CENTERSQUARE INVESTMENT MANAGEMENT LLC

Background CenterSquare is a limited liability company organized under the laws of the State of Delaware. The Firm is wholly owned by CenterSquare’s sole member, CenterSquare Investment Management Holdings LLC (“CenterSquare Holdings”). Funds managed by a subsidiary of Lovell Minnick Partners LLC (“Lovell”), a private equity firm registered with the SEC as an investment adviser, along with a third-party co-investor, own a majority ownership interest in CenterSquare Holdings. CenterSquare Management Equity Holdings LLC (“CSME”) also has primary ownership which is owned and controlled by certain executive officers of CenterSquare (“Executive Officers”). Certain other employees of CenterSquare have also invested in CSME. As a result of the allocation of profit interests, CSME has a significant ongoing economic interest in CenterSquare Holdings which is in excess of its ownership interest based on capital invested. The Executive Officers of CenterSquare control the day-to-day operations of the Firm. CenterSquare, formerly CSIM Investment Management LLC, was organized and formed in September 2017. Other minority ownership interests are held by former employees and affiliates of RCG Longview Management, LLC ( an investment adviser acquired by CenterSquare in 2019), CenterSquare’s third-party lender, an advisory board member of the Firm, and an independent director appointed by Lovell. On January 5, 2018, CenterSquare completed the purchase of the assets of CenterSquare Investment Management Holdings, Inc. and CenterSquare Investment Management Inc., each of which was a direct or indirect wholly owned subsidiary of The Bank of New York Mellon Corporation. These predecessor entities were also formerly registered with the SEC. At the time of the purchase, the executive officers and other employees, service contracts, assets and performance-related information of these two entities were fully transferred to CenterSquare. Advisory Services CenterSquare is an independent, diversified real estate manager focused on listed and private real estate globally. The Firm is headquartered in Conshohocken, Pennsylvania with affiliates in London and Singapore. CenterSquare provides discretionary and non-discretionary investment advisory services to:

institutional in the form of separate accounts; pooled investment vehicles which include funds that are either registered as investment companies pursuant to the Investment Company Act of 1940, as amended (the “1940 Act”), including mutual funds, or exempt from such registration in the United States including certain private funds; and other investment advisory services through subadvisory agreements.

CenterSquare’s business is not limited to U.S. clients and U.S. operations and is subject to foreign registration and regulation. Please see Item 7 for more information about the types of clients we manage.

The Firm provides advisory services to client investments in diversified portfolios of publicly traded real estate equity securities. These advisory services represent the Firm’s “Public Securities Strategy.” CenterSquare also provides advisory services to client investments in Alternative Investment Strategies as described at the end of this Item 4. Publicly Traded Real Estate Equity Securities CenterSquare invests client assets in publicly traded securities of real estate related companies including listed real estate investment trusts (“REITs”) and listed real estate operating companies (“REOCs”) whose principal business is the ownership, management and/or development of income producing and for-sale real estate. At times, accounts may also hold positions in publicly traded homebuilders and other real estate related businesses. The equity securities include common and preferred stocks. CenterSquare’s primary real estate investment objective is total return, consisting of dividends and capital appreciation. CenterSquare’s two main strategies include investments in Global and U.S. real estate securities. The Global real estate securities strategies primarily invest in developed markets of Europe, Australia, Asia, and North America (including the United States). Emerging market countries will also be considered subject to any client investment guideline restrictions. In addition to the primary strategies, certain other client investment objectives and mandates may result in the creation and management of other models and sub strategies. These other models include, but are not limited to, geographical mandates (i.e., North America), security concentrated mandates (i.e., U.S. Concentrated and Global Concentrated), preferred securities, investment specific mandates (i.e., high-yield focus or Environmental, Social, and Governance (“ESG”) focus) or customizable mandates to meet the needs of each client. Mandates may differ due to specific benchmarks selected by one or more clients. Separate Accounts For CenterSquare’s Public Securities Strategy, the Firm offers investment advisory services through separate accounts tailored to meet clients’ individual investment goals. CenterSquare works with clients to create investment guidelines mutually acceptable to the client and the Firm. When creating investment guidelines, clients may impose investment restrictions in certain individual securities or types of securities. CenterSquare’s strategies are generally managed in accordance with a model portfolio for all client accounts employing a similar strategy. Clients who impose investment restrictions, including different benchmarks, will have a portfolio that differs from the model portfolios which may result in investment performance that differs from that of the model and other client accounts.

Pooled Investment Vehicles CenterSquare also offers investment advisory services to pooled investment vehicles including private funds. Each pooled investment vehicle has an investment objective and a set of investment policies and/or guidelines that must be followed. For this reason, CenterSquare cannot tailor the investment advisory services it provides to pooled investment vehicles to meet individual investor needs or restrictions. CenterSquare also manages private real estate and private real estate debt portfolios as separate accounts and/or act as sub-adviser to registered investment companies and bank commingled funds, and other commingled vehicles. Certain investment vehicles CenterSquare manages are structured as joint ventures in which the Firm co-invests along with a client and agree to pay certain costs related to the joint venture. Wrap Programs CenterSquare provides portfolio management services for a limited number of clients participating in a managed account/wrap fee program with unaffiliated broker-dealer sponsor programs. In these dual-contract programs, CenterSquare receives a fee for providing investment advisory services based on a separate investment advisory agreement with the client and the broker-dealer receives a fee for providing execution services for the purchase and/or sale of securities in the client’s account along with other services as determined by the broker-dealer and client. The fees CenterSquare earns from managed account/wrap fee programs are based on a percentage of the market value of the assets managed for the client accounts. CenterSquare does not act as a sponsor to any managed account/wrap-fee program. When CenterSquare acts as an investment adviser under a managed account/wrap fee program, the Firm does not normally negotiate on the client’s behalf brokerage commissions or other costs for the execution of transactions in the client’s account. Rather, it is expected that most transactions will be executed through the program sponsor or the program sponsor’s designated affiliate since execution costs for agency transactions are normally included in the all-inclusive fee charged by the program sponsor. CenterSquare affects transactions through other broker-dealers who may charge a commission on the transaction only when it is reasonably believed that the execution through such other brokers is in the client’s best interest. Unified Managed Account CenterSquare also serves as a non-discretionary asset manager to unified managed account programs (“UMA Programs”). Under an agreement with program sponsors, CenterSquare serves as advisor or sub-advisor and provide the sponsors our model portfolio and position weightings. The sponsors retain discretion as to whether or not to implement the portfolio recommendations for the UMA client accounts.

The sponsors are solely responsible for providing brokerage, reporting, performance, custody and other services to program participants and such participants are not clients of CenterSquare. Other Advisory Services Disclosures CenterSquare manages client accounts pursuant to a written investment management agreement. The Firm utilizes a standard investment management agreement, although CenterSquare will negotiate an agreement using a client or consultant prepared investment management agreement. Alternative Investment Strategies In addition to our primary strategies, CenterSquare offers the following additional strategies (“Alternative Investment Strategies”): Strategic Capital Strategies Private Investment in Public Equity Strategy (“PIPE Strategy”) Subject to client investment guidelines, private investments in public equity (“PIPE Investments”) may be utilized in client portfolios to provide capital to an issuing publicly traded REIT or REOC for new property acquisitions (offensive capital), to deleverage an issuer’s (“Issuer”) balance sheet (defensive capital) and/or for general corporate purpose. These private placement investments will be illiquid until the underlying securities are registered for resale by the Issuer(s) or an exemption from registration that allows sales is available. The PIPE Investments may be in the form of common stock, common stock with fixed or variable priced warrants, convertible preferred stock, and/or convertible debt. The Issuer(s) will include listed U.S. real estate investment trusts and listed real estate operating companies. Clients will invest directly in PIPE Investments or through a separately formed special purpose or pooled investment vehicle. At the client’s request and direction, CenterSquare may also co-invest along with a client in a special purpose vehicle. Subject to investment guidelines or separate client approval, clients will pay or reimburse CenterSquare for allocable closing costs related to origination of a PIPE Investment. Additionally, special purpose vehicles will pay for administrative costs including tax preparation fees and other operating expenses. PIPE Investments will be illiquid for a predefined time period and CenterSquare will not be able to transact in the underlying securities until such securities are registered for resale by the Issuer or an exemption from registration that allows sales is available. At this time, CenterSquare has not made any PIPE Investments on behalf of client accounts. Private Investments in Non-Public Companies Strategy (“Private Company Investments Strategy”) Private Company Investments focus on private equity investments in non-public real estate related companies and platforms positioned for growth. These Private Company Investments may be utilized in client portfolios that allow for investment opportunities that fall outside typical avenues

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Separate Account Fees Publicly Traded Real Estate Equity Securities CenterSquare provides investment advisory services to separate account clients for a fee. This fee is typically charged as a percentage of an account’s assets under management. The assets under management will include publicly traded real estate related securities and, to the extent applicable to a client, PIPE Investments, and Private Company Investments. While this fee is expressed as an annual percentage, it is typically calculated based on the average market value of the account’s securities portfolio held during the quarter, based on the average of the month-end market values in the quarter. The market values are generally based on the client’s custodian values. Fees are billed on a quarterly basis in arrears, although certain client agreements require a different billing cycle. A client’s investment advisory agreement provides further information on how CenterSquare charges and collects fees along with expenses incurred by a client including brokerage costs. Please see Item 12 of this Brochure for more information on our brokerage practices. Our standard annual fee schedules for our main strategies utilizing a segregated account structure are stated below: Asset Size First $10 million Next $40 million Next $50 million In Excess of $100 million

U.S. 0.70% 0.65% 0.55% 0.50%

Global 0.75% 0.75% 0.65% 0.60%

Fees for separate account advisory services may be pro-rated for partial periods and for client contributions or withdrawals. CenterSquare reserves the right, in our sole discretion, to negotiate or modify (either up or down) the basic fee schedules set forth above for any client due to a variety of factors, including but not limited to, the level of reporting and administrative operations required to service an account, the investment strategy or style, the number of portfolios or accounts involved, and/or the number and types of services provided to the client. Because CenterSquare’s fees are negotiable, the actual fee paid by any client or group of clients could be different from the fees reflected in our basic fee schedule set forth above. CenterSquare has agreed to “most-favored-nation” clauses in agreements with certain clients. Certain clients require inclusion of a performance fee in the investment advisory agreement in addition to the asset-based management fee. Representative fees payable to us for separate accounts that invest in our Private Company Investment and PIPE Strategies:

Asset Management fee: Up to .50% annually of net asset value and

Performance fee: 15% of net profit, if any, subject to the return being above an agreed upon threshold.

Please see Item 6 below for more information on our performance fees. Private Fund Fees CenterSquare offers a Delaware Limited Partnership structure in our global publicly traded real estate equity securities strategy. The standard annual fee schedule for the private fund (exempt from registration in the United States), is as follows: Asset Size First $10 million Next $40 million Next $50 million In Excess of $100 million

0.75% 0.75% 0.65% 0.60%

Fees are calculated based on each underlying investor’s capital account balance and are charged quarterly in arrears. The fund permits each investor to select whether it would like fees to be deducted automatically from its capital account balance or billed separately. Private funds that CenterSquare manages are also subject to additional charges such as custody, brokerage and other transaction costs, administrative, professional (legal, audit, and tax preparation fees) and other expenses. Such additional charges are paid by the fund and therefore are allocated pro-rata to investors. A fee also may be charged on the full or partial redemption by an investor pursuant to the fund’s redemption schedule. In addition, and at the discretion of the General Partner, transaction costs will be borne by investors in connection with their contribution to, or withdrawals from, the private fund which generally are in excess of 10% of the total value of the private fund’s aggregate capital balance. Any separate arrangements with investors, such as separately negotiated fee arrangements, are subject to a written letter agreement between the private fund and the investor. Such arrangements will cause some underlying investors or groups of investors to have terms or to pay fees that are different from the basic fee schedules disclosed in fund offering materials. The fund’s offering materials contain further information regarding fees and other charges. Fees assessed on investments in the private fund by certain CenterSquare employees and related persons are reduced or waived entirely. Please see Item 12 of this Brochure for more information on brokerage practices. Mutual Fund and Other Pooled Fund Fees With a number of publicly traded real estate equity securities strategies, CenterSquare provides advisory services to mutual funds (which are registered as investment companies pursuant to the 1940 Act), to other pooled investment vehicles exempt from such registration, as well as to other

investment advisers through investment advisory or subadvisory agreements. CenterSquare’s fee is negotiated with the respective fund’s named investment adviser or sponsor. Fees on mutual funds and other pooled funds are typically charged as a percentage of assets under management. While this fee is expressed as an annual percentage, it is generally calculated based on the daily average market value of the fund’s securities portfolio held during the quarter. The daily average market values are generally computed by the mutual fund’s service provider. Fees are generally billed on a quarterly basis in arrears. The relevant investment advisory or subadvisory agreement provides further information on how CenterSquare charges and collects fees. Please see Item 12 of this Brochure for more information on our brokerage practices. A subadvisory client may require inclusion of a performance fee in the investment advisory agreement in addition to the asset-based management fee. Please see Item 6 below for more information on our performance fees. Other Fees and Expenses In addition to CenterSquare’s advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers and/or local exchanges. These charges, fees and brokerage commissions are exclusive of, and in addition to, the Firm’s advisory fees. CenterSquare shall not receive any portion of these commissions, fees, or charges, with the exception of research or brokerage products and services as permitted under the safe harbor of Section 28(e) of the Securities Exchange Act of 1934, as amended. For more information about brokerage commissions and commission sharing. Please see Item 12 of this Brochure for more information on our brokerage practices.

CenterSquare invests client assets in global equity securities of companies in the real estate industry, including real estate investment trusts (“REITs”) and real estate operating companies (“REOCs”), located in various countries throughout the world, including emerging market countries. In addition to these primary strategies, CenterSquare offers alternative strategies. Refer to Item 4 above. CenterSquare’s primary strategies are: 1. U.S. Real Estate Securities 2. Global Real Estate Securities

CenterSquare’s investment approach is uniform across all strategies and includes three primary components including Top-down Research, Bottom-up Research, and Risk Management which are outlined below: Top-down Research CenterSquare’s research process begins by considering the macroeconomic landscape. The Firm examines factors such as economic growth, interest rates, inflation, employment, and consumer spending. From this perspective, CenterSquare refines and forms an opinion on how each of these macroeconomic factors will impact the different real estate sectors. CenterSquare’s investment universe is comprised of both traditional or core sectors (e.g., office, apartment, retail, hotel, industrial) as well as alternative sectors (e.g., cell towers, data centers, single-family rental housing, life sciences). CenterSquare layers pricing considerations into this relative value analysis in order to determine which property sectors to overweight or underweight. Bottom-up Research The bottom-up element focuses on detailed stock-level analysis. Real estate is a managementintensive business, and thus CenterSquare begins with a qualitative assessment of each listed security by understanding each company’s strategic vision, ESG practices, and history of value creation in varying economic cycles. Next, CenterSquare quantifies the fundamentals and valuation of the underlying real estate using traditional real estate valuation tools, such as implied capitalization rates, net asset value, and replacement costs. We evaluate each underlying property from an operating perspective, considering items such as rental rates, occupancy, expenses, property locations, and quality of buildings, as well as quality of tenants and tenant turnover. Additionally, we consider ESG attributes using a proprietary quantitative model informed by approximately 100 individual datapoints (depending on region) we believe to be material in assessing ESG for real estate companies. The final phase of the bottom-up portion of our process involves evaluating each security using our proprietary valuation models. We strive to understand how independent variables drive valuation. Our proprietary models look at leverage, growth, size, property type, and other critical factors to derive our view of relative value. A critical component is a rigorous underwriting of each company’s balance sheet to understand the impact of debt and debt maturities on a company’s ability to navigate the capital markets and successfully implement its strategy. This disciplined financial modelling allows us to compare valuations across the listed real estate universe on a likefor-like basis over time. Risk Management While identifying attractive securities is an important element of our process, risk management ensures a proper balance between alpha generation and risk minimization. This third component of our process is embedded into our active portfolio construction process with our investment teams assessing risk at both the portfolio and individual security level. Within the portfolio context, CenterSquare continually assesses our investments at a multitude of

levels (i.e., sector, stock, and region) to ensure that our clients are adequately compensated for the risks they incur. Our intent is to maintain the proper exposures that result in an appropriate and sufficient tracking error relative to our benchmark. Top-down property sector weightings are examined in the risk allocation analysis. We calculate active exposures (sector, intra-sector-geography, stock, market cap), fundamentals (growth rates, earnings multiples, dividend yield, dividend payout ratio, net asset value, implied capitalization rate, financial leverage and EBITDA coverage), risk metrics (standard deviation, beta, volatility, VAR, ex-ante tracking error, performance attribution, correlation) and Liquidity (days-to-trade, daily volume, minimum size). Also, at the portfolio level we apply appropriate ceilings and floors by sector and region and have a 10% maximum weight in any single security. At the Securities Level - CenterSquare monitors risk at the individual security level in three ways: 1. Valuation - To ensure we are adequately compensated for our risk, we assess valuation using several factors including but not limited to implied cap rate, price earnings ratios, adjusted funds from operations (AFFO) and Net Asset Value (NAV). 2. Assessment of Quality - We evaluate risk by quantifying the qualitative aspects of a company through a proprietary quality score. It is during this process that we assess a management team’s experience, alignment, real estate portfolio quality, balance sheet, and overall investment strategy. 3. Security Characteristics - CenterSquare also examines a security’s investment characteristics and how a change to the Firm’s allocation to a security may impact the overall factor exposure of the portfolio, including securities’ quality, value, growth, leverage, and size as well as other metrics. CenterSquare invests substantially all client assets in real estate securities and generally holds less than 5% in cash. CenterSquare’s investment approach and related strategy offerings invest in a variety of securities and employs a number of investment techniques that involve certain risks. Investing in securities involves risk of loss that an investor should be prepared to bear. Environmental, Social, and Governance Considerations Our investment strategy is aligned with our fiduciary duty to make purposeful and well-informed decisions on our clients’ behalf and in conjunction with their values. Pertaining to our listed real estate strategies, our ESG integration is rooted in a proprietary process by which companies are scored on factors specific to environmental stewardship, social responsibility and corporate governance. Our quantitative ranking framework is comprised of ten metrics using nearly 100 KPIs (varied by region) to provide an expanded analysis of material ESG factors. The ESG score is then factored into our investment decision-making process alongside other qualitative measures. While we gather data from multiple sources to inform our ESG scores, data providers generally

assess ESG practices at a point in time or in the past. Therefore, for real time inputs into our model, we rely heavily on information gathered as part of our engagement with a company’s senior management. Engagement is an integral part of CenterSquare’s investment process and provides the opportunity to share our philosophy, corporate governance values, and importantly, encourage best practices within companies. Additionally, it augments our research by providing insight into strategy, competitive positioning, and management of material ESG risks and opportunities. When appropriate, CenterSquare may choose to lead or join with others in a campaign to promote our principles and values as stewards of client capital. In a typical year, the CenterSquare team will conduct more than 200 company engagements on ESG issues. CenterSquare is also committed to advancing ESG best practices globally through participation in industry groups and initiatives. Our collective work with peers promotes data-driven disclosures and the standardization of ESG guidelines and frameworks we believe to be most material to real estate. Together, we share information and thought leadership as it relates to our ESG insights and activities to collectively advocate for the integration of best practices across the real estate industry. Notable global ESG affiliations include: UNPRI, GRESB, The Task Force on Climate-related Financial Disclosures (TCFD), Global Reporting Initiative, Science Based Targets initiative (SBTi), and the Global Real Estate Engagement Network (GREEN). CenterSquare’s Sustainability Committee is comprised of professionals from across our organization. Led by our Senior Investment Strategist and Global Head of Sustainability, the Committee is responsible for developing and maintaining the Firm’s ESG policies and practices, ensuring efficient integration across all investment and administrative functions. In addition to steering the Firm’s overall ESG strategy, the Committee is tasked with understanding and adopting appropriate industry-wide best practices, setting and pursuing appropriate goals, conducting firmwide ESG training, and communicating on all initiatives and progress. Our commitment to growing and incorporating emerging ESG best practices is steadfast, and we look forward to continuing to serve as a trusted partner to our clients, stakeholders and communities in which we invest. CenterSquare continues to seek ways to quantify, track and incorporate ESG into our listed real estate investment processes and policies based on client needs. Areas of development and advancement include measuring impact, applying a UN Sustainable Development Goals (SDGs) framework to measurement and refinement of our ESG measurement models to align with an evolving industry and quantitative measurement of climate risks through a value-at-risk framework. Material Risks The table below and section that follows sets forth information concerning the material risks involved with CenterSquare’s Public Securities Strategies and Alternative Investment Strategies. An “X” in the table indicates that the strategy involves the corresponding risk. An empty box indicates that the strategy does not involve the corresponding risk in a material way. However, an empty box does not guarantee that the strategy will not be subject to the corresponding risk.

The risks set forth on the following pages represent a general summary of the material risks involved in the investment strategies we offer. If applicable, please refer to the “Risk Factors” section in the offering documents for a more detailed discussion of the risks involved in an investment in a fund.

Risk Type

U.S. Real Estate Securities

Global Real Estate Securities

Risk of Loss

ADR risks

Banking System Volatility risk

Clearance and settlement risk

Private Company Investments Strategy

Concentration risk

Country and sector allocation risk

Cybersecurity risk

Emerging market risk Exchange-traded fund (ETF) risk

PIPE Strategy

Foreign currency risk

Foreign investment risk

FX Transactions

IPO risk

Liquidity risk

Market risk

Model risk

Pandemics, Health Risks and COVID-19

Risk Type

U.S. Real Estate Securities

Global Real Estate Securities

PIPE Investment risks Preferred Securities risks

PIPE Strategy

Private Company Investments Strategy

Private Company Investment risks

Real estate and REIT risks

Small and midsize company risk

Stock investing risk

Warrants and rights risk

Risk of Loss. Each investment strategy we offer invests in a variety of securities and employs a number of investment techniques that involve certain risks. Investments involve risk of loss that clients and investors should be prepared to bear. We do not guarantee or represent that our investment program will be successful. Our investment results will vary and will not necessarily be indicative of our future performance. We cannot assure clients that its investments will be profitable, and in fact, clients could incur substantial losses. ADR risks. American Depository Receipts (“ADRs”) are typically issued by a US bank or trust company and represent ownership of underlying foreign securities. In addition to the risks presented in any investment including changes in value and changes in demand, there are several risks unique to ADRs that should be considered. For instance, while ADRs will react to normal market fluctuations like regular stocks, ADRs are still vulnerable to currency risks. If the value of the underlying security's home currency falls too much relative to the US Dollar, the effect will trickle down to the ADR eventually. The same can be said for changes in the underlying security’s government. Banking System Volatility risk. On Friday March 10, 2023, the U.S. Federal Deposit Insurance Corporation (the “FDIC”) was appointed receiver for Silicon Valley Bank (“SVB”) and created the Deposit Insurance National Bank of Santa Clara to protect SVB’s insured depositors. On Sunday March 12, 2023, the FDIC was appointed receiver for Signature Bank and created

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Types of Clients CenterSquare provides advisory services to many types of U.S. and non-U.S. domiciled clients including proprietary accounts, banks or thrift institutions, corporate pension and profit-sharing plans, public/governmental pension plans, Taft-Hartley plans, 401(k) Plans, trusts, charitable institutions, foundations, endowments, U.S. registered investment companies, U.S. private investment funds, other non-U.S. regulated funds and separate accounts, and other U.S. and nonUS institutions. CenterSquare also provides non-discretionary advisory services through certain unaffiliated institutional clients and fund sponsors. The initial minimum investment amount accounts in funds or the UMA or SMA programs vary depending on the platform and the sponsor. Account Requirements CenterSquare requires clients to execute a written investment management agreement, granting the Firm authority to manage their assets. Generally, client accounts are subject to minimum account sizes which vary depending upon the strategy of the account and account investment vehicle. Account Strategy U.S. Real Estate Securities Global Real Estate Securities

Minimum Account Size $5 Million $10 Million

CenterSquare sponsored pooled investment vehicles are generally subject to a $1 million minimum account size, regardless of a particular strategy. Non-firm sponsored pooled vehicles in which CenterSquare services as a sub-advisor have different minimum investment sizes. Please refer to the offering documents or prospectuses of such funds for more information. CenterSquare reserves the right to waive the minimum account size requirements.

CenterSquare’s performance-based fee arrangements and side-by-side management activities entail inherent conflicts that are described in this Item 6. CenterSquare has entered into performance-based fee arrangements with pooled investment vehicle clients and certain separate account clients. These arrangements provide for an asset-based management fee, based on the average market value of a portfolio, plus a performance fee based on the portfolio’s gross or net return in excess of a specified benchmark during a designated period of time. Additionally, for certain clients that participate in PIPE or Private Company Investments, a performance fee is charged based on PIPE or Private Company Investments performance (on an individual or aggregate basis) in excess of a stated Internal Rate of Return (IRR). A client with a performance fee arrangement should refer to its investment management agreement for details on the performance fee computation. It is possible that two client accounts in the same strategy may have different fee structures because one may have a performance-based fee. In this situation, the two clients could pay different amounts for the same service solely because of the performancebased fee.

Performance-based fee arrangements will be charged only to “qualified clients”, in accordance with Rule 205-3 under the Investment Advisers Act of 1940 (“Advisers Act”). Side-by-Side Management “Side-by-side management” refers to CenterSquare’s simultaneous management of multiple types of client accounts/investment products. For example, CenterSquare manages separate accounts and pooled investment vehicles (including, but not limited to, private funds) through investment management and subadvisory agreements at the same time. The Firm’s clients have a variety of investment objectives, policies, strategies, limitations and restrictions. CenterSquare’s affiliates likewise manage a variety of separate accounts and pooled investment vehicles. Please see Item 10 for more information on our affiliated investment advisers. Side-by-side management gives rise to a variety of potential and actual conflicts of interest for CenterSquare, its employees, and its supervised persons. Below a summary of the conflicts that the Firm and its employees and supervised persons face when engaging in side-by-side management and how CenterSquare deals with them. Note that CenterSquare manages its accounts consistent with applicable law and follows procedures that are reasonably designed to treat clients fairly and equitably to prevent any client or group of clients from being systematically favored or disadvantaged. For example, CenterSquare has a Trade Allocation/Aggregation and Directed Brokerage Policy that is designed and implemented to ensure that all clients are treated fairly and equitably, and to prevent these conflicts from influencing the allocation of investment opportunities among clients. Please see Item 12 for an explanation of our brokerage practices. Conflicts of Interest Relating to Accounts with Different Strategies During the normal course of managing assets for multiple clients of varying types and asset levels, CenterSquare’s portfolio managers (“Portfolio Managers”) encounter conflicts of interest. Management of multiple funds and accounts create potential conflicts of interest relating to the allocation of investment opportunities, and the aggregation and allocation of client trades. Additionally, Portfolio Managers manage client accounts with varying fee structures. Portfolio Managers oversee the investment of various types of accounts in the same strategy, such as mutual funds, pooled investment vehicles and separate accounts for individuals and institutions. Investment decisions are applied to all accounts utilizing a particular strategy, model and Portfolio Manager, taking into consideration client restrictions, client benchmark, instructions and individual needs. Please see Item 12 of this Brochure for more information on our brokerage practices. In addition, CenterSquare and its affiliates manage numerous accounts with a variety of strategies, which may present conflicts of interest. For example, CenterSquare may buy a security for one client account while it is selling that security for another client account. In addition, CenterSquare may cause one client account to buy a particular security “long” and another client account to sell that same security short. Please see Item 10 for further information about such conflicts.

Conflicts of Interest Relating to the Management of Multiple Client Accounts CenterSquare and its affiliates perform investment advisory services for multiple client accounts, including accounts with different fee arrangements. CenterSquare has no obligation to purchase or sell for a client any security or other property which it purchases or sells for the Firm’s own account or for the account of any other client. CenterSquare may give advice or take action in the performance of its duties with respect to any of the Firm’s clients which may differ from the advice given, or the timing or nature of action taken by affiliates on behalf of their clients. The management of multiple client accounts creates a conflict of interest because CenterSquare may have an incentive to favor one client account over another. Accordingly, CenterSquare has adopted and implemented policies and procedures intended to address conflicts of interest relating to the management of multiple client accounts. In particular, CenterSquare reviews investment decisions for the purpose of ensuring that all accounts with substantially similar investment objectives are treated equitably. Please see Item 12 of this Brochure for more information on our aggregation/allocation practices. The performance of similarly managed accounts is also regularly compared to determine whether there are any unexplained significant discrepancies. Conflicts of Interest Relating to Performance Based Fees When Engaging in Side-by-Side Management CenterSquare manages accounts that are charged a performance-based fee and other accounts that are charged a different type of fee, such as a flat asset-based fee. CenterSquare has a financial incentive to favor accounts with performance-based fees because the Firm (and our employees and supervised persons) have an opportunity to earn greater fees on such accounts as compared to client accounts without performance-based fees. Thus, CenterSquare has an incentive to direct our best investment ideas to client accounts that pay performance-based fees, and to allocate, aggregate or sequence trades in favor of such accounts. The Firm also has an incentive to give accounts with performance-based fees better execution and better brokerage commissions. Performance-based fees also create an incentive to make more speculative investments than CenterSquare would otherwise make in the absence of such compensation. Please see Item 12 of this Brochure for more information on our brokerage practices. Conflicts of Interest Relating to Investment in Affiliated Accounts CenterSquare invests client accounts in affiliated pooled vehicles, including pooled vehicles for which the Firm may act as sub-adviser. The Firm has an incentive to allocate investments to these types of affiliated accounts in order to generate additional fees for CenterSquare or its affiliates. Please see Item 12 for further information about such conflicts. Conflicts of Interest Relating to “Proprietary Accounts” CenterSquare, its affiliates, and existing and future employees manage and/or invest in products managed by the Firm, including private funds, and CenterSquare or its affiliates establish “seeded” funds or accounts for the purpose of developing new investment strategies and products (collectively “Proprietary Accounts”). Investment by CenterSquare, its affiliates, or its employees in Proprietary Accounts may create conflicts of interest. CenterSquare has an incentive to favor

these Proprietary Accounts by, for example, directing best investment ideas to these accounts or allocating, aggregating or sequencing trades in favor of such accounts, to the disadvantage of other accounts. CenterSquare also has an incentive to dedicate more time and attention to Proprietary Accounts and to give them better execution and brokerage commissions than other client accounts. Please see Item 12 of this Brochure for more information on our brokerage practices. Conflicts Relating to the Allocation of Private Company and PIPE Investments CenterSquare allocates Private Company and PIPE Investments among client accounts in a manner it deems appropriate. In making such allocation, CenterSquare will take into account factors that it deems relevant under the circumstances, including one or more of the following: (i) the character and nature of the investment opportunity (e.g., its size, structure, business strategy, minimum required investment size), (ii) the ability of a prospective investor to analyze or consummate a potential investment opportunity, (iii) the investing objectives and existing portfolio of the prospective investor, (iv) the ability of a prospective investor to fund such investment, (v) legal or regulatory constraints to which the proposed investment is expected to give rise, and (vi) CenterSquare’s own interests. With respect to allocations influenced by CenterSquare’s own interests, there could be a variety of circumstances where CenterSquare is incentivized to offer investment opportunities to one prospective investor over another. Additionally, CenterSquare may be contractually incentivized or obligated to offer economic terms that are more favorable to one or more prospective client investors. Other Conflicts of Interest CenterSquare or its affiliates have an incentive to cause investments to be made, managed or realized in seeking to earn compensation or advance the interests of one client over another. Certain client accounts managed by CenterSquare hold illiquid investments for which we receive performance-based compensation only upon their sale or deemed realization. To the extent CenterSquare is entitled to performance-based compensation from its clients upon the sale or deemed realization of illiquid investments, the Firm has an incentive to delay the realization of an illiquid investment. Tracy L. Steele, former Deputy General Counsel, is outside counsel through Ferro Steele LLC (“Ferro Steele”). Ferro Steele receives compensation for providing legal services to our separate account clients, private funds, and special purpose vehicles, but as an unaffiliated third-party legal services provider. Ferro Steele has a Space License Agreement in place with CenterSquare to license space at the Firm’s Pennsylvania headquarters. A fixed annual charge of $54,700 is paid by Ferro Steele in quarterly installments. CenterSquare has no economic ownership of the law firm and the use of the unaffiliated law firm is disclosed in private fund offering materials. Please see Item 10 of this Brochure for more information on other financial industry activities and affiliations.

CenterSquare has conflicts of interest, or conflicting loyalties, as a result of the numerous activities and relationships of the Firm, its Clients, the other CenterSquare vehicles, the portfolio entities of Clients and other CenterSquare vehicles and affiliates, partners, members, officers, directors and employees of the foregoing, some of which are described below. Not all potential, apparent and actual conflicts of interest are included below, and additional conflicts of interest could arise as a result of new activities, transactions or relationships commenced in the future. CenterSquare will take such actions as may be required by the organizational documents of the applicable Clients to handle conflicts.

Ownership Interest in CenterSquare As noted above, funds managed by a subsidiary of Lovell Minnick Partners LLC (“Lovell”) have an ownership interest (through CenterSquare Holdings) in CenterSquare. Lovell (through its affiliation and management of its Funds) has the right to appoint two members to the Board of Managers (“Board”) of CenterSquare Holdings, along with an independent member, but does not otherwise control the day-to-day business or operations of CenterSquare, subject only to any approval rights of the Board. Lovell retains majority voting rights of the Board. Lovell and/or its affiliates will gather data from us about our business operations, including information about holdings within client portfolios, which is either required for regulatory purposes or for other compliance, financial, legal or risk management purposes, pursuant to our policies and procedures. This data is deemed confidential, and procedures are followed to ensure that any information is utilized solely for the purposes intended. Through its relationship with Lovell, CenterSquare may become affiliated with several other entities in the financial services sector. CenterSquare may enter into service arrangements with the Lovell affiliated companies and the existence of common ownership between us and another affiliated company may create a conflict of interest, or the appearance thereof. Affiliated Solicitors and Placement Agents CenterSquare does not currently use affiliated solicitors or placement agents. If we do utilize affiliated placement agents in the future, the payment of these commissions and fees will ultimately not be borne by the private fund or private fund investors. Financial incentives may cause a placement agent and their employees and/or salespersons to steer investors toward a private fund that will generate higher commissions and fees. As noted in Item 14 below, and as part of our Private Real Estate and Private Real Estate Debt Strategies, the Firm has engaged unaffiliated solicitors and third-party placement agents to solicit persons to invest in private commingled funds or separate accounts. Affiliated Private Funds and Sponsors CenterSquare acts as investment adviser to private funds whereby affiliated entities of CenterSquare are the sponsor and general partner of the private funds. The affiliated general partners of the private funds as well as the related conflicts of interest will be disclosed to underlying investors before they invest. Management persons of the affiliated general partners will have conflicts of interest in allocating their time and service among such funds and other clients of ours. We have a conflict of interest in servicing such private funds versus our own clients. The private funds’ offering materials should be reviewed for further information regarding such conflict. In the event that the general partner deems it to be in the best interest of an affiliated fund, the fund will engage one or more sponsor affiliates or third parties to provide (i) transaction management services and (ii) such other services on behalf of the fund as may be approved by a fund advisory committee from time to time (to the extent any such aforementioned services or reports are

provided by sponsor affiliates, the “Affiliate Services”). In addition, one or more sponsor affiliates may also retain application/processing fees paid by borrowers in connection with the execution of a term sheet for an investment to be made by an affiliated private fund. The fees payable to sponsor affiliates for providing any Affiliate Services (“Affiliate Service Fees”) shall not exceed that which would be payable (based upon a reasonable determination by the general partner) if such services were provided by unaffiliated third parties in the business of providing similar services in arm’s length transactions. The general partner will provide the fund advisory committee annually with a schedule showing any Affiliate Service Fees paid to sponsor affiliates. Transaction Management During an affiliate fund’s investment period only, an affiliate of the general partner will provide certain transaction management services to the fund in order to facilitate and oversee the legal documentation and closing process for the fund’s investments. The fee for such services will be $250,000 per year. The general partner may cause an affiliated fund and its investments to enter into one or more agreements with affiliates of CenterSquare (“CenterSquare Service Providers”) pursuant to which such CenterSquare Service Providers will provide property-level services to the affiliated fund and its investments, including property management, leasing, construction management, leasing oversight, development, security and other real estate-related services (“Property-Level Services”), and cause the affiliated fund or its investments to compensate such CenterSquare Service Providers for such services as set forth below (“Property-Level Service Fees”). CenterSquare Service Providers may provide Property-Level Services to the affiliated fund and investments in conjunction with joint venture or other similar partners participating in such investments who may also charge the underlying property fees for property-level services. To the extent the affiliated fund or any investment is charged fees for property-level services by any nonCenterSquare Service Provider, the fees described below will be reduced by the amount charged to the affiliated fund or any investment by such third parties. Property-Level Service Fees received by CenterSquare Service Providers will not be applied to reduce the investment management fee or be required to be contributed to the affiliated fund. Without the approval of the respective fund’s Advisory Committee, Property Level Service Fees will not exceed the lesser of (a) the fees available in the relevant market from service providers that are not CenterSquare Service Providers for the type of property-level services provided and size and type of property and (b) the rates set forth below. Property Management Fees. Property management fees will be charged at a rate ranging from two percent (2.0%) to four percent (4.0%) of gross revenue (depending on property type and project size), and payable monthly in arrears. In the event that a property remains vacant for a significant period of time, a minimum property management fee (which may be lower than the contemplated range) will apply. Leasing Commissions. Leasing commissions will be charged at a rate of one percent (1.0%) of the total base rent in circumstances in which a broker is employed to lease an investment. In circumstances in which a broker is not employed to lease an investment, leasing commissions will

be charged at a rate ranging from four percent (4.0%) to six percent (6.0%) of the total base rent for new leases and a rate ranging from two percent (2.0%) to three percent (3.0%) of the total base rent for renewals. No CenterSquare Service Provider will receive from the Fund or an Investment (a) any leasing commissions for more than the first 10 years of a commercial real estate lease and (b) any leasing commissions on residential leases (including multi-family dwellings, senior housing and student housing) or other leases to individuals (such as for public storage or miniwarehouse facilities). Tenant Improvement Construction Management Fees. Construction management fees will be charged on a tiered-rate basis as follows: (a) five percent (5.0%) of the first five hundred thousand dollars ($500,000) of the project cost related to tenant improvements, (b) four percent (4.0%) of the next two hundred and fifty thousand dollars ($250,000) of the project cost related to tenant improvements, (c) three percent (3.0%) of the next two hundred and fifty thousand dollars ($250,000) of the project cost related to tenant improvements and (d) two percent (2.0%) of all additional amounts of the project cost related to tenant improvements. In the event that a tenant performs its own construction project, the construction management fee will be charged at a rate of one percent (1.0%) of the total project cost related to tenant improvements with respect to such investment. Development Fees. Development fees will be charged at a rate of four percent (4.0%) of the Hard Costs and Soft Costs (each, as defined below) directly related to the physical construction of an Investment. As used herein, “Hard Costs” means total material, services, supplies, machinery, equipment and apparatus acquired or used (including rental charges for such) and labor costs related to, construction, development, redevelopment, remediation, refurnishing, capital replacements and the build-out and restoration of tenant premises in connection with an Investment, including but not limited to building structure, foundations, landscape, site infrastructure, finishings and overhead, and labor costs related thereto. As used herein, “Soft Costs” means the costs related to pre-development planning and design, permitting, construction, development, redevelopment, remediation, refurbishing, capital replacements, and the build-out and restoration of tenant premises that are not classified as Hard Costs, and include, but are not limited to, architectural and engineering fees, design costs, permitting costs, impact fees, certification fees, mitigation fees (or their equivalent), financing fees, consultant fees, professional fees and expenses, insurance, bonding fees and contingency, if used. Affiliated Broker-Dealers, Investment Advisers and Service Providers CenterSquare Investment Management Asia Pacific Pte. Ltd. is a wholly owned subsidiary of CenterSquare Investment Management LLC which is registered with the Monetary Authority of Singapore (MAS License number: CMS101308) as a Capital Markets Licensee. CenterSquare Investment Advisors UK Ltd. (“CenterSquare UK”) is a wholly owned subsidiary of CenterSquare Investment Management LLC and serves as an appointed representative firm

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CenterSquare has adopted a Code of Ethics (the “Code”) pursuant to Rule 204A-1 under the Advisers Act and Rule 17j-1 under the 1940 Act. The Code is designed for the purpose of providing rules for certain personnel, including employees (“Employees”), with respect to adherence to certain standards of conduct along with abiding by policies regarding personal securities transactions. The Code requires Employees to exercise their authority and responsibility for the benefit of clients and to refrain from activities that will conflict with the interests of clients. The Code contains policies and procedures that, among other things:

Prohibit trading on the basis of material non-public information;

Prohibit Employees from taking personal advantage of opportunities belonging to clients;

Place limitations on personal trading by Employees and impose preclearance and quarterly and annual reporting obligations with respect to such trading;

Impose standards of business conduct for all Employees;

Require the distribution of the Code (and any amendments) to Employees and requires Employees to provide a written acknowledgment of their receipt thereof;

Require the reporting and review of Employees’ personal securities transactions;

Require Employees to report violations of the Code to our Chief Compliance Officer; and

Require Employees to comply with federal securities laws.

Separate policies exist relating to other common types of conflicts and procedures to be followed by CenterSquare Employees including:

Gifts and Entertainment;

Political Contributions; and

Outside Employment or Business Activities

CenterSquare’s Chief Compliance Officer monitors compliance with these and all other aspects of the Code. The Chief Compliance Officer will also determine the applicability of the Code to nonEmployees including temporary employees, contractors, Directors, and consultants. It is not expected that accounts in our Public Securities Strategy and the accounts under the Private Real Estate Strategies would be trading in the same securities at the same time, but we have implemented review procedures to track the accounts and shall address any potential conflicts of interests that might arise from the foregoing situation. A copy of our Code of Ethics is available upon request. Interests in Client Transactions Note that while each of the following types of transactions present conflicts of interest for CenterSquare, as described below, it will manage accounts consistent with applicable law, and follow procedures that are reasonably designed to treat clients fairly and to prevent any client or group of clients from being systematically favored or disadvantaged. Principal Transactions “Principal transactions” are generally defined pursuant to Section 206 of the Advisers Act as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys any security from or sells any security to any client. A principal transaction is also deemed to have occurred if a security is crossed between an affiliated pooled investment vehicle and another client account. We do not engage in principal transactions.

It is our policy that neither CenterSquare nor any of our officers or directors shall, as principal, buy securities for itself from or sell securities it owns to any client. Cross Transactions “Cross Trades” are generally defined as transactions in which a person acts as an investment adviser in relation to a transaction in which such adviser, or any person controlling, controlled by, or under common control with such adviser, acts as broker for both such advisory client and for another person on the other side of the transaction. Currently, CenterSquare does not engage in cross transactions. Transactions in Same Securities and Interests in Recommended Securities/Products CenterSquare or its affiliates invest in the same securities that the Firm or its affiliates recommend to clients. When we or an affiliate currently holds for our own benefit the same securities as a client, we could be viewed as having a potential conflict of interest. CenterSquare or its affiliates recommend securities to clients, or buy or sell securities for client accounts, at or about the same time that it or an affiliate buys or sells the same securities for their own account. This practice may give rise to a variety of potential conflicts of interest, particularly with respect to aggregating, allocating and sequencing securities being purchased on both CenterSquare or its affiliate’s behalf and a client’s behalf. For example, CenterSquare could have an incentive to cause a client or clients to participate in an offering because the Firm desires to participate in the offering on its own (or affiliates) behalf and would otherwise be unable to meet the minimum purchase requirements. Likewise, CenterSquare could have an incentive to cause its clients to participate in an offering to increase the Firm’s overall allocation of securities in that offering, or to increase our ability to participate in future offerings by the same underwriter or issuer. On the other hand, CenterSquare could have an incentive to cause its clients to minimize their participation in an offering that has limited availability so that the Firm (or its affiliates) do not have to share a proportionately greater amount of the offering to the client. Allocations of aggregated trades might likewise raise a potential conflict of interest as CenterSquare has an incentive to allocate securities that are expected to increase in value to the Firm’s benefit. See Item 12 for a discussion of CenterSquare’s brokerage and trade allocation practices and policies. Further, a potential conflict of interest could be viewed as arising if a transaction in CenterSquare’s own or affiliate account closely precedes a transaction in related securities in a client account, such as when a subsequent purchase by a client account increases the value of securities that were previously purchased for the Firm or an affiliate account. However, CenterSquare does not have direct or indirect access to securities held by its affiliates nor the power to buy or sell securities on behalf of the Firm’s affiliates, which may be also held in client accounts. CenterSquare recommends the purchase of securities in certain private funds which it manages and for which the Firm may serve as general partner. CenterSquare’s employees and related

persons invest in certain private funds that may also include client assets managed by the Firm, and CenterSquare and such related persons will receive proportional returns associated with an investment. Investments by Related Persons and Employees CenterSquare and its future employees, Board members, and affiliates and their employees will from time to time invest in products managed by the Firm. CenterSquare has developed policies and procedures to address conflicts of interest created by such investment. CenterSquare does permit employees to invest for their own account within the guidelines and restrictions of the Code of Ethics, as described above. For more information, please see Interests in Client Transactions in this Item 11. Agency Transactions Involving Affiliated Brokers CenterSquare will not, acting as broker or agent, effect securities transactions for compensation for any client. CenterSquare will not utilize any affiliated broker-dealers in trading for client accounts. Please also see Schedule D, Section 7A of our Form ADV, Part 1A for a list of brokerdealers which are affiliates.

In managing discretionary client accounts, CenterSquare has the authority to determine the securities to be bought or sold and the amount of such securities to be bought or sold on behalf of clients. Limitations on this authority are provided in client specified investment objectives, guidelines, and restrictions. Where CenterSquare has discretionary authority, the Firm has the authority to select the broker-dealers to whom it directs securities transactions on behalf of clients. These guidelines may be changed by a client upon written notice. Discretionary client accounts with similar investment mandates are managed in accordance with models for a given strategy, subject to any restrictions, benchmarks, or guidelines unique to a client account. Portfolio Managers determine the desired security holdings for each investment model. Investment decisions related to each model are generally implemented across accounts managed for a similar strategy in accordance with the particular model. There are instances where the same security is bought or sold on the same day across one or more strategies. Clients in a given strategy receive the average share price of securities bought or sold which may be higher or lower than the same securities bought or sold for another strategy. Broker Selection When CenterSquare has discretionary authority, the Firm directs securities transactions on behalf of clients to broker-dealers it selects. In doing so, CenterSquare seeks best execution of such transactions. When seeking best execution, CenterSquare considers the full range and quality of a broker-dealer’s services including, among other things, a broker’s trading expertise, reputation and integrity, availability of natural liquidity, financial services offered, willingness and ability to

commit capital, access to under-written offerings, execution capability, financial responsibility, commission rates, and responsiveness. CenterSquare will also consider other brokerage and research services provided by the broker-dealer. CenterSquare will also utilize execution-only automated trading systems. Commission Rates CenterSquare utilizes commission rate guidelines for execution-only brokers, full-service or hightouch brokers (who provide execution services, research and other value-added services such as corporate access, liquidity, access to new offerings) and electronic venues which indicate an appropriate commission rate based on the price of the stock, particular broker utilized, or type of transaction. Actual commission rates may vary from the commission rate guidelines. Soft Dollar Arrangements In the selection of qualified brokers to execute certain transactions, CenterSquare chooses a broker or dealer that provides, along with trade execution services, brokerage and research services and products as defined in Section 28(e) of the 1934 Act. Such services and products include, but are not limited to, analytical systems, models and research databases, company, industry, and market analysis, market data, brokerage routing systems, security exchange pricing and news services as well as independent or proprietary research. Proprietary broker research generally includes access to company executives, conferences, analyses, forecasts, and in-house research. Proprietary broker research may not have an identifiable value and is provided based on our total trading activity. Section 28(e) of the 1934 Act provides a safe harbor that allows an investment adviser to use dollars generated from brokerage commissions from client transactions (“soft dollars”). In a soft dollar arrangement, an investment adviser receives credit from a brokerage firm based on the commissions paid by the adviser’s clients. The adviser uses these credits to pay for proprietary broker research and third-party research services and products. In selecting a broker-dealer for a transaction and in an effort to seek best execution, CenterSquare considers the provision of research and/or brokerage services as one of the determining factors. Accordingly, CenterSquare reviews soft dollar relationships and expenditures on a regular basis to ensure eligibility in accordance with Section 28(e) and to evaluate commission and expenditure levels. CenterSquare will cause client accounts to pay a broker or dealer executing securities transactions a commission higher than the commission another broker or dealer could have charged for executing that securities transaction. CenterSquare determines in good faith that the commission is reasonable in relation to the value of the services and products, including soft dollar benefits, provided by such broker-dealer. CenterSquare performs an annual ranking of broker-dealers based on services and products provided which results in establishment of an annual target of commissions and brokerage to be provided.

CenterSquare makes a mixed-use allocation for certain research services. The percentage of the cost of the product or service that is used for research purposes may be paid for with client commissions, while CenterSquare uses its own funds to pay for the percentage of the product or service that is used for non-research purposes. CenterSquare faces a potential conflict of interest but believes that the Firm’s allocation procedures are reasonably designed to ensure that it appropriately allocates the anticipated use of such products and services to their research and non-research uses. The use of client commissions to obtain research services and products is used by CenterSquare to service all client accounts. Research services furnished or paid for by brokers through whom CenterSquare effects transactions for a particular account may be used by the Firm for the benefit of other accounts, and it is possible in some cases that none of the research services paid for by a given account will actually benefit that account. It is possible that certain client accounts may not permit the use of soft dollar arrangements and it is therefore possible that some of the research and brokerage services received will benefit clients other than those client accounts that generated soft dollar credits. Trade Aggregation/Allocation Clients with similar investment strategies or mandates are managed in accordance with models with target security weightings, subject to factors unique to each account, including investment restrictions, benchmarks, and cash levels. Portfolio Managers determine the desired composition for each investment model. Investment decisions related to each model are generally implemented across accounts managed in accordance with the particular model, with consideration for account specific factors. It may be determined that the purchase or sale of a particular security is appropriate for more than one client account in a particular investment strategy or mandate, in which case client orders for client accounts over which CenterSquare has discretion, will be aggregated or “bunched”. In such cases, CenterSquare owes a fiduciary duty to each client and, therefore, has an obligation to treat each client fairly. When aggregating orders, and in the process of allocating block purchases and block sales to individual client accounts, CenterSquare follows procedures set forth in its Trade Allocation/Aggregation and Directed Brokerage Policy designed to treat all clients fairly and equitably and to achieve an equitable distribution of bunched orders. If discretionary client account orders are combined within a given strategy, CenterSquare gives each client within the strategy the average price and transaction costs the Firm negotiates for the combined order and allocate securities to client accounts in a given strategy in proportion to the size of the orders placed. Orders may also be combined in multiple models or mandates, as determined by Portfolio Managers. Generally, when clients have provided CenterSquare brokerage discretion, client trades are aggregated into blocks based on an allocation plan whereby managed account holdings are increased or decreased to a specific target percentage of total account value, subject to client account specific factors.

This percentage allocation for a given account will be modified by the portfolio manager for a variety of reasons, including a small purchase or sale, lack of cash in a client account to fund a purchase, client cash restrictions, particular client security restrictions, or different client benchmark target. There may be circumstances where trades will not be allocated on a pro-rata basis, or to a specific client account at all, in cases where the trade is inconsistent with client guidelines or restrictions or the client account is not eligible to purchase the security (i.e., Rule 144a/Regulation S offerings). For clients with Directed Brokerage, please see the below description. There will be other reasons why a given account would not participate on a pro-rata basis in an allocation, but any such variance from the overall plan for clients would be guided by the basic principle of fairness to all clients. For the purposes of the Trade Aggregation/Allocation and Directed Brokerage Policy, pro-rata trade allocation means an allocation of a trade among applicable advisory clients within a given strategy in amounts that are proportional to the participating advisory client’s relative net assets. A pre-allocation of trades is made among participating client accounts. It is CenterSquare’s intention that accounts in each model be managed on a pro-rata basis as demonstrated by the use of portfolio models and target weightings. As a result, the pre-allocation takes into account the weighting of the particular security in each account compared to the relevant model weight established by the Portfolio Managers, as well as the cash position of each account (surplus or shortfall in cash as a result of additions or withdrawals). Once the pre-trade allocation is established, the trade is placed and executed. Each account participating in the trade order receives its proportionate share of the amount executed, whether in its entirety or a partial execution, in accordance with the pre-allocation. In this regard, CenterSquare ensures that the aggregation and allocation of securities trades is conducted on a fair and equitable basis in accordance with applicable regulation. Percentage allocations for a given client account will be modified by Portfolio Managers for a variety of reasons, including:

Too small a purchase or sale, in absolute shares or as a percentage change to an existing holding in the same shares; Lack of cash in the account to fund a purchase; Known restriction vis-à-vis the particular security being purchased or sold; Odd lot shares that may be allocated to one or more larger accounts; or Different client benchmark target within a block trade.

Notwithstanding the above, client account cash flows may result in individual trades outside of pro-rata allocation for aggregated trades. Client trades that are initiated separately from a given allocation plan on the same day (e.g., trades related to account rebalancing due to client cash inflows or outflows) will be excluded from participating in the average price of a block at the Portfolio Manager’s discretion.

If all shares ordered are filled in a given trading day, the allocation to accounts will be carried out exactly according to plan. However, if the order is only partially filled in a given trading day, securities will generally be allocated among participating client accounts on a pro-rata basis. Partial fills may be allocated to accounts other than in pro-rata fashion (i.e., other than in proportion to the percentage of total shares ordered that a given account represents) as follows:

Small accounts may be filled (completed) first where the size of their allocation, if split over two days, would have invoked higher fees; If only a small portion of the entire block is filled on a given day, the entire amount might be placed into one or more larger market value accounts where an allocation across more accounts would have resulted in a minimum or zero percentage of the order for all accounts; or If the partial trade generated a small amount of basis points, the smaller market value accounts may not receive any shares due to odd lot/local market conventions.

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Economic Benefits Received from Non-Clients for Providing Services to Clients CenterSquare receives certain research or other products or services from broker-dealers through “soft-dollar” arrangements. These “soft-dollar” arrangements create an incentive for CenterSquare to select or recommend broker-dealers based on the Firm’s interest in receiving the research or other products or services and may result in the selection of a broker-dealer on the basis of considerations that are not limited to the lowest commission rates and may result in higher transaction costs than would otherwise be obtainable by CenterSquare on behalf of its clients. Please see Item 12 for further information on CenterSquare’s “soft-dollar” practices, including the Firm’s procedures for addressing conflicts of interest that arise from such practices. Unaffiliated Solicitors and Placement Agents As part of the Firm’s Private Real Estate Strategies, third-party placement agents are utilized to solicit persons to invest in private funds or separate accounts. The Firm has entered into an agreement with each placement agent to pay the agent commissions or fees for such solicitation and services. CenterSquare is responsible for the payment of these commissions and fees – they will not be borne by the private funds, private fund investors, or separate account clients. CenterSquare will pay these commissions and fees out of Firm profits or if paid by the fund they will be reduced dollar for dollar from investment management fees. These commissions or fees do not increase the fees paid by the private fund’s investors. Financial incentives may cause a placement agent and their employees and/or salespersons to introduce new investment advisory clients to CenterSquare or steer investors toward a private fund that will generate higher commissions and fees. CenterSquare’s participation in a referral arrangement does not diminish its fiduciary duty obligations to its clients. The nature of CenterSquare’s relationship with a placement agent as well

as the method of compensation will be disclosed to relevant potential clients prior to the execution of an investment management agreement. Affiliated Solicitors and Placement Agents CenterSquare does not currently do not have affiliated solicitors or placement agents for which the Firm pays fees. CenterSquare may, in the future, pay referral fees to affiliates for referrals that result in additional investment management business. Please see the discussion of affiliated solicitors, placement agents and affiliated broker-dealers in Item 10, above.

At the time of this filing, CenterSquare is not aware of any material regulatory matters or litigation involving the Firm.

CenterSquare Portfolio Managers review client accounts regularly to ensure that all accounts are managed in a consistent manner within each strategy, and that the Firm adheres to specific client guidelines. Weekly meetings are generally held between Portfolio Managers and Research Analysts to review client accounts and holdings. The Risk Management Team monitors portfolios on a daily basis and formally reviews them with the portfolio management team during a monthly risk management meeting. The risk management meetings are attended by all members of the listed real estate securities team. The risk management meeting is also used to determine if any portfolio limits need to be adjusted upward or downward based on current market conditions. These decisions are made in cooperation with the Co-Chief Investment Officer and the portfolio management team.

In addition, CenterSquare delivers quarterly, written reports to our clients. These reports generally include account holdings, performance, and general market conditions. CenterSquare also prepares and provides other periodic reports, including reporting required by clients. Periodic internal reviews are conducted to ensure the client portfolios are managed in accordance with client guidelines and restrictions. CenterSquare Compliance performs a review of client contracts to ensure compliance with investment guidelines and restrictions. Investments in publicly traded securities are daily priced based on the last reported sale price quoted at the close on the respective primary exchanges. PIPE and Private Company Investments are valued periodically by CenterSquare taking into account a number of factors including market-based inputs, model-based inputs, and other inputs specific to each investment.

CenterSquare does not act as a custodian for client assets and does not have physical custody of client funds or securities. However, CenterSquare is deemed to have “custody” of certain clients’ assets under certain circumstances. Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) defines “custody” to include a situation in which an adviser or a related person holds, directly or indirectly, client funds or securities or has any authority to obtain possession of them, in connection with advisory services provided by the adviser. For purposes of the Custody Rule, CenterSquare is deemed to have custody of certain client assets because it serves as general partner of a private fund organized as a limited partnership. Generally, an adviser that is deemed to have custody of a client’s funds or securities, among other things, is required to arrange for an annual independent verification of such funds or securities in accordance with the Custody Rule (the “Surprise Exam Requirement”). However, the Custody Rule contains the following exception from the Surprise Exam Requirement relating to Pooled Investment Vehicles: Pooled Investment Vehicles Advisers who are deemed to have custody of the assets of clients formed as pooled investment vehicles may comply with the rule if the pool has audited financial statements that are prepared in accordance with generally accepted accounting principles and such statements are distributed to investors in the pool within 120 days of the end of the fiscal year. Where CenterSquare advises a pooled investment vehicle, it intends to cause such pooled investment vehicle to receive and distribute audited financial statements to its investors. Accordingly, private funds are audited annually and investors are provided with audited financial statements within 120 days of the end of the fund’s fiscal year. A client will generally receive from its bank, broker-dealer or other qualified custodian an account statement, at least quarterly, identifying the amount of funds and each security in the account at the end of the period and setting forth all transactions in the account during that period. Clients should review these statements carefully. Clients will also receive account statements separately from CenterSquare. Clients are strongly urged to compare the account statements received from us with those that are received from the respective client qualified custodian.

Generally, CenterSquare has discretionary investment authority over client assets, and clients must grant this discretionary authority to the Firm in writing via a contract and/or through an appointment to become the investment adviser of a private fund. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives and guidelines for the particular client account. Clients must deliver their investment guidelines and restrictions to CenterSquare in writing, and the Firm will adhere to such guidelines and restrictions when making investment decisions. Certain regulated clients, such as mutual funds and institutional accounts that represent the assets of ERISA plans, are subject to additional investment, diversification and other restrictions imposed by applicable law or their organizational documents. Such restrictions are typically reflected in the investment guidelines and may limit CenterSquare’s discretion with respect to an account. As a result, the performance of accounts for which investment restrictions imposed may differ from, and are sometimes worse than, the performance of accounts within the same strategy that lack such restrictions. Additionally, clients may impose directed brokerage or restricted brokerage arrangements, which would limit CenterSquare’s discretion regarding brokerage. The risks associated with directed brokerage and restricted broker arrangements are described in Item 12 above.

As a fiduciary and proponent for responsible investing, CenterSquare believes it is critical to participate in all company meetings and exercise clients’ voting rights with the goal of affecting positive management behavior over time in order generate economic value to shareholders. In accordance with Rule 206(4)-6 under the Advisers Act, CenterSquare has policies for voting proxies for client securities which it applies to those clients who have given the Firm, through the investment advisory agreement, authority to vote proxies. CenterSquare’s proxy voting policies and procedures are intended to give precedence to its clients’ best interests. To minimize conflicts of interest, CenterSquare has engaged a third party, Institutional Shareholder Services, Inc. (“ISS”), as an independent party to provide proxy research, reporting, and to vote all client proxies. As a UNPRI Signatory, CenterSquare has chosen to use the ISS Sustainability Proxy Voting Guidelines as the default proxy policy for its clients. A client of CenterSquare may elect to use other general or customized proxy voting guidelines through ISS. However, CenterSquare does not reconcile client specific voting policies to the ISS Sustainability Proxy Voting Guidelines. A client’s custodian generally directs proxies to ISS. Based on ISS’ research and guidance, proposals assessed to positively impact shareholders generally will be voted by ISS in favor of and proposals that would appear to have adverse impact on shareholders will be voted against. In most cases, CenterSquare will not override ISS recommendations and voting, but the Firm reserves the right to change that vote when a Portfolio Manager disagrees with an ISS recommendation and feels it is in the best interest of all clients to change the proxy vote.

In certain instances, a conflict of interest may arise when CenterSquare votes a proxy. For example, the Firm, or one of its affiliates, may manage an issuer’s retirement plan or an employee may have a business relationship that may affect how CenterSquare votes a proxy. CenterSquare believes that by engaging ISS, its adherence to these policies and procedures ensures that proxies will be voted in the best interest of the clients. Further, CenterSquare obtains information from all employees regarding outside business activities to confirm that they do not have personal interests in proxy matters (such as serving as board members or executive officers of an issuer). A copy of our Proxy Voting Policy and the ISS Sustainability Proxy Voting Guidelines is available to clients, without charge, by contacting Investor Relations via email at ir@centersquare.com. Clients may also obtain a summary of the proxy votes cast by CenterSquare for that client’s portfolio. CenterSquare’s clients are permitted to direct their votes in a particular solicitation. A client that wishes to direct its vote in a particular solicitation shall give reasonable prior written notice to CenterSquare indicating such intention and provide written instructions directing the Firm to change the vote in regard to the particular solicitation. Where such prior written notice is received, CenterSquare will vote proxies in accordance with such written instructions received from a client, provided that such instructions are provided in a timely manner.] At times a share blocking restriction may affect CenterSquare’s ability to vote a particular ballot. Share blocking can occur at the custodian, security, country, or market levels. Share blocking involves a re-registration of the security in order to vote a particular proxy. When share blocking is imposed, the shares are restricted by the custodian form sale/delivery during the re-registration period, which may be several weeks in length. Share blocking impedes CenterSquare’s ability to sell the security in the market and as a consequence may affect the liquidity of the holding. CenterSquare generally elects to not vote these shares thereby avoiding the share blocking reregistration and maintaining its ability to sell the shares if warranted. Clients who participate in a securities lending program may lose the ability to vote the shares being lent.

In certain circumstances, registered investment advisers are required to provide financial information or disclosures about their financial condition in this Item. CenterSquare has no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Brochure Supplements Please refer to the brochure supplement, Form ADV Part 2B, for information on the investment professionals who perform advisory services for you.