CIF Proxy Voting Policies by Sub-Advisor

Aegon USA Investment Management, LLC
Alliance Bernstein, L.P.
American Century Investments
Amundi Asset Management US, Inc.
Baillie Gifford Overseas Limited
Barrow, Hanley, Mewhinney & Strauss, LLC
Blackrock Investment Management, LLC
Brandes Investment Partners, L.P.
Brandywine Global Investment Management,LLC
Brown Brothers Harriman & Co.
Callan LLC
CAPTRUST Financial Advisors
CBIZ Investment Advisory Services, LLC
Clarion Partners, LLC
ClariVest Asset Management LLC
ClearBridge Investments, LLC
Cohen & Steers Capital Management, Inc.
Cramer Rosenthal McGlynn, LLC
D.F. Dent and Company, Inc.
DePrince, Race & Zollo, Inc.
Diamond Hill Capital Management, Inc.
Emerald Advisers, LLC
Envestnet Retirement Solutions, LLC
Epoch Investment Partners, Inc.
Federated Investment Counseling
Fidelity Investments
flexPATH Strategies, LLC
Franklin Advisers, Inc.
Franklin Mutual Advisers LLC
Franklin Templeton Institutional, LLC
Fred Alger Management, LLC
Geneva Capital Management LLC
Granahan Investment Management LLC
Great Lakes Advisors, LLC
Hermes Investment Management Limited
Hotchkis & Wiley Capital Management, LLC
Invesco Advisers, Inc.
J.P. Morgan Asset Management
Jackson Square Partners, LLC
Janus Henderson Investors US LLC
Jennison Associates LLC
Lazard Asset Management, LLC
Legal & General Investment Management
Lord Abbett & Co., LLC
Los Angeles Capital LLC
Martin Currie Inc.
Massachusetts Financial Services Company
Metropolitan West Asset Management Inc. (a TCW subsidiary)
Morgan Stanley Investment Management, Inc.
Newton Investment Management North
Pensionmark Financial Group, LLC
Peregrine Capital Management, LLC
PIMCO Global
Principal Global Investors
Ranger Investment Management, LP
RBC Global Asset Management (UK) Limited
Royce & Associates, LP
Sands Capital Management, LLC
Schroder Investment Management North America Inc.
Sentinel Pension Advisors, Inc.
T. Rowe Price Associates, Inc.
Templeton Global Advisors Limited
The Putnam Advisory Company, LLC
Victory Capital Management, Inc.
Voya Investment Management Co. LLC
Walter Scott & Partners Limited
Wellington Management Company LLP
Western Asset Management Company, LLC
Wilshire Advisors, LLC

Great Gray Trust Company, LLC (“Great Gray”), as Trustee, shall vote, or refrain from voting, all proxies with respect to securities held in each Great Gray Fund in accordance with Great Gray’s proxy voting policies, guidelines, and/or procedures in effect from time to time, or those of the Sub- Advisor Great Gray has retained to advise on investments for the Fund. View our Great Gray Funds and the appointed Sub-Advisor.

If you are unable to find the proxy voting policies for a Great Gray Fund, want a copy of the proxy policy free of charge, or have questions please contact us.

Great Gray Trust Company, LLC Collective Investment Funds (“Great Gray Funds”) are bank collective investment funds; they are not mutual funds. Great Gray Trust Company, LLC   serves as the Trustee of the Great Gray Funds and maintains ultimate fiduciary authority over the management of, and investments made in, the Great Gray Funds. The Great Gray Funds and their units are exempt from registration under the Investment Company Act of 1940 and the Securities Act of 1933, respectively.

Investments in the Great Gray Funds are not bank deposits or obligations of, are not insured or guaranteed by Great Gray Trust Company, LLC, any bank, the FDIC, the Federal Reserve, or any other governmental agency. The Great Gray Funds are commingled investment vehicles, and as such, the values of the underlying investments will rise and fall according to market activity; it is possible to lose money by investing in the Great Gray Funds.

Participation in Collective Investment Trust Funds is limited primarily to qualified retirement plans and certain state or local government plans and is not available to IRAs, health and welfare plans and, in certain cases, Keogh (H.R. 10) plans. Collective Investment Trust Funds may be suitable investments for plan fiduciaries seeking to construct a well-diversified retirement savings program. Investors should consider the investment objectives, risks, charges and expenses of any pooled investment fund carefully before investing. The Additional Fund Information and Principal Risk Definitions (PRD) contains this and other information about a Collective Investment Trust Fund and is available at https://go.greatgray.com/fact-sheet or ask for a copy without charge by contacting Great Gray Trust Company, LLC at (866) 427-6885.