HEITMAN REAL ESTATE SECURITIES LLC

Background The Firm is an SEC registered public securities investment adviser that has been in business since 1989 and has its principal place of business in Chicago, Illinois.

Ownership Structure Heitman LLC (“HLLC”), the sole Member and parent of HRES, is the only entity that controls 25% or more of the Firm. In addition, the only entity that owns 25% or more of HLLC is KE I LLC, which holds a 99.95% stake in HLLC and acts as its managing member. The other member of HLLC is KE 2 LLC, which holds a nominal non-voting stake of 0.05%.

Other Related Entities Section 7.A of Schedule D in the Firm’s Form ADV, Part 1, which is accessible by following the directions on the Cover Page of this Brochure, discloses entities that are subsidiaries of the Firm’s parent entity (hereafter collectively, “Heitman Affiliates”). This disclosure includes all registered investment adviser and broker dealer Heitman Affiliates. Heitman Affiliates utilize limited partnerships or other pooled investment vehicles (the “Heitman Funds”) for investment purposes that are structured for clients of Heitman Affiliates that principally consist of institutional investors. Heitman Affiliates also act as general partner, manager, or in other similar capacities and serve as the investment advisers of these Heitman Funds. As a matter of practice, Heitman Affiliates provide prospective investors in a Heitman Fund with the fund’s private placement memorandum or comparable offering document, which contains information specific to that investment opportunity. Additionally, in certain cases, Heitman Affiliates create special purpose entities, including limited partnerships or similar vehicles that are comprised of one or more investors, but which are not organized as Heitman Funds (“Client SPV Entities”). Similar to Heitman Funds, in these cases, Heitman Affiliates may act as general partner, managing member, or in a similar capacity and also serve as the investment adviser for the Client SPV Entities. As a practical matter, these entities are created to facilitate certain investments in real estate on behalf of one or more clients. These structures are common for real estate investments and are generally utilized for tax efficiency and to protect stakeholders from potential liabilities and third-party claims associated with the underlying real estate.

Advisory Services The Firm provides investment advice and investment management services with respect to investments in equity, convertible and debt instruments of publicly traded real estate related companies, including real estate investment trusts (“REITs”), REIT-like entities and real estate operating companies (“REOCs”). In connection with the provision of the services described above, the Firm provides advice to clients regarding the investment of client funds based on each client’s stated objectives and strategies. Through direct discussions

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with each client, from which investment goals and objectives are identified, the Firm implements an investment policy that is documented in a separately negotiated investment management agreement or other comparable agreement or document (“IMA”). The Firm provides advisory and sub-advisory services to institutions. Examples of such advisory and subadvisory clients are registered investment companies, investment advisers, pension and profit-sharing plans, including government pension plans, sovereign wealth funds and pooled investment vehicles. The Firm manages these advisory clients on a discretionary and non-discretionary basis. Clients may impose reasonable restrictions on investing in certain securities, types of securities, industry sectors, or other factors. The Firm’s investment management is generally limited to securities of publicly traded real estate related companies as well as managing currency exposure to facilitate our trading activity, as required. Such securities are typically in one or more of the following categories: Exchange-listed securities in both US and developed foreign markets; Securities traded in over-the-counter markets; Newly issued securities by domestic and foreign issuers; or Rights and warrants. Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended when consistent with the client’s stated investment objectives. For example, the Firm may use a covered call strategy to derive more income for a client’s portfolio; however, selling covered calls can impart more risk to the portfolio. Please see Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for more information. The Firm’s discretionary investment advisory services include a variety of investment strategies from which clients may select. These strategies include US Real Estate Securities Total Return, US Real Estate Securities Focused, US REIT Asset Value Growth, US Preferred REIT, Global Real Estate Securities, Global Real Estate Securities Concentrated, Global Prime, European Tactical Income , and Japan Real Estate Securities Total Return. The Firm also provides variations of certain of these strategies to accommodate, among other things, country exclusions or targeted yields. From time to time, the Firm establishes vehicles or managed accounts funded by Heitman or its employees to establish new strategies. Such strategies do not overlap with existing investment strategies managed for clients. Collective Investment Trust. The Firm serves as the discretionary investment manager to the Heitman Global Prime Collective Investment Trust, Heitman Global Real Estate Collective Investment Trust, and the Heitman US Diversified Collective Investment Trust (the “Trusts”). The Trusts are bank collective trusts offering units of beneficial ownership to qualified and eligible investors. Benefit Trust Company, a Kansas trust company, is the Trustee of the Trust. The Firm also serves as the discretionary sub-adviser of the Heitman US Real Estate Securities Focused Collective Investment Trust. This trust is a bank collective trust that offers units of beneficial ownership to

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qualified and eligible investors. Great Gray Trust Company, LLC, a Nevada retail trust company, is the trustee of the trust. The trusts are only offered to certain eligible investors that are qualified plans, such as pension, profit sharing and 401(k) plans. More information is available upon request by contacting the Firm’s Client Service and Marketing department at 312-855-5700.

Other Services HRES also provides, on a limited basis, other investment advisory services on a non-discretionary basis. These services include providing model portfolios to certain institutional clients or sponsors and licensing one or more of its strategies for a fee. The Firm exercises no discretion over the assets in either situation. The institutional client or sponsor have the discretionary responsibility for the determination of securities to be purchased or sold and effects all security transactions in connection with such determination. In these cases, the Firm generally does not have any knowledge as to which securities were ultimately purchased or sold or the ending portfolio weighting of the resultant portfolios.

Amount of Managed Assets As of December 31, 2025, the Firm managed approximately $1,821,428,968of client assets on a discretionary basis and approximately $1,631,156,449 of client assets on a non-discretionary basis.

Asset Management Fees As compensation for its investment advisory services, the Firm is normally entitled to an annualized portfolio management fee, which is usually calculated and paid as a percentage of assets under management. In some instances, the Firm earns additional fees based on investment performance results (also referred to as an incentive fee). For additional information, please refer to the “Performance-Based Fees” section (Item 6). Management Fees for Separate Account Clients. To the extent that Heitman has established asset-based investment advisory fees for the strategies it offers, the schedule below is the fee schedule Heitman generally employs. However, fees for certain accounts may fall outside of the stated range. Heitman may amend its fee schedule in accordance with the terms of its advisory contracts. Investment Strategy

Annual Fee (USD) 0.65% on the first $25 million

US Real Estate Securities Total Return

0.50% on $25-$100 million 0.45% on $100-$250 million 0.40% over $250 million

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0.65% on the first $25 million US Real Estate Securities Focused

0.60% on $25-$100 million 0.55% on $100-$250 million 0.50% over $250 million 0.65% on the first $25 million

US REIT Asset Value Growth

0.50% on $25-$100 million 0.45% on $100-$250 million 0.40% over $250 million

US Preferred REIT

0.51% 0.65% on the first $25 million 0.55% on $25-$100 million

Global Real Estate Securities

0.50% on $100-$250 million 0.45% over $250 million

0.80% on the first $25 million Global Real Estate Securities Concentrated

0.70% on $25-$100 million 0.60% on $100-$250 million 0.55% over $250 million

European Tactical Income

0.50%

Global Prime

0.30%

Advisory fees may vary. Asset management fees are negotiated on a client-by-client basis. Client requirements, and other facts and circumstances are considered in determining the fee schedule. These include, but are not limited to, the inception date of the account, the complexity of the client mandate, amount of assets to be placed under management, anticipated future additional assets, related clients, portfolio style and composition, types of securities held, portfolio customization and the nature of reporting requested, among other factors. The asset-based fees that the Firm receives from model portfolio providers, sponsors or third parties to whom the Firm licenses its strategies are separately negotiated with each party. The terms and conditions, including fees for services, are mutually agreed to with clients prior to entering into the IMA and are paid quarterly in arrears. The Firm’s customary practice is to provide quarterly invoices to the client, or other party, as directed by the client. Such fees are typically paid to the Firm through the custodian or other client designee. Upon termination of any IMA, any unearned fees will be promptly refunded, and any earned but unbilled fees will be invoiced. The Firm may group certain related client accounts for the purpose of determining the annualized fee. Clients should note that similar advisory services might be available from other registered (or unregistered) investment advisers for lower fees.

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Product-Specific Fees. The Firm provides investment advisory services to the Trusts. The fees paid to the Firm are disclosed in their applicable offering documents. The Firm also provides sub-advisory services to one or more registered investment companies at terms and conditions including fees for services mutually agreed to with those advisors. Fees paid by these funds for investment advisory services are described in each fund’s prospectus.

General Information Additional Fees and Expenses. In addition to the Firm’s advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers and/or local exchanges, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for clients’ portfolios. These charges, fees and brokerage commissions are exclusive of, and in addition to, the Firm’s advisory fees. The Firm shall not receive any portion of these commissions, fees, or charges, except for 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 (the “Exchange Act”). For more information about brokerage commissions and commission sharing, please refer to the “Brokerage Practices” section (Item 12) of this Form ADV for additional information. ERISA Accounts. The Employee Retirement Income and Securities Act (“ERISA”) and regulations under the Internal Revenue Code of 1986 (the “Internal Revenue Code”), respectively, deem the Firm to be a fiduciary to its clients that are employee benefit plans. As such, the Firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, the Firm only charges fees for investment advice regarding products for which the Firm and/or its “related persons” do not receive any commissions or 12b-1 fees, or conversely, investment advice regarding products for which the Firm and/or its “related persons” receive commissions or 12b-1 fees, however, only when such fees are used to offset the Firm’s advisory fees.

Strategies and Risk of Loss Methods of Analysis The Firm uses the following methods of analysis in formulating its investment advice and/or managing real estate related client assets: Fundamental Analysis. The Firm measures the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis. The Firm analyzes past market movements and applies that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement.

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Quantitative Analysis. The Firm uses mathematical models in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share and predicts changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Qualitative Analysis. The Firm subjectively evaluates non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predicts changes to share price based on that data. A risk in using qualitative analysis is that the Firm’s subjective judgment may prove incorrect. Risks for all forms of analysis. The Firm’s securities analysis methods rely on the assumption that the companies whose securities it purchases and sells, the rating agencies that review these securities, and other publicly available sources of information about these securities are providing accurate and unbiased data. While the Firm is alert to indications that data may be incorrect, there is always a risk that its analysis may be compromised by inaccurate or misleading information. Investment Philosophy. The Firm provides investment management and advisory services for institutional investors wishing to invest in publicly traded real estate related companies listed on various exchanges. The Firm provides clients with an experienced, disciplined, and in-depth investment approach, which includes fundamental securities analysis. It seeks investments that will outperform established benchmarks by purchasing securities of companies with superior growth prospects or securities that it deems undervalued. The Firm generally evaluates securities using an intermediate to long-term investment horizon, which is dictated by the nature of the underlying real estate assets. However, the Firm frequently reevaluates each position in terms of national and local economic conditions, rents, occupancy levels and competition, and changes in management strategies. Sustainability Analysis. As part of its risk analysis, the Firm, when appropriate, may conduct a risk assessment that includes consideration of sustainability factors that can facilitate consistency in the projection of financial returns and positive impact in the valuation of listed real estate equities, where opportunities exist for increasing net income, due to lower expenses, as well as higher valuations resulting from lower risk premiums and capitalization rates. Sources of Information. An important part of the Firm’s analysis is individual property site visits. Properties are analyzed to determine underlying economic values, the consistency and quality of cash flow, the potential for growth through re-leasing or physical enhancement, and their ability to employ leverage to positively enhance results. The Firm maintains contact with industry sources such as bankers, real estate brokers, property managers, local real estate investors and appraisers to access individual properties and local real estate trends. In addition, Heitman Affiliates’ experience in private equity real estate and debt investment, in combination with information from sector specialists within Heitman Affiliates’ research team, provides the Firm with insight into trends, market turns and investment strategy execution across the spectrum of real estate investing.

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Investment Strategies The Firm uses the following strategies in managing client portfolios, provided that such strategies are appropriate to the needs of the client and consistent with a client’s investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. The Firm may purchase securities with the idea of holding them in a client’s portfolio for a year or longer. Typically, the Firm employs this strategy when it believes the securities to be currently undervalued; and/or it wants exposure to a particular asset class over time. Risks associated with a long-term purchase strategy are described below. Short-term purchases. When utilizing this strategy, the Firm may purchase securities with the idea of selling them within a relatively short time. The Firm does this in an attempt to take advantage of conditions that it believes will soon result in a price swing in the securities it purchases. Risks associated with a short-term purchase strategy are described below under Risk of Loss – Trading.

Risk of Loss Investing in real estate securities may be subject to the principal risks summarized below. These risks could adversely affect the investment’s value, yield, and total return. It is possible to lose money by investing in these securities. Moreover, the Firm’s parent has a Compliance Committee that reviews and evaluates compliance issues and potential risks deemed to affect the Firm and its Heitman Affiliates. The Compliance Committee seeks to ensure such issues are addressed. These compliance issues include, among other things, matters involving Know Your Customer, Anti Money Laundering, Privacy and Pay-to-Play issues. Controls are evaluated, enhanced, and/or established to manage such risks. All IMAs are reviewed by a member of the legal and compliance team prior to execution. Customized checklists are prepared to address IMA requirements and these checklists are periodically audited. Real Estate Securities. The Firm concentrates its investments in real estate securities. An investment made by the Firm on behalf of its clients will not constitute a diversified investment program for purposes of applicable mutual fund regulation. Real estate securities are susceptible to the risks associated with direct ownership of real estate, including, without limitation, declines in property values; increases in property taxes, operating expenses, interest rates or competition; overbuilding; zoning changes; risks related to general and local economic conditions; eminent domain; fluctuations in rental income; changes in neighborhood values; the appeal of properties to tenants; and losses from casualty or condemnation. Real estate companies may be affected by changes in the value of the underlying property they own and by the quality of credit extended. Such companies also are subject to heavy cash flow dependency, defaults by borrowers, self-liquidation, and the possibility of failing to qualify for tax-free pass-through of income under applicable income tax regulations in the jurisdiction of the companies. REITs are dependent upon specialized management skills, have limited diversification and are generally dependent on their ability to generate cash flow to make distributions to shareholders. The requirements for qualification as a REIT are extremely complex. It is possible that a real estate company that purports to be a

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REIT may fail to qualify as such. In that event, the purported REIT would be subject to corporate level taxation, which would significantly reduce the return on investment in such enterprise. REITs in non-traditional real estate assets, such as data centers, self-storage or cell-phone towers, may not perform in a manner correlated to their underlying assets or may perform in a manner unrelated to factors, such as interest rates or federal tax law that typically have an impact on more traditional REITs. Concentration of Portfolio. The various strategies executed by the Firm may result in the concentration in a limited number of securities, or one security may constitute a significant percentage of a particular portfolio. A decline in the value of a security or securities in which the portfolio holds a concentrated interest could substantially affect the overall value of the portfolio. Stock Market Risk. The value of the stocks and other securities held as investments fluctuate depending on the performance of the companies that issued them, general market and economic conditions, and investor confidence. The market may also fail to recognize the Firm’s determination of an investment’s value, or the Firm may misgauge that value. Industry and Sector Risk. Companies that have similar lines of business are grouped together in broad categories called industries. Certain industries are grouped together in broader categories called sectors. The Firm concentrates its investments in certain real estate related industries, which may cause the investment’s performance to be susceptible to the economic, business, or other developments that affect those industries. Real estate industries are particularly sensitive to the following economic factors: decreases in demand due to economic recessions; increases in supply due to overbuilding; interest rate changes; changes in zoning laws; changes in neighborhood values; increases in property taxes; casualty and condemnation losses; and regulatory limitations on rents. Risks of Investing in Foreign Securities. Some of the Firm’s strategies require investing in foreign securities that are subject to risks not typically associated with domestic securities. Although ADRs and GDRs are alternatives to directly purchasing the underlying securities in their national markets and currencies, they are also subject to many of the risks associated with investing directly in foreign securities. Foreign investments can be riskier and more volatile as a result of varying custody, brokerage and settlement practices, difficulty in pricing of securities, less public information about issuers of such securities, less governmental regulation and supervision of the issuance and trading of securities, the possibility of expropriation or nationalization, adverse political, social or diplomatic developments, the imposition of withholding and other taxes, limitations on the movement of funds between different countries, and difficulties in invoking legal process abroad and enforcing contractual obligations. Changes in the value of foreign currencies can make it more difficult for the portfolio holding such securities to sell its securities and could reduce the value of an investment in the portfolio. Currency Risk and Exchange Risk. Because foreign securities generally are denominated and pay dividends or interest in foreign currencies, the value of the investments in foreign securities as measured in each security’s local trading currency are affected favorably or unfavorably by changes in exchange rates. Generally, when the local currency rises in value against a foreign currency, a security denominated in that local currency loses value because the currency is worth fewer foreign dollars. Conversely, when the local currency decreases in value against a foreign currency, a security denominated in that currency gains value because the currency is worth more local dollars. This risk, known as “currency risk,” means that a stronger local currency reduces returns for

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Read the rest in the brochure

The Firm may provide advisory services to many types of US and non-US domiciled clients including affiliated investment advisers, government pension and retirement plans, corporate pension and retirement plans, registered investment companies, pooled investment vehicles, sovereign wealth funds, and separate account portfolios managed for institutional entities. The Firm also has arrangements with other advisory firms pursuant to which the Firm has discretionary authority to make investment decisions but is acting not as the primary advisor to the client, but rather in a sub-advisory capacity. The Firm or its affiliates serve as the investment manager or sub-adviser to mutual funds, collective investment, open-ended and finite-term unit trusts and funds formed pursuant to the laws of various jurisdictions.

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Minimum Account Size The minimum dollar amount for establishing a separate account is generally as follows: Investment Strategy

Minimum Portfolio Value

US Real Estate Securities Total Return US Real Estate Securities Focused US REIT Asset Value Growth US Preferred REIT Global Real Estate Securities

$10,000,000

Global Real Estate Securities Concentrated European Tactical Income Japan Real Estate Securities Total Return Global Prime

$50,000,000

The foregoing minimum portfolio amounts can be waived by the Firm in its discretion to permit smaller investments.

Performance-Based Fees As described in Item 5 of this Brochure, the Firm may earn and receive performance- or incentive-based fees from certain of its clients. These types of fee structures are negotiated on an individual basis with the client, subject, if applicable, to the requirements of Section 205 and Rule 205-3 under the Advisers Act. Such fees are generally based upon the extent to which the returns of the account exceed a predefined benchmark or investment return hurdle. These types of fee structures are often viewed as better aligning the Firm and its compensation with its client’s investment objectives and results. In theory, a performance- or incentive-based fee structure could lead to circumstances where the Firm may be perceived as having a conflict. Some examples of why a performance or incentive-based fee structure may be perceived as a conflict for the Firm include instances where the Firm may:

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Favor clients with performance-oriented compensation over other clients of the Firm that have different fee arrangements; Recommend a riskier or more speculative investment that is projected to result in higher fees to the Firm; or Time dispositions or control other factors particular to a security position that have the potential to generate additional fees. The Firm has the following protections in place to mitigate the potential for conflicts caused by performance- or incentive-based fee structures: The Firm’s investment recommendations are created in accordance with the investment guidelines as defined in the client’s IMA; The Firm recommends the same or similar investments for clients participating in the same strategy, regardless of the fee structure; Purchase and sale orders are placed by the portfolio managers across all portfolios in the same strategy at the same time, barring other limiting circumstances, such as individual client restrictions, size of the portfolio, or cash inflows or outflows, which may create differences; All transactions are reviewed by portfolio managers; and The Firm performs a regular review of performance dispersion among portfolios that participate in the same strategy to measure balance across each portfolio within each strategy. INCENTIVE OR PERFORMANCE-BASED FEES WILL ONLY BE CHARGED IN ACCORDANCE WITH THE PROVISIONS OF RULE 205-3 OF THE ADVISERS ACT.

Affiliations As described in Item 4, some Heitman Affiliates are registered as investment advisers or broker-dealers as described below. The Firm’s affiliates conduct the following business activities: 

Heitman International Real Estate Securities Pty Limited (“HIRES Pty”) is a SEC registered investment adviser that provides research and execution services to the Firm. HIRES Pty executes transactions in publicly traded equity securities of real estate investment trusts and other real estate related securities. HIRES Pty is also registered with the Australian Securities and Investment Commission. HIRES Pty may also deal in financial products.



Heitman International HK Limited (“HI HK”), which is a SEC registered investment adviser, provides research and discretionary advisory or sub-advisory services to the Firm. HI HK also provides private equity and debt investment advisory services. HI HK is also registered with the Hong Kong Securities and Futures Commission.



From time to time, the Firm will draw upon the market research capabilities of the Firm’s parent in making its portfolio selections.



HIRES Research Limited provides research services to the Firm and Heitman Affiliates.



Heitman Securities LLC (“HSL”) is a registered broker-dealer and member of the Financial Industry Regulatory Authority. Heitman UK Limited (“HUK”) is an investment firm registered with the United Kingdom’s Financial Conduct Authority. From time to time, the Firm or its affiliates may utilize the services of HSL, HUK, or HIRES Pty for security offerings of Heitman Funds. To the extent that these entities can

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trade in public securities, none of these entities will engage in any transactions as a broker-dealer for advised clients of the Firm. 

Several personnel of the Firm and Heitman Affiliates are registered representatives or approved persons of these registered broker-dealers. These persons do not receive direct compensation for their brokerdealer or placement agent duties.



Heitman Capital Management (“HCM”) and Heitman International LLC (“HI”) are private equity and debt investment advisers that are registered with the SEC. As described further below, HI maintains a branch office in Tokyo, Japan that is also registered with the Kanto Local Finance Bureau (“KLFB”), which was delegated administrative responsibility and oversight for this branch from Japan’s Financial Services Agency. These entities conduct global advisory business managing private equity and debt real estate investments for pooled investment vehicles and separate account clients. These entities may also provide research services to the Firm.



Heitman International – Japan Branch (“HI Japan Branch”) is a branch office of HI, located in Tokyo, Japan. As mentioned above, HI Japan Branch is registered with KLFB and is licensed to provide certain investment management services and related client support activity. This location also acts as an operational liaison and assists in various reporting, client service and marketing and investment oversight matters for Heitman clients and investments that are in the Asia Pacific region generally and Japan, in particular.



Heitman International – Seoul Branch (“HI Seoul Branch”) is a branch office of HI that is located in Seoul, South Korea. HI Seoul Branch conducts basic client service and relationship oversight activities, such as building Heitman’s name/brand recognition in the geographic region and acting as the relationship manager and liaison in respect to existing Korean based clients.



The Firm’s parent provides certain central office support functions such as compliance and anti-money laundering monitoring, human resources, information technology, and other similar enterprise-wide activities.

In the event that any of its affiliations present potential conflicts of interest, the Firm will either resolve the conflict of interest or follow established written policies and procedures for disclosing such conflicts of interest to its clients.

Other Pooled Investment Vehicles As described in Item 4, Heitman Affiliates create limited partnerships or similar pooled investment vehicles referred to as “Heitman Funds” and “Client SPV Entities.” Heitman Affiliates serve as investment adviser to such entities. As described earlier in this section, the Heitman Affiliates solicit investors to invest in these entities through affiliated broker-dealers. Further, unaffiliated third parties may, in some cases, be utilized to solicit investors to invest in these entities, as described in Item 14.

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in Client Transactions and Personal Trading The Firm has adopted a Code of Ethics (the “Code”), which sets forth standards of business conduct required of all of its officers, managers and employees and requires its employees to maintain integrity and ethical dealings with clients and comply with all applicable laws and regulations of the various jurisdictions in which the Firm operates. The Code includes the establishment and enforcement of policies and procedures reasonably designed to prevent the misuse of material, nonpublic information. The Firm and its personnel owe a duty of loyalty, care, fairness and good faith to its clients and have an obligation to adhere to the specific provisions of the Code as well as the general principles that guide the Code. The Firm designed the Code to ensure that the personal securities transactions, activities, and interests of its employees will not interfere with: (i) making decisions in the best interest of clients, and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. The Code includes policies and procedures for the review of quarterly securities transactions reports and initial and annual securities holdings reports submitted by all of the Firm’s Access Persons and their Family Members. The Code requires the prior approval or prohibition of certain securities transactions. It also contains oversight, enforcement, and recordkeeping provisions. Further, Access Persons certify on a quarterly basis and Supervised Persons certify on an annual basis that they have complied with the requirements of the Code. In addition, the Firm has implemented mandatory compliance training that is conducted periodically. Compliance topics address policies applicable to all employees of the Firm, such as conflicts of interest, fiduciary duty, pay-to-play, and anti-money laundering. It is possible that “related person(s)” will have an interest or position in certain securities that the Firm recommends to a client. The Firm’s express policy is that no employee may purchase or sell any security prior to implementing a transaction for an advisory account. This policy is intended to prevent employees from benefiting financially from transactions placed on behalf of advisory accounts. The Code further includes the Firm’s policy prohibiting the use of material nonpublic information for personal trading or on behalf of itself or others. A copy of the Firm’s Code of Ethics is available to its advisory clients and prospective clients. Clients may request a copy by email sent to compliance-us@heitman.com or by calling 312-855-5700. As an investment adviser, the Firm has fiduciary responsibilities with respect to each of its clients. This means that the Firm is required to act in each client’s best interests and to deal with client assets in such a manner as to benefit the client. Compliance with the Firm’s fiduciary duty can be achieved by trying to avoid conflicts of interest and by fully disclosing all material facts concerning any conflict that may arise with respect to any client. The Firm’s employees are required to try to avoid situations that have even the appearance of conflict or impropriety.

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Senior officers of the Firm (or their functional equivalent) may also be senior officers or “related persons” of affiliated investment advisers and/or limited partnerships and other similar entities that serve in the capacity of or in a similar capacity to a General Partner of a Heitman Fund. The General Partner has designated the Firm or an affiliate of the Firm as having primary responsibility for investment management and administrative matters, such as accounting, tax, and periodic reporting that pertain to the entities. The Firm and its affiliates and their managers, officers and employees will devote as much time as necessary and appropriate to manage the entities’ business. However, the Firm and its affiliates form additional investment funds, enter into other investment advisory relationships, and engage in other business activities, even though such activities may be in competition with the entities and those other activities may involve substantial time and resources of the Firm and its affiliates. Potentially, such activities could be viewed as creating a conflict of interest in that the time and effort of the Firm’s management personnel and employees will not be devoted exclusively to the business of the entities but allocated between the businesses of the entities and those of the Firm’s other affiliates. Certain entities (“Firm Related Entities”) have been established by the Firm’s affiliates to invest in commingled funds or other real estate related investment vehicles sponsored or created by the Firm’s parent entity or one of its direct or indirect subsidiaries to develop, acquire, own and/or operate, finance, and ultimately sell interests in office, multi-family residential, industrial, specialty sector, and/or retail properties located principally in North America, Europe and the Asia Pacific region. The beneficial owners of the Firm Related Entities, in all cases, consist of past and present employees of the Firm’s parent entity or a Heitman Affiliate.

Selection of Brokers Ongoing portfolio management decisions for discretionary clients are made by the Firm, including the commission rates at which transactions for client portfolios will be affected, with the objective of obtaining the most favorable price and market for the execution of each transaction. In seeking best execution, the Firm evaluates a wide range of criteria before placing a trade with a broker or dealer, including the broker’s commission rates, execution capability, positioning and distribution capabilities, back-office efficiency, ability to handle difficult trades, financial stability and prior performance in serving the Firm and its clients. Once the Firm has considered a broker or dealer’s ability to provide a favorable price and best execution, the Firm considers whether the broker can provide certain eligible investment research and/or brokerage services.

Commission Sharing The Firm utilizes research, research-related products and other brokerage services on a commission sharing basis. The Firm’s commission sharing policy is to make a good faith determination of the value of the research and brokerage products or services in relation to the commissions paid. The Firm maintains commission sharing arrangements for those research and brokerage products and services that assist the Firm in its investment decision-making process. The Firm and/or affiliated public securities investment advisers have agreements with several brokers to obtain, in return for directing to such brokers securities transactions for which commissions are paid, various research

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and brokerage products and services eligible pursuant to the safe harbor provision of Section 28(e) of the Exchange Act of 1934. Certain of these agreements provide for “commission sharing” credits whereby a commission sharing credit pool will be generated from total commission costs. The Firm can then exchange eligible research and brokerage products and services from credits that accumulate within this pool. Over the past several years, the Firm has obtained and continues to obtain various eligible services in exchange for commission sharing credits. To the extent these uses are not considered strictly research-related (i.e., a “mixed-use” product), the Firm makes an appropriate allocation of the cost between that portion which is eligible as a research or brokerage service and that portion which is not so qualified. The portion eligible as a research or brokerage service will be paid for with discretionary client commissions from the commission sharing credit pool, and the portion which is not eligible for the safe harbor under Section 28(e) of the Exchange Act will be paid for with Firm’s own funds. For any mixed-use products or services, the Firm maintains appropriate records of its reviews and good faith determinations of its reasonable allocations. Clients should be aware that the Firm might have a conflict between its obligations to obtain the best price and execution of the fewest necessary securities transactions and its desire to acquire research services with commission sharing from brokers. The Firm may also have an incentive to minimize its allocation of the mixeduse category, from the 100% commission sharing category since the portion of mixed-use assets allocated to non-research or brokerage services increases the Firm’s expenses. Notwithstanding agreements with brokers to obtain research and brokerage services, the Firm will not direct commissions to brokers in recognition of their having provided research, statistical or other related services in excess of commissions that other qualified brokers would have charged for handling comparable transactions. However, subject to the requirement of seeking best execution, the Firm may, in circumstances in which two or more brokers are in a position to offer comparable prices and execution, give preference to brokers that have provided research, statistical and other related services to the Firm for the benefit of its clients. The Firm may even pay more than the lowest available commission rate in return for research and brokerage products and services, so long as the Firm makes a good faith determination that the amount of commission paid is reasonable in comparison to the value of research and brokerage products and services provided. The brokers with whom the Firm has such agreements may change from time to time. The Firm considers which broker dealer is best able to execute an order based on the type of order and circumstances surrounding the order. In selecting broker dealers and in negotiating commissions on agency transactions, the Firm considers a number of factors, including, but not limited to: the nature of the security being traded; the size and type of the transaction; the nature and character of the markets for the security to be purchased or sold; the desired timing of the trade; the activity existing and expected in the market for the particular security; confidentiality, including trade anonymity; liquidity; the quality of the execution, clearance and settlement services; the existence of actual or apparent operational problems of any broker or dealer; and financial stability of the broker or dealer. In addition, the Firm may consider the value of research and brokerage products or services provided by a broker. Research and brokerage services received from such brokers and dealers cover a wide range of topics and services including basic economic data, prices of various government securities, company specific information including the EDGAR filings of securities issuers, economic indices, economic outlook, political environment,

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demographic and social trends, industry analysis, electronic communication of allocation instructions and trade routing. Research and brokerage services obtained with commission sharing credits are not necessarily utilized for the specific client that generated the credit. The Firm does not attempt to allocate the relative costs or benefits of research and brokerage services among clients because it believes that, in the aggregate, the research and brokerage services it receives benefits clients and assists the Firm in fulfilling its overall duties to its clients. The Firm uses the products or services provided or paid for by broker dealers in return for execution of securities transactions to service clients managed by the Firm and its affiliates, including clients of Heitman Affiliates, and not just the clients whose transactions paid for particular products or services. Moreover, it is possible that the clients whose transactions generate brokerage commissions used to pay for products or services may not benefit in any way from them. However, the Firm expects that each client receives an overall benefit by this practice because each receives the benefit of research and brokerage services that it might not otherwise receive. To the extent the Firm uses broker dealers that generate commission sharing credits in order to supply it with research and brokerage services, a potential conflict of interest may occur since the Firm may be incentivized to utilize those broker dealers in order to minimize research expenses for which it would otherwise be responsible. The Firm may supply proprietary research to the HLLC Client Service - Marketing and Research groups (collectively, the “Support Group”) if the Support Group uses the proprietary research to assist the Firm in carrying out its investment decision-making responsibilities for the Firm’s clients. Investment decision-making responsibilities refers to the quantitative and qualitative processes and related tools used by the Firm in rendering investment advice to its clients, including, but not limited to, financial analysis, trading and risk analysis, securities selection, asset allocation, and suitability analysis.

Directed Brokerage The Firm discourages requests by clients to direct brokerage transactions to a particular broker selected by the client. Although the client may in such circumstances receive products and services from the brokers that benefit the client, the Firm cannot assure the client that it will receive brokerage commissions equally as competitive as the commission rates the Firm has negotiated with its brokers. Moreover, the client may forego any benefit from savings on execution costs that the Firm has obtained for its other clients due, for example, to such factors as the ability to negotiate lower rates and the volume of transactions. In such instance, the client directing the brokerage may receive different prices on executions in the same security for the same transaction effected through other brokers. In agreeing to satisfy a client’s directions to executed transactions for its portfolio through a directed broker, the Firm understands that it is the client’s responsibility to ensure that; (i) all services provided by the Directed Broker will inure solely to the benefit of the client and may properly be provided in consideration for brokerage commissions or other remuneration provided to the directed broker; (ii) using the directed broker in the manner directed in the best interests of the client and any beneficiaries of the portfolio, taking into consideration the services provided by the directed broker; (iii) its directions will not conflict with any obligations that persons acting on behalf of the client’s portfolio may have to the client, its beneficiaries or any third parties, including any fiduciary obligations that persons acting for the client’s portfolio may have to obtain the most favorable price and

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execution; and (iv) persons acting for the client’s portfolio have the requisite power and authority to provide the directions on behalf of the client’s portfolio and have obtained all consents, approvals, or authorizations from any beneficiaries and third parties that may be required under applicable law or instruments governing the portfolio.

Global Strategy Brokerage Practices The Firm will delegate investment discretion for certain Global Real Estate Strategy, Global Real Estate Securities Concentrated Strategy, European Tactical Income, Japan Real Estate Securities Total Return Strategy, and Global Prime clients to a Heitman Affiliated adviser to make the investment decisions and/or recommendations with respect to publicly traded real estate securities in the European and Asia Pacific regions. The Firm may also delegate brokerage discretion for those clients to a Heitman Affiliate, and, therefore, the Heitman Affiliate will have the discretionary authority to determine which broker dealers will be used when purchasing and selling principally European and Asia Pacific securities on behalf of those clients. In the instances that a Heitman Affiliate is recommending transactions in publicly traded real estate securities, the Firm or another Heitman Affiliate may retain the investment discretion. In selecting brokers to effect purchase and sale transactions, Heitman Affiliates take into consideration a number of factors, including the overall best execution results to a client, the broker’s commissions, financial strength, stability, trade efficiency and other factors, as described above in “Selection of Brokers.” For trades executed in a currency other than the currency in which a portfolio is denominated, a Spot FX transaction is necessary to facilitate trade settlement. The Firm uses an unaffiliated third party to execute those Spot FX transactions.

Order Execution and Allocation The Firm and Heitman Affiliates often purchase and sell the same security at the same price and time for more than one client because: (i) the Firm typically makes similar trade recommendations for similar strategies that it manages, (ii) the Firm only recommends a limited number of real estate related securities, and (iii) numerous clients have similar investment objectives and similar portfolios. The Firm generally allocates orders among participating clients on a pro rata average price basis. Consistent with its best execution obligations and the terms of its investment advisory agreements, the Firm typically aggregates or “bunches” multiple client orders for the purchase and sale of the same security and allocates such transactions as previously described with each participating client’s proportionate share of such order, reflecting the average transaction price with respect to the total order placed for that day. Aggregate or bunched transactions may result in better prices, including lower commission costs and/or better execution for larger orders than single orders with smaller volumes. As mentioned above, clients that request the Firm direct trades to a particular broker may not benefit from aggregate transactions, as the Firm does not generally “step out” a portion of aggregated trades to clients’ directed brokers. Some of the Firm’s clients are investment advisers of wrap programs, for which the Firm acts as a nondiscretionary subadviser. The Firm considers these as “rotational clients.” In those instances, HRES provides a model portfolio to the wrap program adviser, and the wrap program adviser is responsible for applying the model and trading the corresponding orders. As a general matter, the Firm will rotate the placement of orders; either providing the model to the rotational clients first or placing orders for the non-rotational clients first. This means that at times orders are built and are partially filled for the Firm’s non-rotational clients before providing the

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Compensation The Firm, or certain of its affiliates, have, from time to time, engaged third-party solicitors to assist in obtaining assignments with clients. In return for these services, the Firm has compensated the solicitor from its own funds, and it is possible such arrangements could, in some instances, provide for non-cash compensation. The Firm discloses such referral arrangements to its clients as required by applicable law. These arrangements may pose certain conflicts of interest. Accordingly, the Firm has implemented procedures that are reasonably designed to avoid or mitigate these potential conflicts, such as ensuring that referral fees will not affect the level of the advisory fee paid by the client and that any such arrangements will otherwise comply with Rule 206(4)-1 under the Advisers Act. As described in Item 10, the Firm may use Heitman Affiliates for security offerings of Heitman Funds. It is the Firm’s policy not to accept or allow its “related persons” to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services it provides to its clients.

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The Firm and its management personnel are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the Firm’s advisory business. The Firm and its management personnel have no reportable disciplinary events to disclose.

Portfolio Management Services Reviews. Both before and after the time when client assets are invested, the Firm establishes a strategy for the long-term growth of capital and the generation of income pursuant to the investment objectives as noted in the client’s IMA. Guidelines are established by the Firm based on liquidity, risk, and investment potential with respect to price levels and the number of shares purchased or sold. For portfolio management purposes, and to determine transaction strategy based on current market conditions, each discretionary client’s portfolio is reviewed regularly. In addition to personnel within the Support Group, responsibility for communication with the client rests with the Firm’s employees and officers assigned to such clients. Reports. In addition to the statements and confirmations of transactions that clients receive from their custodians, the Firm provides monthly and/or quarterly reports summarizing performance, balances, and holdings pursuant to the obligations set forth in each client’s IMA. The Firm will provide reports on a more frequent basis to discretionary clients upon request.

In addition to the periodic statements that clients receive directly from their custodians, the Firm also sends portfolio statements directly to its clients on a monthly and/or quarterly basis. The Firm urges its clients to compare the information provided on these statements carefully to ensure that all transactions, holdings, and values are correct and current. The Firm does not have actual or constructive custody of securities or cash.

Clients generally engage the Firm to provide discretionary asset management services, in which case, the Firm places trades for a client without contacting the client for their permission prior to each trade. The Firm’s discretionary authority includes the ability to do the following without contacting the client: Determine the security to buy or sell; and/or Determine the amount of the security to buy or sell; and/or Determine the broker, price, and commission related to the security bought or sold. Clients generally give the Firm discretionary authority when they sign an IMA with the Firm and may limit this authority by giving the Firm additional written instructions. Clients may also change or amend such limitations by providing the Firm with written instructions. The Firm will not begin the management of client assets without a written IMA. For Global Real Estate Securities, Global Real Estate Securities Concentrated, Japan Real Estate Securities Total Return, and Global Prime clients, the Firm may retain Heitman Affiliates to make the investment decisions with respect to publicly traded real estate securities in the Asia Pacific region.

Clients may obtain a copy of the Firm’s complete proxy voting policies and procedures by contacting the individual designated on the first page of this Brochure. In addition, clients may request, in writing, information on how proxies for its shares were voted. If any client makes such a request, the Firm will promptly provide such information. The Firm votes proxies unless the IMA specifically requests that the proxies be forwarded to the client for processing. To direct the Firm to vote a proxy in a particular manner or according to particular criteria (for example, to always vote with management), clients must make these requests in writing and should direct them to the individual designated on the first page of this Brochure. The Firm utilizes the services of an independent unaffiliated proxy voting recommendation firm. The proxy firm is responsible for: notifying the Firm in advance of the shareholder meeting; providing the appropriate proxies to be voted; providing independent research on corporate governance, proxy and corporate responsibility issues;

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recommending actions with respect to proxies; and maintaining records of proxy statement received and votes cast. Pursuant to the Firm’s Proxy Voting policy, the voting recommendations from the proxy voting firm are deemed to be in the best interest of the shareholders. The Firm’s policy is to follow the proxy firm’s recommendations unless compelling reasons not to do so are identified and approved by the Firm’s Proxy Voting Committee. There may also be occasions when the Firm determines, contrary to the proxy firm recommendation, that not voting such proxy may be in the best interest of clients, such as: (i) when the cost of voting such proxy exceeds the expected benefit to the client, or (ii) if the Firm is required to re-register shares of a company in order to vote a proxy and that re-registration process imposes trading and transfer restrictions on the shares, commonly referred to as “blocking.”

The Firm does not require or solicit payment of fees in excess of $1,200 per client more than six months in advance of rendering services. Therefore, the SEC does not require the Firm to include a financial statement for its most recent fiscal year in this Brochure. As an advisory firm that maintains discretionary authority for clients, the Firm is also required to disclose any financial condition that is reasonably likely to impair its ability to meet its contractual obligations. Other items of this Brochure have disclosed all of the conditions that are likely to affect the Firm’s contractual obligations with respect to its clients. The Firm has no such additional financial circumstances to report. The Firm has not been the subject of a bankruptcy petition at any time.

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