IFM Investors

Overview IFM Investors Pty Ltd was formed in 2004 through the merger of IFS Private Capital Group and Development Australia Fund Management Limited (“DAF”), with IFM assuming full management and the trusteeship roles for all DAF products. DAF was established in 1990 by Australian superannuation funds to invest in growing Australian private and public companies and infrastructure assets and appointed IFS Private Capital Group as manager in 1995. As of the date of this Brochure, IFM is indirectly 100% owned by 15 Australian superannuation funds and one U.K. pension fund (the “Shareholders”). IFM is directly owned by IFM Holdings Pty Ltd, which is a wholly-owned subsidiary of Industry Super Holdings Pty Ltd. Industry Super Holdings Pty Ltd is owned by the 16 Shareholders. No single Shareholder owns 25% or more of the shares of Industry Super Holdings Pty Ltd. Advisory Services IFM provides investment advisory services to various clients organized as privately offered pooled investment vehicles (the “Funds”) and institutional clients that invest through separately managed accounts (“Managed Accounts”) (collectively, “Advisory Clients”). Funds offered in the United States and/or to US persons are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and their securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”). The operating companies in which our Advisory Clients invest are generally referred to herein as “portfolio companies”. As of the date of this Brochure, IFM has assets under management across five asset classes, with investments in listed equities, private equity, infrastructure, debt and real estate. We provide investment advisory services and manage client accounts and Funds on both a discretionary and non-discretionary basis. Any limitation on our authority is described in an Advisory Client’s confidential offering memorandum, limited partnership agreement, investment management agreement and/or other governing documents (collectively, the “Governing Documents”) of each Fund and/or Managed Account. IFM has and may in the future enter into “side letters” or similar agreements with certain Investors in the Funds (“Investors” or “Fund Investors”) granting the Investor certain rights, benefits, or privileges that are then generally made available to Investors who have the same or a larger investment, subject to certain exceptions and limitations. Such agreements can include, among other items, provisions addressing Investor notifications, reporting, management fees and performance fees and specific legal or regulatory requirements of an Investor. IFM acquired ISPT Pty Ltd, ISPT Operations Pty Ltd and their subsidiaries (collectively, “ISPT”) in December 2024. The ISPT brand has since been retired and IFM now provides unlisted real estate investment advisory services to Australian-based client accounts and Funds as part of the IFM Real Estate brand.

Funds IFM provides investment advisory services to the Funds pursuant to the Governing Documents. Investors generally have no authority to influence or change the Funds’ investment objectives or limitations nor do they have the authority to participate in the management of the Funds. Funds are generally organized with an IFM affiliate serving as the general partner or trustee of each Fund and IFM appointed as each Fund’s investment adviser. In certain cases, a Fund’s general partner has appointed a third-party Alternative Investment Fund Manager (“AIFM”) to manage the Fund with respect to the European Union or United Kingdom Alternative Investment Fund Managers Directive (“AIFMD”). In these cases, such Fund’s AIFM has delegated the portfolio management and administration functions to IFM, subject to the supervision and control of the AIFM. Investors in certain Funds generally have no right to remove or replace the Funds’ investment adviser and/or AIFM. Investors are advised to carefully read the applicable Fund’s Governing Documents to understand the investment strategy and risks involved. Certain Funds are organized into master-feeder structures. In such structures, the feeder funds invest all or substantially all of their assets in the master fund, subject to certain structuring considerations for legal, tax, or regulatory purposes. From time to time, certain Funds designate officers or employees of IFM or certain IFM related persons to serve on the boards of directors of Fund portfolio companies. Such officers or employees have the right to receive compensation in connection with such services and roles. Managed Accounts IFM also provides investment advisory services to Managed Accounts. IFM generally has discretionary authority to supervise and direct the investments for each Managed Account, subject to each Managed Account’s investment management agreement. Managed Accounts impose investment restrictions and guidelines within the investment management agreements. Co-Investments IFM is permitted, but not required, to offer Investors, potential Investors and/or other parties an opportunity to co-invest with the Funds depending on the capital requirements of the particular transaction. Any such co-investment offers will be made consistent with IFM’s internal policies and any applicable agreements (which may be amended from time to time). Regulatory Assets Under Management We had approximately US$202,970,534,587 in regulatory assets under management (“RAUM”) as of June 30, 2026. Of the RAUM, US$128,357,979,353 was managed on a discretionary basis and US$74,612,555,235 was managed on a non-discretionary basis.

Applicability of the Advisers Act The principal place of business of IFM is outside of the United States. Thus, consistent with SEC statements, the substantive provisions of the Advisers Act generally do not apply to IFM’s nonUS clients, including non-US private funds. 1 The information about the investment advisory services provided by IFM is qualified in its entirety by reference to the Governing Documents.

General We generally charge our Advisory Clients investment management fees calculated as a percentage of net asset value of the relevant portfolio or of portfolio value or, in the case of real estate Advisory Clients, as a percentage of gross asset value. We generally bill our management fees on a monthly or quarterly basis in arrears. The amount, and the manner and calculation, of the management fee for each Advisory Client is established by IFM and is set forth in the applicable Governing Documents. We also enter into arrangements with certain Advisory Clients to receive performance- or incentive-based fees. In such cases, we generally assess performance-based fees only on capital appreciation, if any, over a threshold amount, as described in the applicable Governing Documents. With respect to certain Funds, our performance-based fees are also subject to a threshold return and a high water mark. Performance fees are generally accrued quarterly and charged annually and from time to time following each withdrawal or redemption and certain transfers from certain Funds. Management fees and performance fees can differ from one Advisory Client to another, as well as among Investors in the same Fund. We generally negotiate such fees with Managed Accounts and Investors, as applicable, and we are permitted to reduce, waive, or calculate fees differently, in our sole discretion, for different Managed Accounts and/or Investors. Management fees and performance fees paid by a Fund are indirectly borne by the Investors in such Fund. Performance-Based Compensation We receive performance-based fees as described above. The receipt of performance-based compensation creates an incentive for IFM to make investments that are riskier or more speculative than those the Firm would otherwise make in the absence of such incentive compensation. We address this conflict by focusing on long term relationships with our Advisory Clients and Investors, and by managing Advisory Client assets in accordance with the applicable investment management agreement and the Advisory Clients’ investment strategies.

1 See, e.g., Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers With Less Than $150 Million in

Assets Under Management, and Foreign Private Advisers, Investment Advisers Act Release No. 3222 (June 22, 2011) [76 FR 39645 (July 6, 2011)].

Real Estate Fees and Compensation In addition to investment management fees, the Firm or its affiliates are permitted to charge certain Advisory Clients fees for asset management services, property services, development services, capital works services, leasing services, and retail tenancy design services. We charge our real estate Advisory Clients asset-based fees calculated as a percentage of gross asset value. Other fees are calculated by reference to project costs, capital works expenditure, rental amounts, increases in rent, time spent, fixed amounts or another basis specified in the relevant Governing Documents. Fees calculated by reference to gross asset value are not reduced by an Advisory Client’s liabilities, which creates an incentive for IFM to maintain or increase gross asset value, including through acquisitions, development, capital expenditure or borrowing. Where the Firm or an affiliate receives a fee based on the occurrence, size or cost of a transaction, project or service, it creates an incentive to recommend, undertake, continue or increase the relevant activity. We address these conflicts by focusing on long term relationships with our Advisory Clients and Investors, and by managing Advisory Client assets in accordance with the applicable investment management agreement and the Advisory Clients’ investment strategies. Refunds and Fee Waivers Because we do not charge fees in advance, there are no unearned fees to refund to an Advisory Client upon termination of an investment advisory relationship or upon withdrawal of an Investor in one of our Funds. Should an Investor fully redeem its investment during a quarter, we will prorate the management fees and any performance-based fees to be charged to the Investor for that quarter. We are permitted, in our sole discretion, to waive all or part of any fees or expenses payable by or attributable to Advisory Clients, Investors or their assets. To the extent IFM agrees to waive the management fee, or charge an Investor a reduced management fee rate, such waiver or reduction in certain cases is effected by way of a rebate or credit. For Investors, amounts refunded in this manner are generally added to such Investor’s capital account and subsequently reinvested by the relevant Fund at the next available period in IFM’s sole discretion, or, in IFM’s sole discretion, paid out in cash. Amounts refunded to the Investor’s capital account are otherwise available for redemption, subject to the terms applicable to redemptions generally as provided in the applicable Fund’s Governing Documents. Other Costs and Expenses Expenses borne by the Funds are set forth in the relevant Fund’s Governing Documents and generally include payment (or reimbursement to IFM) for all costs, expenses and liabilities relating to the organization and operation of the Fund, to the extent not paid by portfolio companies or other investment vehicles. For certain Funds, management fees are reduced in some circumstances in connection with the receipt by IFM or its related persons of various fees paid by actual or prospective portfolio companies, as described in further details within each Fund’s

Governing Documents. The types of expenses borne by a particular Fund vary among Funds and generally include the following: • Each Fund will bear all expenses incurred in connection with its investment activities, operations, organization and administration. These expenses include, among other things, legal fees and expenses; compliance fees and expenses; accounting, audit and tax preparation fees and expenses; governmental fees and taxes; professional and consulting fees; custodian and depositary expenses; costs of registering and reporting to regulatory and tax authorities in any jurisdiction in which an Advisory Client, general partners, IFM, any sub-investment advisors, any portfolio company or any issuer or other entity owned directly or indirectly by an Advisory Client invests, is organized or is marketed or otherwise directly or indirectly conducts business related to the Advisory Client or its investments; brokerage commissions and other investment-related expenses incurred in connection with conducting due diligence on potential investments (including transactions that fail to close) and monitoring investments (which from time to time includes business or firstclass airfare); interest expense and borrowing charges and expenses (including fees and expenses related to any Fund borrowing facilities); currency hedging expenses; advisory committee expenses; travel expenses of the Firm; third-party data and software expenses; legal, compliance, trading, settlement, client relations, accounting, reporting and information management software, extranet tools, web portals and computer systems used in connection with an Advisory Client; industry association expenses; insurance expenses; administrator’s and directors’ fees and expenses; registrar and transfer agency fees and expenses; appraisal and valuation costs, fees and expenses, including costs, fees and expenses of independent appraisal or valuation services or third-party vendor price quotations; property management, facilities management and external leasing agent costs; expenses relating to communicating with Investors or holding annual meetings; organizational and offering expenses; all extraordinary expenses (including, without limitation, indemnification and litigation); and all other reasonable costs related to the operation of the Fund or the purchase, sale or transmittal of its assets. • The Firm or its affiliates from time to time perform and charge separate fees for administrative, legal, deal-related and other services for certain Funds. The Firm or its affiliates will also be reimbursed for all out-of-pocket expenses incurred in connection with such services to the extent permitted under the applicable Governing Documents. • In certain cases, the Firm or its affiliates engage a professional AIFM to provide oversight and management services for a Fund for the purposes of the European Union or United Kingdom AIFMD and the fees and expenses of such AIFM will be borne by the relevant Fund. • The Firm is also permitted to engage a professional third-party administrator to perform administrative services for a Fund and the fees and expenses of such administrator will be borne by the relevant Fund. • The Firm or its affiliates will also be reimbursed for reasonable travel expenses which include meals, entertainment, transportation, and lodging and other similar expenses and

are incurred in connection with the acquisition, evaluation, structuring, holding and disposition of investments and travel expenses related to annual meetings. As a general matter, travel expenses are booked at the business-class level, with some exceptions. All first-class air travel requires Firm CEO approval. • IFM or one or more of its affiliates are permitted to engage or retain one or more third party consultants or investment professionals to assist IFM or its affiliates in sourcing transactions and/or providing consulting or related services to the Funds’ portfolio companies (collectively, “Senior Advisors” or “Operating Partners”). The Senior Advisors or Operating Partners are independent contractors that receive a recurring retainer (e.g., quarterly) and are not employees of IFM or any affiliate. They include professionals who are former executives with operating experience, industry specific knowledge and/or geographic expertise. The Funds and/or one or more of their respective existing or prospective portfolio companies (a) may pay one or more Senior Advisors or Operating Partners consultancy, advisory, directors’, monitoring, transaction, sourcing or other similar fees for services provided in respect of the applicable Fund or one or more potential and existing investments, and (b) will reimburse each Senior Advisor or Operating Partner for such person’s out-of-pocket expenses incurred in performing any services for the applicable Fund, including any expenses incurred in connection with performing services for one or more of its potential or existing investments. If a portfolio company of a Fund directly engages a Senior Advisor or Operating Partner, such portfolio company will bear the expenses in connection with such person’s services (including compensation which can be in the form of equity grants), and therefore the applicable Fund indirectly bears the expense of any such Senior Advisors or Operating Partners. Any amounts paid to third party consultants, Senior Advisors or Operating Partners by a Fund or a portfolio company will not offset or reduce any amount of the management fee payable by the applicable Fund to IFM or an affiliate. • From time to time, for certain Funds, officers or employees of IFM or its affiliates are: i) seconded to one or more portfolio companies to provide finance, accounting, operation support, data management and other similar services; or ii) appointed to serve as a director on the board of a portfolio company. Such officers or employees have a right to receive compensation in connection with such services and roles. Fees and expenses associated with these activities are generally directly or indirectly borne by the applicable Funds and in such cases will not offset the management fees paid by the applicable Funds. • Where co-investment opportunities are offered, co-investors are generally required to share the costs and expenses of the investment with the Funds on a proportionate basis. However, the Firm has, and may in the future in its sole discretion, structure a coinvestment opportunity such that the proposed participants in such co-investment opportunity do not bear any broken deal expenses, with the result that the applicable Funds will bear all such broken deal expenses. From time to time, strategic investors or other syndication partners or other parties invest in the same asset as a Fund, but not through vehicles controlled by IFM or an affiliate. In such circumstances, such Investor will not necessarily bear the same expenses as any Advisory Client and generally are not treated as “co-investors” pursuant to IFM’s policies and procedures.

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Loss Methods of Analysis We do not employ a single set of objective criteria when evaluating each potential investment opportunity. In our experience, each investment opportunity must be evaluated for its particular risks and opportunities. We seek to employ a high-level analysis to assess the initial attractiveness of an opportunity before proceeding further with, or rejecting, an investment opportunity. Depending on the type of investment strategy, we perform background research, financial modeling, qualitative assessment, and/or on-site or other in-person visits as part of our evaluation. The IFM Group Investment Committee (“IFMIC”) provides governance oversight of all IFM investment programs and portfolios and reports to the IFM Board Investment Committee (“BIC”). The investment committee’s oversight role covers both private market portfolios and investment strategies (i.e., infrastructure equity or debt, private equity, real estate or debt) and public market portfolios and investment strategies (i.e., listed equities and liquid/public debt). Public market portfolios and investment strategies are monitored by the IFMIC on an ongoing basis. Meanwhile, if an investment team decides a private market investment is worth pursuing, they are generally required to make a proposal to the IFMIC or the applicable infrastructure, private equity, real estate and debt sub-committee (each a “Sub-IC”) for consideration and approval. The BIC and IFMIC can approve, within mandate/fund guidelines, all IFM acquisitions and divestments up to a certain predetermined amount. Sub-ICs have the authority to make investment decisions under a certain threshold amount. The infrastructure team, private equity team, debt team and real estate team each have a set of individuals that operate as a Sub-IC. The real estate Sub-IC includes members who are not part of the real estate team.

Investors will ultimately bear the risk of whether a portfolio investment is well conceived and the underlying investment assumptions are realized. Fund Investors and Managed Account clients should refer to the applicable Governing Documents for a more detailed description of the methods of analysis employed by the Firm, a Fund or Managed Account’s investment strategy and the risk of loss associated with an investment in a Fund or Managed Account. Investment Strategies IFM and its investment teams offer a broad range of investment strategies across the listed equities, private equity, infrastructure, real estate, and debt asset classes, regions, and the risk spectrum. Advisory Client portfolios differ across the asset classes by investment objectives, guidelines, strategies, and sub-strategies. Risk of Loss We do not guarantee the success of any investment advice that we provide to our Advisory Clients. Any investment involves significant risk, including the risk of loss of all or substantially all capital invested. The following is a brief description of some, but not all, of the risks involved in investing in many of the types of investments that are typically included in Advisory Client portfolios. Advisory Clients and Investors should carefully consider these factors along with other matters discussed in the relevant Governing Documents and consult these Governing Documents for a more fulsome discussion of each risk factor. General Risks

Currency and Exchange Rate Risk . An Advisory Client could hold certain investments in

financial instruments denominated in currencies other than the US Dollar or in financial instruments which are determined with reference to currencies other than the US Dollar. The value of a portfolio’s assets will fluctuate with exchange rates in these currencies as well as with price changes in the various other local markets and currencies.

Currency Hedging. Certain Advisory Clients are permitted to enter into transactions or investments in relation to currency exchange risks in connection with investments that are held in currencies other than the US Dollars, to the extent that it is reasonably practicable and IFM determines it to be prudent. IFM could employ hedging techniques through the purchase of swaps, derivatives and other similar instruments. There can be no assurance, in such cases, that: (i) such hedges will (a) be available, (b) be available at a reasonable cost, (c) be sufficient or (d) actually eliminate the risk of fluctuation in the rates being hedged or (ii) that counterparties to any hedging transaction would perform as expected. Further, if an Advisory Client enters into hedging transactions such transactions may, while reducing certain rate risks, themselves entail other risks that could result in the Advisory Client obtaining a poorer overall performance than if such party had not entered into any hedge. Non-US Investments . Advisory Clients are permitted to invest in non-US markets (which include, but are not limited to, emerging market countries – see “Emerging Market Risk” below). Such investments could involve certain factors not typically associated with investing in the United States, including risks relating to: (i) currency exchange matters, including fluctuations in the rate

of exchange of the US Dollar against the applicable currency, and costs associated with conversion of the investment principal and income from one currency into another; (ii) differences in or the absence of uniform accounting, auditing and financial reporting standards, practices and disclosure requirements, and differences in government supervision and regulation; (iii) certain economic and political risks, including potential exchange-control regulations and potential restrictions on non-US investments; and (iv) certain geographically specific risks (such as weather).

Emerging Market Risk . Advisory Clients could hold assets in countries considered to be

“emerging markets” at the time of investment. These are countries that have started developing financial markets but have yet to reach a mature stage of development. Many Latin American, Eastern European and Asian countries are considered emerging markets. Emerging markets could have increased risks due to political and social instability, including the potential for civil wars; pervasiveness of corruption and crime; increased likelihood of nationalization of infrastructure; and little or no government authority in supervising and regulating business and industry practices. Many emerging market countries have experienced high rates of inflation for many years, which has had and may continue to have significant negative effects on the economies of those countries. Economies in individual emerging markets could differ favorably or unfavorably from the US economy in such respects as gross domestic product rate of growth, rates of inflation, exchange rate depreciation, capital reinvestment, resource self-sufficiency and balance of payments positions.

Cybersecurity Risks. The increasing reliance on internet‐based programs and applications to conduct transactions and store data also creates increased security risks. Targeted cyber‐attacks, or accidental events, can lead to a breach in computer and data systems and access by unauthorized persons to sensitive transactional or personal information. Data taken in breaches can be used by criminals to commit identity theft, obtain loans or payments under false identities, and other crimes. Cybersecurity breaches could directly or indirectly affect Advisory Clients, and could lead to theft, data corruption, interference with business operations, disruption of operational systems, interference a portfolio’s ability to execute transactions, direct financial loss or reputational damage, or violations of applicable laws related to data and privacy protection and consumer protection. In certain events, an investment’s failure or deemed failure to address and mitigate cybersecurity risks could be the subject of civil litigation or regulatory or other action. Any of such circumstances could subject an investment and/or the portfolio to substantial losses and negatively impact returns Advisory Clients and Investors. In addition, in the event that such a cyber-attack or other unauthorized access is directed at IFM, its affiliates, or one of its service providers holding its financial or investor data, then IFM, its affiliates or its portfolios could also be at risk of loss, despite efforts to prevent and mitigate such risks under the relevant policies. Similar types of operational and technology risks are also present for the portfolio companies in which our Advisory Clients invest, which could have material adverse consequences for such companies, and could cause an investment to lose value and negatively impact returns to Advisory Clients and Investors. Third parties, including cybercriminals, could attempt to fraudulently induce employees, investors, third-party service providers, or other users of IFM’s systems to disclose sensitive information in order to gain unauthorized access to data or assets of IFM, its Advisory Clients, or their investors. A successful penetration or circumvention of security measures protecting IFM’s systems, or

those of its service providers, could result in the loss, theft, or unauthorized disclosure of investor data, Advisory Client assets, proprietary information, or other confidential or corporate data. Such incidents could also result in the inability to access electronic systems, loss or theft of proprietary or confidential information, physical damage to computer or network systems, or costs associated with system repairs and remediation. These events could cause an Advisory Client, IFM, or their service providers to incur regulatory penalties, reputational harm, additional compliance costs, or financial loss.

Alternative Data. IFM is permitted to obtain and use alternative data in its investment processes.

Alternative data includes datasets collected from a variety of sources, such as internet usage, payment records, financial transactions, sensor data (including weather and other physical phenomena), applications and devices (such as smartphones) that generate location and mobility data, satellite imagery, and government or other public records databases. IFM could apply such alternative data to anticipate micro- and macroeconomic trends and to develop or improve investment themes. No assurance exists that IFM will be successful in utilizing alternative data in its investment process or that such use will enhance investment performance.

AI Technologies. IFM is also permitted to use machine learning, predictive data analytics,

automated decision-making technologies, and similar technologies (collectively, “AI Technologies”) in certain circumstances. For example, IFM may use such technologies for purposes such as, but not limited to, certain administrative tasks, virtual assistants, fraud detection, predictive analysis, data interpretation, and the generation of template communications. The maintenance and deployment of these technologies involve significant risks, and no assurance exists that their use will enhance IFM’s services or benefit Advisory Clients.

AI Technologies have the potential to result in significant and disruptive changes in companies, sectors or industries, including those in which the Advisory Clients invest, which could render existing underwriting models, investment processes or operational practices obsolete or less effective, and any such changes could create new and unpredictable operational, legal and/or regulatory risks. To the extent competitors of IFM, the Advisory Clients and the portfolio companies make more efficient or extensive use of AI Technologies, there is a possibility that such competitors will gain a competitive advantage, accelerating product or service obsolescence, or reducing demand for offerings that incorporate, facilitate or rely upon AI Technologies, particularly as AI capabilities continue to evolve. Additionally, IFM, the Advisory Clients and the portfolio companies could be further exposed to the risks of AI Technologies if third-party service providers or any counterparties, whether or not known to IFM, use AI Technologies in their business activities. IFM will not be able to control the use of AI Technologies in third-party products or services, including those provided by IFM and its affiliate service providers. IFM employs a risk‑based framework for overseeing the use of AI Technologies in connection with its business activities, including investment activities, and has implemented internal policies governing such use. Notwithstanding these policies, the use of AI Technologies by personnel of IFM, as well as senior advisors, industry advisors, affiliates or other persons engaged by IFM, present certain risks. AI Technologies are highly reliant on the accuracy, adequacy, completeness and objectivity of their underlying data and on the collection and analysis of large amounts of data and complex

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We provide investment advisory services to a variety of Funds across listed equities, private equity, infrastructure, real estate, and debt. Investors in our Funds include pension and profit-sharing plans, corporations, endowments, foundations, sovereign wealth funds, trusts, and estates. We also provide investment advisory services to Managed Account clients across listed equities, private equity, infrastructure, real estate, and debt, consisting primarily of institutions such as pension plans and insurance companies. Generally, only “qualified purchasers”, as that term is defined under Section 2(a)(51) of the 1940 Act can invest in any Funds that are offered in the United States or to US persons. Although IFM generally does not impose minimum dollar values on creating a Managed Account, legal eligibility requirements must be met. The Funds typically require a minimum investment commitment from Investors with IFM typically having the ability to waive the required minimum investment commitment at its sole discretion, as set forth in the applicable Governing Documents.

We receive performance- or incentive- based fees as described in Item 5, “Fees and Compensation,” above. We could receive investment management fees, performance-based fees, or both from an Advisory Client. Managing Advisory Client accounts that pay both an assetbased investment management fee and a performance-based fee and managing Advisory Client accounts that pay only an asset-based investment management fee creates certain conflicts of interest for IFM. IFM and its supervised persons have an incentive to disproportionately allocate time, services, or functions and allocate the best investment ideas to those Advisory Clients that pay a performance-based fee (and/or to those Advisory Clients that pay a higher rate of management fees or performance fees) and thus favor them over those Advisory Clients that pay only an asset-based fee (or those Advisory Clients that pay a lower rate of fees). We primarily mitigate this conflict through our investment allocation policies. Our policies require investment opportunities to be allocated on a basis that IFM determines in good faith is fair and equitable and in a manner consistent with each Advisory Client’s investment objectives. Where an investment opportunity is suitable for two or more Advisory Clients, we seek to ensure that our Advisory Clients have equitable access to investment opportunities and that such opportunities are allocated in a manner consistent with IFM’s policies and procedures and the Governing Documents of the relevant Advisory Clients. We charge performance-based fees to US Advisory Clients in accordance with Section 205 of the Advisers Act and Rule 205-3 thereunder.

IFM is an investment adviser to Managed Accounts and Funds. IFM and its related persons reported in Part 1 of our ADV are members of an Australian-based financial services group that includes certain trust companies, other investment advisers, general partners to the Funds, and other financial services entities. IFM is not registered as a broker-dealer, a futures commission merchant, commodity pool operator, or a commodity trading advisor. IFM holds an Australian Financial Services License issued by the Australian Securities and Investments Commission. IFM is registered with the South Korea Financial Supervisory Services as a cross border discretionary investment management and investment advisory entity. IFM is related to other investment advisers, including IFM Investors (US) Advisor, LLC (and its relying adviser IFM Investors (US), LLC), IFM Investors (UK) Ltd, IFM Investors (HK) Limited, and IFM Investors (Singapore) Pte. Ltd. IFM Investors (UK) Ltd, IFM Investors (HK) Limited, and IFM Investors (Singapore) Pte. Ltd., are “participating affiliates” of IFM and provide certain investment advisory services to IFM. As “participating affiliates”, these entities are subject to IFM’s supervision, including the Code of Ethics. IFM Investors (US) Advisor, LLC is registered with the SEC, IFM Investors (UK) Ltd is registered with the FCA, IFM Investors (HK) Limited is registered with the Hong Kong Securities and Futures Commission, and IFM Investors (Singapore) Pte. Ltd. is registered with the Monetary Authority of Singapore. IFM is also related to the following broker-dealers: IFM (US) Securities, LLC, IFM Investors (Switzerland) AG, and IFM Investors (Japan) Pty Ltd. IFM (US) Securities, LLC is registered with the SEC and is a member of FINRA. It is authorized to engage in the business of soliciting investors in the United States to purchase privately offered securities (exempt from registration under the Securities Act), issued by private funds advised by IFM and IFM Investors (US) Advisor, LLC. IFM Investors (Switzerland) AG is approved by the Swiss Financial Market Supervisory Authority as a Representative Office of the Master Advisor and IFM Investors (Japan) Pty Ltd is registered with the Financial Services Agency of Japan. IFM Investors (Switzerland) AG and IFM

Investors (Japan) Pty Ltd are authorized by their respective financial regulator to distribute and offer funds and separately managed accounts advised by the Master Advisor to certain investors in Switzerland and Japan, respectively. IFM also is affiliated with the following entities which serve as general partner, trustee or managing member (or equivalent) to one or more Funds, feeder funds or investment vehicles: (i) IFM Global Infrastructure (US) GP, LLC; (ii) IFM Infrastructure (UK) General Partner, LLP; (iii) IFM Global Infrastructure (Canada) GP Inc.; (iv) IFM Investors (Nominees) Limited; (v) IFM Fiduciary Pty Ltd; (vi) IFM Fiduciary No. 2 Pty Ltd; (vii) IFM Core Energy Transition GP S.a.r.l; (viii) IFM Global Infrastructure (US 2) GP, LLC; (ix) IFM Global Infrastructure (US 3) GP, LLC; (x) IFM Global Infrastructure Debt GP S.a.r.l; (xi) IFM Growth Partners GP Pty Ltd; (xii) IFM Growth Partners Services A Pty Ltd; (xiii) IFM Growth Partners Services B Pty Ltd; (xiv) IFM Asia-Pac Debt Fund GP S.a.r.l.; (xv) IFM Private Equity (US) GP, LLC; (xvi) IFM Global Infrastructure (US 4) GP, LLC; (xvii) IFM Infrastructure Equity (N) GP S.a.r.l; (xviii) IFM Real Estate Fiduciary Pty Ltd; (xix) IFM Real Estate Fiduciary No. 2 Pty Ltd; (xx) IFM Real Estate Fiduciary No. 3 Pty Ltd; (xxi) IFM Real Estate Fiduciary No. 4 Pty Ltd; (xxii) IFM Real Estate Fiduciary No. 5 Pty Ltd; (xxiii) IFM Global Value Add Infrastructure Fund GP; (xxiv) IFM Global Value Add Infrastructure Fund A GP; (xxv) IFM Global Value Add Infrastructure Fund B GP, LLC; (xxvi) IFM GVI SIS GP; (xxvii) IFM GVI TC GP; (xxviii) IFM Lift Co-Investment GP S.a.r.l.; (xxix) IFM Matterhorn Co-Investment GP S.a.r.l.; (xxx) IFM Bolt Co-Investment (UK) GP, LLP; (xxxi) IFM Bolt Co-Investment (Manager), LLC; and (xxxii) IFM Investors (Singapore) GP Pte. Ltd. IFM is directly owned by IFM Holdings Pty Ltd. IFM and its affiliates listed above collectively make up the “IFM Group”. IFM Holdings Pty Ltd, is a wholly-owned subsidiary of Industry Super Holdings Pty Ltd. Industry Super Holdings Pty Ltd is wholly-owned by the 16 Shareholders. No single Shareholder owns 25% or more of the shares of Industry Super Holdings Pty Ltd. IFM has a board of directors composed of individuals that are unrelated to the Shareholders other than through the Shareholders’ indirect ownership interest in IFM. Industry Super Holdings Pty Ltd also wholly-owns Industry Fund Services Limited, which only operates in Australia and primarily provides consulting and advice services to Australian superannuation funds. Industry Fund Services Limited is registered with the Australian Securities and Investments Commission. All of the Shareholders are Investors in IFM’s Funds and generally pay some level of fees to IFM. The Shareholders also have other relationships with IFM and its affiliates. These relationships create certain conflicts of interest and in certain situations present an incentive for IFM to favor the Shareholders’ interests. For example, in certain circumstances, IFM will have an incentive to offer investment opportunities to, or grant requests from, those Fund Investors that are Shareholders over those Investors that are not. IFM seeks to mitigate conflicts of interest in the foregoing and similar situations, including through policies, procedures and controls (i) designed to identify and mitigate conflicts of interest on a transaction-by-transaction basis and (ii) that require investment decisions for all Advisory Clients to be made independently from those of other Advisory Clients. For further information, see “Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”. The above relationships pose conflicts of interest in transactions that involve both Shareholders and other Advisory Clients, because IFM has an incentive to favor the Shareholders. These

incentives are more pronounced where IFM has multiple relationships with the Shareholders. IFM seeks to directly and purposefully mitigate such conflicts through IFM’s investment allocation policies and procedures with respect to the allocation of investment opportunities. IFM and its personnel do not have any relationships or arrangements with other financial services companies outside of the IFM Group that pose material conflicts of interest. However, our affiliated investment advisers provide investment advisory services to certain feeder funds and sub-advisory services to us. We do not charge any additional management fees to our Advisory Clients as a result of the arrangements; however, we do pay our affiliated investment advisers for their services and our affiliated investment advisers are entitled to receive certain expense reimbursements. Further, IFM does not receive any compensation directly or indirectly from our affiliated advisers for such arrangements. We charge different performance and management fees to different Advisory Clients managed or advised by us, which creates certain conflicts of interest. Please see Item 5, “Fees and Compensation,” above for information regarding how our Advisory Clients compensate us, the conflict of interest created by allocating investment opportunities among Advisory Client accounts, and how IFM addresses such conflicts of interest.

Transactions, and Personal Trading General Code of Ethics We expect our employees to be responsible for maintaining the highest ethical standards when conducting business. It is IFM’s policy that our employees must always place our Advisory Clients’ interests ahead of their own. IFM requires that all employees act in accordance with all applicable federal and state regulations governing investment advisory practices. Any employee not in observance of the above could be subject to discipline or termination. IFM has adopted a written code of ethics (the “Code”) under Rule 204A-1 of the Advisers Act expressing our commitment to ethical conduct that is applicable to all employees. Among other things, the Code requires that we act in our Advisory Clients’ best interests, abide by all applicable regulations and not engage in insider trading or other inappropriate behaviors that call into question the exercise of our judgment. The Code comprises a group of documents including, but not limited to, a Market Abuse Policy and associated Personal Trading Procedure. We provide each of our employees with a copy of the Code initially as they are onboarded and annually thereafter, and each must sign an attestation that he or she has read and understands the Code. Investors or potential investors may obtain a copy of the Code free of charge by writing to the Chief Compliance Officer (“CCO”) at the address on the cover page of this Brochure. Interest in Client Transactions There are some instances when IFM follows an investment strategy for a Managed Account that is substantially similar to the strategy of one or more Funds managed by the Firm. In such instances, IFM’s policies require investment opportunities to be allocated on a basis that IFM determines in good faith is fair and equitable and in a manner consistent with each Advisory Client’s investment objectives.

In addition, IFM or one of its advisory affiliates could, in some instances, invest in the same securities as our Advisory Clients or co-invest in an investment with an Advisory Client. This could create a conflict of interest to allocate certain investments to the Firm or its affiliates. We seek to manage any such conflicts that could arise through our investment allocation policies, conflicts committee, and/or investment advisory committee for the applicable Fund. Cross Trades and Principal Transactions Subject to applicable investment guidelines and restrictions, IFM has in the past and may from time to time in the future engage in cross trades, which generally are transactions in which IFM or an affiliate effects a trade directly between two or more Advisory Clients (e.g., a Fund and a Managed Account). In addition, subject to applicable investment guidelines and restrictions, IFM may from time to time engage in principal transactions, which generally are transactions in which IFM or an affiliate is deemed to be acting for its own account in connection with buying a security from, or selling a security to, an Advisory Client (e.g., a Fund). IFM has established policies and procedures to comply with the Advisers Act when engaging in cross trades and principal transactions. Cross trades are generally executed at a price determined in accordance with the Firm’s conflicts and valuation policies. No fees will be charged by IFM or its affiliates to Advisory Clients in connection with the completion of a cross trade. In certain cases, cross trades could be viewed as principal transactions due to the ownership interest in an Advisory Client by IFM and its personnel. Cross trades and principal transactions give rise to conflicts of interest between Advisory Clients as well as between Advisory Clients and IFM. For example, one Advisory Client could be advantaged to the detriment of another Advisory Client where investments being exchanged are not priced in a manner that reflects fair value. On the other hand, cross trades could benefit Advisory Clients because such Advisory Clients can avoid certain transaction fees. To the extent that any cross trade or affiliated transaction described above could be viewed as a principal transaction due to the ownership interest in the client of IFM and its personnel, IFM will comply with the requirements of Section 206(3) of the Advisers Act and its internal policies and procedures. Generally, in order to ensure that any cross trade or principal transaction is effected in compliance with applicable laws and regulations, IFM will confirm as applicable that: such cross trade or principal transaction is allowed by the applicable Governing Documents; the applicable conflicts and valuation policies were followed when pricing the transaction, including obtaining a third-party valuation when appropriate; and, in the case of principal transactions, that notice of the specific transaction was provided to the relevant Advisory Client, and consent from the Advisory Client was obtained in compliance with Section 206(3) of the Advisers Act. Investments in Portfolio Companies Held by Other Funds Given the different investment focuses, target return profiles, hold periods and other characteristics of the Funds, to the extent that a Fund and/or one or more other Funds participate in the same investment opportunity, IFM will have conflicting loyalties between its duties to each involved Fund, and there will be conflicts of interest arising for a variety of reasons, including but not limited to a different basis for investing in a particular investment, different return

expectations and exit horizons and different incentives or appetites for participating in follow-on investment opportunities with respect to such investment. As a consequence of the type of investment held by each Fund in the relevant portfolio company or issuer, each such Fund will likely have a different assessment of the situation and the approach that best serves its interest, including in respect of significant matters such as the best exit strategy for an investment, the quality of the management team, the achievability of a company’s financial budget or the economic and other terms of an investment (such as the interest rate to be paid, the security granted, the nature of the covenants and terms of amendments or restructurings). If a conflict of interest were to arise, IFM is likely to take certain actions that, in the absence of such conflict, it would not take, which could have an adverse impact on one Fund and have the effect of benefiting other Funds at the expense of the prior Fund. Investments in Which Portfolio Companies Also Hold an Interest A Fund may be permitted to invest alongside its own portfolio companies, or portfolio companies of other Funds, in investments that are suitable for both the Fund and such portfolio companies. To the extent the Fund holds securities in an investment that are different (including with respect to their relative seniority) from those held by its portfolio companies in the same investment, the applicable general partner and its affiliates could be presented with decisions where the interests of the Fund and its portfolio companies or the portfolio companies of other Funds are not aligned or are in conflict. For example, if a Fund makes or has an investment in a company in which a portfolio company has a mezzanine, senior debt or distressed debt investment, IFM will generally have conflicting loyalties between its duties to the Fund and to such portfolio companies. In that regard, actions could be taken for the portfolio companies that are adverse to the Fund. In addition, it is possible that, in a bankruptcy proceeding, the Fund’s interest could be subordinated or otherwise adversely affected by virtue of such portfolio companies’ involvement and actions relating to its investment. Moreover, to the extent that the Fund and a portfolio company invest in the same securities, their interests could similarly not be aligned or could be in conflict in light of differing investment strategies, liquidity needs or other considerations. Investments in Which Other Funds Have a Different Principal Investment From time to time, a Fund could invest alongside other Funds in investments that are suitable for both the Fund and such other Funds. To the extent the Fund holds securities in an investment that are different (including with respect to their relative seniority) from those held by other Funds in the same investment, the appliable general partner and its affiliates could be presented with decisions where the interests of the two funds are in conflict. For example, if the Fund makes or has an investment in a company in which another Fund has a mezzanine, senior debt or distressed debt investment, IFM will generally have conflicting loyalties between its duties to the Fund and to such other affiliates. In that regard, actions could be taken for the other Funds that are adverse to the Fund. In addition, it is possible that in a bankruptcy proceeding the Fund’s interest could be subordinated or otherwise adversely affected by virtue of such other Funds’ involvement and actions relating to its investment.

Participation by One Fund in Another Fund Funds managed or advised by IFM or its affiliates have made, and may in the future make, capital commitments to other Funds. Such capital commitments could result in conflicts of interest for IFM as manager of such Funds and, as applicable, as AIFM of a Fund, including but not limited to (i) the impact of a withdrawal of the other Funds’ capital commitments from a Fund, which would result in a reduction in capital commitments available to invest by such Fund and could negatively impact the ability of other Investors in the Fund to withdraw their capital commitments, (ii) the way in which voting rights and consent rights are cast by other Funds by IFM as manager of such other Funds in a Fund, and (iii) IFM making decisions on behalf of such other Funds (in their capacity as Limited Partners) which are in the best interests of such other Funds but which could negatively impact the invested-in Fund. Personal Trading IFM has adopted a Market Abuse Policy and associated Personal Trading Procedure designed to ensure that the personal securities transactions, activities, and interests of our employees do not interfere with their judgment in advising our Advisory Clients. Although employees are not prohibited from personal trading, employees must present any investment opportunities suitable for any investment strategy of our Advisory Clients to such Advisory Clients prior to engaging in any transaction related thereto for personal benefit. To minimize the risk of potential conflicts of interests, we have implemented pre-clearance procedures for employees’ personal trading activities. Employees must also report all personal transactions to the Risk and Compliance team on at least a quarterly basis. The CCO, with assistance from the Risk and Compliance team, monitors transactions by employees in order to identify possible patterns of conduct that could evidence conflicts or potential conflicts with the principles and objectives of the Code and Market Abuse Policy, or other inappropriate behavior. Credit Facility IFM is permitted to establish a credit facility for certain Funds with one or more financial institutions. In such cases, IFM generally has broad discretion over the permitted uses for the credit facility, including the ability to use the facility for general investment purposes, to pay investor redemptions, for general operating purposes, or any other purpose identified in the applicable Governing Documents. Implementation and utilization of the credit facility will generally result in fees and expenses to the Fund. For example, to the extent that the Fund uses the credit facility to pay investor redemptions, the interest charges associated therewith will be borne by all investors who own interests in the Fund during the time period for which such credit facility is drawn and outstanding, and such expenses are expected to be disproportionately borne by non-redeeming investors. In order to obtain the credit facility, IFM expects that (i) it could be required to assign or pledge to each such credit facility issuer/lender the applicable general partner’s right to call capital from the Investors as could be required to honor any credit facility draws and/or repay any loans, including any interest accrued thereon, and (ii) the Investors could be required to acknowledge and consent to the assignment of the applicable general partner’s rights in respect thereof. If the applicable Fund does not honor its obligations pursuant to the credit facility, the provider(s) of the credit facility could have the right to take action against any

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For certain Advisory Clients where we have discretion, we could select broker-dealers to transact with and endeavor to select broker-dealers that provide the best execution for securities transactions so that an Advisory Client’s total costs or proceeds in each transaction are the most favorable under the circumstances on the basis of best price and execution capability. In selecting broker-dealers to effect portfolio transactions, we consider various factors, including, without limitation: price; quality of execution, including the level of accuracy and confidentiality in executing orders; extensiveness of the broker-dealer’s distribution network; commission rates; the financial strength of the broker-dealer; the reputation and stability of the broker; the ability to effect the particular transaction; other matters involved in the receipt of brokerage and research; and the broker-dealer’s familiarity with our investment practice. Although the primary consideration in allocating transactions to broker-dealers will be to obtain favorable prices and efficient executions, the Firm does not have an obligation to, and does not always seek to, obtain the lowest priced execution regardless of qualitative considerations. Selecting broker-dealers on the basis of considerations that are not limited to the applicable commission rates will likely result in higher transaction costs than would otherwise be obtainable. The use of brokerage commissions to obtain research does benefit IFM since IFM would otherwise be required to produce or pay for this research out of its own pocket. The Firm may pay higher commissions or direct trading business to a particular broker-dealer in order to receive research or other services (a practice known as “soft dollar arrangement”). Research or brokerage services that can be acquired by IFM with soft dollars include, without limited and to the extent permitted by applicable law: (1) research reports on companies, industries and securities; and (2) economic and financial data. All of the Firm’s soft-dollar arrangements meet the requirements of the Section 28(e) safe harbor. Because many broker-dealers do not unbundle the cost of proprietary research from the cost of execution, the option of paying separately for execution and research does not always exist. The receipt of such research and other services and the determination of the appropriate allocation thus creates a conflict. While research or brokerage services obtained in this manner can be used in servicing any or all of the Firm’s Advisory Clients, such products and services tend to disproportionately benefit one or more Advisory Clients relative to others based on the amount of brokerage commissions paid, the nature of the research or brokerage products and services acquired and their relative use or value of particular accounts. Although IFM will make a good faith determination that the amount of commissions paid by an Advisory Client is reasonable in relation to the value of the research and brokerage services received, the research and brokerage services received may be used in servicing any or all of IFM’s Advisory Clients.

IFM compensates its related person, IFM (US) Securities, LLC, for the solicitation of US investors for certain Funds. IFM has engaged, and could from time to time in the future engage, third-party marketers or solicitors to solicit potential investors to Funds and/or Managed Accounts. The compensation of the marketer or solicitor is negotiated in the context of the particular engagement and could be different with respect to the different Funds and/or Managed Accounts. As compensation for its services, the third-party marketer is likely to receive a fee from IFM or one of its affiliates. No person, other than our Advisory Clients, provides us with compensation for providing investment advisory services to our Advisory Clients.

Neither IFM nor any of its management personnel has been involved in, or subject to, any investment-related legal or disciplinary events that would be material to a client’s evaluation of the company or its management personnel.

IFM personnel monitor and review Advisory Client portfolios on an ongoing basis for overall adherence to investment objectives and strategies, as well as any guidelines or restrictions. Each

review is conducted by a specialized investment management team and subject to oversight by the Firm’s board of directors, the BIC, and the IFMIC. Fund Investors receive written account statements, which generally contain unaudited performance results for the fiscal quarter, on a quarterly basis. These quarterly statements are supplemented with periodic reports, letters or other written communications. Fund Investors also receive annual reports that include audited financial statements of the Fund as of the end the Fund’s fiscal year. Annual reports generally contain an Investor’s capital account statement as of the fiscal year end, a listing of investments held by the relevant Fund, and the audited financial statements of such Fund. In addition to the information provided to all Investors, IFM could provide certain Investors with additional information or more frequent reports that other Investors will not receive as discussed above in Item 8. Managed Account clients also receive written account statements on a scheduled basis (e.g., monthly, quarterly) describing clients’ holdings and performance during the reporting period.

IFM does not physically hold client assets. Advisory Clients’ funds and securities are held with a custodial bank. The principal place of business of IFM is not in the United States and is thus not subject to Rule 206(4)-2 of the Advisers Act (the “Custody Rule”) with respect to the Managed Accounts and certain of the Funds that are not US persons (as defined in Regulation S under the Securities Act of 1933), as per ABA Subcommittee on Private Investment Entities, SEC Staff No-Action Letter (Aug. 10, 2006). The Funds IFM is considered to have “custody”, solely for purposes of the Custody Rule, for Funds that are US persons or the Custody Rule is otherwise applicable due to the provision of sub-investment advisory services by IFM Investors (US) Advisor, LLC and any other affiliate based in the US with respect to certain Funds that may or may not be US persons (“Custody Funds”). The term

“custody” is defined under the Custody Rule as holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them. We maintain the Custody Funds’ securities and funds with a “qualified custodian” in accordance with the Custody Rule. In addition, IFM arranges for the delivery of a copy of the audited financial statements for each Custody Fund to that Fund’s Investors. The audited financials are prepared annually in accordance with US generally accepted accounting principles (or with another comprehensive body of accounting standards and reconciled against US general accepting accounting principles for Funds that are not organized under US laws or that have a general partner or other manager with a principal place of business outside the US) and distributed within the required time frames set forth in the Custody Rule. Audited financial statements are distributed to Investors within 120 days of each Fund’s fiscal year end in accordance with the Custody Rule. Also, as described above in Item 13, “Review of Accounts” above, Fund Investors receive unaudited periodic reports and quarterly statements regarding performance. Fund Investors should carefully review their periodic reports, their quarterly statements and their Fund’s audited financial statements. Managed Accounts US Managed Accounts advised by IFM select their own custodian to maintain custody of their funds and securities, and IFM does not hold the funds or securities of such accounts and does not have authority to access them for any purpose other than trading on behalf of the US Managed Account; except that, that in certain cases, IFM does have the ability to instruct a custodian to deduct the outstanding advisory fee from a US Managed Account’s custodial account and remit such payment to IFM. In situations where IFM is deemed to have “custody”, solely for purposes of the Custody Rule of a US Managed Account by virtue of its ability to deduct advisory fees, IFM is not required to comply with the annual surprise exam requirement of the Custody Rule. In such cases, IFM will comply with the Custody Rule by having a reasonable basis, after due inquiry, for believing that the qualified custodian for such US Managed Account is not a related person of IFM, and is sending at least quarterly account statements directly to the client (and that such statements reflect the deduction of advisory fees). In addition, IFM will seek to have a reasonable basis for determining that the assets in such account are held with a qualified custodian.

We provide investment advisory services on a discretionary and non-discretionary basis. Any limitation on IFM’s authority is described in an Advisory Client’s Governing Documents in the case of the Funds and/or investment management agreement. We do not assume discretionary authority to manage portfolios on behalf of Advisory Clients until completing the appropriate Governing Documents in the case of the Funds and/or entering into an investment management agreement. IFM’s portfolio investment teams are primarily responsible for ensuring that the securities or other financial instruments that we advise our Advisory Clients to invest in are consistent with the respective Advisory Client’s investment objectives.

We may accept authority to vote Advisory Client securities with respect to assets that are publicly traded issuers. This creates a conflict of interest because of the possibility of us voting Advisory Client securities to further our own interests at the expense of our Advisory Clients’ interests. We take seriously our responsibility to exercise proxies on behalf of Advisory Clients and have adopted written procedures to do so in a manner consistent with our professional and regulatory responsibilities. These procedures are reasonably designed to ensure that proxies are voted in the best interest of our Advisory Clients, which generally means voting proxies with a view to enhancing the value of Advisory Client securities. The financial interest of our Advisory Clients is the primary consideration in determining how proxies should be voted. IFM will take reasonable measures under the circumstances to obtain knowledge of meetings and other events giving rise to solicitation of proxies and to assure that proxies are received in sufficient time for IFM to take action, vote proxies, and return the proxies to the parties soliciting them in time to be counted. Advisory Clients are permitted to direct the vote of IFM in a particular solicitation, obtain information from us about how we voted Advisory Clients’ securities, and obtain a copy of our proxy voting procedures by writing to IFM, Attn: Chief Compliance Officer, at the address on the cover page of this Brochure. If one of our advisory employees serves on the board of directors for a portfolio company in which an Advisory Client invests, unique conflicts of interest in relation to proxies could exist. Prior to any vote, the IFM advisory employee is required to determine whether a material conflict of interest exists between the IFM advisory employee and the interests of the Advisory Client, or between the IFM advisory employee and company shareholders. The IFM employee must notify the Chief Compliance Officer if he/she is aware of any material conflict of interest associated with a proxy vote. There could also be instances where IFM appoints an external representative to serve on the board of directors for a portfolio company in which an Advisory Client invests. In such circumstances when proxies need to be voted, the investment team is responsible for assessing conflicts of interest and oversight of the external representative’s activities in accordance with the IFM Group Policy for the Engagement of External Advisors. Similar to the above, the investment team must notify the Chief Compliance Officer if he/she is aware of any material conflict of interest associated with a proxy vote made by the external representative.

We do not require or solicit prepayment from our Advisory Clients and there is no financial condition that is reasonably likely to impair our ability to meet our contractual commitments to Advisory Clients.