Beach Point Capital Management LP

Beach Point Capital Management LP (“Beach Point”) commenced operations on January 1, 2009. Beach Point was founded by, and remains under the control of, its Co-Chief Executive Officers (“CEOs”) / CoChairmen, Carl Goldsmith and Scott Klein, through a management buyback of the alternative investment business of Post Advisory Group, LLC (“Post”). Beach Point manages assets within the following strategies: Opportunistic Credit, Performing Credit (including Senior Loans, High Yield Bonds, and CLO Origination), Structured Credit and Asset-Based Finance, Capital Solutions, Hybrid Solutions, Real Estate Credit, and Private Senior Loans which are described more fully in Item 8 below. Beach Point offers investment advisory services to privately-offered limited partnerships, limited liability companies and other investment vehicles (including collateralized loan obligation vehicles (“CLOs”) and private REITs) (the “Funds”) and clients with separately managed accounts (the “Managed Accounts”). Beach Point (or a Beach Point affiliate) serves as the general partner, managing member and/or investment manager of the Funds and as the investment manager of the Managed Accounts. Additionally, Beach Point (or a Beach Point affiliate) acts as collateral manager to securitized asset Funds that are structured as CLOs (each a “Beach Point-Managed CLO”). Beach Point also serves as the investment adviser to Funds with one, or only a limited number of, investors and which are not offered to new investors (“Single Client Funds”). Typically, Single Client Funds are structured as a limited partnership or limited liability company managed by Beach Point (or a Beach Point affiliate) as the general partner, managing member and/or investment manager. At times, Funds and Managed Accounts are referred to in this brochure collectively as “Clients” or "accounts." Beach Point generally has discretionary authority to manage the Funds and Managed Accounts, including the authority to determine which investments are bought and sold and the amounts of such investments that are appropriate for each Client. Any limitation on Beach Point’s authority is described in a Client’s governing documents (e.g., investment management agreement, private placement memorandum, articles of association, or partnership agreement). In connection with Managed Accounts, Clients establish such accounts with Beach Point by depositing funds or securities into accounts maintained by qualified independent custodians and granting Beach Point discretionary investment authority to invest such funds pursuant to each Client's investment objectives and guidelines, as set forth in each Client's investment management agreement and other account documentation, including any written instructions provided by the Client to Beach Point. Funds are managed in accordance with investment objectives and guidelines set forth in the governing documents for each Fund. As of December 31, 2025, Beach Point manages approximately $20.8 billion in assets on a discretionary basis and $0 in assets on a non-discretionary basis. The amount of assets under management reported in this brochure differs from the amount of regulatory assets under management reported in Part 1 of our Form ADV. Part 1 of Form ADV requires an adviser to report assets under management without deducting any outstanding indebtedness or other accrued but unpaid liabilities. Beach Point believes that reporting firm assets under management in our brochure based on regulatory assets under management may appear to overstate our assets under management. Therefore, in this brochure, Beach Point’s methodology for calculating firm-wide AUM includes (i) the gross asset value (GAV) of assets managed directly by Beach Point, (ii) undrawn capital that Beach Point is entitled to call from investors in certain funds pursuant to their capital commitments, and (iii) the aggregate notional liabilities of CLOs at pricing. This calculation methodology may differ from the definitions outlined in an account’s governing documents. The result is

that the amount of assets under management reported in this brochure is lower than the amount of regulatory assets under management reported in Part 1 of our Form ADV.

A. Compensation for Advisory Services The following description of Beach Point’s fees and compensation is intended to provide a summary of the more typical fee structures shared by certain Clients and is not intended to describe every fee arrangement to which Beach Point is a party. Beach Point believes that its fees are competitive with those fees charged by other investment advisers for comparable services; however, comparable services may be available from other sources for lower fees. Please refer to the account’s governing documents for specific details regarding all fees and expenses for specific accounts. From time to time Beach Point has afforded, and may in the future in its sole discretion afford, certain investors in Funds or certain Clients in the same or similar strategy more favorable economic terms than other investors in the same Fund or other Clients within the same or similar investment strategy, including with respect to both management and performance-based fees, generally based on the timing and aggregate size of commitments of such investor or Client, as applicable, to one or more accounts managed by Beach Point or its affiliates. Any fees may be reduced or waived entirely by Beach Point or its affiliates in their sole discretion. Certain investors in a Fund, including employees, business associates and other “friends and family” of Beach Point, its affiliates or their personnel, may receive special fee arrangements. This can include related entities such as trusts, charitable programs, endowments, family investment vehicles and other estate planning vehicles related to these individuals. Typically, these investors will not pay management fees or other incentive or performance-based compensation in connection with their investment in a Fund, or they will pay a reduced rate. All investors, regardless of fee arrangements, are responsible for paying their allocated portion of all other expenses incurred by the Fund(s) in which they are invested. Beach Point calculates management fees strictly in accordance with the terms of each Client’s governing documents. Investors should carefully review the applicable governing documents for the specific rules that apply to their investment. 1. Management Fees As consideration for investment advisory services provided to its Clients, Beach Point (or an affiliate) generally receives management fees on a monthly or quarterly basis based on annual fee rates, the amount of which varies depending upon the applicable account, and which is set forth within the terms of the governing documents, offering documents, investment management agreement or sub-advisory agreement of such account. For Beach Point’s open-end Funds, the management fee is generally based on investment strategy of the relevant Fund. Open-end Funds typically pay management fees ranging from 0.50% to 1.50% of the net asset value of the relevant Fund per year, paid monthly or quarterly. For certain evergreen Funds within Beach Point’s Private Senior Loan strategy, management fees are calculated based on the gross asset value of such Funds, which includes investments funded, directly or indirectly, through borrowings or other forms of indebtedness (including borrowings or other forms of indebtedness incurred by Fund subsidiaries or special purpose vehicles). Applying the management fee to the gross asset value of such evergreen

funds, including leverage, results in higher management fees payable to Beach Point than would be the case if the management fees were applied to the net asset value of such evergreen Funds. In the case of Beach Point’s closed‑end Funds, management fees during the investment period are calculated quarterly as a fixed percentage, generally ranging from 1.50% to 1.75% per year, based on (i) aggregate capital contributions less the aggregate distributions made (net of any recalled distributions), (ii) the aggregate cost basis of the Fund’s investments, or (iii) the lesser of invested capital and committed capital, as specified in each Fund’s governing documents. After the expiration of the investment period, the management fee generally remains a fixed percentage applied against (i) the aggregate cost basis of the Fund’s investments or (ii) the lesser of invested capital and committed capital, depending on the applicable Fund terms. The base on which management fees are charged may be reduced for investments that have been completely written off for U.S. federal income tax purposes or permanently written down to zero by Beach Point or its related person, to the extent provided in a Fund’s governing documents. Fund investors should review the fee calculation provisions in their governing documents to understand when, if at all, the management fee base may be reduced. Beach Point’s fees for Managed Accounts and Single Client Funds are determined on a negotiated basis based on various parameters including the scope of management involved, the size of the account, and the particular investment objectives and needs of each Client. Management fees are typically billed on a quarterly basis and paid in arrears; however, other arrangements may be negotiated with individual Managed Account and Single Client Fund Clients. Additionally, collateral management fees for Beach Point-Managed CLOs are payable in arrears only to the extent that funds are available in accordance with the priority of payments described in the governing documents of such CLOs and may include a performance fee in the event that certain subordinated note return thresholds are exceeded. Collateral management fees for Beach Point-Managed CLOs are calculated as a fixed percentage, generally ranging from 0.40% to 0.50%, and are subject to the provisions set out in the governing documents of such CLOs. Beach Point also receives management fees based on the net asset value of a private REIT. A description of scenarios where Beach Point elects to provide a fee offset to Clients is provided below in Item 12.E – Potential Conflicts of Interest in Connection with Trade Allocation. 2. Performance-Based Fees Beach Point (or a related person) has the potential to earn performance-based compensation in the form of performance fees, profit/incentive allocations, or carried interest from Clients. The amount of such performance-based compensation and the calculation and timing of payment of such compensation are set forth in the terms of the governing documents of such account. With respect to certain open-end Funds, Beach Point (or a related person) generally receives annual performance-based compensation of up to 20% of the year's net profit (which includes net changes in unrealized appreciation of investments and realized gains and income) in excess of any previously unrecovered losses (proportionately reduced by withdrawals). In other words, Beach Point (or a related person) is entitled to annual performance-based compensation on a “high water mark” basis. Generally, for closed-end Funds, Beach Point (or a related person) is entitled to receive up to 20% of the realized profits of a Fund’s aggregate investments after such Fund first distributes all contributed capital

from the inception of the Fund plus an annual preferred return, typically 8%, to its investors. As a result, Beach Point (or a related person) generally receives a profit or incentive allocation from a closed-end Fund, if any, in the latter part of a Fund's term, although earlier in such Fund's term Beach Point (or a related person) may receive tax distributions to cover its allocable share of income taxes. With respect to Managed Accounts and Single Client Funds in certain strategies, Beach Point will enter into arrangements to receive performance-based compensation (typically subject to a priority return or hurdle rate). The amount of such performance-based compensation and the calculation and timing of payment of such compensation are set forth in the governing documents of such account. Performance fees for Beach Point-Managed CLOs are payable in the event that certain subordinated note return thresholds are exceeded as described in the governing documents of such CLOs. Beach Point is also entitled to an incentive allocation for its management of a private REIT as long as it surpasses a specified threshold. The incentive allocation is accrued and payable as described in the governing documents. Any performance-based compensation will be charged in accordance with Section 205 of the Advisers Act and Rule 205-3 thereunder. Section 205 and Rule 205-3 permit an investment adviser to charge a performance-based fee only in certain circumstances. Beach Point will not accept clients who do not satisfy the eligibility criteria of applicable law. Clients should be aware that the existence of performance-based compensation (including, in the case of the closed-end Funds, carried interest) may create an incentive for Beach Point to make investments that are riskier or more speculative than would otherwise be made in the absence of such performance-based compensation or, in the case of the closed-end Funds, to make determinations regarding the timing and structure of realization transactions that may not be consistent (or that are adverse) with the interests of closed-end Fund investors. Beach Point addresses this conflict by focusing on long-term relationships with its Clients and Fund investors and managing accounts in accordance with its governing documents. In addition, performance-based compensation creates a potential conflict of interest for Beach Point in valuing investments that are not readily marketable or difficult to value. Beach Point receives performancebased compensation on unrealized appreciation as well as realized gains with respect to certain Clients. Beach Point addresses this conflict by adhering to its valuation policies and using third-party pricing sources for investments above a de minimis threshold, subject to limited exceptions. 3. Multiple Classes and Series of Interests Certain Funds may establish and issue multiple classes or series of interests with different rights, privileges, and obligations. These structural variations can create conflicts of interest and different economic outcomes for investors in the same Fund. For example, certain classes or series may bear different management or performance fee rates, or charge additional fund‑level expenses, which can cause the net returns or risk profiles of investors within the same Fund to diverge. Other classes (such as “income distribution” or “distribution” classes) may be structured to receive regular distributions of income or realized gains, while “accumulation” or other classes may reinvest such amounts, resulting in different timing and character of returns, tax consequences, and capital appreciation for different investors.

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Fund investors should refer to a Fund’s offering documents and/or other governing documents for a more detailed description of the methods of analysis employed by Beach Point, a Fund’s investment strategy and the risk of loss associated with an investment in a Fund. Each Managed Account’s investment strategy and the risk of loss associated with such account are described in the investment management agreement and/or governing documents for such account. A. Methods of Analysis – Research Process Beach Point seeks to employ both fundamental and technical analysis in its research process. Key elements of Beach Point’s investment process include: (i) value identification of companies, utilizing both internal research and proprietary tools, as well as external sources, to provide deal flow; (ii) a detailed analysis and due diligence process that includes structural review of an issuer’s capital structure, review of the applicable indenture covenants, asset coverage and liquidation valuation and bankruptcy analysis; (iii) a relative-value decision-making process that evaluates how each particular investment relates to comparable investments available or currently in a Client’s portfolio; and (iv) ongoing monitoring that continues the due diligence process after an investment is entered into the Client’s portfolio.

In addition, Beach Point aims to integrate certain financially material ESG factors into its investment process (“Responsible Investment”) in accordance with its Responsible Investment Policy and subject to its fiduciary duty and any applicable legal, regulatory or contractual requirements. B. Investment Strategies Beach Point typically provides two options through which investors can gain access to the investment strategies described below – Funds or Managed Accounts. 1. Performing Credit (including Senior Loans, High Yield Bonds, and CLO Origination) The Performing Credit strategy invests primarily in corporate loans and/or high yield bonds. The strategy seeks upside opportunity from a combination of current income and capital appreciation and seeks protection from inflation by virtue of the floating rate nature of most corporate loans. The strategy also seeks to generate attractive levels of current income by investing in high-yield bonds. The strategy is generally expected to favor investments in instruments that are collateralized, or relatively senior in the capital structure to attempt to protect against downside risks. In addition, the strategy participates in the origination and management of Beach Point-Managed CLOs. 2. Opportunistic Credit The Opportunistic Credit strategy typically has broad flexibility to capture investment opportunities across the universe of below investment grade credit. The strategy employs a flexible, value-oriented approach with investments up and down the capital structure. Investment ideas are sought among both long and short positions in various investments including high yield bonds, corporate loans, stressed and distressed debt, special situation investments, credit-related opportunities, structured credit, undervalued and eventdriven equities, and a variety of other securities and instruments. The strategy also makes selective investments in convertible notes and capital structure arbitrage opportunities. 3. Structured Credit and Asset-Based Finance The Structured Credit strategy invests primarily in a variety of securitized products, mortgage loans, commercial mortgages, Property Assessed Clean Energy (PACE), asset-backed securities, collateralized loan obligations, mortgage-backed securities, real estate investment trusts (REITs), derivatives, undervalued and event-driven equities, and credit instruments, complemented by other investments. The strategy attempts to generate risk-adjusted returns by seeking out structural inefficiencies in mortgage and related credit market opportunities where a discernible competitive advantage can be identified through fundamental research. 4. Capital Solutions The Capital Solutions strategy seeks to invest across private credit strategies. The strategy aims to (i) identify secured financing opportunities in the middle market across sponsored and non-sponsored transactions; and (ii) capitalize on complex business models, highly-structured financing and temporary market or company dislocations. 5. Hybrid Solutions The Hybrid Solutions strategy aims to invest primarily in: (i) credit-informed private equity, (ii) special situations and (iii) investments in companies experiencing dislocation or financial distress, or in the midst of a bankruptcy or restructuring. The strategy seeks to invest in structures that we believe provide rationally

calibrated risk-adjusted pricing which may offer an attractive blend of downside protection and equity upside potential. The strategy will pursue investment opportunities in complex situations, such as: (i) corporate carve-outs, (ii) undermanaged private or family owned businesses, (iii) companies with complicated capital structures and elevated leverage profiles, (iv) companies trading at depressed valuations due to identified and correctable challenges, (v) companies facing unusual circumstances resulting in outcomes that exhibit low correlation to broader markets, and (vi) companies at an inflection point. To achieve its goals, Beach Point expects to take an active role in the strategy’s portfolio companies. 6. Real Estate Credit The Real Estate Credit strategy aims to invest primarily in (i) opportunities across private and public real estate credit sectors and market cycles and (ii) overlooked or underserved segments of commercial real estate (“CRE”) debt markets where we believe there is less reliance on leverage to generate attractive returns. The strategy seeks to utilize structural, or internal leverage with the goal of reducing unwanted financing risks (including borrower recourse, mark-to-market / margin calls, term mismatch, increased haircuts and pulled facilities). The strategy’s objective is to invest in a mix of lending (direct origination or primary syndication), secondary debt strategies and special situations with the goal of capturing high-yield returns across performing real estate credit sectors. 7. Private Senior Loans The Private Senior Loans strategy targets investments in private senior secured, first lien loans to middle market companies. The strategy seeks sponsor-backed middle-market loans as well as high yield and upper middle market loans. The strategy pursues opportunities sourced through bank partnerships coupled with opportunities sourced by leveraging Beach Point’s long-term relationships and industry knowledge. C. Risk of Loss Beach Point does not guarantee the future performance of any account, the success of any investment decision or strategy that Beach Point employs or the success of Beach Point’s overall management of any account. Any investment in a Fund or Managed Account involves significant risk, including the risk of loss of all or substantially all capital invested. Clients and Fund investors should be prepared to bear the loss of the entire amount of their investment. As described above in Item 4 and this Item 8, Beach Point manages several investment strategies and invests in a wide range of investments on behalf of its Clients. The risks associated with accounts managed by Beach Point are more fully described in the offering documents and/or other governing documents for such accounts. Clients and Fund investors must carefully review such offering documents and governing documents prior to making an investment. In addition, Managed Accounts and Single Client Funds are offered only to large, sophisticated institutional clients. Managed Account Clients and Single Client Fund investors generally have their own investment staff and/or investment consultants that understand the risks involved in an investment strategy and are able to customize their investment guidelines accordingly. The following discussion of certain risk factors does not purport to be a complete explanation of the risks involved with investing with Beach Point. Clients and Fund investors should read all documents and agreements related to opening a Managed Account or investing in a Fund (including a Fund’s Offering Memorandum and other relevant documents).

1. General Risks Associated with Debt Instruments and Fixed-Income Securities Client accounts typically include debt instruments and fixed-income securities. The value of such instruments and securities changes in response to fluctuations in interest rates and in the perceived credit risk associated with a particular instrument/security and its issuer. When interest rates decline, the value of fixed-rate debt instruments generally can be expected to rise. Conversely, when interest rates rise, the value of fixed-rate debt instruments generally can be expected to decline. In addition, to the extent that the receivables or loans underlying specific securities are prepayable without penalty or premium, the value of such securities may be negatively affected by increasing prepayments, which generally occur when interest rates decline. In addition, fixed income and debt obligations are subject to the risk of an issuer’s inability to meet principal and interest payments on the obligation. 2. Prepayment Risk The frequency at which prepayments (including voluntary prepayments by the obligors and liquidations due to default and foreclosures) occur on loans and other underlying debt investments will be affected by a variety of factors including, but not limited to, the prevailing level of interest rates as well as economic, demographic, tax, social, legal and other factors. In general, “premium” financial instruments (i.e., financial instruments whose market values exceed their principal or par amounts) are adversely affected by faster than anticipated prepayments, and “discount” financial instruments (i.e., financial instruments whose principal or par amounts exceed their market values) are adversely affected by slower than anticipated prepayments. Since Client accounts may include discount financial instruments when interest rates are high, and may include premium financial instruments when interest rates are low, such investments will be adversely affected by prepayments in any interest rate environment. 3. High Yield Investments Client accounts typically include high-yield or non-investment grade securities and instruments. Such investments generally trade in the over-the-counter marketplace, which is less transparent and less liquid than the exchange-traded marketplace. In addition, Client portfolios often invest in the debt of companies that do not have publicly traded equity securities, making it more difficult to determine or to hedge the risks associated with such investments. Client accounts generally have no minimum credit standard for investments in any asset, and as a result, a significant portion of a Client account is frequently invested in below investment grade obligations. Non-investment grade securities face ongoing uncertainties and exposure to adverse business, financial or economic conditions which could lead to the issuer's inability to meet timely interest and principal payments. The market values of certain of these lower-rated and unrated debt securities (often referred to as junk bonds) tend to reflect individual corporate developments to a greater extent than do higher-rated securities which react primarily to fluctuations in the general level of interest rates and tend to be more sensitive to economic conditions. Companies that issue such securities are often highly leveraged and may not have available to them more traditional sources of financing. It is possible that an economic downturn could adversely affect the ability of the issuers of such securities to pay interest or repay principal on such securities, which would likely have an adverse impact on their value. 4. Corporate Loans A Client’s investment program will generally (or primarily in the case of the certain loan-focused investment products) include investments in corporate loans and commitments to purchase loans. These obligations are subject to unique risks, including, but not limited to: (i) limitations on the ability of a Client to directly enforce its rights with respect to loan investments entered into through participations; (ii) counterparty risk due to extended settlement periods or in connection with participations; (iii) the possible invalidation of an

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As described above in Items 4 and 5, Beach Point Clients and Fund investors may include, but are not limited to, state and local government pension plans, foreign funds, foreign governmental entities, foreign pension schemes, individuals, companies, insurance companies, private pension plans, corporate plans, endowments, trusts, foundations, charitable organizations and other investment funds. Fund investors must meet the investor qualifications associated with each Fund (which generally require Fund investors to be “accredited investors” and “qualified purchasers”, as such terms are defined in the federal securities laws). A. Managed Accounts and Single Client Funds Beach Point generally requires a minimum investment of $100 million to open a Managed Account or Single Client Fund. This minimum may be reduced or waived by Beach Point in its sole discretion. B. Open-End Funds With respect to open-end Funds, minimum investments are generally set forth in each Fund’s governing documents; however, the general partner or the Board of Directors of a Fund, as the case may be, may reduce or waive the minimum investment amount in its sole discretion (subject to certain minimum subscription requirements under Cayman Islands law in the case of certain offshore funds). C. Closed-End Funds The minimum capital commitment for an investor in a closed-end Fund is generally between $5 million and $10 million; however, the general partner may reduce or waive the minimum investment amount in its sole discretion.

As more fully described above in Item 5, Beach Point Clients pay an asset-based management fee and certain Beach Point Clients also pay performance-based compensation. Managing Client accounts that pay both an asset-based management fee and performance-based compensation alongside Client accounts that pay only an asset-based management fee creates certain conflicts of interest for Beach Point. Beach Point and its supervised persons have an incentive to allocate the best investment ideas to those accounts that pay performance-based compensation and thus favor them over those accounts that pay only an asset-based management fee. In order to address this conflict, and in accordance with Beach Point’s fiduciary duty owed to our Clients, Beach Point has implemented an allocation policy to help ensure investment opportunities are allocated among accounts in a fair and equitable manner over time. The allocation policy provides the acceptable criteria upon which trades may be allocated and does not permit Beach Point to give preference to accounts based on the type of fee structure, the amount of fees, or the receipt of any other benefit by Beach Point or its personnel. In general, Beach Point’s practice is to allocate trades pro rata (based on the current or anticipated asset value of each account or the target position size or the size of the existing position, etc.) among accounts within the same strategy. Notwithstanding the foregoing, but subject to Beach Point’s fiduciary duty to treat all Clients fairly and equitably over time, certain allocations will deviate from a pro rata allocation among

accounts due to certain circumstances and factors described below in Item 12 Brokerage Practices under the heading Order Aggregation and Allocation.

A. Related Investment Advisers Beach Point CLO Management LLC, a related person of Beach Point, acts as the collateral manager of Beach Point-Managed CLOs and is deemed to be a relying adviser pursuant to Beach Point’s SEC registration. B. Other Entities Sponsored by Beach Point and its Affiliates A related person of Beach Point acts as the general partner or managing member of certain Funds. Beach Point Capital Europe LLP (“Beach Point Europe”), a related person of Beach Point, is an entity organized under the laws of the United Kingdom and authorized by the U.K. Financial Conduct Authority to, among other things, provide investment advisory services and perform marketing activities. Beach Point Capital (Ireland) DAC (“Beach Point Ireland”), a related person of Beach Point, is an entity organized under the laws of the Republic of Ireland that manages vehicles organized as designated activity companies which are qualifying companies for the purposes of section 110 of the Irish Taxes Consolidation Act 1997 (each, a “DAC”). Beach Point Europe and Beach Point Ireland also provide research services to Beach Point and its affiliates with respect to issuers located outside of the United States. BPCM Investment Trust GP LLC, a related person of Beach Point, acts as the general partner of BPCM Investment Trust LP, the entity that currently owns equity of a private REIT for which Beach Point serves as investment manager. BPC RT Manager LLC, a related person of Beach Point, acts as the general partner of BPC RT LLC, the captive REIT of BPC Real Estate Debt Fund LP. BPC Lending Holdings LLC, a related person of Beach Point, acts as the managing member of lending entities through which certain loan origination activities are conducted. In some circumstances, Clients may invest in or through a special-purpose vehicle, or SPV, formed to hold certain assets (for example residential whole mortgage loans), or formed to address certain tax, legal, accounting, regulatory, financing, or other concerns. BPC AS LLC or BPC AS Cayman LLC, each a related person of Beach Point, typically manage or act as the general partner or managing member of such SPVs. Joint participation in SPVs by multiple Clients can lead to conflicts among them when, for example, one Client seeks to end its participation or seeks the resolution or disposition of an SPV’s assets while other Clients seek continued participation.

Conflicts of Interest A. Code of Ethics Pursuant to Rule 204A-1 under the Advisers Act, Beach Point has adopted a Code of Ethics (the “Code”) which sets forth standards of business and personal conduct for all Beach Point employees and addresses conflicts including those that may arise from personal trading by employees. Below is a summary of certain provisions contained in the Code. The Code requires employees to pre-clear all purchases and sales of securities unless otherwise exempted by the Code. If the requested security transaction is approved, the approval is good only for the day on which it was received (i.e., employees need to execute the approved trade on the day it is approved or preclear and receive approval again). Employees are prohibited from transacting in options on single-name stocks, single-stock ETFs and transacting in any Security of an issuer (other than a Fully Exempt Security or a Partially Exempt Security) if any Client holds an investment in such issuer. In addition, certain blackout periods apply to the purchase and sale of certain financial instruments. With limited exceptions, employees are prohibited from selling (or buying to cover) a Security (other than a Fully Exempt Security or a Partially Exempt Security) within 30 calendar days of the most recent purchase (or short sale), regardless of gain or loss. Employees are prohibited from acquiring securities in an initial public offering (IPO) or acquire coins in an initial coin offering (ICO) unless prior approval is received from the Chief Compliance Officer. Investments in private funds, including funds advised by Beach Point, require prior approval from the Chief Compliance Officer or a designee. Employees are also generally prohibited from serving as directors of other companies unless approval is obtained from (a) the Chief Investment Officer or a Portfolio Manager to serve as a director, or in a similar capacity, of a portfolio company of a Client managed by Beach Point and (b) except as otherwise provided in the Code, the Chief Compliance Officer to serve as a director, or in similar capacity, in all other circumstances. In addition, the Code includes restrictions and reporting obligations in connection with gifts and entertainment. The Code also requires employees to pre-clear all Political Activity (as defined in the Code). Employees may make a request to the Chief Compliance Officer for an exception from certain of the abovelisted restrictions. Such exceptions are granted, if at all, only under limited circumstances. Employees must report personal securities holdings upon becoming an employee and annually thereafter. Employees must also report their personal securities transactions on a quarterly basis. In addition, employees are required to provide duplicate brokerage statements to Beach Point’s Compliance Department (preferably via electronic data feed into Beach Point’s code of ethics monitoring system). Beach Point also maintains insider trading policies and procedures (the “Insider Trading Policies”) that are designed to prevent the misuse of material, non-public information. Beach Point’s personnel are required to certify to their compliance with the Code and the Insider Trading Policies on a periodic basis. Beach Point or its related persons, in the course of their investment management and other activities (e.g., board or creditor committee service), may come into possession of confidential or material nonpublic information about issuers, including issuers in which Beach Point or its related persons have invested or

seek to invest on behalf of Clients. Beach Point is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, regardless of whether such other person is a Client. Beach Point maintains and enforces written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to assure that Beach Point is meeting its obligations to its Clients and remains in compliance with applicable law. In certain circumstances, Beach Point may possess certain confidential or material, nonpublic information that, if disclosed, might be material to a decision to buy, sell or hold a security, but Beach Point will be prohibited from communicating such information to the Client or using such information for the Client’s benefit. In such circumstances, Beach Point will have no responsibility or liability to the Client for not disclosing such information to the Client (or the fact that Beach Point possesses such information), or not using such information for the Client’s benefit, as a result of following the Beach Point’s policies and procedures designed to provide reasonable assurances that it is complying with applicable law. Beach Point’s Compliance Committee has been formed to help ensure that a proper compliance control environment exists at Beach Point. All employees are subject to oversight by the Compliance Committee and are expected to be familiar with Beach Point’s compliance policies and procedures and their responsibilities thereunder. Compliance Committee’s oversight responsibility includes, but is not limited to: (i) reviewing the Annual Compliance Program Review Report and policies and procedures submitted by the Chief Compliance Officer for committee review; (ii) monitoring regulatory developments, risk alerts, and enforcement actions, and disseminating relevant information to maintain and enhance the compliance program; (iii) reviewing reports prepared by the Chief Compliance Officer regarding compliance-related issues including, but not limited to, instances of non-compliance with Beach Point’s policies and procedures; and (iv) addressing and resolving significant compliance issues or conflicts of interest, as necessary. Beach Point maintains a strong culture of compliance and a commitment to addressing compliance violations. Violations of the trading prohibitions and restrictions set forth in the Code may result in disciplinary action which may include, among other things, a warning, additional training, suspension of personal trading privileges, reversal of a transaction, disgorgement of profits and other action as determined by the Chief Compliance Officer and other members of Beach Point’s Compliance Committee as considered necessary at that time, including termination of employment. Beach Point strives to maintain an environment that encourages compliance with securities laws and internal reporting of any possible violation thereof. Beach Point will not under any circumstances prohibit an employee from reporting a possible securities law violation in connection with Beach Point’s business or operations (referred to herein as “Misconduct”). Each employee is encouraged to immediately report any possible Misconduct that the employee believes has occurred, is ongoing or is about to occur in accordance with Beach Point’s whistleblower procedures set forth in Beach Point’s Compliance Manual. Beach Point’s policies and procedures require employees to conduct Firm‑related business communications only through approved channels that are subject to Beach Point’s books‑and‑records and retention requirements and prohibit the use of unapproved personal devices or messaging applications for Firm‑related business communications, except as permitted under Beach Point’s policies. Beach Point periodically reviews and updates its compliance policies and procedures, including those relating to fees and expenses, marketing practices, cybersecurity, privacy, and the use of technology such as AI, considering evolving SEC rules, Risk Alerts and examination priorities.

New employees receive initial compliance training on the Code and other compliance policies and procedures. In addition, the Compliance Department provides various compliance trainings throughout the year for employees. Managed Account Clients and Fund investors may obtain a copy of the Code free of charge by contacting the Compliance Department at (310) 996-9700. B. Cross Trades Beach Point may cause the purchase or sale of a financial instrument to be made between two or more Funds or Managed Accounts (“cross trades”) unless prohibited or restricted by applicable law or by a Client. When effecting cross trades between Clients, Beach Point will have potentially conflicting division of loyalties and responsibilities with respect to each participating Client. Beach Point addresses this potential conflict of interest by conducting cross trades only in compliance with Beach Point’s Cross Trade Policy. The policy permits a cross trade only under certain conditions, including that Beach Point believes the transaction is in the best interest of all of the Clients participating in the cross trade. In addition, Beach Point has developed cross trade procedures which include submitting (i) the proposed cross trade price (and supporting documentation) to the Valuation Department for review; and (ii) a completed Cross Trade Report, with required portfolio manager signatures, to the CCO for review and approval or denial of the proposed cross trade. At each monthly meeting of the Valuation Committee, the committee reviews cross trades executed during the prior month as part of the committee’s oversight responsibilities. Beach Point does not receive any special compensation for effecting cross trades. Commissions, if any, related to such cross trades are generally shared equally among the Clients involved in the trade. C. Other Conflicts of Interest The following discussion enumerates certain potential conflicts of interest in addition to those described above that should be carefully evaluated before making an investment in any Fund, Managed Account or any future investment vehicle managed by Beach Point. Beach Point has established policies and procedures that seek to identify, manage and/or mitigate such potential conflicts of interest, although they may not be successful in doing so. 1. Investments Managed by Third-Party Investment Managers Certain Clients have an equity interest in a third-party investment manager that provides investment advisory services to certain private partnerships in which such Clients are invested. Beach Point may allocate an investment in future private funds or partnerships advised or managed by such third-party investment manager to certain Funds and Managed Accounts (including those that do not own an interest in the third-party investment manager). From time to time, Beach Point may cause certain Funds and Managed Accounts to invest in pooled investments or other structured vehicles or funds, including, without limitation, those managed by thirdparty investment managers. A Client may incur expenses (including, without limitation, asset-based management fees and performance-based compensation earned by third-party investment managers) in addition to the fees paid to Beach Point even though the Client may not achieve any gain with respect to such investments.

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Beach Point generally has discretionary authority to manage the Client accounts, including the authority to determine which securities are to be bought and sold and the amounts appropriate for each Client. Any limitation on Beach Point’s authority is described in a Client’s investment management agreement and/or other governing documents. Beach Point’s Brokerage Committee oversees all trading practices and brokerage relationships of Beach Point. The responsibilities of the Brokerage Committee include, but are not limited to the following: reviewing, approving and monitoring executing brokers and other trading counterparties (i.e., ISDA counterparties); reviewing the results of quarterly testing of best execution; monitoring the brokerage volume levels for both Beach Point and the Clients for which Beach Point provides investment advisory services. The Brokerage Committee is also responsible for reviewing and approving Beach Point’s (i) commission sharing arrangements (if any), (ii) use of soft dollars (if any), and (iii) the implementation of policies and procedures related to soft dollars. In selecting brokers or dealers to effect portfolio securities transactions, Beach Point will comply with its fiduciary duty to seek “best execution” on behalf of Clients. Beach Point will consider relevant factors, including, among other things: (a) price, (b) the nature of the market, (c) quantity, (d) the execution capabilities required by the transaction, (e) commissions, (f) the importance of speed and efficiency, (g) the reputation and perceived soundness of the broker or dealer, (h) block trading and block positioning

capabilities, (i) willingness to execute related or unrelated difficult transactions in the future, and (j) brokerage and research products and services provided to Beach Point. There are rarely brokerage commissions on fixed income transactions. Fixed income transactions are typically effected on a “net” basis. Therefore, Clients are not expected to pay significant brokerage commissions on fixed income transactions. It is noted, however, that should any transactions for Clients be effected for which brokerage commissions are charged, Beach Point will seek to obtain favorable commissions in light of its efforts to obtain “best execution” on all transactions. Beach Point is not obligated to obtain the lowest commission or best net price for a Client on any particular transaction. A. Research and Other Soft Dollars Benefits From time to time, unless prohibited by a Client’s investment management agreement and/or other governing documents, Clients pay a broker-dealer commissions (or markups or markdowns with respect to certain types of riskless principal transactions) for effecting transactions in excess of that which another broker-dealer might have charged for effecting the transaction in recognition of the value of the brokerage and research products or services provided by the broker-dealer or a third party vendor (“soft dollars”). Beach Point will endeavor to effect such transactions, and receive such brokerage and research products and services, only to the extent that they fall within the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934, as amended, and subject to prevailing guidance provided by the SEC regarding Section 28(e). Beach Point believes it is important to its investment decision-making processes to have access to independent research. While Beach Point seeks to comply with its best execution obligations, Clients should be aware that the value of research and services received may influence broker selection decisions. Beach Point’s use of soft dollars to pay for research products and services benefits Beach Point because Beach Point does not have to produce or pay for the research products or services. Beach Point may have an incentive to select a broker-dealer based on its interest in receiving the research or other products or services rather than on a Client’s interest in receiving the most favorable execution of trades. Beach Point mitigates this conflict through the oversight procedures described above and by seeking to ensure that commissions paid are reasonable in relation to the value of brokerage and research services received. At meetings of the Beach Point Brokerage Committee, members of the trading staff are asked to confirm that commissions paid during the applicable period were reasonable in relation to the value of the brokerage and research products and services provided by the brokers. Traders are also asked to confirm the broker selection process was not influenced by conflicts of interest. In addition, a portfolio manager is asked to confirm that (i) the research services provided by the brokers assisted in the performance of the investment team’s investment decision-making responsibilities, (ii) the portfolio manager believes that the commissions paid during the period were reasonable in relation to the value of the services paid with soft dollar credits, and (iii) the Beach Point trading desk sought to achieve best execution during the applicable quarter. The research products or services furnished by brokers-dealers through which Beach Point effects transactions may be used for the benefit of Clients other than the particular Client whose transactions generated the soft dollars. Beach Point does not seek to allocate soft dollar benefits to Funds or Managed Accounts in proportion to the soft dollar credits generated by such Funds or Managed Accounts. The research products or services furnished to Beach Point by broker-dealers may include, among other things, investment and financial market research, securities and economic analysis, company information and quotation services. The research received from a broker-dealer may be proprietary research (created

or developed by the broker-dealer) and/or research created or developed by a third party. For example, Beach Point has used soft dollars to acquire proprietary research analyzing the performance of particular companies and to pay for certain third party products and services, including financial software and data license fees, but excluding any hardware fees for the terminal, computer cables and cable lines associated with the delivery of such software or data. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker-dealer may be less than the suggested allocation, but can exceed the suggested level, because total brokerage is allocated on the basis of all of the considerations described above. In no case will Beach Point make binding commitments as to the level of brokerage commissions it will allocate to a broker-dealer, nor will it commit to pay cash if any informal targets are not met. A broker-dealer is not excluded from receiving business because it has not been identified as providing research products or services. B. Brokerage for Client Referrals Certain Fund investors are vehicles organized and managed by affiliates of broker-dealers. In addition, certain broker-dealers organize events pursuant to which certain of their clients may learn more about select investment advisers, including Beach Point. There may be an incentive for Beach Point to direct Client transactions to such broker-dealers. Beach Point has policies in place, including a best execution policy, designed to prevent the selection of broker-dealers based solely on the receipt of such benefits by Beach Point or its Clients. In addition, Beach Point has a Brokerage Committee that reviews, approves and monitors executing broker-dealers and other trading counterparties. C. Directed Brokerage To the extent a Client directs Beach Point to use a particular broker or dealer, Beach Point may not be authorized under those circumstances to negotiate price and may not be able to obtain volume discounts or best execution for such Client. In addition, under these circumstances a disparity in prices may exist between Clients who direct Beach Point to use a particular broker or dealer and other Clients who do not direct Beach Point to use a particular broker or dealer. As a result, the Client that directs brokerage may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions than would otherwise be the case if Beach Point used other or multiple brokers. D. Order Aggregation and Allocation 1. Overview Due primarily to the nature of the market for the investments that typically comprise a significant portion of the assets held in Client accounts (e.g., below investment grade credit-related instruments, private investments, structured products, etc.), the amount of an investment that Beach Point desires to buy or sell at the price Beach Point deems appropriate often cannot be fully accommodated. As a result, Beach Point has implemented an Investment Allocation and Aggregation Policy (the “Allocation Policy”) to set forth how Beach Point aggregates trade orders and allocates investments purchased and sold among accounts. In accordance with Beach Point’s fiduciary duty owed to our Clients, the overall objective of the Allocation Policy is to allocate trades to Clients fairly and equitably over time. Beach Point does not allocate trades based on a Client’s fee structure, including whether the Client pays a performance-based fee, and does not otherwise allocate trades to benefit itself or its officers or employees. In general, Beach Point’s practice is

to allocate trades pro rata (based on the asset value of each account or the target position size or the size of the existing position, etc.) among accounts within the same strategy. Notwithstanding the foregoing, but subject to Beach Point’s fiduciary duty to treat all Clients fairly and equitably over time, certain allocations will deviate from a pro rata allocation among accounts due to certain circumstances and factors described below. 2. Trade Order Aggregation To achieve optimal execution and lower transaction costs, whenever practicable, Beach Point trades blocks of financial instruments in order to aggregate orders for groups of Clients. In such circumstances, an account participating in the aggregated order will do so at the executed price, and all transaction costs, if any, are shared on a pro rata basis or equally, depending on the type of cost. Beach Point allocates such orders among all participating accounts in a manner Beach Point believes to be fair and equitable to each Client over time. As noted below, in the event that Beach Point is not able to buy or sell a specified amount of an investment at the desired price, the amount bought or sold is allocated based upon the investment allocation considerations detailed in Beach Point’s Allocation Policy as described below. 3. Trading Authority and Timing of Allocation Beach Point is authorized to determine which investments are bought and sold and the amounts appropriate for each account. Any limitation on Beach Point’s authority is set forth in an account’s governing documents (e.g., investment management agreement, private placement memorandum, partnership agreement, etc.). Although a portfolio manager places a trade order with an understanding of the accounts to which such trade will be allocated, Beach Point’s practice is to allocate investments after a trade has been executed so that Beach Point knows the actual amount to be allocated. To the extent certain accounts in a strategy are not allocated an investment due to investment allocation considerations set forth in the Allocation Policy, the portfolio manager for such excluded accounts may seek to purchase the investment at a later date (if the investment is available at an attractive price) or may purchase other investments for the accounts. Furthermore, in the event accounts within a strategy are consistently excluded from certain investments (e.g., offshore Funds and Managed Accounts are frequently unable to participate in loan originations due to tax considerations), such accounts may receive a larger than pro rata allocation of other investments. E. Allocation Guidelines 1. Overview When practicable and permissible, trades are allocated pro rata (based on the current or anticipated asset value of each account, the target size of the position within each account, the amount of available cash, the size of the existing position in the account, etc.) among accounts within the same strategy. However, due to circumstances and factors described above and in accordance with the allocation guidelines set forth below, among others, Beach Point expects to deviate from a pro rata allocation given the nature of the investments it trades on behalf of Clients and the investment strategy and objectives pursued by such Clients. In addition, as stated above, the allocation of follow-on investments may differ from the allocation of the initial purchase of such investments due to the existence of circumstances and/or factors described in the Allocation Policy at the time of the allocation of such follow-on investments.

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Beach Point may receive research products or services provided by broker-dealers or third-party vendors as described in Item 12 of this brochure. From time to time, Beach Point compensates third parties, Clients or Fund investors (collectively, “Promoters”) for the solicitation or referral of a Client or Fund investor in a manner that constitutes a testimonial or endorsement under Rule 206(4)‑1 under the Advisers Act (the ‘Marketing Rule’). Beach Point has adopted policies and procedures reasonably designed to comply with the Marketing Rule, including provisions governing the use of testimonials and endorsements. Despite these policies and procedures, the use of testimonials and endorsements in marketing materials involves inherent conflicts of interest. Beach Point maintains documentation to demonstrate compliance with the Marketing Rule. These arrangements may involve cash compensation, non‑cash compensation, or other economic benefits and therefore create a conflict of interest because Promoters have a financial incentive to recommend Beach Point. Clients should also be aware that testimonials and endorsements reflect the experience of specific individuals and may not be representative of all client experiences and compensated endorsers have a financial incentive to provide favorable testimonials. Beach Point enters into written agreements with compensated Promoters when required by the Marketing Rule and takes reasonable steps to ensure that such Promoters provide prospective Clients and investors, at the time the testimonial or endorsement is disseminated, with the disclosures required by the Marketing Rule, including the fact and nature of the compensation, the material terms of the relationship, and any material conflicts of interest. Beach Point also conducts due diligence reasonably designed to avoid compensating ‘ineligible persons’ as defined in the Marketing Rule and to ensure that relationships with affiliated Promoters are clearly disclosed.

To Beach Point’s knowledge, none of the Firm or any of its management personnel has been involved in, or subject to, any disciplinary events or legal actions that would be material to a Client’s or prospective client’s evaluation of Beach Point’s advisory business or the integrity of Beach Point’s management.

Each Client is assigned to one or more portfolio managers in the investment strategy being pursued by such account and, where practicable, to a portfolio manager who is managing similar portfolios within the strategy for other Clients (i.e., accounts with similar investment guidelines and limitations and/or restrictions). A portfolio manager assigned to a Client’s portfolio is primarily responsible for daily oversight of the portfolio. Additionally, all the portfolio managers in a strategy (to the extent there is more than one portfolio manager managing accounts in the strategy) meet regularly as a team to evaluate, among other things, (1) investment ideas, (2) current positions in the portfolios, (3) appropriate sizing of positions, (4) buy / sell lists (including target sizes and prices and current market levels), (5) portfolio exposure to certain

assets types, industries, issuers, etc. (6) the risk profile of the portfolio (including liquidity profile and, as applicable, Responsible Investment scores), (7) how the portfolio compares to its benchmark, if any, and (8) if the Client’s investment objectives are being achieved. With respect to specialized accounts focusing on certain types of investments or asset classes, there may be only one portfolio manager managing the account(s) in the strategy. Beach Point portfolio managers are supported by a team of investment analysts, portfolio analysts, and risk analysts. In addition, the portfolio managers of specialized strategies have access to the other portfolio managers to discuss investment ideas. Finally, all portfolio managers are subject to oversight by Beach Point’s Chief Investment Officer. The Chief Investment Officer is supervised by one or both of Beach Point’s Co-CEOs. Oversight by the CEOs and/or the Chief Investment Officer may include participation in portfolio manager meetings and investment team research meetings, and membership on a Fund’s investment committee, as applicable. The combination of individual portfolio manager supervision of each account, broader investment team idea generation, and CEO/Chief Investment Officer oversight is designed to ensure that each account receives the requisite attention required to maintain an appropriately constructed portfolio (given the particular circumstances of each account) and to provide consistency in the investment process across all accounts in the same strategy. In addition, each Client is regularly monitored by Beach Point’s order management and compliance system to help ensure that account investment guidelines are followed. Each compliance alert triggered by the system is reviewed, researched and, where appropriate, cleared by Beach Point’s Compliance Department. If an alert cannot be cleared, appropriate remedial action is taken (e.g., the instrument is not allocated to the Client). Fund investors receive unaudited monthly/quarterly account statements and an annual report containing audited financial statements and a statement of their capital account/share holdings as of the fiscal yearend. Managed Account Clients receive monthly statements and quarterly/annual reports from third-party custodians. Fund investors and Managed Account Clients typically receive monthly exposure reports and quarterly letters that generally include performance data and market commentary. Fund investors in domestic Funds also receive annual K-1 statements for the Fund in which they are invested. From time to time, Beach Point receives information requests from investors concerning their investments in a Fund. In connection with such requests, Beach Point, in its discretion, may disclose certain portfolio holdings information (or other information related thereto) of a Fund to entities that evaluate portfolio risk for investors or to certain investors that have unique regulatory and/or risk reporting obligations. However, Beach Point reserves the right (i) to determine what information is appropriate to provide in response to such requests, or (ii) refuse such request. When information is disclosed, every effort is made to require the recipient of such information to keep the information confidential, including requiring the recipient to enter into a non-disclosure agreement prior to providing the information to them. However, there can be no assurance that these entities will fulfill their confidentiality obligations to Beach Point. In addition, investors, in the course of conducting due diligence, may request information pertaining to their investments in a Fund (either verbally or in writing), including information that is not generally made available to all investors of such Fund. Beach Point may respond to such requests without providing all of such information to other Fund investors so long as Beach Point reasonably believes that the disclosure of such information would not have a material adverse impact on other Fund investors.

Beach Point has an obligation to safeguard Client assets and protect them from loss or destruction. Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) imposes specific conditions on registered investment advisers who have actual or deemed custody of Client assets. The Custody Rule contains a definition of the term “custody” which includes “holding, directly or indirectly, Client funds or securities or having any authority to obtain possession of them.” The definition also includes three non-exclusive examples of custody, including when an investment adviser acts as general partner of a limited partnership. Accordingly, Beach Point is deemed to have custody of the assets of each Fund for which Beach Point or an affiliate serves as general partner or managing member. Beach Point adheres to the applicable requirements of the Custody Rule with respect to each Fund for which it or an affiliate serves as general partner. All Fund securities are held with at least one qualified custodian, and the offering memorandum for each such Fund identifies each qualified custodian used by the Fund. For Funds, Beach Point relies on the audit provision of the Custody Rule. Each Fund undergoes an annual audit by an independent public accountant registered with and subject to regular inspection by the Public Company Accounting Oversight Board (PCAOB). In addition, Beach Point arranges for the delivery to investors in each of the Funds of a copy of the audited financial statements for their Fund, prepared in accordance with U.S. generally accepted accounting principles, on an annual basis, and within the required periods set forth in the Custody Rule. In addition, as described above in Item 13, Fund investors also receive unaudited monthly account statements from their Fund’s administrator and a statement of their

capital account / share holdings as of the fiscal year-end. Fund investors should carefully review their monthly account statements, their annual statements and their Fund’s audited financial statements. Managed Account Clients select their own custodian to maintain custody of their funds and securities. Beach Point is not a party to the custodial agreements between the Managed Account Clients and their custodians. As a discretionary investment adviser, Beach Point has trading discretion over the funds and securities maintained in a Managed Account Client’s custodial account, but Beach Point does not hold such funds or securities or have authority to obtain possession of them.

Beach Point serves as the investment adviser to Clients. Beach Point generally has discretionary authority to manage Client portfolios, including the authority to determine which investments are bought and sold and the amounts appropriate for each Client. Any limitation on Beach Point’s authority is set forth in a Client’s governing documents (e.g., investment management agreement, private placement memorandum, partnership agreement, etc.). Beach Point does not assume discretionary authority to manage portfolios on behalf of Clients until entering into an investment management agreement and/or other governing documents.

Beach Point votes proxies on behalf of Clients when so authorized by the Client’s investment management agreement or other governing documents. In addition, there may be a variety of corporate actions or other matters for which shareholder or bondholder action is required or solicited with respect to which Beach Point may take action that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the relevant Client. These actions requiring shareholder or bondholder action may involve, for example and without limitation, tender offers or exchanges, bankruptcy proceedings and class actions. When voting on proxy proposals and corporate actions for Clients, Beach Point’s utmost concern is that all decisions be made solely in the interests of the Client consistent with the Advisers Act and (as applicable) the Employee Retirement Income Security Act of 1974, as amended. Beach Point has retained the services of an independent third party to help receive and evaluate proxies, effect proxy votes and maintain appropriate proxy voting records. Beach Point will act in a manner that is intended to enhance the economic value of the assets held in its Clients’ portfolios. Where a proxy proposal or corporate action raises a material conflict of interest between Beach Point and a Client, Beach Point will (i) disclose the conflict to the Client and obtain its consent to the proposed vote prior to voting the securities, (ii) vote the securities based on the recommendation of an independent third party, or (iii) take such other action as may be appropriate given the particular facts and circumstances. In addition, a Client may direct Beach Point how to vote in a particular solicitation by providing instructions to Beach Point prior to the date such vote is due. Beach Point’s proxy voting authority creates potential conflicts of interest in various circumstances. For example, when Beach Point votes in opposition to a portfolio company’s management recommendations, such voting decisions may adversely affect Beach Point’s relationship with the company’s management and may impact Beach Point’s ability to negotiate favorable terms for current or future investments, participate in board representation, or receive confidential information from the company.

In some cases, Beach Point or its affiliates may have business relationships with portfolio companies (such as serving as administrative agent, arranger, or advisor) or with selling shareholders, financial sponsors, or other stakeholders in proxy matters; these relationships may create conflicts between Beach Point’s interests and the best interests of Clients with respect to proxy voting decisions. Additionally, because Beach Point manages multiple Clients that may hold different securities in the same issuer’s capital structure (for example, one Client may hold senior debt while another holds equity), proxy matters may present situations where the interests of senior creditors diverge from those of equity holders. Beach Point will vote in accordance with its assessment of each Client’s best interests based on the securities held by such Client, but its determination may not be optimal for all Clients. Beach Point maintains a Proxy Voting and Corporate Actions Policy that governs these circumstances and is designed to ensure it votes in the best interests of Clients, taking into account the conflicts described above. Clients may obtain a copy of Beach Point’s Proxy Voting and Corporate Actions Policy and information about how Beach Point voted proxies on their behalf by contacting Beach Point’s Investor Relations Department at (310) 996-9700.

Beach Point does not require or solicit pre-payment of advisory fees. There are no financial conditions that are reasonably likely to impair Beach Point’s ability to meet its contractual commitments to Clients.