Private company

BROOKFIELD RENEWABLE ENERGY GROUP LLC

BROOKFIELD RENEWABLE ENERGY GROUP LLC is a limited liability company registered in Delaware, active since 2011.1 It is headquartered in New York, United States.1

Last updated Oct 21, 2026.

Overview

Oct 7, 2011Founded1
  • HeadquartersNew York, United States1
  • Legal formLimited Liability Company1
  • LEI5493000N53YK2HIMED691
  • StatusActive1
  • LEI statusIssued and current1
  • Registered addressC/O CORPORATION SERVICE COMPANY, 19808 Wilmington, United States1
  • Registered withDivision of Corporations, Department of State, 50493171

Corporate structure

BROOKFIELD RENEWABLE ENERGY GROUP LLC is part of a group headed by Brookfield Corporation. 428 entities, 22 countries on record. Switch between the flow chart and the network, and select any entity to see its details.

Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); subsidiaries listed in Exhibit 21 of annual reports filed with the SEC; subsidiaries, stakes and holdings from Wikidata (CC0). Each entity in the chart links to its source.

Investment adviser

BROOKFIELD RENEWABLE ENERGY GROUP LLC is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.

  • Assets it manages$99.1B2 125 accounts, all with discretion
  • Employees1,072 1,072 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and: 122 ($97.2B); Investment companies: 1 ($1.9B); Other: SEPARATELY MANAGED ACCOUNTS: 2 ($26.2M)
  • How it is paidA percentage of assets under its management; Performance-based fees
  • What it doesPortfolio management for pooled investment vehicles (other than investment companies)
  • Holds client assetsYes: cash and securities
  • RegistrationSEC 801-122588, CRD 316590 IAPD record

Who owns it

Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).

  • BROOKFIELD POWER HOLDINGS LLCowns 75% or more, since 10/2011
  • BROOKFIELD ASSET MANAGEMENT ULCowns 75% or more of BROOKFIELD US, since 12/2022
  • BROOKFIELD US HOLDINGS INCowns 75% or more of BROOKFIELD US, since 11/1994
  • BROOKFIELD US INCowns 75% or more of BROOKFIELD, since 10/2011

Disciplinary record

The firm answered yes to 2 of the disciplinary questions on Form ADV (Item 11). A yes can concern the firm itself or an affiliate.

  • Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has found the firm or an advisory affiliate to have been involved in a violation of investment-related regulations or statutes.
  • In the past ten years, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has entered an order against the firm or an advisory affiliate in connection with an investment-related activity.

Each event as the firm describes it on its Disclosure Reporting Pages:

SECURITIES AND EXCHANGE BOARD OF INDIA (SEBI) · Mar 19, 2021 · fine $114,865 · final about SRIDHAR RENGAN

Allegations: THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT: (1) PENBROOK CAPITAL ADVISORS PRIVATE LIMITED ("PENBROOK"), THE INVESTMENT MANAGER OF PENINSULA BROOKFIELD INDIA REAL ESTATE FUND (THE "FUND") AND A JOINT VENTURE BETWEEN (I) BROOKFIELD CAPITAL PARTNERS LTD (BERMUDA), A WHOLLY OWNED SUBSIDIARY OF BROOKFIELD ASSET MANAGEMENT INC., AND (II) PENINSULA LAND LTD, A THIRD-PARTY REAL ESTATE DEVELOPER); (2) THE CURRENT AND FORMER DIRECTORS OF PENBROOK, INCLUDING ANUJ RANJAN (FORMER DIRECTOR) AND SRIDHAR RENGAN (CURRENT DIRECTOR); AND (3) PENINSULA BROOKFIELD TRUSTEE PRIVATE LIMITED, (THE TRUSTEE OF THE FUND, HAVING THE SAME SHAREHOLDERS AS PENBROOK) ((1), (2) AND (3) COLLECTIVELY, THE "NOTICEES"), ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT OF 1922 AND REGULATIONS FRAMED THEREUNDER (THE "SEBI ACT"). SEBI FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCE MATTERS ASSOCIATED WITH THE ALLEGED VIOLATIONS.

Sanction: Civil and Administrative Penalt(ies) /Fine(s)

How it ended: Settled

Detail: THE NOTICEES AGREED TO A TOTAL SETTLEMENT AMOUNT OF INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID WITHOUT AN ADMISSION OR DENIAL OF GUILT.

Summary: ON MARCH 19, 2021, THE NOTICEES RECEIVED A NOTICE FROM SEBI ALLEGING THAT THE NOTICEES ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SEBI ACT. THE NOTICE FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCES ASSOCIATED WITH THE ALLEGED VIOLATIONS. IN ORDER TO FULLY SETTLE THE PROCEEDING, THE NOTICEES AGREED TO PAY INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID WITHOUT AN ADMISSION OR DENIAL OF GUILT. No Information Filed

Resolved: Jan 28, 2022

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

Brookfield is a global alternative asset manager with significant assets under management and a long history of owning, managing and operating assets, businesses and investment vehicles across various industries, sectors, geographies, and strategies. Brookfield’s activities include, among others: (a) investment and asset management; (b) sponsoring, offering and managing private and public investment vehicles, including vehicles with proprietary and/or third-party capital, that invest in the global fixed income, currency, commodity, equities, private equity and other markets; (c) managing and investing insurance and reinsurance capital; (d) developing, constructing, owning, managing, operating and servicing a diverse portfolio of real estate, renewable power, infrastructure, private equity, and other companies and assets held by investment vehicles, including among others residential, commercial, logistics, hospitality, storage and mixed-use real estate, data, transport, utilities, midstream, and other infrastructure assets, hydro, wind, solar, distributed energy, sustainable solutions and other renewable power and climate transition assets, and other businesses and assets that provide essential products and services; (e) providing capital and financing solutions, including value-driven, opportunistic and bespoke credit and financing structures, as well as financial advisory, business development and other financial services to its investment vehicles and third-parties; and (f) other activities (collectively, “Brookfield Activities”). Brookfield provides investment advisory services through affiliates that are registered with the SEC as investment advisers under the Advisers Act (collectively, the “Brookfield Advisers”). Each Brookfield Adviser generally serves as investment adviser or sub adviser to Brookfield-sponsored public and private investment vehicles managed on behalf of third-party investors and Brookfield proprietary accounts, including private funds, publicly listed issuers, joint ventures, partnerships, consortiums, separate accounts, co-investment vehicles, sidecar vehicles, region-, strategy- and sector-specific vehicles, and insurance companies (collectively with the Related-Party Investor (as defined herein), “Brookfield Accounts”). BREG, a Delaware limited liability company, provides investment advisory services to Brookfield Accounts that primarily focus on investments in the renewables sector. BREG is a subsidiary of Brookfield Asset Management ULC (“BAM”), which is the primary vehicle through which Brookfield provides investment advisory and related services to Brookfield Accounts. BAM is owned 73% by Brookfield Corporation and 27% by Brookfield Asset Management Ltd., both publicly traded corporations. BAM and its affiliates are collectively referred to herein as “Brookfield.” Among other things, the Brookfield Advisers identify investment opportunities for Brookfield Accounts and participate in the acquisition, management, monitoring and disposition of such investments using an operations‐oriented approach, as described in more detail under “Methods of Analysis, Investment Strategies and Risk of Loss” in Item 8 below. Investment advice is provided directly to Brookfield Accounts and not individually to the investors in Brookfield Accounts (the “Investors”).

BREG tailors the investment advisory services provided to each Brookfield Account based on the Brookfield Account’s investment mandate, which differs from Brookfield Account to Brookfield Account, as set out in the investment management agreement, limited partnership agreement, private placement memorandum and/or other governing documents for each such Brookfield Account (collectively, the “Governing Documents”). The terms of the Governing Documents of each Brookfield Account could differ based on the investment objectives, strategy and other features relating to the Brookfield Account. A key element of BREG’s strategy for each Brookfield Account is to seek to benefit from Brookfield’s broader investment, operational and financial platform by leveraging Brookfield’s broader business platform’s experience, expertise, reach, relationships, connectivity and positioning to enhance and optimize investments, operations and other business activities across industries, sectors, geographies and strategies, including in connection with the sourcing of investment opportunities and deal flow, financial resources, access to capital markets and operating needs. Brookfield believes that this is in the overall best interests of the Brookfield Accounts – i.e., the access to and leveraging of Brookfield’s broader business platform is expected to enhance BREG’s capabilities and increase the value of the Brookfield Accounts – and forms an integral part of Brookfield’s operations. For example, BREG relies on Brookfield’s broader business platform to provide: (a) investment advisory and portfolio management services to Brookfield Accounts, and their direct and indirect investments, (b) operational services to assets and portfolio companies in which Brookfield Accounts invest, and (c) additional investment, operational and financial support. This results in, among other things, Brookfield Accounts: (a) investing in or alongside other Brookfield Accounts, (b) investing in securities, loans, structured financings, and/or other financial instruments issued by other Brookfield Accounts and/or portfolio companies thereof and/or syndicated by Brookfield-related parties, (c) investing in different parts of an issuer’s or portfolio company’s capital structure (relative to investments made by other Brookfield Accounts), (d) transacting with other Brookfield Accounts, including in respect of investments, other assets and/or services, (e) providing financing, refinancing and/or other loans to other Brookfield Accounts and/or portfolio companies / investments thereof for acquisition, investment, financing, working capital, and/or other purposes, (f) providing acquisition financing and other capital solutions to purchasers of assets sold by other Brookfield Accounts, (g) warehousing investments on behalf of other Brookfield Accounts, and (h) retaining Brookfield-related parties for operational, management and/or other services relating to assets and portfolio companies in which Brookfield Accounts invest, including indirectly through other Brookfield Accounts. This business strategy and overall relationship with Brookfield will give rise, in the ordinary course, to various potential and/or actual conflicts of interest considerations, particularly where a Brookfield Account’s interests could conflict with those of other Brookfield Accounts and their third-party investors. For example, Brookfield expects Brookfield Accounts to: (a) compete with other Brookfield Accounts for investment opportunities, (b) from time to time, invest in (or exit from) investments on terms and/or at times that are different from those applicable to other Brookfield Accounts, (c) invest in different parts of an issuer’s / portfolio company’s capital

structure (e.g., debt investments) relative to investments made by other Brookfield Accounts (e.g., equity investments), potentially leading to divergent interests upon certain events, such as defaults by the issuer on debt payments, (d) limit (and, under certain circumstances, reduce) the size of investments made in different parts of an issuer’s / portfolio company’s capital structure relative to investments made by other Brookfield Accounts and manage such investments pursuant to a passive investment strategy – i.e., Brookfield Accounts generally will not vote matters presented to investors in the relevant tranche / class to vote on or otherwise participate in, or seek to influence the outcome of, negotiations and/or decisions relating to the relevant tranche / class, but rather defer to the third-party investors controlling the tranche / class (or an independent third-party agent acting on behalf of all investors in the relevant tranche / class) to act on behalf of all investors in that tranche / class as a whole – so as to mitigate the potential and/or actual conflicts of interest considerations relative to Brookfield’s other client accounts and their investors, (e) provide capital solutions – including financings and/or refinancings – to other Brookfield Accounts and/or portfolio companies thereof, which require a negotiation of the terms of such arrangements, (f) facilitate activities of other Brookfield Accounts, including through warehousing arrangements for and/or joint transactions with other Brookfield Accounts, (g) from time to time be subject to investment / trading restrictions (including prohibitions on trading activities and/or limitations on position sizes) as a result of information obtained and/or other activities engaged in by Brookfield on behalf of other Brookfield Accounts, and/or (f) execute other transactions between certain Brookfield Accounts, on the one hand, and other Brookfield Accounts, on the other hand. A more detailed description of the potential and/or actual conflicts of interest considerations that will arise in connection with the management of Brookfield Accounts as well as the manner in which they are expected to be resolved, is set out under “Other Financial Industry Activities and Affiliations” in Item 10 below. The descriptions of these potential and/or actual conflicts considerations do not purport to provide a complete list or explanation of such considerations that could arise over time. While Brookfield will manage all such situations in a manner that it deems to be fair and reasonable in accordance with regulatory requirements taking into account the relevant circumstances, there can be no assurance that Brookfield’s determinations will be the most beneficial or favorable to the Brookfield Accounts. Brookfield does not participate in any wrap fee programs. As of December 31, 2025, BREG had $99,118,583,713 in regulatory assets under management.

Item 5: Fees and compensation Fees

As compensation for the services it provides to Brookfield Accounts, Brookfield is generally entitled to an annual management fee that is typically calculated and paid quarterly in advance, subject to the terms of the applicable Governing Documents. In addition, Brookfield is generally entitled to performance-based compensation, which typically is equal to a portion of the distributions of investment proceeds attributable to each Investor in a Brookfield Account (other

than affiliates of BREG), subject to the terms of the applicable Governing Documents. Overall fees may vary by Brookfield Account and are determined in accordance with the applicable Governing Documents. Brookfield reserves the right to apply different fee and expense arrangements to Investors on an individual basis. Brookfield charges additional fees in connection with an investment for a Brookfield Account and earns break‐up fees in connection with investments that are not consummated as outlined in the applicable Governing Documents. In addition, representatives of Brookfield from time to time serve on the board of directors of one or more portfolio investments that a Brookfield Account is invested in and receive directors’ fees in connection with such appointment. As set out in the Governing Documents for each Brookfield Account, up to 100% of the Investors’ portion of the Brookfield Account’s allocable share of any transaction, monitoring, consulting, advisory, directors’, break-up or similar fees received by Brookfield and its employees (or, in the case of directors’ fees, representatives of Brookfield) are generally applied, net of the Investor’s allocable share of applicable expenses, to reduce the annual management fee (provided that any of these fees that would reduce the annual management fee in excess of the management fee for the applicable period may be applied to the management fee for subsequent periods). In addition, as set out in more detail in “Affiliated Services and Transactions” in Item 10 below: •

Brookfield may make available certain discount programs to its employees as a result of Brookfield’s relationship with an investment, which discounts are not available to the Investors;

•

Brookfield has and will be retained to perform services for a Brookfield Account or a portfolio investment of a Brookfield Account that would otherwise be provided by third parties, and will charge the relevant Brookfield Account or portfolio investment for such services;

•

Certain portfolio investments of Brookfield Accounts will provide services to, receive services from, or participate in transactions or other arrangements with, Brookfield and its affiliates (including other portfolio investments owned by Brookfield, Brookfield Accounts or non-controlled affiliates);

•

Brookfield (or other Brookfield Accounts or businesses) will from time to time make equity or other investments in companies or businesses that provide services to or otherwise contract with a Brookfield Account and/or its portfolio investments; and

Furthermore, in certain circumstances Brookfield employees are hired by, seconded to, or retained by one or more portfolio investments of a Brookfield Account or by Brookfield on behalf of a portfolio investment, as set out in more detail in “Transfers and Secondment of Employees” in Item 10 below. Brookfield Accounts also incur brokerage and other transaction costs, as set out in more detail in “Brokerage Practices” in Item 12 below.

In addition to the fees above, each Brookfield Account generally bears all of its operating expenses, including legal, organizational, offering expenses and other expenses, and each Investor bears its pro rata portion of these expenses, as set out in more detail in “Allocation of Costs and Expenses” in Item 10 below. Brookfield will from time to time determine that it is advisable to invest additional capital in or with respect to an investment and (a) this additional investment must be made within a timeframe that would preclude the issuance of a funding notice in respect thereof or (b) unfunded capital commitments are unavailable for this purpose, then Brookfield may loan additional capital to such investment in accordance with a Brookfield Account’s Governing Documents. Any such loan is expected to be repaid by such investment in priority to any distributions to a Brookfield Account by such investment, or be converted into an equity interest in such investment on a dollar-for-dollar basis using an appraisal or arm’s length valuation, in Brookfield’s sole discretion. As noted above, the asset-based management fee in respect of a Brookfield Account is typically paid quarterly in advance. An Investor in a Brookfield Account that is a closed-end private investment fund is generally only permitted to withdraw from the account under limited circumstances and will generally not be entitled to a refund of fees paid in advance in such circumstances. Certain redemption rights are generally afforded to investors in Brookfield Accounts that are open-ended. Certain Brookfield subsidiaries, including Brookfield Private Advisors LLC, a limited purpose broker‐dealer that is registered with the SEC and is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”); Brookfield Private Wealth LLC, a limited purpose broker-dealer that is registered with the SEC and is a member of FINRA; Brookfield Private Capital (UK) Limited, which is authorized and regulated by the United Kingdom’s Financial Conduct Authority; Brookfield Singapore Pte. Ltd., which is an exempt Financial Advisor authorized and regulated by the Monetary Authority of Singapore; Brookfield Advisors (Hong Kong) Limited, which is authorized and regulated by the Hong Kong Securities and Futures Commission; and Brookfield Investment Management (Canada) Inc., which is authorized as a dealer under applicable Canadian regulations, solicit prospective investors for the Brookfield Accounts and as a result, their representatives generally receive compensation in connection with the sale of interests in a Brookfield Account. The compensation paid to such representatives will be from Brookfield and not from Brookfield Accounts or any Investors. The amount of such compensation will vary based on a number of different factors, including the amount of interests in a Brookfield Account that have been sold by such representative. As a result of such arrangements, such representatives have a financial interest in promoting interests in Brookfield Accounts. In addition, the compensation that such representatives receive in respect of the sale of the interests in a Brookfield Account may be higher than the compensation that they would receive in respect of the sale of other (including similar) products or services, which may give such representatives an incentive to promote the interests in a Brookfield Account over other (including similar) products or services. Potential

investors should therefore be aware that there are financial and other interests that incentivize such representatives to promote certain Brookfield Accounts and related interests. The considerations set forth above are similar (and in certain instances may be heightened) in the event Brookfield retains a third-party placement agent to market interests in the Brookfield Account. Brookfield pays its affiliates that solicit prospective investors for the Brookfield Accounts out of its profits, and such payments do not increase the fees paid by the Brookfield Accounts’ Investors. BREG is not a broker‐dealer and does not charge commissions or markups in addition to its investment advisory fees.

Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks

Brookfield pursues the specific investment objectives and strategies of each Brookfield Account as set out in the Brookfield Account’s Governing Documents. Brookfield’s operations‐oriented approach plays an important role in the investment process. This approach leverages Brookfield’s business groups in the evaluation and optimization of investments. This approach is generally comprised of the following attributes:

•

Operational expertise. Brookfield’s operations‐oriented approach is an essential differentiating factor in its ability to generate superior risk‐adjusted returns. During its 120‐year history as an owner and operator of real assets, Brookfield has built global business groups, primarily in real estate, infrastructure and sustainable resources, renewable power, private equity and timberlands/agrilands. These business groups are backed by the expertise of approximately 100,000 operating employees.

•

Industry knowledge. Brookfield’s business groups enhance its ability to develop fundamental views on the major factors that impact asset values. Brookfield will utilize this knowledge to make acquisition and divestiture decisions, as well as to take advantage of sophisticated financing and operating practices.

•

Active management of investments. Through Brookfield’s representation on boards of directors, leadership on advisory or operating committees, as well as frequent interaction with management, Brookfield will actively manage its investments. A key aspect of this management role is a “hands on approach” to key value drivers such as growth capital investments, development projects, follow‐on acquisitions and financings.

The Brookfield Accounts focus on real estate, infrastructure and private equity investment strategies. As noted in Item 4 above, Brookfield is a global alternative asset manager with significant assets under management and a long history of owning, managing and operating assets, businesses and investment vehicles across various industries, sectors, geographies and strategies. The discussion of Brookfield Accounts that appears in this Brochure is not intended to constitute an offer of interests in such Accounts. Real Estate – This strategy focuses on acquiring control positions in real estate assets and real estate companies located around the globe through a variety of structures, including direct property acquisitions, equity positions in real estate companies, distressed debt, recapitalizations, toe-hold positions in debt and equity securities, control-oriented loan originations, and development or redevelopment projects. This strategy involves investing in various real estate platforms, including office, retail, residential, multifamily and development. Infrastructure – Brookfield defines infrastructure assets as long‐life, real assets that serve as the backbone for the provision of essential products or services to the global economy. Due to their nature, infrastructure assets are typically critical to support sustainable economic development and are characterized by some or all of the following attributes: (i) sustainable, long‐term cash flows; (ii) inflation‐correlated revenues; (iii) strong competitive position and high barriers to entry; and (iv) high operating margins. A Brookfield Account will target investments across the infrastructure sector with particular emphasis on opportunities in the utility, energy, renewable power, data and transportation sectors, including oil and gas pipelines, regulated electricity and gas transmission and distribution systems, hydroelectric power generation, water and waste water distribution and treatment systems, storage facilities, toll roads, bridges, tunnels, airports, ports and railroads. Certain Brookfield Accounts may also invest in other infrastructure

opportunities such as communication infrastructure, industrial infrastructure and parking garages. Renewables and Transition – This strategy focuses on accelerating the transition to net zero by investing primarily in the transformation of carbon-intensive businesses and developing and increasing the accessibility of renewable energy sources and emerging, viable low-carbon solutions and services, while seeking to deliver attractive risk-adjusted returns for investors. The strategy targets investments which (through Brookfield’s operational expertise, influence or financial commitment) contribute to an incremental impact in the path to net zero. Brookfield intends to do this by investing in opportunities with identifiable, long term, and stable revenue streams that scale the development of clean energy and other decarbonization solutions, as well as through partnerships or investment into carbon-intensive businesses where Brookfield can achieve emission reductions in the near term. Private Equity – This strategy focuses on opportunities in industries in which Brookfield has expertise, and in businesses in need of strategic redirection and operational repositioning, employing an operations‐oriented approach for value creation. The strategy is to seek control investments in mid‐market companies that require a restructuring of their operations and/or capital structure. Brookfield seeks to take a leadership role through the restructuring process of each portfolio investment and add value through ongoing, active participation in management and governance. Investing in securities involves risk of loss that clients should be prepared to bear, INCLUDING THE RISK OF LOSS OF THE ENTIRE INVESTMENT. The following risks do not purport to be a complete list or explanation of all risks involved in an investment in a Brookfield Account and prospective investors should consult the Brookfield Account’s Governing Documents, including the Brookfield Account’s private placement memorandum together with any supplements. Material Risks of Key Investment Strategies: Highly Competitive Market for Investment Opportunities. The activity of identifying, completing and realizing attractive real estate, infrastructure and private equity investments is highly competitive and involves a high degree of uncertainty. There can be no assurance that Brookfield will be able to locate and complete investments which satisfy the Brookfield Accounts’ investment objectives, realize the value of these investments, or fully invest the Investors’ committed capital, nor can there be any assurance that Brookfield will be able to make investments on favorable terms and conditions. Competition for such investment opportunities could come from other consortia, financial investors, and other asset managers and owners. These competitors may have financial, geographic, or strategic advantages that may reduce Brookfield’s competitiveness and potentially materially and adversely affect its ability to successfully conclude transactions. Further, failures in identifying or consummating investments on satisfactory or favorable terms could reduce the number of investments that are completed, reduce returns, and slow growth.

The Brookfield Accounts compete for the right to make investments with an ever-increasing number of other parties, including other consortia and companies, other private investment funds as well as individuals, financial institutions and other institutions, some of which may have greater resources than the Brookfield Accounts. As a result of such competition, the Brookfield Accounts may have difficulty in making certain investments or, alternatively, the Brookfield Accounts may be required to make investments on economic terms less favorable than anticipated. If the Brookfield Accounts fail to make new investments or make investments on less favorable terms, the Brookfield Accounts’ financial condition and results of operations could be materially and adversely affected, and the objective of the Brookfield Accounts may not be achieved. General Economic Conditions. Changes in general global, regional and/or U.S. economic and geopolitical conditions may affect Brookfield Accounts’ activities. Interest rates, general levels of economic activity, the price of securities and participation by other investors in the financial markets may affect the market for debt and credit-related instruments in which Brookfield Accounts make investments or the value and number of investments made by Brookfield Accounts or considered for prospective investment. Material changes and fluctuations in the economic environment, particularly of the type experienced in the years following 2008 that caused significant dislocations, illiquidity and volatility in the wider global economy, and the market changes that have resulted and may continue to result from the spread of the novel coronavirus (“COVID-19”) also may affect the market for such debt and credit-related instruments (including the ability of issuers of such instruments to repay principal and pay interest thereon, increasing the incidence of default for such instruments) or Brookfield Accounts’ ability to make investments and the value of investments held by Brookfield Accounts or Brookfield Accounts’ ability to dispose of investments. The short-term and the longer-term impact of these events are uncertain, but they could continue to have a material effect on general economic conditions, consumer and business confidence and market liquidity. Any economic downturn resulting from a recurrence of such marketplace events and/or continued volatility in the financial markets could adversely affect the financial resources of the entities (i.e., borrowers or asset holding companies) in which a Brookfield Account will make investments. Investments can be expected to be sensitive to the performance of the overall economy. Moreover, a serious pandemic, natural disaster, armed conflict, threats of terrorism, terrorist attacks and the impact of military or other action could severely disrupt global, national and/or regional economies. A resulting negative impact on economic fundamentals and consumer and business confidence may negatively impact market value, increase market volatility and reduce liquidity, all of which could have an adverse effect on the performance of investments, Brookfield Accounts’ returns and Brookfield Accounts’ ability to make and/or dispose of investments. No assurance can be given as to the effect of these events on investments or Brookfield Accounts’ investment objectives. See also “Public Health Risk” below. FCPA Considerations. Brookfield and the Brookfield Accounts seek to comply with the U.S. Foreign Corrupt Practices Act (“FCPA”) and other anti-corruption laws, anti-bribery laws and regulations, as well as anti-boycott regulations, to which they are subject. As a result, the Brookfield Accounts may be adversely affected because of their unwillingness to participate in

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Item 7: Types of clients

Brookfield’s clients include private investment funds structured as limited partnerships (and alternative investment vehicles and parallel or co‐investment vehicles formed for investments made outside or alongside the limited partnerships), publicly listed operating partnerships and joint ventures. Investors in Brookfield Accounts generally include public and corporate pensions, sovereign wealth funds, insurance companies, financial institutions, corporations and high net worth individuals.

Item 6: Performance-based fees and side-by-side management Conflicts of interest

As described in Item 5 above, Brookfield is generally entitled to performance-based compensation from Brookfield Accounts in accordance with their Governing Documents, which such compensation is structured to comply with Rule 205‐3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), to the extent applicable. Performance-based compensation arrangements may create an incentive for Brookfield to recommend investments which may be riskier or more speculative than those which would be recommended under a different compensation arrangement. Such compensation arrangements may also create an incentive for Brookfield to favor higher fee-paying Brookfield Accounts over lower fee-paying Brookfield Accounts in the allocation of investment opportunities. Brookfield has adopted allocation policies and procedures (as described below) to help mitigate conflicts of interest relating to the management of multiple Brookfield Accounts with varying fee arrangements. At all times, Brookfield will act and make decisions on behalf of Brookfield Accounts that it believes are in their best interests, taking into account all facts and circumstances that it deems relevant, including potential participation by Brookfield Client Relationships (as defined herein) in the pursuit or the consummation of certain investments. See Items 5, 10 and 11 for a description of certain other conflicts (and potential conflicts) of interests relating to the advisory services provided by Brookfield. A more detailed description of applicable conflicts of interest is set forth in the Governing Documents of each Brookfield Account. Allocation of Investment Opportunities. Brookfield provides investment advice and performs related services for itself and other Brookfield Accounts (including, among others, for its own account and/or accounts that are being seeded and/or incubated), which are similar to the advice provided and services performed for other Brookfield Accounts. Certain Brookfield Accounts have (and additional future Brookfield Accounts will in the future have) investment mandates that overlap with those of other Brookfield Accounts and compete with and/or have priority over other Brookfield Accounts for particular investment opportunities. As a result, certain opportunities sourced by Brookfield that would otherwise be suitable for Brookfield

Accounts are not expected to be available to them, Brookfield Accounts will receive a smaller allocation of such opportunities than would otherwise have been the case, or Brookfield Accounts will receive an allocation of such opportunities on different terms than Brookfield or other Brookfield Accounts, which may be less favorable to Brookfield Accounts than otherwise would have been the case. The factors considered by Brookfield in allocating investments among the Brookfield Accounts may change over time (including to consider new, additional factors) and different factors may be emphasized or be considered less relevant to different investments. Further to the foregoing, Brookfield manages and participates in, and will in the future manage and participate in, Brookfield Accounts that have or will have overlapping investment mandates with other Brookfield Accounts. By way of example only, these include Brookfield Accounts that focus on (i) equity and debt investments in companies and assets; (ii) secondary investments, which include, among other things, third-party general partner-led recapitalizations of assets and/or investment vehicles (including closed-end funds, joint ventures and other vehicles) where the third-party general partner maintains day-to-day asset management responsibilities, investments in pooled investment vehicles managed by third parties and co-investments alongside such investment vehicles, structured solutions and/or preferred equity investments in assets managed by thirdparty general partners, recapitalization of third-party managed investment vehicles (in whole or in part), and related separately managed accounts; (iii) investments that contribute to the transition to a net -zero emissions global economy; and (iv) private equity and private equityrelated investments (including among others provision of capital solutions to third-parties). Investment opportunities generally will be allocated pursuant to (and in accordance with) Brookfield Accounts’ investment priorities (if any). Under certain circumstances, where the investment mandate of a Brookfield Account overlaps with the investment mandate of one or more other Brookfield Accounts, any investment opportunity that is suitable for such Brookfield Accounts may be allocated among them on a basis that Brookfield determines in good faith is fair and equitable taking into account one or more factors (the “Allocation Factors”), as it deems relevant in its discretion including (among others): (i) the size, nature and type of the investment opportunity (including the risk and return profiles of the opportunity, expected holding period and other attributes) as well as its fit within each Brookfield Account’s investment focus; (ii) the nature of the relevant Brookfield Accounts’ investment mandates (including their investment focus, objectives, strategies, guidelines, limitations, risk-return targets, client instructions (if any) and risk tolerance, as each is determined and adjusted from time to time over the lives of the Brookfield Accounts; (iii) the geographic location of the investment opportunity, and Brookfield’s determination of the appropriateness of the risks of investing in such location for the relevant Brookfield Accounts; (iv) investment priorities of each Brookfield Account, including in connection with follow-on opportunities; (v) the relative amounts of capital available (or expected to be available) for investment for the period in which such investment will be consummated; (vi) principles of diversification of investments (including, among others, sector, geographic, risk, asset and/or other portfolio diversification and/or concentration

considerations); (vii) the expected future capacity of the Brookfield Accounts; (viii) the relevant Brookfield Accounts’ liquidity needs (including for pipeline, follow-on, staged draw investments (including funding obligations with respect to such investments that are contingent upon achievement of certain milestones) and other opportunities pursued by the Brookfield Accounts); (ix) the management (including mitigation) of any actual or potential conflict of interest considerations, including in connection with investment in different parts of an issuer’s capital structure; (x) limitations imposed by investors in one or more Brookfield Accounts (pursuant to consent and/or approval rights or as otherwise agreed to with such investors); (xi) statutory minimum capital, risk retention and surplus requirements applicable to the relevant Brookfield Accounts; (xii) the capital efficiency of the investment opportunity for insurance and/or other purposes; (xiii) expected or actual ratings or lack of ratings of the investment opportunity; (xiv) the availability of other appropriate or similar investment opportunities; (xv) the extent to which the investment professionals involved in the Brookfield Accounts participated in the sourcing and/or diligencing of the investment opportunity and as a result their knowledge and understanding of the investment opportunity; (xvi) whether the allocation would result in a Brookfield Account receiving a de minimis amount or an amount below the established minimum quantity; (xvii) related-party nature of the transaction and potential conflicts considerations that could arise as a result; (xviii) whether the relevant Brookfield Accounts are in liquidation; and/or (xix) other considerations deemed relevant by Brookfield (including legal, regulatory, tax, structuring, compliance, investment-specific, timing and similar considerations). To the extent that Brookfield determines that an overlap situation is likely to be recurring for particular types of investment opportunities, Brookfield could (but will not be required to) determine to apply the Allocation Factors in accordance with a formulaic or other systematic approach for any period of time, as it deems appropriate in its sole discretion. The determination of whether an investment is within the scope of the investment mandate of a Brookfield Account will be made in the discretion of Brookfield. Further, if Brookfield determines that investment opportunities in respect of a particular sector (which can be comprised of multiple industries) or region are expected (in the fullness of time) to exceed the investment limitations (or appropriate portfolio concentration) of one or more Brookfield Account(s), Brookfield may sponsor, act as general partner and/or manager to, and otherwise participate in, sidecar vehicles that participate in such opportunities, and such opportunities and any investment opportunity related thereto (e.g., follow-on investment opportunities) will be allocated between Brookfield Accounts and the applicable sidecar vehicle on a basis that Brookfield believes is fair and equitable taking into account various factors that it deems relevant in its discretion, including the Allocation Factors (which may include allocating investment opportunities in accordance with a formula or other systematic approach that Brookfield determines to be fair and equitable at the time such sector- or region-specific sidecar fund is formed). From time to time, in applying the principles described above, Brookfield could determine that an investment opportunity will be shared among two or more Brookfield Accounts by causing one Brookfield Account to acquire certain portions of the investment opportunity while one or more other Brookfield Accounts acquire other portions. In such cases, given its varying economic

interests in different Brookfield Accounts, Brookfield will face conflicts of interests in valuing portions of an investment opportunity that is allocated among different Brookfield Accounts, in particular where a portion of the opportunity is to be allocated to a Brookfield Account in which Brookfield has a larger economic interest relative to the other Brookfield Account that is participating in the opportunity Brookfield will value the portion of the opportunity allocated to each Brookfield Account (which will impact the purchase price paid by such Brookfield Account) and allocate transaction expenses among such Brookfield Accounts in accordance with its fiduciary duties to the Brookfield Accounts, consistent with each Brookfield Account’s Governing Documents and Brookfield’s internal policies and procedures, in particular those relating to the underwriting and valuation of investment opportunities and allocation of fees and expenses. Notwithstanding the foregoing, Brookfield generally will not, unless otherwise required to pursuant to applicable law and/or regulation, seek independent review, opinion, support and/or appraisal for such allocation and/or valuation determinations, including in situations where Brookfield has different economic interests in the participating Brookfield Account(s). See also “Determinations of Value” below. Among other things, if one Brookfield Account is unable to make an additional investment in a particular asset in which it has previously invested, such investment opportunity could be allocated to another Brookfield Account. In such circumstances, the liabilities (including certain expenses related to the investment) will be allocated across such Brookfield Accounts, though there may not be a clear delineation between the expenses and liabilities attributable to each Brookfield Account’s portion, and as a result, one of the Brookfield Accounts could be responsible for more than its share of any shared expenses. The process for making allocation determinations is inherently subjective and the factors considered by Brookfield in allocating investments among Brookfield Accounts are expected to change over time (including to consider new, additional factors) and one or more different factors are likely to be emphasized or be considered less relevant with respect to different investments depending on the then-existing facts-and-circumstances deemed relevant by Brookfield and taking into account the broader facts and circumstances and portfolio construction considerations applicable to each Brookfield Account. In some cases, this will result in certain transactions being shared among two or more Brookfield Accounts (including, for example, on a rotational, pro rata or other basis), while in other cases it will result in one or more Brookfield Accounts being excluded from an investment entirely. In some instances, Brookfield may receive new, different or additional information regarding an investment opportunity during the course of performing continued due diligence on such investment opportunity. To the extent such investment opportunity had already been allocated to one or more Brookfield Accounts pursuant to the allocation methodology described above, Brookfield is not obligated to reconsider its allocation decision, and could elect not to do so, including in cases where structuring work has already been undertaken with respect to the initial allocation or changing the allocation would otherwise be costly or burdensome. Since certain Brookfield Accounts represent Brookfield's proprietary investments activities, the fact that investment opportunities deemed unsuitable for Brookfield Accounts could be pursued by Brookfield itself presents a conflict of interest when making such suitability determination. Brookfield will make such suitability determination in a manner consistent with its fiduciary

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Item 10: Other financial industry activities and affiliations Conflicts of interest

BREG is an indirect subsidiary of BAM and Brookfield Corporation, both publicly traded corporations. BREG (together with its participating affiliates) is an affiliate of the Brookfield Advisers, which consist of Brookfield Asset Management Private Institutional Capital Adviser US, LLC (together with its relying advisers, “BAM PIC US”), Brookfield Asset Management Private Institutional Capital Adviser (Canada), L.P. (together with its participating affiliates, “BAM PIC Canada”), Brookfield Asset Management Private Institutional Capital Adviser (Private Equity), L.P. (together with its participating affiliates, “BAM PIC PE”), Brookfield Asset Management Private Institutional Capital BMG, LLC (“BAM PIC BMG”), and Brookfield Asset Management Credit and Insurance Solutions Advisor LLC. The Brookfield Advisers (other than the participating affiliates) are registered with the SEC as investment advisers under the Advisers Act, and each serves as investment adviser or sub adviser to Brookfield Accounts. Any references to Brookfield in this section will be deemed to include its respective affiliates (including the general partners of Brookfield Accounts), partners, members, shareholders, officers, directors and employees. As noted in Item 4 above, Brookfield is a global alternative asset manager with significant assets under management and a long history of owning, managing and operating assets, businesses and investment vehicles across various industries, sectors, geographies and strategies. As noted throughout this Brochure, a key element of Brookfield’s investment strategy on behalf of Brookfield Accounts is to leverage its experience, expertise, broad reach, relationships and position in the market for investment opportunities and deal flow, financial resources, access to capital markets and operating needs. Brookfield believes that this is in the best interests of Brookfield Accounts. However, being part of this broader platform, as well as activities of and

other considerations relating to Brookfield Accounts, gives rise to actual and potential conflicts of interest between certain Brookfield Accounts, on the one hand, and Brookfield and/or other Brookfield Accounts, on the other hand, that may not be resolved in the most favorable manner to the interests of any particular Brookfield Account. Brookfield’s activities include, among others: investment and asset management; managing and investing reinsurance capital; sponsoring, offering and managing private and public investment vehicles that invest in the global fixed income, currency, commodity, equities, private and other markets; developing, constructing, owning, managing, operating and servicing real estate, renewable power, infrastructure and other companies and assets, including among others residential, commercial, storage and mixed-use real estate, data centers, transportation facilities, electric utilities, industrial and manufacturing facilities, energy companies, metals and mining companies, timberlands and agrilands, natural gas pipelines, and other assets; providing capital and financing solutions, as well as financial advisory, business development and other financial services; and other activities (collectively, “Brookfield Activities”). It is expected that Brookfield Accounts will benefit from Brookfield’s expertise, market positioning and connectivity that arise from Brookfield Activities. At the same time, in the ordinary course of its business, Brookfield’s and certain Brookfield Accounts’ interests are expected to conflict with the interests of other Brookfield’s Accounts, notwithstanding Brookfield’s direct or indirect participation in the Brookfield Advisers’ investment activities and Brookfield Accounts’ investments. While Brookfield expects that its expertise as a global real asset operator will directly impact the ability of Brookfield Accounts to identify, access and assess investment opportunities, and that Brookfield Accounts’ investments will benefit from the greater Brookfield ecosystem, there can be no assurance of any such successful collaboration or synergies. A lack of successful collaboration or synergies, whether as a result of concerns related to conflicts or otherwise, could impact Brookfield Accounts’ ability to successfully implement their strategies or achieve their investment objectives. Investors should note that this Brochure and the Governing Documents contain disclosures and provisions that, subject to applicable law, (i) reduce or modify the duties (including fiduciary or other duties owed to Brookfield Accounts and Investors) to which Brookfield would otherwise be subject, (ii) waive duties or consent to conduct of Brookfield that might not otherwise be permitted pursuant to such duties and (iii) limit the remedies of Investors with respect to breaches of such duties. Additionally, the Governing Documents contain exculpation and indemnification provisions that, subject to the specific exceptions therein, provide that Brookfield and its affiliates and its directors will be held harmless and indemnified for matters relating to the operation of its business, including matters that may involve one or more potential or actual conflicts of interest. Notwithstanding anything to the contrary contained herein or in the Governing Documents, nothing contained herein or in the Governing Documents shall restrict, amend, eliminate or waive any fiduciary duties of an indemnified party (or any rights of the Brookfield Accounts or the investors in respect thereof) under (A) the Advisers Act or (B) any other applicable Federal or U.S. state law to the extent (but only to the extent) that such restriction, amendment, elimination or waiver would be in violation of such other Federal or U.S. state law.

The discussion below describes certain of the actual and potential conflicts of interest that are expected to arise between Brookfield Activities, on the one hand, and Brookfield’s management of Brookfield Accounts, on the other hand. These conflicts of interest are not a complete list or explanation of all actual and potential conflicts of interest that could arise, and additional conflicts of interest are expected to arise as a result of new activities, transactions or relationships commenced in the future. In addition, certain terms described herein may only be applicable to certain Brookfield Accounts, but not others. Potential investors should review this section and the relevant Brookfield Account’s Governing Documents carefully for additional risks and conflicts disclosure before making an investment decision. While Brookfield acts in good faith to resolve potential conflicts in a manner that is fair and equitable taking into account the facts and circumstances known to it at the time, there can be no assurance that any recommendation or determination made by Brookfield will be most beneficial or favorable to any particular Brookfield Account or Investor, or would not have been different if additional information were available to it. Potential conflicts of interest generally will be resolved in accordance with the principles summarized herein, Brookfield’s policies for adequately addressing potential conflicts considerations that arise in managing its business activities, Governing Documents of Brookfield Accounts, and conflicts protocols. CONFLICTS RELATING TO INVESTMENTS BY OTHER BROOKFIELD ACCOUNTS As noted throughout this Brochure, Brookfield Accounts are expected to benefit from Brookfield’s expertise and resources. Brookfield believes that operating within its integrated investment platform is in the best interests of all of its clients. However, being part of the broader Brookfield platform gives rise to actual and potential conflicts. Advice to Certain Brookfield Accounts May Conflict with Other Brookfield Accounts’ Interests. In light of the extensive scope of Brookfield’s investment and related business activities: (i) Brookfield and its personnel will give advice, and take actions, with respect to current or future Brookfield Accounts (including proprietary accounts of Brookfield) that could compete or conflict with the advice Brookfield gives to other Brookfield Accounts, or will involve a different timing or nature of action than that taken with respect to other Brookfield Accounts, and (ii) investments by certain Brookfield Accounts and/or Brookfield could have the effect of diluting or otherwise disadvantaging the values, prices and/or investment strategies of other Brookfield Accounts. For example, when a Brookfield Account either manages or implements a portfolio decision ahead of, or contemporaneously with, portfolio decisions for other Brookfield Accounts, market impact, liquidity constraints and/or other factors could result in the applicable Brookfield Account receiving less favorable results, paying higher transaction costs, or being otherwise disadvantaged. In making certain decisions with regard to portfolio investments that compete with or differ from the interests of one or more Brookfield Accounts Brookfield could face certain conflicts of interest between the interests of a Brookfield Account and the interests of such other Brookfield Accounts. These potential conflicts will be exacerbated in situations where Brookfield is entitled to higher fees from some Brookfield Accounts than from others, where portfolio managers

making an allocation decision are entitled to higher performance-based compensation from some Brookfield Accounts than from others, where Brookfield (and/or the Related-Party Investor) has larger proprietary investments in some Brookfield Accounts than in others, or where there are capacity constraints with respect to a particular strategy or opportunity as a result of, for example, position limits and/or regulatory reporting obligations applicable to Brookfield. In addition, as an investment changes over time, additional conflicts of interest are expected to arise, including as a result of earlier investment allocation decisions. Brookfield will determine the appropriate investment decision for each Brookfield Account and Brookfield taking into account the mandate and interests of such accounts (where applicable) and, when applicable, in accordance with Brookfield’s investment allocation protocols and such Brookfield Account’s governing documents. The investment and divestment decisions made with respect to other Brookfield Accounts may be made without regard to the interests of a Brookfield Account, even where such decisions are informed by that Brookfield Account’s investment activities and/or adversely affect that Brookfield Account. In addition, certain Brookfield Accounts (and/or portfolio companies of such Brookfield Accounts) may provide investment banking and other advisory services to third parties with respect to assets in which another Brookfield Account may be invested or seeking to invest. The interests of such Brookfield Accounts (and/or portfolio companies of such Brookfield Accounts) in such circumstances could conflict with those of other Brookfield Accounts, and a Brookfield Account could compete with other Brookfield Accounts (and/or portfolio companies of such Brookfield Accounts) in pursuing certain investments. Different business units and teams within the LPACs of the Brookfield Accounts and Brookfield may take views, and make decisions or recommendations, that are different than other areas of the LPACs of the Brookfield Accounts and Brookfield. Different portfolio management teams within the LPACs of the Brookfield Accounts and Brookfield may make decisions or take (or refrain from taking) actions with respect to Brookfield Accounts they advise in a manner that may be different than or adverse to other Brookfield Accounts. Such teams might not share information with the portfolio management team of other Brookfield Accounts, including as a result of certain information barriers. See “Data Management” below. In particular, Brookfield Accounts that focus on making secondary investments are expected to invest in Third Party Vehicles. While such Brookfield Accounts are expected to negotiate for certain control rights over (and to offer strategic advice to) such Third Party Vehicles, such Third Party Vehicles will not be “Brookfield Accounts” and will not be considered “affiliates” of Brookfield for purposes of the provisions of the Governing Documents that limit the ability of Brookfield Accounts to transact with Brookfield affiliates. As a result, Brookfield Accounts will not be restricted from purchasing investments from, selling investments to, or otherwise transacting with or alongside such Third Party Vehicles. The interests of such Brookfield Accounts and the Third Party Vehicles in which they invest may conflict with those of Brookfield Accounts, including in circumstances in which such other Brookfield Accounts exercise (or decline to exercise) control rights over, or otherwise offer strategic advice to, such Third Party Vehicles in a manner that differs from Brookfield’s advice to Brookfield Accounts.

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Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest

Brookfield has adopted a code of business conduct and ethics (the “Code of Ethics”) for its supervised persons, which sets out its standards, principles, commitments, policies, procedures, and guidelines. The Code of Ethics includes, among other things, provisions relating to duties to stakeholders, the confidentiality of client information, the creation of a positive work environment, employee personal conduct policies, the giving and/or receiving of gifts and entertainment, a prohibition on insider trading, personal securities trading procedures, and guidelines for reporting potential violations of the Code of Ethics. All supervised persons of Brookfield must acknowledge the terms of the Code of Ethics upon commencement of employment with Brookfield and annually thereafter. Under the Code of Ethics, Brookfield’s supervised persons are expected to, among other things: • • • • • • •

Always observe their fiduciary duties to investment management clients; Not take personal opportunities that are discovered through the use of property or information of the company or through their role with Brookfield; Protect the confidentiality of “non‐public information” concerning the company, customers, clients, investments and others; Maintain a respectful work environment free from discrimination, violence and harassment; Not trade in the company’s securities or any other company’s securities if they possess material “non‐public information” or during a blackout period; Know and comply with applicable laws, rules, regulations and policies; and Report potential violations of the Code of Ethics.

Clients or prospective clients may request a copy of the firm’s Code of Ethics by contacting ronald.fisher-dayn@brookfield.com. As discussed above in “Conflicts Relating to Investments by Other Brookfield Accounts” in Item 10, Brookfield buys and sells securities and interests for Brookfield Accounts in portfolio investments in which Brookfield and other Brookfield Accounts have material financial interests. Brookfield and other Brookfield Accounts also invest in the same securities and portfolio investments as a Brookfield Account, including at the same time. The various actual and potential conflicts that these practices present are discussed above. Conflicts of interest shall be managed and resolved as discussed in “Management and Resolution of Conflicts” in Item 10 above. From time to time, subject to and in accordance with applicable law and the terms of Brookfield’s conflicts policy, Brookfield expects (but is under no obligation) to effect cross trades and/or

principal transactions pursuant to which Brookfield Accounts purchase investments from or sell investments to Brookfield and/or other Brookfield Accounts. Pursuant to applicable law and Brookfield’s conflicts policy, certain of these transactions will require approval of the applicable Brookfield Account’s Investors (or LPAC or similar bodies), which approval will be deemed to constitute the approval of, and be binding upon, Brookfield Account and all Investors (in the case of approval of the LPAC or similar bodies). In light of the potential conflicts of interest and regulatory considerations relating to cross trades and/or principal transactions, including among others Brookfield’s conflicting division of loyalties and responsibilities to the parties in these transactions, Brookfield has developed policies and procedures in order to guide the effecting of such transactions. However, there can be no assurance that such transactions will be effected, or that such transactions will be affected in the manner that is most favorable to Brookfield Accounts as a party to any such transaction. For the avoidance of doubt, transactions among portfolio investments of Brookfield Accounts and portfolio investments of other Brookfield Accounts and/or Walled-Off Business Accounts that get effected in the ordinary course will not be treated as cross trades or principal transactions and will not require approval of the applicable Brookfield Account’s Investors (or LPAC or similar bodies) or the Conflicts Committee. See “Transactions with Portfolio Companies” in Item 10 above.

Item 12: Brokerage practices Conflicts of interest

Brookfield generally has discretionary authority to determine, without obtaining specific client consent, the investments (including in securities) and the amount thereof to be bought or sold for a Brookfield Account, subject to the conditions and restrictions contained in a Brookfield Account’s Governing Documents. Brookfield Accounts generally do not conduct frequent transactions in publicly‐traded securities requiring the use of a broker. In determining the brokers through whom, and commission rates and other transaction costs at which, securities transactions for the Brookfield Accounts are to be executed, Brookfield seeks to negotiate a combination of the most favorable commission and the best price obtainable, taking into account execution capability and trading expertise consistent with the effective execution of the transaction. Brookfield enters into “soft dollars” arrangements from time to time when executing on transactions for Brookfield Accounts, but will do so only where Brookfield reasonably believes that the services benefit the Brookfield Accounts, and that the amount of commission was reasonable in relation to the value of the brokerage and research services provided. Brookfield analyzes its use of client brokerage commissions quarterly to determine whether its use of soft dollar falls within the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934. Brookfield currently has soft dollar contracts open with one broker. The resources currently funded by these soft dollar relationships are primarily data/pricing feeds (i.e., Interactive Data Pricing and Reference Data, Inc., Factset, Bloomberg) and connectivity. Benefits received are used for the benefit of Brookfield clients generally. The receipt of such benefits creates a potential conflict of interest. To the extent that Brookfield uses client commission

dollars to obtain research or brokerage services, it will not have to pay for those products and services itself, and Brookfield has an incentive to select or recommend a broker-dealer based on its interest in receiving the benefits, rather than on Brookfield Accounts’ interest in receiving most favorable execution. During 2025, Brookfield paid certain permitted costs via a soft dollar program with one US-based broker. These costs primarily comprised market data feeds and proprietary third-party research. Brookfield does not consider, in selecting broker‐dealers, whether the broker‐dealer has referred clients to Brookfield and does not permit a Brookfield Account to direct brokerage to particular broker‐dealers. In the event that orders for the same security for more than one client are placed with the same broker, Brookfield may aggregate or “bunch” such orders across client accounts (including accounts advised by certain affiliates), although it will have no obligation to do so. If orders are aggregated, they will be allocated across the client accounts so that no account will be treated less favorably than another over time. While in some cases the aggregation of orders could have a detrimental effect upon the price or value of a security for a particular account, or upon the ability to complete an entire order, in other cases coordination and the ability to participate in volume transactions may be beneficial to the account. Brookfield may in its discretion choose not to aggregate orders, for example, where portfolio management decisions for clients are made separately or where aggregation could result in less favorable execution for a particular client.

Item 14: Client referrals and other compensation Conflicts of interest

Brookfield does not have any arrangements pursuant to which someone other than a Brookfield Account provides an economic benefit to Brookfield for providing investment advisory services to such Brookfield Account. See Items 5, 6 and 10 above for compensation that may be earned by Brookfield in connection with certain transactions, and Item 10 above for other services that may be provided by Brookfield in connection with a Brookfield Account’s investments for which it may be compensated. As described in Item 5 above, certain supervised persons of Brookfield may obtain commitments from prospective investors to Brookfield Accounts while acting in that capacity.

Item 9: Disciplinary information

An administrative proceeding filed against (i) PenBrook Capital Advisors Private Limited (“PenBrook”), the investment manager of Peninsula Brookfield India Real Estate Fund (the “Fund”), (ii) PenBrook’s current and former directors, and (iii) Peninsula Brookfield Trustee Private Limited, the trustee of the Fund ((i), (ii), and (iii) collectively, the “Noticees”), was settled on January 28, 2022. The proceeding involved allegations brought by the Securities and Exchange Board of India (“SEBI”) that the Noticees accepted impermissibly small investments from certain investors in the Fund, failed to maintain sufficiently large investments themselves in the Fund, and extended the tenure of the Fund beyond the permissible period, in violation of the Securities and Exchange Board of India Act of 1922. SEBI further alleged that the annual compliance test report for the Fund did not reflect the non-compliance matters associated with the alleged violations.

Item 13: Review of accounts

The Brookfield Accounts’ investment positions and accounts are monitored on a current basis, and a complete list of the accounts and positions is more formally reviewed as necessary. Such reviews are generally conducted by one or more members of a Brookfield Account’s Investment Committee. Brookfield Accounts are audited on a yearly basis by a firm of independent public accountants. Certain events may require an account review other than the periodic reviews. Such events include a transfer or withdrawal of an Investor interest in a Brookfield Account or a material change in the business of a portfolio investment. Brookfield makes available the books and records of a Brookfield Account to its Investors as provided in its Governing Documents. In addition, Brookfield provides the following written reports to each Investor of a Brookfield Account: •

within a period ending no later than 120th day after the end of the fiscal year an annual report with audited financial statements of the Brookfield Account including an overview of the investment activities of the Brookfield Account during the fiscal year covered by the annual report; and

•

within a period generally ending no later than the 60th day after the end of each of the first three fiscal quarters of each fiscal year, (i) an overview of the Brookfield Account’s investments, (ii) a statement showing the distributions to each Investor during the applicable fiscal quarter, (iii) a reconciliation of changes in the capital accounts of Investors during the immediately preceding fiscal quarter and (iv) a description of any material event regarding the business of the Brookfield Account or dispositions of investments during the quarter covered by the report.

Item 15: Custody

Brookfield may be deemed to have custody, as defined under Rule 206(4)‐2 under the Advisers Act, of funds or securities of the Brookfield Accounts. With respect clients, Brookfield generally relies on the “audit exemption” under Rule 206(4)‐2(b)(4) under the Advisers Act, which exempts an adviser to a limited partnership, limited liability company or other pooled investment vehicle from the requirement to deliver account statements to its clients if the adviser requires the vehicle to be audited annually by an independent public accountant that is registered with and subject to inspection by the Public Company Accounting Oversight Board and distributes the audited financial statements annually to the investors in the vehicles.

Item 16: Investment discretion

Brookfield has discretionary authority to manage the portfolios of certain Brookfield Accounts pursuant to their investment objectives, as set out in the applicable Governing Documents. Consent from Investors or a committee of representatives of Investors is required for a Brookfield Account to invest in securities or interests outside of its investment objectives, or as otherwise indicated by a Brookfield Account’s investment management agreement with Brookfield.

Item 17: Voting client securities

Brookfield may be deemed to have authority to vote proxies relating to the portfolio investments in which the Brookfield Accounts invest. Therefore, Brookfield has adopted a set of policies and procedures (together, the “Proxy Policy”) in compliance with Rule 206(4)‐6 under the Advisers Act. To the extent Brookfield exercises or is deemed to be exercising voting authority over Brookfield Account securities, the Proxy Policy is designed and implemented in a manner

reasonably expected to ensure that voting with respect to proxy proposals, amendments, consents or resolutions (collectively, “proxies”) is exercised in a manner that serves the best interest of the Brookfield Account, as determined by Brookfield in its discretion. Notwithstanding the foregoing, because proxy proposals and individual company facts and circumstances may vary, Brookfield may not always vote proxies in accordance with the Proxy Policy. In addition, many possible proxy matters are not covered in the Proxy Policy. Generally, Brookfield will vote proxies (i) in favor of management’s recommendation for the election of the board of directors and (ii) to approve the financial statements as presented by management. Each proxy is voted on a case‐by‐case basis taking into consideration any relevant facts and circumstances at the time of the vote. For matters covered in the Proxy Policy, generally the vote will be in accordance with the Proxy Policy. In situations where Brookfield wishes to vote differently from what is recommended in the Proxy Policy, or where a potential material conflict of interest relating to the proxy vote exists, Brookfield will take such actions as are required by the Proxy Policy. Investors may request a copy of the Proxy Policy and the voting records relating to proxies of the Brookfield Account in which they have invested by contacting Brookfield using the contact information on the cover page of this Brochure.

Item 18: Financial information

Not applicable.

Subsidiaries and ownership

Parent company (GLEIF)

Ownership links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); each one cites its LEI record.

Timeline

  1. Jul 14, 2023Parent Directly consolidated by Brookfield Corporation1
  2. Oct 7, 2011Founded BROOKFIELD RENEWABLE ENERGY GROUP LLC is founded1