictions. Our Compliance Officers also ensure that our Delegated Subadvisors are authorized to do business in the jurisdiction where the Client resides. Clients should review the Firm Brochure of any firms acting as Portfolio Manager or Delegated Subadviser, which will contain additional information about those firms’ policies concerning the Review of Accounts. In cases where BNYSC, rather than a Delegated Subadvisor, is the Portfolio Manager, BNYSC’s Firm Brochure will contain the relevant information concerning the Review of Accounts. Nature and Frequency of Reports Except with respect to the Municipal Bond Series and Personal Bond Strategy Program Accounts, on a quarterly basis the Client will receive a written Quarterly Performance Report (“QPR”), which includes the deduction of any Advisory Fees, and provides a description and analysis of the composition and performance of the Program Account’s portfolio. Shares of each Fund in the Mutual Fund Series will be valued at their respective net asset values as reported by the applicable Fund on the last business day of each calendar quarter. The valuation of securities held in a Separate Account will be conducted by Pershing as custodian, utilizing independent pricing services where available, and reported on the Client’s QPR. The QPR will contain historical information and may not be relied on as predictive of future performance. With respect to Personal Bond Series Program Accounts, Insight will provide an individualized quarterly report to the Client’s Representative, comparing the actual cashflow experience of the Program Account versus the desired cashflow parameters as specified by the Client at the inception of the Program Account. 52  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 All Program Clients will receive written confirmations of all transactions made for the Program Account as required by law. Clients will also receive a periodic, written statement of Program Account activity no less than quarterly and monthly should investment activity occur during a particular month. Client Referrals and Other Compensation Our ultimate parent, BNY, has organized its lines of business into two primary groups: BNY Investments and Wealth and BNY Investment Services (collectively “Groups”). We are part of the BNY Investments and Wealth Group. A sales force has been created to focus on developing new customer relationships and developing and coordinating large complex existing customer relationships within those Groups. In certain circumstances, BNY Investments and Wealth sales representatives are paid fees for sales. The fees may be based on revenues and may be a one-time payment or paid out over a number of years. In particular, members of this sales force: (i) acting as representatives of BNYSC in our capacity as investment adviser, solicit prospective clients with respect to the institutional separate account products and strategies of our affiliates, including a Portfolio Manager or Delegated Subadviser and (ii) acting as registered representatives of BNYSC in our capacity as broker-dealer, sell alternative investment products (such as private funds) managed by our affiliates, including products managed by a Portfolio Manager or Delegated Subadviser. We receive compensation from these affiliates in connection with successful referrals or sales, respectively, typically as a percentage of the revenue received by the manager attributable to the client. We, in turn, compensate these salespeople from the compensation we receive. These arrangements create a conflict of interest for us in recommending an affiliated Portfolio Manager or Delegated Subadviser because we have a financial incentive to do business with these affiliates generally. We address this conflict by disclosing it to you and through oversight of the Portfolio Managers and Delegated Subadviser. However, we do not currently compensate any affiliates or third parties for referring clients to us, nor do we direct securities transactions to any broker-dealer in exchange for referral of investment management clients. 53  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Voting Client Securities With respect to client accounts for which we have investment discretion or are otherwise contractually required, we exercise the voting rights delegated to us by clients. Voting rights are most commonly exercised by casting votes by proxy at shareholder meetings on matters that have been submitted to shareholders for approval. Consistent with applicable rules under the Advisers Act, we have adopted and implemented written proxy voting policies and procedures (the “Proxy Policies”) that are reasonably designed: (1) to vote proxies, consistent with our fiduciary obligations, in the best interests of clients; and (2) to prevent conflicts of interest from influencing proxy voting decisions made on behalf of clients. We provide these proxy voting services as part of our investment management service to client accounts and do not separately charge a fee for this service. If presented with a proxy voting opportunity, we will seek to make voting decisions that are in the best interest of the client and have adopted detailed, pre-determined, written proxy voting guidelines for specific types of proposals and matters commonly submitted to shareholders by U.S. and non-U.S. companies (collectively, the “Voting Guidelines”). These Voting Guidelines are designed to assist with voting decisions which over time seek to maximize the economic value of the securities of companies held in client accounts (viewed collectively and not individually) as determined in our discretion. We believe that this approach is consistent with our fiduciary obligations and with the published positions of applicable regulators with an interest in such matters (e.g., the U.S. Securities and Exchange Commission and the U.S. Department of Labor). Clients who have granted us voting authority are not permitted to direct us on how to vote in a particular solicitation. With respect to clients that have not granted us voting authority over securities held in their accounts and choose either to retain proxy voting authority or to delegate proxy voting authority to another firm (whether such retention or delegation applies to all or only a portion of the securities within the client’s account), either the client’s or such other entity’s chosen proxy voting guidelines will apply to those securities. We generally do not provide proxy voting recommendations to clients who have not granted us voting authority over their securities. With respect to the Mutual Fund Series, BNYSC does not take any action or provide any advice with respect to the voting of proxies for securities held in client accounts; as described in the client’s Investment Advisory Agreement, the client retains the right and obligation to vote any proxies relating to securities held. With respect to the Customized Investment and Municipal Bond Series, the respective Portfolio Manager (including, where applicable, BNYSC) is responsible for voting proxies in accordance with the Portfolio Manager’s proxy voting policies. 54  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 If we receive a proxy from a non-U.S. company, we will seek to effect a vote decision through the application of the Voting Guidelines. However, corporate governance practices, disclosure requirements and voting operations vary significantly among the various non-U.S. markets in which our clients may invest. In these markets, we may face regulatory, compliance, legal or logistical limits with respect to voting securities held in client accounts which can affect our ability to vote such proxies, as well as the desirability of voting such proxies. Non-U.S. regulatory restrictions or company-specific ownership limits, as well as legal matters related to consolidated groups, may restrict the total percentage of an issuer’s voting securities that we can hold for clients and the nature of our voting in such securities. Our ability to vote proxies may also be affected by, among other things: (1) late receipt of meeting notices; (2) requirements to vote proxies in person: (3) restrictions on a foreigner’s ability to exercise votes; (4) potential difficulties in translating the proxy; (5) requirements to provide local agents with unrestricted powers of attorney to facilitate voting instructions; and (6) requirements that investors who exercise their voting rights surrender the right to dispose of their holdings for some specified period in proximity to the shareholder meeting. Absent an issue that is likely to impact clients’ economic interest in a company, we generally will not subject clients to the costs (which may include a loss of liquidity) that could be imposed by these requirements. In these markets, we will weigh the associative costs against the benefit of voting and may refrain from voting certain non-U.S. securities in instances where the items presented are not likely in our view to have a material impact on shareholder value. Process With respect to U.S.-based and Japan-based issuers and companies, we utilize internally developed Voting Guidelines. With respect to issuers and companies domiciled in other jurisdictions, our Voting Guidelines consist of standardized guidelines for those jurisdictions provided by an independent, third-party proxy advisor (the “Proxy Advisor”). The Voting Guidelines in all instances are intended to address routine, non-controversial proxy proposals. We have also engaged the Proxy Advisor to serve as our proxy agent to administer the mechanical, non-discretionary elements of proxy voting and reporting for clients. The Proxy Advisor is directed, in an administrative role, to follow the specified Voting Guideline and apply it to each applicable proxy proposal or matter where a shareholder vote is sought. Accordingly, proxy items that can be appropriately categorized and matched either will be voted in accordance with the applicable Voting Guideline or will be referred to us if the Voting Guideline so requires. The Voting Guidelines require referral to us of all proxy proposals or shareholder voting matters for which there is not an established applicable Voting Guideline, and generally for those proxy 55  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 proposals or shareholder voting matters that are contested or similarly controversial. We will in turn refer such proxy proposals to the relevant Delegated Subadviser, where applicable, for the purpose of obtaining non-binding proxy voting recommendations in respect of such matters. In cases where we are unable to obtain, or to timely obtain, such proxy voting recommendations directly from a Delegated Subadviser, we will utilize the BNY Proxy Governance team (the “PGT”), an affiliated proxy agent, to vote such proposals in the same manner as voted by the Delegated Subadviser, where available. In cases where no such vote is available, BNYSC will default to the Proxy Advisor’s applicable standardized guideline for the proposal and jurisdiction in question. Clients may receive a copy of the Voting Guidelines, as well as our Proxy Voting Policy, upon request. Clients may also receive information on the proxy voting history for their managed accounts upon request. Please contact us for more information. Managing Conflicts: It is our policy to make proxy voting decisions that are solely in the best long-term economic interests of clients. We are aware that, from time to time, voting on a particular proposal or with regard to a particular issuer may present a potential for conflict of interest for us. For example, potential conflicts of interest may arise when: (1) a public company or a proponent of a proxy proposal has a business relationship with a BNY affiliated company; and/or (2) an employee, officer or director of BNY or one of its affiliated companies has a personal interest in the outcome of a particular proxy proposal. Aware of the potential for conflicts to influence the voting process, we have consciously developed the Voting Guidelines and their application with several layers of controls that are designed to ensure that our voting decisions are not influenced by interests other than those of our clients. For example, we developed the Voting Guidelines with the assistance of internal and external research and recommendations provided by third party vendors but without consideration of any BNY client relationship factors. We have directed our Proxy Advisor to apply the Voting Guidelines to individual proxy items in an objective and consistent manner across client accounts. When proxies are voted in accordance with these pre-determined Voting Guidelines, it is our view that these votes do not present the potential for a material conflict of interest and no additional safeguards are needed. 56  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 For those proposals that are referred to us in accordance with the Voting Guidelines or our direction, we seek to make voting decisions based upon the principle of maximizing the economic value of the securities held in client accounts. In this context we seek to address the potential for conflicts presented by such “referred” items through utilization of the independent expertise of our Delegated Subadvisers, where applicable. With respect to the potential for personal conflicts of interest, BNY’s Code of Conduct requires that all employees make business decisions free from conflicting outside influences. Under this Code, BNY employees’ business decisions are to be based on their duty to BNY and to their clients, and not driven by any personal interest or gain. All employees are to be alert to any potential for conflict and to identify and mitigate or eliminate any such conflict. Accordingly, employees with a personal conflict of interest regarding a particular public company or proposal that is being voted upon must recuse themselves from participation in the discussion and decision- making process with respect to that matter. Additionally, as described below, we have developed specific protocols for instances involving actual or potential conflicts of interest involving ourselves or our ultimate corporate parent, BNY. Conflicts involving BNYSC typically arise due to relationships between proxy issuers (or companies) and BNYSC and/or its employees, executives, officers or directors (“BNYSC Conflicts”). BNYSC Conflicts may include proxies issued by a company for which a BNYSC employee, executive, officer or director serves as a board member; proxies issued by a company that is a current client of BNYSC (such as a wrap fee program sponsor) and that contributed materially to BNYSC’s total revenue as of the end of the last fiscal quarter; and other proxies deemed to present an actual, potential or perceived material conflict because of a relationship between a proxy issuer and BNYSC and/or its executive officers or directors. In addition, BNY has established a Proxy Voting Conflicts Policy (“BNY Policy”) that establishes the required actions and reporting protocols for business units that have discretionary authority to vote proxies on behalf of clients (each, a “Voting Firm”) when actual or potential conflicts of interest involving BNY itself arise. The BNY Policy identifies several specific types of proxy solicitations that are considered “Primary Conflicts” for all Voting Firms (including BNYSC) and directs the manner in which such Primary Conflicts are to be addressed (e.g., application of written guidelines, delegation to independent fiduciary, abstention, client consent, etc.). The BNY Policy also identifies those situations that, while not identified as a Primary Conflict, may present an actual, potential or perceived material conflict because of a relationship between a proxy issuer and BNY or its executive officers or Board of Directors (a “Secondary Conflict”). 57  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 The BNY Policy has further established the BNY Proxy Voting Conflicts Committee (the “PCC”) with responsibility (among others) to (1) maintain and approve changes to the BNY Policy; (2) confirm whether a “Primary Conflict” or “Secondary Conflict” exists if unclear; (3) provide interpretive guidance and/or determine how certain actual or potential conflicts should be addressed; and (4) periodically review proxy conflict decisions as reported by the Voting Firms. The BNY Policy requires each BNY investment adviser to establish a proxy voting conflicts committee or, alternatively, to delegate that function to the PCC. BNYSC has adopted the latter approach and accordingly will present to the PCC for consideration and direction any need for guidance (1) to determine whether a certain situation should be treated as a BNYSC Conflict, Primary Conflict or Secondary Conflict, and (2) the manner in which such actual or potential conflicts should be addressed. The PCC will have sole discretion to determine how a BNYSC Conflict, Primary Conflict or Secondary Conflict is to be addressed -- to the extent a situation is not addressed sufficiently under the applicable policy or if BNYSC deems the applicable policy to be unclear and PCC guidance is needed. Depending on the circumstances, the PCC may determine that the situation: (1) does not rise to the level of a material conflict of interest and will not prohibit BNYSC from voting the proxy; or (2) does present a material conflict of interest requiring some form of mitigation by BNYSC. The PCC may direct any conflict mitigation approach it deems necessary and appropriate (e.g., voting in accordance with the guidance of an independent fiduciary; voting in proportion to other shareholders (“mirror voting”); abstaining from voting; erecting informational barriers around, or recusal from the vote decision making process by, the person or persons making voting decisions; obtaining client consent; or voting in other ways that are consistent with our obligation to vote in our clients’ best interest. Controls and Oversight: We currently apply our proxy voting policies and procedures uniformly across client accounts, without distinction based on investment strategy or client type, but maintain processes designed to periodically re-evaluate this approach and determine its ongoing appropriateness. In addition, we, or the PGT on our behalf, perform a variety of qualitative and quantitative evaluations and maintain processes designed to: i) incorporate additional information that may become available about a pending proxy proposal that would reasonably be expected to affect our voting decision; ii) conduct monitoring to verify that proxy votes have been cast in accordance 58  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 with the Voting Guidelines or our specific direction, as applicable; iii) verify the continued efficacy and applicability of the Voting Guidelines; iv) help ensure the adequacy, transparency and sufficiently broad dissemination of our proxy voting disclosures; v) periodically review the adequacy of our proxy voting policies and procedures to ensure that they have been reasonably formulated and effectively implemented and are reasonably designed to ensure that we continue to cast proxy votes in the best interest of our clients; and vi) conduct due diligence oversight of the Proxy Advisor and qualitatively determine whether continued engagement of the Proxy Advisor is warranted. (This due diligence oversight includes, but is not limited to, annual completion of a comprehensive due diligence questionnaire and provision of a detailed policy and procedure inventory by the Proxy Advisor; annual provision by the Proxy Advisor of a detailed control evaluation performed by an independent auditor; submission of an annual compliance, regulatory and conflicts-related attestation by the Proxy Advisor’s Chief Compliance Officer; and periodic due diligence meetings and on-site visits conducted by the PGT.) Financial Information In certain circumstances, registered investment advisers are required to provide you with financial information or disclosures about their financial condition in this Item. BNYSC has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has never been the subject of a bankruptcy proceeding. Appendix A American Depository Receipts and Global Depository Receipts risk. American depository receipts ("ADRs") are receipts issued by a U.S. bank or trust company evidencing ownership of underlying securities issued by non-U.S. issuers. ADRs may be listed on a national securities exchange or may be traded in the over-the-counter market. Global depository receipts ("GDRs") are receipts issued by either a U.S. or non-U.S. banking institution representing ownership in a non-U.S. company's publicly traded securities that are traded on non-U.S. stock exchanges or non- U.S. over-the-counter markets. Holders of unsponsored ADRs or GDRs generally bear all the costs of such facilities. The depository of an unsponsored facility frequently is under no obligation to distribute investor communications received from the issuer of the deposited security or to pass through voting rights to the holders of depository receipts in respect of the deposited securities. Investments in ADRs and GDRs pose, to the extent not hedged, currency exchange risks (including blockage, devaluation and non-exchangeability), as well as a range of other potential risks relating 59  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 to the underlying shares, which could include expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains, other income or gross sales or disposition proceeds, political or social instability or diplomatic developments that could affect investments in those countries, illiquidity, price volatility and market manipulation. In addition, less information may be available regarding the underlying shares of ADRs and GDRs, and non- U.S. companies may not be subject to accounting, auditing and financial reporting standards and requirements comparable to, or as uniform as, those of U.S. companies. Such risks may have a material adverse effect on the performance of such investments and could result in substantial losses. Allocation risk. The asset classes in which a strategy seeks investment exposure can perform differently from each other at any given time (as well as over the long term), so a strategy will be affected by its allocation among the various asset classes. If the strategy favors exposure to an asset class during a period when that class underperforms, performance may be hurt. Banking industry risk. The risks generally associated with concentrating investments in the banking industry, such as interest rate risk, credit risk and regulatory developments relating to the banking industry. Call risk. Some bonds give the issuer the option to call, or redeem, the bonds before their maturity date. If an issuer “calls” its bond during a time of declining interest rates, the strategy might have to reinvest the proceeds in an investment offering a lower yield, and therefore might not benefit from any increase in value as a result of declining interest rates. During periods of market illiquidity or rising interest rates, prices of “callable” issues are subject to increased price fluctuation. Clearance and settlement risk. Many emerging market countries have different clearance and settlement procedures from developed countries. There may be no central clearing mechanism for settling trades and no central depository or custodian for the safekeeping of securities. The registration, record-keeping and transfer of instruments may be carried out manually, which may cause delays in the recording of ownership. Increased settlement risk may increase counterparty and other risk. Certain markets have experienced periods when settlement dates are extended, and during the interim, the market value of an instrument may change. Moreover, certain markets have experienced periods when settlements did not keep pace with the volume of transactions resulting in settlement difficulties. Because of the lack of standardized settlement procedures, settlement risk in emerging markets is more prominent than in more mature markets. 60  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Concentration risk. A strategy may have a concentrated portfolio due to investment in a limited number of securities, giving rise to concentration risk. A fall in the value of a single security may have a greater impact on the strategy’s value than if the strategy had a more diversified portfolio. Counterparty risk. Under certain conditions, a counterparty to a transaction, including repurchase agreements and derivative instruments, could fail to honor the terms of the agreement, default and the market for certain securities or financial instruments in which the counterparty deals may become illiquid. Country, industry and market sector allocation risk. A strategy may be overweighted or underweighted, relative to the benchmark index, in companies in certain countries, industries or market sectors, which may cause the strategy’s performance to be more or less sensitive to positive or negative developments affecting these countries, industries or sectors. In addition, a strategy may, from time to time, invest a significant portion (more than 25%) of its total assets in securities of companies located in particular countries, such as the United Kingdom and Japan, depending on such country’s representation within the benchmark index. Credit risk. Failure of an issuer to make timely interest or principal payments, or a decline or perception of a decline in the credit quality of a bond can cause a bond’s price to fall, lowering the value of a strategy’s investment in such security. The lower a security’s credit rating, the greater the chance that the issuer of the security will default or fail to meet its payment obligation. See also “High yield bond risk.” Cybersecurity risk. In addition to the risks described above that primarily relate to the value of investments, there are various operational, systems, information security and related risks involved in investing, including but not limited to “cybersecurity risk”. In general, cybersecurity incidents can result from deliberate attacks or unintentional events. Cybersecurity attacks include electronic and non-electronic attacks that include but are not limited to gaining unauthorized access to digital systems (e.g., through "hacking" or malicious software coding) for purposes of misappropriating assets or sensitive information, corrupting data or causing operational disruption. Cybersecurity attacks also may be carried out in a manner that does not require gaining unauthorized access, such as causing denial of service attacks on websites (i.e., efforts to make services unavailable to intended users). As the use of technology has become more prevalent, we and the client accounts we manage have become potentially more susceptible to operational risks through cybersecurity attacks. These attacks in turn could cause us and client accounts (including funds) we manage to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. Similar adverse consequences could result from 61  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 cybersecurity incidents affecting issuers of securities in which we invest, counterparties with which we engage in transactions, third-party service providers (e.g., a client account’s custodian), governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers and other financial institutions and other parties. While cybersecurity risk management systems and business continuity plans have been developed and are designed to reduce the risks associated with these attacks, there are inherent limitations in any cybersecurity risk management system or business continuity plan, including the possibility that certain risks have not been identified. Accordingly, there is no guarantee that such efforts will succeed, especially since we do not directly control the cybersecurity systems of issuers or third-party service providers. Disease/Epidemic risk. Investments could be materially adversely affected by the widespread outbreak of infectious disease or other public health crises, including the COVID-19 pandemic. Public health crises such as the COVID-19 pandemic, together with any containment or other remedial measures undertaken or imposed, could have a material and adverse effect on various investments. Emerging market risk. Emerging markets tend to be more volatile and less liquid than the markets of more mature economies and generally have less diverse and less mature economic structures and less stable political systems than those of developed countries. The securities of issuers located or doing substantial business in emerging markets are often subject to rapid and large changes in price. In particular, emerging markets may have relatively unstable governments, present the risk of sudden adverse government or regulatory action and even nationalization of businesses, have restrictions on foreign ownership or prohibitions on repatriation of assets and impose less protection of property rights than more developed countries. The economies of emerging market countries may be based predominantly on only a few industries and may be highly vulnerable to changes in local or global trade conditions and may suffer from extreme debt burdens or volatile inflation rates. Local securities markets may trade a small number of securities and may be unable to respond effectively to increases in trading volume, potentially making prompt liquidation of substantial holdings difficult. Transaction settlement and dividend collection procedures also may be less reliable in emerging markets than in developed markets. The fixed income securities of issuers located in emerging markets can be more volatile and less liquid than those of issuers in more mature economies. In addition, such securities are often considered to be below investment grade credit quality and predominantly speculative. The imposition of sanctions, confiscations, trade restrictions (including tariffs) and other government restrictions by 62  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 the United States and other governments, or problems in share registration, settlement or custody, may also result in losses. Equity securities risk. The value of equity securities of public and private, listed and unlisted companies and equity derivatives generally varies with the performance of the issuer and movements in the equity markets. As a result, an account may suffer losses if it invests in equity instruments of issuers whose performance diverges from expectations or if equity markets generally move in a single direction. Accounts may also be exposed to risks that issuers will not fulfill contractual obligations such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering restricted securities for public resale. ESG investment approach risk. A strategy’s investment approach may cause it to perform differently than strategies that invest in securities of companies but that do not integrate consideration of environmental, social and governance (“ESG”) issues when selecting investments. An investment approach that systematically integrates the consideration of ESG issues in the securities selection process may result in such strategy forgoing opportunities to buy certain securities when it might otherwise be advantageous to do so or selling securities when it might be disadvantageous for such strategy to do so. Exchange-traded fund (“ETF”) risk. Exchange Traded Funds ("ETFs") are shares of publicly traded unit investment trusts, open-end funds or depository receipts that seek to track the performance and dividend yield of specific indexes or companies in related industries. These indexes may be either broad-based, sector or international. However, ETF shareholders are generally subject to the same risk as holders of the underlying financial instruments they are designed to track. ETFs are also subject to certain additional risks, including, without limitation, the risk that their prices may not correlate perfectly with changes in the prices of the underlying financial instruments they are designed to track and the risk of trading in an ETF halting due to market conditions or other reasons, based on the policies of the exchange upon which the ETF trades. ETFs in which the strategy may invest involve certain inherent risks generally associated with investments in a portfolio of common stocks and/or bonds, including the risk that the general level of stock prices may decline, thereby adversely affecting the value of each unit of the ETF. Moreover, an ETF may not fully replicate the performance of its benchmark index because of the temporary unavailability of certain index securities in the secondary market or discrepancies between the ETF and the index with respect to the weighting of securities or the number of securities held. In addition, legal, tax and regulatory changes, such as certain sanctions imposed by governments, may occur which may restrict an ETF’s ability to purchase, hold or sell 63  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 certain constituents of the relevant index in their appropriate proportions or otherwise adversely affect the ability of the ETF to pursue its indexing strategy. Investing in ETFs, which are investment companies, may involve duplication of advisory fees and certain other expenses. Foreign currency risk. Investments in foreign currencies are subject to the risk that those currencies will decline in value relative to the U.S. dollar, or in the case of hedged positions, that the U.S. dollar will decline relative to the currency being hedged. Currency exchange rates may fluctuate significantly over short periods of time. A decline in the value of foreign currencies relative to the U.S. dollar will reduce the value of securities held by the strategy and denominated in those currencies. Foreign currencies are also subject to risks caused by inflation, interest rates, budget deficits and low savings rates, political factors and government controls. Foreign investment risk. Special risks associated with investments in foreign companies include exposure to currency fluctuations, less liquidity, less developed or less efficient trading markets, lack of comprehensive company information, political or economic instability, seizure or nationalization of assets, imposition of taxes or repatriation restrictions and differing auditing and legal standards. The securities of issuers located in emerging markets can be more volatile and less liquid than those of issuers in more mature economies. The imposition of sanctions, confiscations, trade restrictions (including tariffs) and other government restrictions by the United States and other governments, or problems in share registration, settlement or custody, may also result in losses. General risks: Investing in securities involves risk of loss that you should be prepared to bear. We do not guarantee or represent that our investment program will be successful. Our past results are not necessarily indicative of our future performance and our investment results may vary over time. We cannot assure you that our investments of your money will be profitable, and in fact, you could incur substantial losses. Your investments with us are not bank deposits and are not insured or guaranteed by the FDIC or any other government agency. Growth and value stock risk. Investors often expect growth companies to increase their earnings at a certain rate. If these expectations are not met, investors can punish the stocks inordinately, even if earnings do increase. In addition, growth stocks typically lack the dividend yield that can cushion stock prices in market downturns. Value stocks involve the risk that they may never reach their expected full market value, either because the market fails to recognize the stock’s intrinsic 64  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 worth, or the expected value was misgauged. They also may decline in price even though in theory they are already undervalued. Health care sector risk. When a strategy’s investments are concentrated in the health care and related sectors, the value of your investment will be affected by factors particular to those sectors and may fluctuate more widely than that of a strategy which invests in a broad range of industries. Health care companies are subject to government regulation and approval of their products and services, which can have a significant effect on their market price. The types of products or services produced or provided by these companies may quickly become obsolete. Moreover, liability for products that are later alleged to be harmful or unsafe may be substantial and may have a significant impact on the health care company’s market value and/or share price. Biotechnology and related companies are affected by patent considerations, intense competition, rapid technology change and obsolescence and regulatory requirements of various federal and state agencies. In addition, some of these companies are relatively small and have thinly traded securities, may not yet offer products or may offer a single product and may have persistent losses during a new product’s transition from development to production, or erratic revenue patterns. The stock prices of these companies are very volatile, particularly when their products are up for regulatory approval and/or under regulatory scrutiny. Securities of companies within specific health care sectors can perform differently than the overall market. This may be due to changes in such things as the regulatory or competitive environment, or to changes in investor perceptions regarding a sector. Because the strategy may allocate relatively more assets to certain health care sectors than others, the strategy’s performance may be more sensitive to developments which affect those sectors emphasized by the strategy. Inflation risk. Rising prices associated with inflation may outpace the returns delivered by investments, in particular with respect to cash and cash equivalents and other investments whose returns are not linked to the rate of inflation in the reference economy. Interest rate risk. Prices of debt securities tend to move inversely with changes in interest rates. Typically, a rise in rates will adversely affect the prices of these securities and, accordingly, the value of your investment. The longer the effective maturity and duration of the strategy’s portfolio, the more the value of your investment is likely to react to interest rates. Mortgage-related securities can have a different interest rate sensitivity than other bonds, however, because of prepayments and other factors, they may carry additional risks and be more volatile than other types of debt securities due to unexpected changes in interest rates. 65  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Investment strategy risk. A strategy’s investment criteria (for example, sustainability) may limit the number of investment opportunities available to the strategy, and, as a result, at times the strategy’s returns may be lower than those of strategies that are not subject to such special investment considerations. Issuer risk. The value of a security may decline for a number of reasons which directly relate to the issuer, such as management performance, financial leverage and reduced demand for the issuer’s products or services. Large cap stock risk. To the extent a strategy invests in large capitalization stocks, the strategy may underperform strategies that invest primarily in the stocks of lower quality, smaller capitalization companies during periods when the stocks of such companies are in favor. Liquidity risk. When there is little or no active trading market for specific types of securities, it can become more difficult to sell the securities at or near their perceived value. In such a market, the value of such securities and the value of your investment may fall dramatically, even during periods of declining interest rates. Liquidity risk also exists when a particular derivative instrument is difficult to purchase or sell. If a derivative transaction is particularly large or if the relevant market is illiquid (as is the case with many privately negotiated derivatives), it may not be possible to initiate a transaction or liquidate a position at an advantageous time or price. The secondary market for certain municipal bonds tends to be less well developed or liquid than many other securities markets, which may adversely affect the strategy’s ability to sell such municipal bonds at attractive prices. Trading limits (such as “daily price fluctuation limits” or “speculative position limits”) on futures trading imposed by regulators and exchanges could prevent the prompt liquidation of unfavorable futures positions and result in substantial losses. In addition, the ability to execute futures contract trades at favorable prices if trading volume in such contracts is low may be limited. It is also possible that an exchange or a regulator may suspend trading in a particular contract, order immediate liquidation and settlement of a particular contract or order that trading in a particular contract be conducted for liquidation only. Therefore, in some cases, the execution of trades to invest or divest cash flows may be postponed, which could adversely affect the withdrawal of assets and/or performance. Market risk. The market value of a security may decline due to general market conditions that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the outlook for corporate earnings, outbreaks of an infectious disease, changes in interest or currency rates or adverse investor sentiment generally. A security’s market value also may decline because of factors that affect a particular industry or industries, such as 66  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 labor shortages or increased production costs and competitive conditions within an industry. Global economies and financial markets are becoming increasingly interconnected, and conditions and events in one country, region or financial market may adversely impact issuers in a different country, region or financial market. These risks may be magnified if certain events or developments adversely interrupt the global supply chain; in these and other circumstances, such risks might affect companies worldwide. Municipal lease risk. Because municipal leases generally are backed by revenues from a particular source or depend on future appropriations by municipalities and are not obligations of their issuers, they are less secure than most municipal obligations. Municipal securities risk. The amount of public information available about municipal securities is generally less than that for corporate equities or bonds. Special factors, such as legislative changes and state and local economic and business developments, may adversely affect the yield and/or value of the strategy’s investments in municipal securities. Other factors include the general conditions of the municipal securities market, the size of the particular offering, the maturity of the obligation and the rating of the issue. Changes in economic, business or political conditions relating to a particular municipal project, municipality or state, territory or possession of the United States in which the strategy invests may have an impact on the strategy’s performance. Non-diversification risk. A non-diversified strategy may invest a relatively high percentage of its assets in a limited number of issuers. Therefore, the strategy’s performance may be more vulnerable to changes in the market value of a single issuer or group of issuers and more susceptible to risks associated with a single economic, political or regulatory occurrence than a diversified strategy. Portfolio turnover risk. A strategy may engage in short-term trading, which could produce higher transaction costs and taxable distributions and lower the strategy’s after-tax performance. Preferred stock risk. Preferred stock is a class of capital stock that typically pays dividends at a specified rate. Preferred stock is generally senior to common stock, but subordinate to debt securities, with respect to the payment of dividends and on liquidation of the issuer. The market value of preferred stock generally decreases when interest rates rise and is also affected by the issuer’s ability to make payments on the preferred stock. Prepayment and extension risk. When interest rates fall, the principal on mortgage-backed and certain asset-backed securities may be prepaid. The loss of higher yielding underlying mortgages and the reinvestment of proceeds at lower interest rates can reduce the strategy’s potential price 67  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 gain in response to falling interest rates, reducing the value of your investment. When interest rates rise, the effective duration of the strategy’s mortgage-related and other asset-backed securities may lengthen due to a drop in prepayments of the underlying mortgages or other assets. This is known as extension risk and would increase the strategy’s sensitivity to rising interest rates and its potential for price declines. Real estate sector risk. When a strategy’s investments are concentrated in the securities of companies principally engaged in the real estate sector, the value of your investment will be affected by factors particular to the real estate sector and may fluctuate more widely than that of a strategy which invests in a broader range of industries. The securities of issuers that are principally engaged in the real estate sector may be subject to risks similar to those associated with the direct ownership of real estate. These include: declines in real estate values, defaults by mortgagors or other borrowers and tenants, increases in property taxes and operating expenses, overbuilding, fluctuations in rental income, changes in interest rates, possible lack of availability of mortgage funds or financing, extended vacancies of properties, changes in tax and regulatory requirements (including zoning laws and environmental restrictions), losses due to costs resulting from the clean-up of environmental problems, liability to third parties for damages resulting from environmental problems and casualty or condemnation losses. In addition, the performance of the economy in each of the regions and countries in which the real estate owned by a portfolio company is located affects occupancy, market rental rates and expenses and, consequently, has an impact on the income from such properties and their underlying values. In addition to the risks which are linked to the real estate sector in general, Real Estate Investment Trusts (“REITs”) are subject to additional risks. Equity REITs, which invest a majority of their assets directly in real property and derive income primarily from the collection of rents and lease payments, may be affected by changes in the value of the underlying property owned by the trust, while mortgage REITs, which invest the majority of their assets in real estate mortgages and derive income primarily from the collection of interest payments, may be affected by the quality of any credit extended. Further, REITs are highly dependent upon management skill and often are not diversified. REITs also are subject to heavy cash flow dependency and to defaults by borrowers or lessees. In addition, REITs possibly could fail to qualify for favorable tax treatment under applicable U.S. or foreign law and/or to maintain exempt status under the Investment Company Act of 1940, as amended. Certain REITs provide for a specified term of existence in their trust documents. Such REITs run the risk of liquidating at an economically disadvantageous time. Small and mid-size company risk. Small and mid-size companies carry additional risks because the operating histories of these companies tend to be more limited, their earnings and revenues less 68  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 predictable (and some companies may be experiencing significant losses) and their share prices more volatile than those of larger, more established companies. The shares of smaller companies tend to trade less frequently than those of larger, more established companies, which can adversely affect the pricing of these securities and the strategy’s ability to sell these securities. These companies may have limited product lines, markets or financial resources, or may depend on a limited management group. Some of the strategy’s investments will rise and fall based on investor perception rather than economic factors. Other investments are made in anticipation of future products, services or events whose delay or cancellation could cause the stock price to drop. State-specific risk. A state-specific strategy is subject to the risk of that state’s economy, and the revenues underlying its municipal bonds, may decline. Investing primarily in a single state makes the strategy more sensitive to risks specific to the state and may magnify other risks. Stock investing risk. Stocks generally fluctuate more in value than bonds and may decline significantly over short time periods. There is the chance that stock prices overall will decline because stock markets tend to move in cycles, with periods of rising prices and falling prices. The market value of a stock may decline due to general market conditions that are not related to the particular company, such as real or perceived adverse economic conditions, changes in the outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. A security’s market value also may decline because of factors that affect a particular industry, such as labor shortages or increased production costs and competitive conditions within an industry or factors that affect a particular company, such as management performance, financial leverage and reduced demand for the company’s products or services. Stock selection risk. The stocks selected for implementing a given investment strategy may not perform as well as anticipated or in relation to available stock alternatives, negatively impacting account performance. Style risk. Investment strategies that focus on particular market segments or asset types may underperform the broader market during intervals when such securities are out of favor with investors. Systemic risk. World events and/or the activities of one or more large participants in the financial markets and/or other events or activities of others could result in a temporary systemic breakdown in the normal operation of financial markets. Such events could result in a portfolio losing substantial value caused predominantly by liquidity and counterparty issues which could result in a portfolio incurring substantial losses. 69  BNY Mellon Securities Corporation Form ADV Part 2A, Appendix 1 BNY Managed Asset Program March 31, 2025 Tax risk. To be tax-exempt, municipal bonds generally must meet certain regulatory requirements. If any such municipal bond fails to meet these regulatory requirements, the interest received by the strategy from its investment in such bonds and distributed to you will be taxable. Technology company risk. The technology sector has been among the most volatile sectors of the stock market. If the strategy’s investments are concentrated in the technology sector, its performance can be significantly affected by developments in that sector. Technology companies, especially small-cap technology companies, involve greater risk because their revenue and/or earnings tend to be less predictable (and some companies may be experiencing significant losses) and their share prices tend to be more volatile. Certain technology companies may have limited product lines, markets or financial resources, or may depend on a limited management group. In addition, these companies are strongly affected by worldwide technological developments and their products and services may not be economically successful or may quickly become outdated. Investor perception may play a greater role in determining the day-to-day value of tech stocks than it does in other sectors. Investments made in anticipation of future products and services may decline dramatically in value if the anticipated products or services are delayed or cancelled. The risks associated with technology companies are magnified in the case of small-cap technology companies. The shares of smaller technology companies tend to trade less frequently than those of larger, more established companies, which can have an adverse effect on the pricing of these securities and on a strategy’s ability to sell these securities. Value stock risk. Value stocks involve the risk that they may never reach their expected market value, either because the market fails to recognize the stock’s intrinsic worth or the expected value was misgauged. They also may decline in price even though in theory they are already undervalued. 70