KAYNE ANDERSON CAPITAL ADVISORS LP

Kayne Anderson Capital Advisors, L.P. (“Kayne” or the “Firm”) has engaged in the investment advisory business since its inception in 1984, during which time it has been registered as an investment adviser with the SEC. Kayne is owned by its employees. Richard Kayne, the Firm’s co-chairman and co-founder, owns 26.92% of Kayne. No other individual owns 25% or more of the equity interests in Kayne. The remaining interests in the Firm are owned by approximately 44 limited partners, including current executives, portfolio managers and other Kayne personnel. As of February 28, 2026, Kayne’s Assets Under Management (“AUM”) is approximately $34.3 billion. AUM is calculated on the market value of the securities portfolios for which Kayne provides continuous and regular supervisory or management services. Kayne engages in alternative investing primarily through private pooled vehicles (except as described below), and to a lesser extent separate accounts and sub-advisory relationships. Kayne focuses on generating returns across a variety of strategies, which include investing in (1) energy and power infrastructure marketable securities, (2) private equity upstream oil and gas companies and opportunistic investing in long-life, low-risk onshore oil and gas assets, (3) private credit, infrastructure credit and specialized real estate debt, and (4) alternative real estate sectors (primarily focused on medical office, off-campus student housing/multifamily, high-end seniors housing, and self-storage). Kayne manages assets for institutional investors, family offices, high-net-worth and retail clients and employs approximately 310 employees in six offices across the United States. Kayne has three affiliated investment adviser subsidiaries that are each separately registered with the SEC. More detail on each of these advisers can be found in Item 10. Kayne Anderson Real Estate (“KA Real Estate”), the real estate investment platform of Kayne, has a strategic partnership with AIMS Petershill, an investment fund managed by Goldman Sachs Asset Management. AIMS Petershill has a strategic, passive minority investment in KA Real Estate which it initially made in 2020. KA Real Estate continues to maintain control of the business with no changes to management. Kayne Anderson Private Credit (“KAPC”), the middle-market private credit investment platform of Kayne, entered into a strategic partnership in 4Q23 with Bonaccord Capital Partners, a private equity platform that acquires noncontrol equity interests in leading private markets investment firms. Bonaccord Capital Partners’ strategic, minority investment in KAPC is passive. KAPC continues to maintain control of the business with no changes to management. Privately Offered Pooled Investment Vehicles Kayne serves as investment adviser to privately offered pooled investment vehicles formed as limited partnerships or limited liability companies (where Kayne or a controlled subsidiary is the general partner or manager), or offshore corporations. Kayne’s pooled investment vehicles are available only to investors who are “accredited investors” under the Securities Act of 1933, as amended (the “1933 Act”), and “qualified clients”

under the Investment Advisers Act of 1940 (“Advisers Act”), as amended. In most cases, investors must also be “qualified purchasers” under the Investment Company Act of 1940 (“1940 Act”), as amended. These pooled investment vehicles are not made available to the general public and are not registered investment companies. Kayne’s private pooled investment vehicles are managed by Kayne (or a controlled subsidiary) in its sole discretion. Kayne’s private pooled investment vehicles include: (i) redeemable funds, where capital contributions and withdrawals are permitted at stated intervals (generally monthly or quarterly) at then-current net asset values, and (ii) closed-end funds, where each limited partner makes an up-front commitment to contribute a stated amount of capital as it is called by Kayne (or a controlled subsidiary) for investment, and generally may not withdraw capital prior to the end of the stated multi-year term of the fund. Redeemable Funds Our redeemable funds consist of several strategies, including energy and power infrastructure and real estate. As of February 2026, our active redeemable funds include: Energy and Power Infrastructure The majority of Kayne’s redeemable funds invest in energy and power infrastructure companies. Certain of these funds are intended to operate without the use of sustained leverage, while others may obtain leverage through prime brokerage financing. These funds invest primarily in equities, debt (convertibles and hybrids), or a blend of the two, and incorporate a variety of strategies including long-only and hedging strategies. The funds that employ hedging do so to protect against company, market, foreign currency, and interest rate risk by utilizing direct issuer shorts, U.S. Treasury and ETF shorts, options, index ETFs, total return and credit default swaps, and foreign currency forwards. Core Real Estate Kayne Anderson Core Real Estate, L.P. (“KACORE”) targets primarily stabilized investments in four alternative real estate sectors: medical office buildings, high-end private-pay seniors housing properties, amenity-rich student housing properties near campus, and self-storage. Commercial Real Estate Debt Kayne Commercial Real Estate Debt, L.P. (“KCRED”) invests primarily in Freddie Mac structured products and direct loan originations secured by assets in Kayne Anderson Real Estate’s sectors of expertise (multifamily, student and seniors housing, medical office, and self-storage), with flexibility to selectively invest in non-agency CMBS. Generally speaking, limited partners in Kayne’s redeemable funds may invest or withdraw (entirely or partially) on either a monthly or quarterly basis. Withdrawing partners must provide Kayne with proper advance written notice, which may be anywhere from 10 to 45 days depending on the fund.

Closed-End Funds Kayne’s closed-end funds are single-strategy funds engaged in making private investments in (1) private oil and gas companies; (2) the equity or debt of medical office, high-end seniors housing, off-campus student housing/multifamily, self-storage and other specialized real estate assets; and (3) private lending to middlemarket companies. As of February 2026, our active Closed-End Funds include: Energy Private Equity Kayne’s energy private equity strategies focus on acquiring large-scale, producing oil and gas assets with low production decline rates and select, high-confidence development inventory. The funds seek to generate equity returns by partnering with experienced, talented management teams driven to build profitable, cash-flowing businesses in the North American energy space. Real Estate Kayne’s real estate equity funds invest in alternative real estate asset classes that exhibit favorable demographic patterns, supply-demand imbalances, fragmented ownership, and stable historical growth. These asset classes include medical office, seniors housing, student housing, multifamily, and self-storage. Our funds seek to build a portfolio of real estate investments producing solid, steady cashflow growth, with strong potential for upside value creation. Kayne’s real estate debt strategy invests in commercial real estate debt and securities in targeted sectors including medical office, seniors housing, multifamily/student housing, and self-storage. The debt team invests primarily in Freddie Mac structured products and direct loan originations, with flexibility to selectively invest in non-agency CMBS. Private Credit Kayne’s private credit platform leverages a diversified sourcing model across a range of industries in North America, targeting senior loans in traditional middle market companies with strong, sustainable cash flows. Investment structures include senior secured loans, equity co-invest, and unitranche facilities. Investments in the closed-end funds are permitted only at scheduled fund closings. As portfolio holdings are sold in a closed-end fund, the proceeds realized (as well as cash interest and dividends received) are generally distributed to limited partners. However, limited partners in these funds generally may not otherwise reduce or withdraw their investments until the fund’s maturity without the consent of Kayne (or a controlled subsidiary) in its capacity as general partner. Such consent, if given, may require that the withdrawing limited partner be penalized for such early withdrawal.

Separate Accounts and Investment Companies In addition to managing the investment vehicles described above, Kayne serves as investment adviser or subadvisor to separate accounts for institutional clients and registered investment companies. Kayne may act in such a capacity under an investment advisory agreement or, in a limited number of instances, as the manager of a joint venture limited liability company or limited partnership. These accounts invest in the same strategies generally employed by one or more of Kayne’s pooled investment vehicles, but generally have modified investment guidelines that are tailored to the individual objectives of the client. Kayne does not participate directly in any wrap-fee programs. Model Portfolio Services Kayne also manages Energy and Power Infrastructure model portfolios that can be used as an investment strategy by a client or a third-party manager in the management of its client accounts. The model portfolios generally reflect Kayne’s investment strategy and outlook.

Privately Offered Pooled Investment Vehicles Redeemable Funds Generally speaking, Kayne’s redeemable funds are charged annual management fees of 0.6% to 1.5% of portfolio assets, calculated and payable quarterly or monthly either in advance based on the fair market value of the account portfolio at the beginning of the period or in arrears based on such fair market value at the end of the period. In its redeemable funds, Kayne may also receive an incentive allocation based on the performance of the portfolio, and calculated on the basis of both realized and unrealized gains and losses. Performance allocations range up to 20% of such realized and unrealized gains, and may or may not be subject to a high water mark and/or calculated after a stated “hurdle” rate of return to the limited partners. Performance allocations are calculated and accrued as described in each fund’s offering documents; the calculation periods vary depending on the fund. All performance-based allocations are calculated cumulatively or are subject to a high-water mark (on an individual investment basis) and a hurdle (as applicable) to prevent such fees from being generated on recouped gains. Limited partners in Kayne’s redeemable funds may withdraw, entirely or partially, on either a monthly or quarterly basis, depending on the fund. Withdrawing limited partners must provide Kayne with proper advance written notice, which may range anywhere from 30 to 45 days depending on the fund. To enable periodic investments in, and withdrawals from, the redeemable funds (and to calculate management fees and performance allocations), the third-party administrator or Kayne, as applicable, determines net asset values for such accounts at each reporting period. The fair market values of investments which do not trade on an exchange or in other active markets are valued by Kayne or an independent third-party valuation firm based on its judgment exercised in good faith taking into consideration all factors it believes to be relevant. Such fair market valuations

are consistent with the organizational documents of the funds and Kayne’s Valuation Policy which require reporting based on applicable Generally Accepted Accounting Principles. Closed-end Funds Generally, investors in Kayne’s closed-end funds are charged annual management fees of 1.0% to 1.75% of capital commitments (which are expected to significantly exceed portfolio assets early on in the life of the funds) or invested capital, calculated and payable quarterly or semi-annually. After the investment commitment period, the management fee is typically based on the lower of aggregate net asset value or net invested capital. Kayne or an affiliated management company also receives a “carried interest” in its capacity as general partner generally entitling it to up to 20% of realized profits after a preferred return to limited partners. This carried interest is based on realized gains and received income only, and is payable as portfolio holdings are liquidated or otherwise monetized, subject, in some cases, to a reserve or claw-back arrangement to account for possible or actual losses incurred on holdings subsequently sold. As portfolio holdings are sold in a closed-end fund, the proceeds received (as well as cash interest dividends received) are generally distributed to limited partners. However, limited partners in these funds generally may not otherwise reduce or withdraw their investments until the fund’s maturity without the consent of Kayne (or a controlled subsidiary) in its capacity as general partner. Separate Accounts The separate accounts managed by Kayne are generally charged management fees and in some cases performance fees similar to (but not necessarily the same as) those applicable to Kayne’s redeemable or closedend funds. A separate account client may terminate its investment advisory contract with Kayne on not less than 30 days’ notice. Separate accounts may also be structured as “parallel vehicles” to closed-end funds to accommodate legal, tax, regulatory, or other considerations for investors. Such parallel vehicles are generally expected to (i) co-invest with the closed-end fund in each investment in proportion to the respective available capital commitments, (ii) make each investment at the same time and on substantially the same terms, and (iii) unless otherwise approved by the advisory board of the closed-end fund, sell each of their respective interests at the same time and on the same terms. Additionally, Kayne has a number of traditional separately managed accounts and single investor funds for large institutional investors in order for them to take advantage of the breadth of Kayne’s investment offerings in an efficient manner. The fees for these cross-platform strategy vehicles are negotiated directly with such client and vary depending on the structure of the vehicle, the size of the investment, and other relevant factors. Kayne believes that its fees, both for its pooled investment vehicles and its separate accounts, are competitive with those charged generally by other investment advisers for comparable services. However, some investment advisers may provide comparable services for lower or different fee structures. Performance-based

allocations/fees are only charged consistent with applicable rules and regulations, including Rule 205-3 under the Advisers Act and the Employee Retirement Income Security Act (ERISA) as applicable. Fee Arrangements and Payments With respect to private commingled funds, Kayne is generally authorized to charge and deduct advisory fees directly from the assets of the applicable funds at times and in an amount set forth in governing fund documents. Separate account fees are billed directly to the investor. Kayne generally does not negotiate different fee arrangements with investors in its pooled investment vehicles, but has and may in the future do so for very large accounts at the sole discretion of such general partner or manager. Kayne generally waives all or a portion of fees with respect to investments made by employees in its pooled investment vehicles. Separate account fee structures are determined through negotiation. Investments in our redeemable funds can generally only be initiated and terminated at the beginning or end of the month or quarter, as applicable, which means that fee proration is not relevant. If separate accounts are terminated during a fee period, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. For our closed-end funds, our practice is to charge the management fee quarterly in advance through the quarter in which the commitment period ends (which may not be the last day of the quarter). After the commitment period expires, there may be a stepdown in the management fee, to be charged on the lower of (a) the aggregate total cost of all investments held by the fund, or (b) the aggregate net asset value of all investments held by the fund through the remaining term of the fund. Management fees may be waived in instances where the fund term is extended at the discretion of the fund’s general partner. Kayne’s fees are charged separately net of any brokerage commissions, transaction fees, fund fees, or other fund or separate account related costs and expenses (which are incurred by the fund or separate account client, including legal and accounting costs). Portfolio consultant services fees for the use of a model portfolio are charged at a fixed quarterly rate, as negotiated with the client. Additional Fees and Expenses Kayne has a fiduciary duty to ensure that expenses allocated to clients (whether commingled funds or separate accounts) are appropriate, permissible under offering and governing client documents, and consistent with disclosures made to investors, including, without limitation, via fund governing documents and Part 2 of Form ADV. Additionally, Kayne must ensure that it allocates such expenses equitably to all relevant parties.

Generally, each investor will be responsible for all costs and expenses relating to the organization, operation and administration of such fund or managed account, including, without limitation, (i) administration and valuation fees and expenses, whether provided by a third party or by Kayne or an affiliate of Kayne; (ii) audit fees; (iii) consummated and broken deal expenses; (iv) brokerage commissions, clearing and settlement charges; (v) prime brokerage fees, custodial fees, and other bank service fees; (vi) interest and other expenses incurred in respect of borrowings, if any; (vii) due diligence related expenses, including, without limitation, third party consultants and related travel; (viii) out-of-pocket expenses incurred by members of the advisory boards in connection with the fulfillment of their duties to the applicable funds and expenses of periodic meetings of limited partners, including without limitation, travel expenses (including business class airfare, or when business class is not available, first class airfare) incurred in connection with attending advisory board meetings (including, without limitation, transportation, meal and lodging expenses); (ix) expenses associated with communication and periodic reporting to investors; (x) expenses incurred in connection with legal and regulatory compliance with U.S. federal, state, local and non-U.S. or other law or regulation, including reporting prepared to comply with EU Sustainable Finance Disclosure Regulations; (xi) financial statements, tax returns and Schedules K-1; (xii) legal fees, including costs of litigation involving the funds or accounts and the amount of any judgments or settlements paid in connection therewith, as well as the fees of legal counsel (including the cost of in-house counsel and legal support) or other experts or consultants; (xiii) initial and ongoing marketing expenses incurred in connection with fundraising activities, including transportation, lodging, meals and investor entertainment, in each case subject to the organization expense cap for the applicable fund; (xiv) the costs associated with winding up and liquidating applicable funds; (xv) the costs associated with the indemnification obligations of the funds; (xvi) fees and expenses of any third-party providers of “back office” and “middle office” trade settlement services; (xvii) fees associated with the organization and operation of any special purpose investment vehicles for purposes of making investments; (xiii) costs and expenses incurred in maintaining and monitoring investments, including, without limitation, any architectural, engineering, environmental, third-party payment processing, travel, legal (including the cost of in-house counsel and legal support) and accounting expenses and other fees and out-of-pocket costs related thereto; (xix) the management fees and any other fees payable to each Fund’s General Partner and its affiliates; (xx) expenses related to or arising from defaults by investors in the payment of capital contributions; (xxi) expenses incurred in connection with distributions to investors; (xxii) costs and expenses incurred in relation to obtaining waivers, consents or approvals pursuant to the governing documents and preparing related amendments, modifications, revisions or restatements to the governing documents of a fund; and (xxiii) any insurance premiums or expenses incurred by the funds in connection with their activities, including similar coverage for the general partners and their affiliates and any other person acting on behalf of the funds. In relation to (xiii) above, for certain private equity funds that utilize placement agents for marketing purposes, the fees paid to such placement agents may be charged back to the fund. The fund will then offset such fees against the management fee otherwise payable by the fund on a dollar-for-dollar basis, so that those fees are not included in the calculation of the organization expense cap for the applicable fund. In-house expenses are permissible when there is clear, tangible benefit to the fund (e.g. efficiency and significant cost savings) and the applicable Advisory Board approves rates or amounts on an annual basis. Such in-house expenses are generally charged to real estate funds for internal legal and project management costs, subject to a

Read the rest in the brochure

Investment Strategies & Risks Kayne manages a variety of alternative investment products intended to take advantage of market opportunities. Certain of these products may involve a higher level of investment risk, while seeking greater returns than traditional investment products. These products are privately offered through private funds and are typically structured as limited partnerships or limited liability companies. Kayne, or a controlled subsidiary, acts as general partner, managing member, investment manager or otherwise exercises investment discretion with respect to these products in which clients are solicited to invest. Further information can be found in the offering memorandum for each fund. Kayne may, from time to time and as appropriate, solicit clients to invest in such vehicles, and may make such investments on a discretionary basis on the client’s behalf. As these may not be appropriate investments for all clients, not all clients will be offered the opportunity to invest, and not all clients afforded that opportunity will choose to invest. At a high level, Kayne’s investment approach is to focus on industries and asset classes in which it has considerable knowledge and expertise, focusing first and foremost on downside protection and the preservation of capital. Kayne investment personnel conduct commercially reasonable and appropriate due diligence of each investment based on the facts and circumstances applicable to each potential opportunity. The objective of such analysis is to identify attractive investment opportunities and the possible risks associated with that investment in order to develop a sound investment strategy that has a high probability of delivering attractive returns for our investors. When conducting due diligence and making an assessment regarding potential investment opportunities, Kayne relies primarily on publicly available information and resources. Kayne may also rely on information provided by the target of such investment, and, in some circumstances, third-party consultants where additional technical expertise is needed. Certain investment teams may employ so-called expert networks to consult with paid industry experts. Kayne has adopted policies and procedures to mitigate any potential conflicts

of interest related to the use of such experts. The due diligence process may at times be subjective. Accordingly, Kayne cannot be certain that its investment process or its due diligence with respect to potential investment opportunities will reveal or highlight all relevant facts that may be necessary or helpful in evaluating such investment opportunity. General market, economic, environmental, and other conditions, which by their nature are unpredictable, may have an adverse impact on the reliability of such due diligence. Kayne’s investment teams are responsible for integrating sustainability analysis into the underwriting, analysis and monitoring of investments in line with the firm’s sustainability policy and the sustainability integration plan of the particular investment strategy. It should not be assumed that any particular sustainability practices or standard will apply to every investment in a particular strategy or that they have applied to prior investments. Sustainability is only one of many considerations taken into account when making investment decisions and other considerations can be expected in certain circumstances to outweigh sustainability considerations. Any sustainability information, standards or initiatives applied to a particular investment is done with the consideration of Kayne’s ultimate goal of maximizing financial returns on investments. There is a growing regulatory interest across many jurisdictions in improving transparency regarding the definition, disclosure, and measurement of sustainability considerations. Kayne cannot guarantee that its current sustainability approach and policy will meet future regulatory requirements or predict the manner in which any such future requirements could affect a client or its investments, including with respect to future classifications, administrative burdens and costs. In evaluating a security or an issuer’s sustainability characteristics, Kayne may be dependent upon information and data from third party providers with differing methodologies for measuring sustainability, and which may be incomplete, inaccurate or unavailable. As a result, there is a risk that Kayne could incorrectly assess a security or issuer. There is also a risk that Kayne may not apply the relevant sustainability criteria correctly or that a portfolio could have indirect exposure to issuers that do not meet the relevant sustainability criteria used by such portfolio. Kayne does not make any representation or warranty, express or implied, with respect to the fairness, correctness, accuracy, reasonableness or completeness of such sustainability assessment. Investors may have different views of what constitute positive or negative sustainability characteristics. Further, there may be limitations with respect to the readiness of sustainability data in certain sectors, as well as limited availability of investments with relevant sustainability characteristics in certain sectors. Kayne may change its sustainability assessment of an issuer over time. While Kayne views sustainability considerations as having the potential to contribute to a portfolio’s long-term performance, there is no guarantee that such results will be achieved. Kayne’s success is dependent upon the talents and efforts of the highly skilled individuals it employs and Kayne’s ability to identify, and willingness to provide acceptable compensation to attract, retain and motivate, talented investment professionals and other employees. There can be no assurance that Kayne’s investment professionals will continue to be associated with the Firm throughout the life of its funds, and the failure to attract or retain such investment professionals could have a material adverse effect on the funds and investors’ investments therein. Competition in the financial services industry for qualified employees is intense and there is no guarantee that, if lost, the talents of Kayne’s investment professionals could be replaced.

There can be no assurance that the funds will successfully implement and execute their investment strategies, or that Kayne’s investment process will produce the desired results. The availability of investment opportunities and our ability to identify and invest in such opportunities may be limited by market conditions, investment minimums, investor qualification requirements, research capacity limitations and available capital. Although each of the funds invests in a strategy which is designed to mitigate the risk of loss through the decisionmaking or “underwriting” process, the structuring of positions, and/or hedging techniques, each such strategy will nonetheless involve significant levels of risk as a result of market and issuer-specific factors affecting securities generally. A portfolio’s performance depends on the performance of individual securities in which the portfolio invests. Changes to the financial condition or credit rating of an issuer of those securities may cause the value of the securities to decline or even become worthless. In connection with the financing of certain investments, some of our funds employ hedging techniques designed to protect them against adverse movements in currency and/or interest rates. While such transactions may reduce certain risks, such transactions themselves may entail certain other risks including, but not limited to, additional costs such as transaction fees or breakage costs. Thus, while a fund may benefit from the use of these hedging mechanisms, unanticipated changes in, for example, interest rates, security prices or currency exchange rates may result in a poorer overall performance for the fund than if it had not entered into such hedging transactions. Because the funds may make only one or a limited number of investments and since many of these investments involve significant degrees of risk, poor performance by one or a few of the investments could severely affect the total returns to investors. Concentrating investments in a particular portfolio company, industry, asset class, market or region means that performance will be more susceptible to loss due to adverse occurrences affecting that portfolio company, industry, asset class, market or region. For example, a portfolio concentrating in a single industry is subject to greater risk of adverse economic conditions and regulatory changes than a fund with broader industry diversification in its portfolio. A fund may be called upon to provide follow-on funding for its portfolio companies or have the opportunity to increase its investment in such portfolio companies. There can be no assurance that a fund will wish to make follow-on investments or that it will have sufficient funds to do so. Any decision by a fund not to make follow-on investments or its inability to make them may have a substantial negative impact on a portfolio company in need of such an investment, may result in loss of value or missed opportunities for the fund, or may diminish the fund’s ability to influence the portfolio company’s future development. A fund’s general partner may fund the making of investments and other permissible items under the fund’s offering documents with proceeds from drawdowns under one or more revolving credit facilities (the collateral for which can be, for example, the unused commitments of the limited partners, i.e., subscription lines) prior to calling commitments. For administrative convenience, capital calls, including those used to pay interest on subscription lines and other indebtedness, may from time to time be “batched” together into larger, less frequent

capital calls or closings, with a fund’s interim capital needs being satisfied by the fund borrowing money from such credit facilities. In particular, it is expected that capital needs of a fund during the fundraising period may be met through drawdowns from such credit facilities rather than capital calls. The interest expense and other costs of any such borrowings will be fund expenses and, accordingly, decrease net returns of the fund. The amount of leverage used varies among funds and is described in further detail in each fund’s respective offering documents. For the funds that do employ leverage, the funds’ investments are expected to often include businesses or assets with significant leverage. Leverage may involve the use of various financial instruments or borrowed capital in an attempt to increase the return of an investment. Leverage can take the form of borrowing funds, trading on margin, derivative instruments that are inherently leveraged, including but not limited to options, swaps (including total return financing swaps and interest rate swaps), forward contracts, repos, or other forms of direct and indirect borrowings and other instruments and transactions that are inherently leveraged. Any such leverage, including instruments and transactions that are inherently leveraged, can result in the portfolio’s market value exposure being in excess of the net asset value of the portfolio. A portfolio could need to liquidate positions when it is not advantageous to do so in order to satisfy its borrowing obligations. The use of leverage involves heightened risk, including the potential for higher volatility and greater declines of a portfolio’s value, and fluctuations of dividend and other distribution payments. A leveraged capital structure of a portfolio company or a leveraged asset will increase the exposure of that company or asset to adverse economic factors such as rising interest rates, downturns in the economy or deterioration in the financial condition of the company or its industry. Additional information on investment risk is discussed in each fund’s individual private placement memorandum. Investments in closed-end funds require a long-term commitment, with no certainty of return. The funds may invest in companies that subsequently experience financial difficulties, which difficulties may never be overcome. Investments made by these funds are expected to be illiquid, and there can be no assurance that the funds will be able to realize such investments in a timely manner. Liquidity risk exists when particular investments are difficult to purchase or sell. This can reduce a portfolio’s returns because the portfolio may be unable to transact at advantageous times or prices. Additionally, the funds may acquire securities that cannot be sold except pursuant to a registration statement filed under the 1933 Act or in accordance with Rule 144 of the 1933 Act or another exemption under the 1933 Act. There may be little or no near-term cash flow available to fund investors. Certain of our funds utilize the services of joint venture operating partners with expertise in the particular specialized sector in which the joint venture is investing. These funds’ investments may be owned by joint ventures or partnerships between the fund or a subsidiary or affiliate of the fund and other third parties. The investment by the fund in a joint venture could subject the fund to risks that may not otherwise be present if investments were made directly by the fund. These risks include the following possibilities: (i) that the fund’s joint venture partner may not perform; (ii) that the joint venture partner may have economic or business interests or goals which are inconsistent with or adverse to those of the fund; (iii) that the joint venture partner may take actions contrary to the requests or instructions of the fund or the fund’s objectives or policies; and (iv) that the

Read the rest in the brochure

Kayne provides investment supervisory services through privately offered (i.e., unregistered) pooled investment vehicles, and to a lesser extent through separate accounts. Kayne generally provides its services and markets its funds and separately managed accounts to endowments, foundations, financial institutions, insurance companies, operating companies, Taft-Hartley plans and other institutional clients, family offices, funds of funds, registered

investment companies, and high-net-worth individuals. Interests in funds are offered only to those investors who qualify as (i) “qualified clients” within the meaning of Rule 205-3 under the Advisers Act, as amended, (ii) “accredited investors”, as defined in regulation D under the 1933 Act, and, (iii) where applicable, “qualified purchasers” within the meaning of Sections 2(a)(51) and 3(c)(7) of the 1940 Act, as amended. Each of Kayne’s pooled investment vehicles has a stated minimum investment requirement. These generally range from $100,000 to $10 million. Kayne may, and in many cases has, accepted initial investments in its pooled investment vehicles below the stated minimums. These situations are evaluated on a case-by-case basis and include a consideration of whether the investor has an existing investment in any other of Kayne’s pooled investment vehicles or has an expectation of fulfilling the stated minimum requirement over a relatively short period of time. Additionally, Kayne manages separate accounts where there is no stated minimum investment, although all such accounts exceed the minimum requirements of comparable pooled investment vehicles.

As described in Item 5, Kayne generally receives a performance-based or incentive allocation or fee in its redeemable and closed-end funds. All such arrangements conform to Section 205(a)(1) of the Advisers Act and ERISA, as applicable. In measuring clients’ assets for the calculation of performance-based fees, in our redeemable funds, we include realized and unrealized capital gains and losses. Performance fees in our closedend funds are determined based on proceeds distributed to investors. Our performance-based fee arrangements may create an incentive to favor higher potential fee-paying accounts over other accounts in the allocation of investment opportunities. Similarly, Kayne or its affiliates or employees may have a significant proprietary investment in a fund or account, and Kayne may have an incentive to favor such fund or account to the detriment of other funds or accounts. Kayne’s procedures are designed to ensure that all investment decisions are made without consideration of Kayne’s (or its affiliates’ or employees’) pecuniary interest but, instead, in accordance with Kayne’s fiduciary duties to its clients.

Kayne has claimed the appropriate exemptions from registration as a commodity pool operator and commodity trading adviser with the Commodity Futures Trading Commission (CFTC) and National Futures Association (NFA). The CFTC and NFA each administer a comparable regulatory system covering futures contracts and various other financial instruments in which certain Kayne managed funds may invest. Kayne is affiliated with KA Associates, LLC (“KAA”), a FINRA-member broker-dealer. KAA shares office space and certain overhead expenses with Kayne. In addition, certain officers and employees of Kayne are registered representatives of KAA. In limited circumstances, Kayne may open temporary brokerage accounts with KAA for certain private funds that trade in marketable securities. Such permitted temporary arrangements include, but are not limited to, circumstances where (i) Kayne is in the process of onboarding a fund with a third-party prime broker or custodian and Kayne (or a controlled affiliate) determines in good faith that waiting for such process to be completed may result in missed investment opportunities to the detriment of fund investors, (ii) certain private equity funds receive a large block of stock in a public company and seek to leverage Kayne’s expertise (such arrangements require advisory board approval), (iii) Kayne is “incubating” a new strategy with firm capital in order to determine viability and develop a track record, or (iv) in circumstances where Kayne is directed by a separately managed account client to establish an account at KAA because the client does not have a pre-existing custodian relationship. Such arrangements require the prior approval of Kayne’s Chief Compliance Officer (who is also the President of KAA), and the fund advisory board, as applicable. Generally speaking, no fees or commissions are charged by KAA for any trades executed under such arrangements. For the avoidance of doubt, the ‘40 Act funds advised and/or sub-advised by Kayne are prohibited from opening accounts or otherwise trading with KAA. Kayne is also affiliated with KA Fund Advisors, LLC (“KAFA”), a separately registered investment adviser. KAFA is the investment manager of a publicly traded closed-end fund, Kayne Anderson Energy Infrastructure Fund, Inc. (NYSE: KYN). Kayne is the sole managing member of this adviser. Additionally, Kayne is affiliated with KA Credit Advisors, LLC (“KA Credit”), a separately registered investment adviser that is the investment manager of Kayne Anderson BDC, Inc. (NYSE: KBDC), a publicly traded business development company. Kayne is the sole managing member of this adviser. Kayne is also affiliated with KA Credit Advisors II, LLC (“KA Credit II”), a separately registered investment adviser that is the investment manager of another business development company (“BDC”), Kayne DL 2021, Inc. Kayne is the sole managing member of this adviser.

Code of Ethics Kayne has adopted a Code of Ethics in accordance with Rule 204A-1 of the Advisers Act. As a fiduciary, Kayne owes its clients undivided loyalty – our clients trust us to act on their behalf, and we hold ourselves to the highest standards of fairness in all such matters. This is predicated on the principle that Kayne owes a fiduciary duty to its clients. As a fiduciary, Kayne must serve in its clients’ best interests. In other words, employees may not benefit at the expense of advisory clients and must avoid activities, interests and relationships that run contrary (or appear to run contrary) to the best interests of clients. Kayne expects all employees to:

act with integrity, competence, dignity, and in an ethical manner when dealing with the public, clients, prospects, their employer, and their fellow employees. adhere to the highest standards with respect to any potential conflicts of interest with client accounts – simply stated, no officer or employee should ever enjoy an actual or apparent benefit over the account of any client. preserve the confidentiality of information that they may obtain in the course of our business and to use such information properly and not in any way adverse to our clients’ interests. conduct their personal financial affairs in a prudent manner, avoiding any action that could compromise in any way their ability to deal objectively with our clients.

Violations of the Code of Ethics may warrant sanctions which may include suspension or dismissal, at the discretion of management. In addition to personal trading, political contributions, outside business activities, and acting in the best interest of clients, the Code of Ethics outlines Kayne’s policies regarding gifts and entertainment; anti-bribery and compliance with the U.S. Foreign Corrupt Practices Act; lobbying; and charitable contributions. Personal Trading As a general rule, Kayne’s employees are not permitted to purchase and sell for their own accounts securities in the asset classes in which Kayne is generally active, including but not limited to the equity and debt securities of energy and power infrastructure (i.e. midstream) companies. Policies and procedures have been designed to ensure that any employee personal securities transactions do not disadvantage Kayne’s clients. These procedures require pre-clearance of all personal trades by employees in securities (other than open-end mutual funds that are not advised or sub-advised by the Firm, U.S. government securities, exchange traded funds that track multiple securities, and various money market instruments) and require employees to represent an intent to hold the securities for at least 90 days. Neither Kayne nor its employees may enter trades on behalf of their own account

or any account over which they have control or in which they have a beneficial interest if, in Kayne’s judgment, such trade would cause them or any such account to benefit from any trade entered into or being contemplated on behalf of any client of Kayne or cause the accounts of any such clients to be disadvantaged. Kayne’s Compliance department receives and reviews all trading reports and employee certifications to confirm that any personal trading (as well as other activities subject to compliance oversight) conducted by employees and other covered persons is consistent with the requirements and restrictions set forth in the Code of Ethics and does not otherwise indicate any improper trading activities. Clients may request a copy of Kayne’s Code of Ethics by contacting Michael O’Neil, Chief Compliance Officer, at (310) 282-7905. Political Contributions and Charitable Donations It is the policy of Kayne to not make, and to prohibit its employees from making, any political or charitable contributions for the purpose of influencing a Kayne client or prospective client, a public official or his or her agency. However, employees may make political or charitable contributions in accordance with the requirements and restrictions of applicable law and Kayne’s policies. To help ensure compliance with SEC rules and the many state and local pay-to-play rules, all Kayne employees must obtain prior approval from the Chief Compliance Officer before they (or their immediate family members) make contributions over certain thresholds to a political candidate, government official, or political action committee in accordance with Kayne’s policies and procedures. Kayne’s Political Contribution Policy includes the following general prohibition: All employees (and their immediate family members) are prohibited from making any contributions or gifts to, or soliciting or coordinating any contributions or gifts for (i) any incumbent U.S. state or local officeholder (including one who is a candidate for federal office); (ii) any candidate or elections winner for U.S. state or local office; and (iii) any staff member or employee of a U.S. public pension fund, or any elected or appointed trustee, fiduciary, or other official whose official duties involve responsibility for such a fund. Outside Business Activities Kayne’s Code of Ethics requires employees to obtain approval before engaging in outside business activities so that Kayne has the opportunity to consider whether such activities create actual or potential conflicts of interest (the Code of Ethics details certain instances where only notification to the CCO is required, such as serving as a director of a 501(c)(3) charitable organization). Certain senior employees may also serve as directors with portfolio companies held by Kayne clients and the compensation received from such service, where applicable, is subject to the management fee offset and governing fund documents. In instances where these outside affiliations are permitted, the employee will not be permitted to be involved in the investment decision‐making process regarding that portfolio company.

Potential Conflicts Relating to Advisory Clients The results of the investment activities of a Kayne client may differ significantly from the results achieved by Kayne for other current or future clients. Kayne will manage the assets of a client in accordance with the investment mandate of the applicable fund or, if a separate account, as selected by such client. However, because of differing guidelines, risk profiles, timing issues and other possible considerations, Kayne may give advice, and take action, with respect to a client account (including its own account) that may differ from the advice Kayne may give to, or an investment action Kayne may take on behalf of, another client account. In particular, Kayne or one or more clients may buy or sell positions while another Kayne client is undertaking the same or a differing, including potentially opposite, strategy. The purchase, holding and sale, as well as voting of investments by Kayne clients may enhance the profitability or increase or decrease the value of Kayne’s or Kayne clients’ investments in such companies. This may give rise to certain potential conflicts of interest. Kayne has adopted its trade allocation procedures (and other relevant policies) to mitigate any conflicts of interest. Inconsistent Investment Positions and Timing of Competing Transactions Under certain circumstances, a Kayne client (or group of clients) may invest in a transaction in which one or more other Kayne clients are expected to participate, or already have made or will seek to make an investment. Such clients may have conflicting interests and objectives in connection with such investments, including with respect to views on the operations or activities of the portfolio companies involved, the targeted returns from the investment, the timeframe for, and method of exiting the investment. Conflicts will also arise in cases where different clients (or group of clients) invest in different parts of an issuer’s capital structure, including circumstances in which one or more clients may own private securities or obligations of an issuer and other clients may own public securities of the same issuer. Principal Transactions with Clients Kayne’s practice (and that of its principals) is to avoid engaging in securities transactions with its managed accounts. However, Kayne believes that there may be circumstances from time to time where it is beneficial to its clients for Kayne (or its principals) to engage in a securities transaction with such clients. This could involve the sale by an investor to Kayne of such investor’s limited partnership interest in a closed-end fund, or Kayne warehousing investments on behalf of a fund. Under such circumstances, provided informed prior written consent is given by the affected client(s), Kayne may engage in a principal transaction. On occasion and subject to applicable law and a fund’s governing documents, Kayne may warehouse investments on behalf of a new fund prior to it reaching its target size or commencing operations. Once the fund has commenced operations or reached its target size, such investments will be transferred to the fund. Generally, to the extent permitted by law, the transfers would be effected at Kayne’s acquisition cost, which may or may not include interest expenses associated with bank financing. To the extent that this applies to a particular fund, the offering documents would clearly disclose such warehousing arrangement and the terms thereof. Since prior to such transfer, such investments would be owned by Kayne, conflicts of interest may arise regarding the decision of whether or not to transfer such investments and the timing of such transfers. More information on these

arrangements can be found in the offering documents of the particular fund. Kayne or an affiliate may also provide a bridge loan to a fund in order for the fund to close a transaction where the fund does not yet have capital commitments or may not have a subscription line of credit to draw on. In such circumstances, Kayne may pass along the borrowing costs to the fund (but would not make a profit on any such transaction). Conflicts of interest may arise regarding which funds Kayne provides bridge loans to, in what amounts, and the frequency with which bridge loans are provided to these funds. Advisory board approval will be sought for such loans from the relevant fund where appropriate and required under governing fund documents. Further disclosure can be found in the offering documents of the funds where such loans are permitted. Subject to applicable requirements in fund offering documents, which include obtaining advisory board consent, Kayne will in certain circumstances determine to sell one or more investments from an existing Kayne fund (sometimes where the selling fund is approaching the end of its term, but not always) to a new vehicle created to acquire portfolio company interests in secondary market transactions from other Kayne funds (a “continuation vehicle”). In each such instance, Kayne will engage a third party to substantiate valuation for the sale of assets to a continuation vehicle. The sale of an investment to a continuation vehicle could result in certain investors and/or Kayne (including employees and affiliates) disposing of their investments in the underlying assets at a different time than some other investors, depending on each investor’s decision on whether to participate in the secondary transaction. In some circumstances, certain limited partners will not be eligible to invest in a continuation vehicle due to relevant securities, tax or other considerations, and will have to sell their interests. Where Kayne or an affiliate will continue to receive fees and/or performance-based compensation relating to the subject assets following the transaction, their incentives are expected to diverge from those of investors who elect to sell their interests. A conflict of interest may also arise in the allocation of fees and expenses related to such secondary transactions, as Kayne may allocate bankers’ fees and certain other fees and expenses solely to selling investors and not to investors in the continuation vehicle, or vice versa. Further, Kayne may be incentivized to make investments in portfolio companies with the view of holding such investments for longer periods of time or to make investments that it would not otherwise have made if the possibility of liquidity through a secondary transaction did not exist. Although relevant potential conflicts of interest are disclosed to investors and/or the relevant advisory board prior to the closing of the transaction, there can be no assurance that Kayne will successfully identify all conflicts of interest or resolve or mitigate all such conflicts of interest in favor of a fund or any individual investor or group of investors. Cross Trades between Clients Kayne will only engage in a cross transaction (causing one client account to buy or sell a security from or to another client account) when a transaction is permitted under applicable law and is in the best interests of, and consistent with the investment objectives and policies of, both clients involved in the transaction. If a cross trade is considered, it is Kayne's policy to effect all such trades in the most equitable and fair manner for all participating accounts.

Read the rest in the brochure

Brokerage Discretion Kayne has full authority to determine broker-dealers to be utilized and commissions to be paid with respect to securities transactions effected for its pooled investment vehicles. Similarly, unless a separate account client directs the use of a particular broker-dealer, Kayne has the authority to select broker-dealers to be used to effect trades and the commission rates to be paid. Kayne’s policy is to not effect trades through its affiliated brokerdealer, KA Associates, LLC (“KAA”), except in certain limited temporary circumstances as described in Item 10 above. The overriding consideration in allocating client orders for execution is the maximization of client profits (or minimization of losses) through a combination of controlling transaction costs and seeking the most effective uses of a broker’s capabilities. When Kayne has the authority to select brokers or dealers to execute transactions for its clients, it seeks the best execution reasonably available under the circumstances (which may or may not result in paying the lowest available brokerage commissions or spread). In doing so, Kayne considers all factors it deems relevant. Such factors may include, but are not limited to: (i) the nature and character of the security or instrument being traded and the markets on which it is purchased or sold; (ii) the desired timing of the transaction; (iii) Kayne’s knowledge of negotiated commission rates and spreads currently available; (iv) the activity existing and expected in the market for the particular security or interest; (v) the full range of brokerage services provided; (vi) the broker’s or dealer’s capital strength and stability, as well as its execution, clearance, and settlement capabilities; (vii) if applicable, the quality of the research and services provided (see “Research and Other Soft Dollar Benefits” below); (viii) the reasonableness of the commission or its equivalent for the specific transaction; and (ix) Kayne’s knowledge of any actual or apparent operational problems of a broker or dealer. Kayne endeavors to be aware of current charges assessed by relevant broker-dealers and to minimize the expense incurred for effecting portfolio transactions, to the extent consistent with the interests and policies of the client account. However, Kayne will not select broker-dealers solely on the basis of “posted” commission rates nor always seek in advance competitive bidding for the most favorable commission rate applicable to any particular transaction. Although Kayne generally seeks competitive commission rates, it will not necessarily pay the lowest commission or commission equivalent as transactions that involve specialized services on the part of a brokerdealer generally result in higher commission rates or equivalents than would be the case with more routine transactions. Kayne may pay higher commission rates to those broker-dealers whose execution capabilities, brokerage services or other legitimate and appropriate services are particularly helpful in seeking good investment results. The reasonableness of the commissions is based on Kayne’s view of the broker’s ability to provide professional services, competitive commission rates, and other services which will help Kayne in providing investment advisory services to its clients, viewed in terms of either the particular transaction or Kayne’s overall responsibility to its clients, as the extent to which the commission rate or net price associated with a particular transaction reflects

the value of services provided often cannot readily be determined. In making these determinations, Kayne recognizes that some firms are better at executing some types of orders than others, and it may be in the clients’ best interests to use a broker-dealer whose commission rates are not the lowest but whose executions and other services, Kayne believes, may result in lower overall transaction costs or more favorable or more certain results. Outsourced Trading Arrangements Kayne has engaged Jones Trading Institutional Services, LLC (“JonesTrading”) to assume trade execution responsibilities for equities and certain derivative securities. Kayne’s operations and compliance departments provide oversight of JonesTrading activities performed on behalf of Kayne. All trades executed by JonesTrading originate within Kayne’s order management system to ensure pre- and post-trade compliance checks are run on each order. Additionally, JonesTrading will perform a secondary check of all trades before being routed to the JonesTrading Execution Management system Fidessa, where additional risk controls are in place. All trades executed by JonesTrading are analyzed on trade date by Kayne personnel and on a quarterly basis by Kayne’s third-party transaction cost analysis provider. On a quarterly basis, Kayne’s Trading Committee reviews the trading results for all counterparties (including JonesTrading) in their capacity as trading partners. Kayne investment professionals remain primarily responsible for trading fixed income (bonds and broadly syndicated bank loans), convertible securities, certain other derivative securities, and foreign exchange. ECNs, Swap Clearing Firms and Other Trading Systems Kayne may also place orders for the purchase and sale of securities or other instructions for its clients through electronic trading systems or alternative trading systems (ATSs), including Electronic Communications Networks (ECNs), swap clearing firms or with brokers or dealers that participate in such trading systems or platforms, consistent with its duty to seek best execution of client transactions. ECNs and swap clearing firms may charge fees for their services, including access fees and transaction fees. Access fees may be paid by Kayne even though they are incurred in connection with executing transactions on behalf of clients, while transaction fees will generally be charged to clients and, like commissions and markups/markdowns, would generally be included in the cost of the securities purchased. Research and Other Soft Dollar Benefits Research services include economic forecasts, investment strategy advice, fundamental and technical advice, market analysis, statistical services and analyses of particular securities and investment situations. Some of these services would be considered “soft dollars”. Kayne has no formal arrangements with specific broker-dealers to receive such research services beyond transaction execution in exchange for brokerage commissions from client transactions. However, Kayne may pay a brokerage commission in excess of that which another broker might have charged for effecting the same transaction if Kayne determines in good faith that the amount of commission is reasonable in relation to the value of the brokerage and research services provided by the broker-dealer, viewed in terms of either the particular transaction or Kayne’s overall responsibilities with respect to the account

over which it exercises investment discretion. Such rates are commensurate with those paid to so-called “full service” sell-side firms. Kayne’s policies prohibit contractual third-party soft dollar arrangements pursuant to a Commission Sharing Agreement or equivalent. It is possible that accounts which may not directly benefit from the ancillary service provided by a particular broker-dealer will enter occasional transactions through such broker-dealer, but Kayne believes that the overall effect of such occasional transactions on all accounts, when the ancillary services furnished to all accounts are considered in totality, will be beneficial to all accounts. While Kayne research analysts occasionally suggest commission targets for particular broker-dealers, and brokerdealers sometimes state in advance the amount of brokerage commissions they expect to receive for certain research services, Kayne is not contractually required to meet any such targets. Kayne has not entered into any written or unwritten agreements that would contractually obligate it to direct a specific amount of brokerage transactions or commissions to any broker-dealer. Trade Aggregation and Allocation Kayne is aware of its fiduciary obligation to seek the “best execution” on securities transactions. Best execution entails the efficient placement of orders, clearance, settlement and overall execution quality as well as the price obtained in the transaction. As part of its efforts to obtain best execution, Kayne may aggregate orders or “block trade” for several clients. Each client that participates in a block trade will receive the average share price and a pro rata portion of the transaction cost on a trade. Because clients have different affiliate relationships, some client accounts may not be eligible to participate in block trades. Kayne seeks to allocate investment opportunities among client accounts in a fair and equitable manner over time. Securities are generally allocated among client accounts on a pro rata, percentage, or other objective basis. Kayne may also allocate securities among such accounts based upon the nature of the investment opportunity and an assessment of the appropriateness of that opportunity for such accounts, taking into consideration the various risk characteristics associated with the investment opportunity and the relative risk profile of the accounts. A variety of allocation metrics will be considered in making such allocation decisions. These metrics include (i) investment objectives of the accounts; (ii) risk or investment concentration parameters of the accounts; (iii) supply or demand for a security at a given price level; (iv) size of available investments; (v) cash availability and liquidity requirements of the accounts; (vi) relative size of the accounts; (vii) regulatory and client-imposed restrictions applicable either to the accounts or to the securities; (viii) tax considerations of the accounts; (ix) minimum investment size of the accounts (including maintaining round lots); and (x) such other factors as may be relevant to a particular transaction. Investments may not be allocated to one client account over another based on any of the following: (i) to unduly favor an account in which Kayne, its employees or affiliates has a significant interest at the expense of another client account; (ii) to generate higher fees paid by one client account over another or to produce greater

performance compensation to Kayne; (iii) to develop or enhance a relationship with a client or prospective client; (iv) to compensate a client for past service or benefits rendered to Kayne or to induce future services or benefits to be rendered to Kayne; or (v) to manage or equalize investment performance among different client accounts. Kayne and certain of its affiliates were granted an exemptive relief order by the SEC (the “Order”), which permits registered investment companies (RICs), business development companies (BDCs) and other affiliates to co-invest alongside each other in certain negotiated transactions. The Order generally requires allocating such coinvestment transactions in accordance with Kayne’s Allocation Procedures Policy, enhanced reporting and recordkeeping, and where applicable, approval of independent directors of the applicable RICs and/or BDCs. Although interrelated, Kayne’s trade allocation and aggregation practices are separate from Kayne’s coinvestment policy for transactions not involving registered investment companies (see “Co-Investments” section below). As indicated earlier, co-investment opportunities may be offered to investors in funds and accounts managed by Kayne, employees, and third parties who Kayne believes may provide a strategic benefit to such investment or future capital raising opportunities. Such opportunities will only be provided in accordance with applicable regulations in accordance with the Co-Investment Policy discussed in this Item 12 below and with the prior approval of Kayne’s Chief Compliance Officer. Please note that since Kayne invests in a variety of strategies and platforms, allocation of investment opportunities may be subject to restrictions or priority rights in applicable offering documents. Any deviation from the standard procedures must be fully documented, state the reason for deviation, and be approved by Compliance. Co-Investments Kayne maintains various co-investment relationships. These relationships enable Kayne to consummate transactions on behalf of a Platform Fund Complex (as defined below) where additional capital is required above the target (or contractual maximum) investment amount of the Platform Fund Complex. In order to facilitate these transactions and subject to applicable offering documents, Kayne considers a number of factors, including, most notably, its fiduciary and contractual obligations, as well as corresponding investment mandates of the single-strategy largest commingled fund, in prioritizing allocations of co-investment opportunities. A “Platform Fund Complex” consists of the largest Kayne-managed commingled fund (based on committed capital) formed to pursue a single investment strategy (as opposed to a multi-strategy fund) and all Kayne managed accounts established and structured to invest in parallel with the commingled fund. Kayne has adopted a Co-Investment Policy in an effort to ensure that all co-investment opportunities will, to the extent practicable, be allocated on a basis that over a period of time is fair and equitable, taking into account relevant facts and circumstances. Generally, subject to the conditions set forth in the SEC Order referenced above, the offering documents of each Platform Fund Complex include provisions with respect to the rights of a particular Platform Fund Complex to (i) receive a first priority right to suitable investment opportunities, or where

Read the rest in the brochure

Kayne has entered into contractual agreements with certain unaffiliated solicitors and placement agents who assist with marketing our funds in order to refer potential clients to Kayne (i.e. provide endorsements as defined in the Marketing Rule). Such referral sources must be appropriately registered/licensed with the required regulatory authorities in the jurisdictions in which they operate. All agreements with unaffiliated solicitors and placement agents who assist with marketing our funds are made in writing pursuant to Rule 206(4)-1 of the Advisers Act. While the specific terms of each agreement may differ, the solicitor or placement agent will typically receive cash compensation in the form of a monthly retainer, and either a flat-rate success fee or a percentage of the fees received by Kayne from accounts referred by the solicitor. The solicitor may also receive trailing fees that are contingent on an investor remaining invested with Kayne for a specified length of time. Kayne does not expect to award non-cash compensation to a solicitor, nor will it provide compensation for testimonials or endorsements that is at or below the de minimis threshold as defined in Rule 206(4)-1. Any compensation payable to a solicitor is not a factor in determining the fee Kayne will charge for its investment management services, and an investor will never pay increased advisory fees as a result of being referred by a solicitor Kayne compensates. Compensation for solicitations and endorsements paid to third parties will either be paid by Kayne, an affiliated management company, or by the relevant fund; if paid for by a fund, the compensation paid will offset, on a dollar-for-dollar basis, the management fees otherwise payable by the fund. Where Kayne uses endorsements or testimonials from solicitors in advertisements, it will clearly and prominently (i) state that the testimonial was given by a current client/investor or that the endorsement was given by a person other than a current client or investor, as applicable; (ii) disclose the material terms of the compensation arrangement with the solicitor for their endorsement or testimonial, including the type and amount of cash

compensation paid to the solicitor, whether the compensation is paid directly or indirectly to the solicitor, or whether the solicitor was not compensated for their endorsement or testimonial; and (iii) disclose material conflicts of interest that result from Kayne’s relationship with the solicitor and/or its compensation arrangement (as a compensation arrangement inherently incentivizes a solicitor to recommend the compensating investment adviser). Kayne will deliver the required disclosures at the time the endorsement or testimonial is disseminated, or it will have a reasonable belief that the solicitor is delivering the required disclosures at the time they are disseminating the endorsement or testimonial. Kayne will exercise reasonable care to ensure that solicitors compensated for testimonials or endorsements are and remain eligible to receive compensation and have not experienced a disqualifying event or disqualifying Commission action as described in Rule 206(4)-1.

Neither Kayne nor any of its executive officers, members of investment committees or “other management persons” as defined in Form ADV has been subject to the legal or disciplinary events related to this Item or is otherwise required to disclose any event required by this Item.

All accounts are reviewed on a continuous basis to determine their conformity with investment objectives and guidelines. Each portfolio manager receives daily updates of portfolio positions and transactions for which such portfolio manager is responsible. With members of the respective investment team or investment committee as applicable, portfolio managers regularly review and discuss portfolio status, potential investments and related issues. Limited partners in Kayne’s private pooled accounts (i.e., investment partnerships and offshore funds) receive quarterly statements indicating their capital balances and the account’s balance sheet and income statement. These materials are provided with a letter highlighting the developments for the period. Separate account clients receive quarterly (or other frequency if requested) reports showing open positions, dividend and interest income, realized gains and losses, and performance for the period. Portfolio managers or other Kayne investment professionals may also make themselves available to clients, upon request, to conduct portfolio reviews or answer other relevant questions.

Investments and cash in Kayne’s pooled investment vehicles and separate accounts are held by third-party custodians. Nonetheless, by virtue of its ability to deduct fees from its accounts, Kayne is deemed under applicable rules to have custody of client accounts. With respect to client accounts that may be opened at KA Associates, LLC, National Financial Services is the clearing firm for KAA and is deemed to be the custodian. Investors in pooled investment vehicles receive quarterly statements from Kayne. Investors receive audited financials within 120 days following the end of the pooled investment vehicle’s fiscal year. Audited financial statements are prepared by an independent accounting firm, which is registered and subject to inspection by the Public Company Accounting Oversight Board. In all circumstances where Kayne or an affiliate is deemed to have custody of client assets, Kayne seeks to comply with the custody rules of the Advisers Act and the 1940 Act and any applicable SEC No-Action Relief letters. In certain cases, Kayne may be deemed to have indirect custody of client accounts when an affiliated subsidiary acts as an administrative agent to certain loan syndication arrangements. Kayne utilizes a commingled agency account opened in the name of its affiliate and maintained by a major U.S. bank to facilitate the movement of cash to and from lenders and borrowers in these loan syndication arrangements. In any such circumstances where Kayne or an affiliate is deemed to have custody of client assets, Kayne seeks to comply with the Advisers Act custody rule and any applicable SEC No-Action Relief letters.

Kayne has full discretion with respect to securities transactions effected for its pooled investment vehicles. In addition, Kayne also has full discretion in its separate accounts to buy and sell securities without prior client approval. Kayne exercises its investment discretion consistent with the applicable investment strategy, as well as any separate account investment guidelines or restrictions imposed by the client and accepted by Kayne. Kayne does not advise clients concerning holdings outside their respective accounts with Kayne.

Kayne acknowledges its responsibility to vote proxies consistent with its fiduciary obligations, in the best interests of its clients and to prevent conflicts of interest from influencing proxy voting decisions made on behalf of clients. Our Proxy Voting Guidelines can be found on our website, https://www.kayneanderson.com. While third-party instructions may be useful, Kayne may, and generally is expected to have in-depth knowledge of the vast majority of the companies and related sectors in which it has invested, which knowledge may provide good reason to vote in a manner that is not consistent with the advice of a third-party service provider. Relevant portfolio management personnel are responsible for voting proxy ballots in a manner that protects and promotes the economic value of our clients’ investments. While these personnel may review research reports provided by proxy voting services, Kayne is responsible for forming a recommendation on each and every ballot proposal. Once the recommendations are made, a member of the Compliance department will vote the proxy(ies) according to the recommendations. There may be circumstances which lead Kayne to vote the same proxy in two directions for different accounts. This may occur, for example, if a client requires Kayne to vote a certain way on an issue, while Kayne deems it beneficial to vote in the opposing direction for its other clients. In all such cases, Kayne maintains relevant supporting documentation. Kayne may occasionally be subject to conflicts of interest in the voting of proxies because of business or personal relationships it maintains with persons having an interest in the outcome of specific votes. The Firm and its employees may also occasionally have business or personal relationships with other proponents of proxy proposals, participants in proxy contests, corporate directors, or candidates for directorships. If at any time the responsible voting parties become aware of any type of potential conflict of interest relating to a particular proxy proposal, they will promptly report such conflict to the Chief Compliance Officer. Conflicts of interest are handled in various ways depending on the nature of the conflict and its perceived materiality. For inquiries regarding how a specific proxy proposal was voted, please contact Michael O’Neil, Chief Compliance Officer, at (310) 282-7905.

Kayne is in sound financial standing and does not use long-term borrowings in its capitalization structure. Kayne has no financial commitment that impairs its ability to meet its contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.