MetLife Investment Management, LLC

MetLife Investment Management, LLC (the “Firm”) was founded in 2006 and is an indirect, whollyowned subsidiary of MetLife, Inc. (together with its subsidiaries, “MetLife”), a publicly held company. The Firm is part of MetLife Investment Management (“MIM”), MetLife’s institutional investment management business. MIM includes PineBridge Investments, LLC and its global affiliates that were acquired by MetLife on December 30, 2025 (collectively, “PineBridge Investments”). The Firm offers investment management services in the following business units: Real Estate; Private Fixed Income and Alternatives; Public Fixed Income; Index Strategies; and Equity. Such business units are not separate legal entities or formal sub-divisions of MIM and the Firm but are utilized for purposes of the Firm’s Disclosure Brochures in order to more accurately describe the Firm’s business activities in specific asset classes to clients and prospective clients of the Firm. This Disclosure Brochure relates solely to the investment management unit of the Firm dedicated to advising clients with respect to real estate assets (“MIM RE”). Each of the Firm’s other investment management business units is described in greater detail in its own disclosure brochure. The Firm typically makes investments for clients in accordance with written investment guidelines or other investment specific documentation for each advisory mandate. Investment services can be tailored for each client’s specific needs and objectives, including restrictions on investing in certain securities or types of securities. The Firm has procedures and controls to monitor compliance with each client’s specific investment guidelines. Where the Firm is the investment adviser to a pooled investment vehicle, investment objectives, guidelines and any investment restrictions generally are not tailored to the needs of individual investors in those vehicles, but rather are described in the prospectus or other relevant offering document for such vehicle. As of December 31, 2025, the Firm had $563,779,494,417 in assets under management, of which $560,911,238,227 was managed on a discretionary basis and $2,868,256,190 was managed on a non-discretionary basis.

The Firm is typically compensated for its advisory services based upon a percentage of assets under management and for certain clients the Firm charges an asset-based fee based on book value or principal balance outstanding. The Firm tailors its advisory services based on the needs of the client. As such, all advisory fees are agreed with the client depending on the scope of services the Firm is providing (other than for any funds or other pooled investment vehicles (“funds”), where the fee is set forth in the offering documents, as amended from time to time). The amount and terms of the fee is either set forth in the fund offering documents or constituent fund documents or in an agreement between the Firm and the client. For separately managed accounts, the Firm also receives other fees such as acquisition fees, disposition fees, development fees, and debt placement fees, in connection with the mandate as agreed to between the client and the Firm. The Firm also receives [fixed, variable] fees for certain loan asset management and reporting services. Additionally, certain clients pay a performancebased fee, the terms of which are agreed upon with the Firm. Any performance-based fee arrangements are structured to comply with Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The valuation methodology, as well as the frequency in which portfolio holdings are valued used to calculate the Firm’s fee, is agreed to between the client and the Firm. The Firm generally charges its fee in arrears on a quarterly basis. While the Firm does not solicit clients to pay in advance, it can accept such arrangement at a client’s request. For any fees collected in advance where a client terminates prior to the end of a billing period, any prepaid fees would be refunded on a pro rata basis. In addition to the Firm’s fee, clients incur additional charges imposed by other service providers, including service providers that are affiliates of the Firm. As a general matter, these fees are separate from the Firm’s advisory fee, and the Firm receives no portion of them. In some

circumstances, the Firm has agreed to reduce its advisory fee to offset certain fees received by MIM’s affiliates. These arrangements are negotiated on a case-by-case basis and agreed to by each client. Common Types of Expenses Related to Real Estate Strategies Clients and funds investing in real estate strategies either directly or through allocations by the Firm or its Affiliates to such strategies, bear, directly or indirectly, certain expenses relating to those investments. Examples of such expenses include, without limitation:

all fees, expenses and costs associated with making investments, including transaction fees, due diligence costs, legal fees, transfer taxes, title premiums, closing costs, among others;

property, loan administration servicing and similar fees;

taxes, fees, related interest, or other governmental charges; and

In addition, clients investing in funds also are subject to:

fund organizational and operating expenses, including fees associated with the retention of service providers such as a custodian, transfer agent, auditors, among others;

the costs, fees, and expenses relating to marketing the fund to potential investors, including the costs, fees, and expenses associated with marketing, advertising, printing, wholesaling, (where applicable) registering the fund for marketing in certain jurisdictions and other capital raising expenses; and

If the fund is a feeder fund, such feeder funds bear a pro rata share of the expenses associated with the master fund.

The above lists are not exhaustive. Clients should refer to an applicable offering document for a more extensive description of the expenses associated with an investment in such a strategy. In addition, Clients will also incur brokerage and other transaction costs. Please refer to the section entitled “Brokerage Practices” below for more information on these practices. Expense Allocation Expenses frequently will be incurred by multiple client accounts and funds. Expense allocation decisions involve conflicts of interest (e.g., an incentive to favor advisory clients that pay higher incentive fees or conflicts relating to different expense arrangements with certain advisory clients). The Firm allocates aggregate costs among the applicable client accounts (and, in certain cases, among the Firm and applicable client accounts and funds) in accordance with expense allocation policies and procedures, which are reasonably designed to allocate expenses in a fair and reasonable manner over time among such advisory clients. Under its current expense allocation policies, the Firm generally allocates the expense among the client accounts and funds on a pro rata basis based on assets under management. However, the Firm will in certain cases bear the allocable share, or a portion thereof, of expenses for particular clients and funds and not for others, as agreed with such clients or funds or as determined in its sole discretion, which will lead to a lower expense ratio for certain clients and funds. The Firm can also allocate a portion of any expense to itself where a product or service is shared between the Firm and its Affiliates on the one hand and the Firm's client accounts and funds on the other. In these and other circumstances, the Firm can deviate from pro rata allocation if it deems another method more appropriate based on the relative use of, or benefit from, a product or service, or other relevant factors. While the Firm’s policies and procedures are intended to result in expense allocation that is fair and equitable across client accounts over time, the portion of a common expense that the Firm allocates to a client account or fund for a particular product or service may not reflect the relative benefit derived by the relevant client account or fund in each instance.

Investment in Affiliated Funds If a separately managed account or private fund is directly invested in a pooled investment vehicle managed by the Firm or its affiliates, the Firm generally does not receive advisory fees from both the client’s separate account and the affiliated fund in which the separate account is invested. Where permitted by applicable law, separate accounts and fund-of-funds advised by the Firm or an affiliate that are invested in an affiliated fund will also incur their pro rata portion of other fees and expenses charged at the affiliated fund level, e.g., custodian fees and transfer agency fees. Because the Firm and its affiliates receive fees from the funds, the investments in underlying funds benefit the Firm and/or its affiliates, which creates an incentive for the Firm to invest client assets in affiliated funds. Multi-asset Strategy Depending on the type of fee arrangement with the client, when managing multi-asset strategies, the Firm could face a conflict of interest in allocating client assets among the various investment strategies. For example, if a client pays a fixed account level advisory fee, then the Firm faces a conflict of interest when allocating clients’ assets because it has an incentive to allocate to investment strategies that are more cost efficient for the Firm. Where there is no fixed account level advisory fee, the Firm faces a conflict of interest when allocating clients' assets because it has an incentive to allocate to investment strategies that have higher fund fees over investment strategies that have lower fund fees. Other Compensation: Sales personnel associated with PineBridge Investments (collectively, “PBI sales personnel) are paid discretionary bonuses (“Bonus”) for the sale of funds sponsored by, and investment advisory services provided by, the Firm and its affiliates. The Bonus is generally based on a percentage of the management fees received by the Firm or its affiliated investment advisers, and the percentage of the management fee paid to personnel differs in some cases depending on the particular products and services. The Bonus will not increase the fees or other compensation that the investment adviser charges you and is not an additional separate fee. For example, in situations where a Client requests a specific investment strategy and that strategy is available to an Investor both through a fund product and an investment advisory contract and the fees related to such product and services are different, the structure of the Bonus plan presents a conflict of interest whereby PBI sales personnel would receive a larger Bonus for recommending a fund product over an investment advisory service. The Firm and its affiliates have adopted a Code of Ethics to address the ethical conduct of employees, including sales personnel. The Code of Ethics requires, among other things, that employees place the interests of clients first. Training on the Code of Ethics is conducted annually. Such training emphasizes employees’ obligations to avoid placing personal interests ahead of the interests of Clients. Further mitigants include disclosure, as appropriate.

The information presented below relates to MIM RE. Information about the additional investment management business units of the Firm is contained in separate disclosure brochures. The current investment strategies offered by MIM RE are as follows: Real Estate Strategies Commercial Mortgages. MIM RE offers investors a Commercial Mortgage Loan managed account strategy that seeks to identify mortgages that offer attractive relative value. Under this strategy, MIM RE sources loan opportunities for its clients. Upon closing of the loan, the client to whom the loan is allocated either becomes (x) the sole lender of record or (y) a lender of record alongside a MetLife Account on behalf of the client. MIM RE manages these loans. In certain instances, a client retains approval rights with respect to certain matters with respect to management of the loan. Each mandate can be customized to each client’s individual goals, objectives, target markets, and guidelines. MIM RE generally targets loans on assets located in primary markets with the remainder

in defined secondary and tertiary markets. MIM RE primarily sources loans secured by institutional quality office buildings, retail centers, apartment buildings, industrial properties and hotels. Professionals in MIM RE’s regional field office network solicit, underwrite and process the loans and have in-depth real estate knowledge and longstanding industry relationships. Agricultural Loans. MIM RE offers managed account agricultural loan strategies tailored to each client’s individual goals, objectives, target markets, and guidelines. Agricultural loans include agribusiness loans, timber loans, and farm & ranch loans. MIM RE sources agricultural loan opportunities for its clients by leveraging existing and building new relationships. MIM RE’s platform relies on a decentralized regional office structure for the origination, administration and portfolio surveillance of loan assets. The regional offices are responsible for originating and managing long-term buy and hold mortgage loan opportunities in a defined geographic area. MIM RE analyzes whether a proposed opportunity fits the client’s guideline parameters. Participations in Commercial Mortgage Loans and Agricultural Loans: From time to time, MetLife Real Estate Lending, LLC (“MREL”), an affiliate of the Firm, in its discretion offers the Firm’s clients, including MetLife Accounts, the opportunity to acquire participation interests in certain commercial mortgage loans or agricultural loans that MREL is originating for itself. Each party interested in participating in these loan opportunities enters into a master participation and servicing agreement with MREL (“MPSA”) and the Firm. Each party specifies its own investment parameters, including target markets, desired characteristics, investment limitations, and other factors in its MPSA. Once a loan opportunity is identified, MIM RE on behalf of MREL will determine whether a proposed opportunity fits the participants’ guideline parameters and then allocate such opportunities to those participants. In certain mandates, clients have given investment discretion to MIM RE; however, others require client approval of each opportunity. For each loan participation acquired by the participant, the Firm earns a reporting and advisory fee from each third-party participant until the earlier of (x) the maturity of the loan or (y) the participant’s sale of its interest in the loan. Certain participants have major decision rights with respect to the management of the loan and certain participants, potentially including MetLife Accounts, may have the right to block the sale of their interest in a loan (or property related thereto) or have other rights. MIM RE sources loan opportunities for MREL the same way that it sources commercial mortgage and agricultural whole loans above. Loan Asset Management and Reporting From time to time, MIM provides loan asset management and reporting services on agricultural loans for a fee. This includes loans that were not acquired as a participation interest through MREL. Secondary Sales of Participations in Mortgage Loans. From time to time, the MetLife Accounts sell their loan participations in certain loans originated and held by MREL. If the MetLife Accounts wish to do so, MIM RE will offer these participations on behalf of the MetLife Accounts to its third-party clients, on a secondary sale basis, in accordance with its allocation policy. Each investment must be approved by the third-party client, on a case-by-case basis. Each third-party client acquiring a participation interest from the MetLife Accounts must enter into an MPSA with MREL and the Firm pursuant to which the Firm earns a reporting and advisory fee until the earlier of (x) the maturity of the loan or (y) the third-party client’s sale of its interest in the loan. Real Estate Equity. MIM RE offers investors a Real Estate Equity strategy that seeks to achieve income growth and capital appreciation by acquiring high-quality properties in markets with favorable economic drivers. These investments are typically made through a joint venture structure between the client and a MetLife Account whereby MIM RE manages the venture and its investments subject to each client’s major decision rights. Each mandate can be customized to each client’s individual goals, objectives, target markets, and guidelines. MIM RE generally focuses on the top 30 U.S. markets in terms of commercial real estate asset value, and often prefers those with a concentration of knowledge workers in science, technology, engineering and mathematics occupations. MIM RE engages in the acquisition of stabilized assets, as well as build-to-core investing, a strategy that involves developing and holding assets after occupancy levels have stabilized, in certain instances, MIM also engages in the development of assets with the intention of liquidating after construction completion and stabilization. In sourcing real estate equity investments, MIM RE professionals

leverage their extensive industry relationships and investment experience. These two factors help maintain active deal flow, underwriting discipline, and proper risk management.

Sustainable Investments. MIM offers sustainability focused strategies that prioritize greenhouse gas (GHG) emission reduction and efficiency optimization initiatives for MIM-managed and controlled real estate properties and funds. Our broad energy and sustainability strategy is centered on the U.S. Environmental Protection Agency’s (EPA) ENERGY STAR program, the U.S. Department of Energy’s (DOE) Better Buildings and Better Climate Challenge, and the Urban Land Institute (ULI) Greenprint Net Zero by 2050 Commitment. The specific strategic objectives for these programs include: 1) increase efficiency and sustainability; 2) decrease net emissions; 3) improve operational and financial performance; 4) increase value by aligning our sustainability goals with those of our occupants and prospects; and 5) embed energy and sustainability optimization considerations in our real estate decision making processes. Additionally, specific to MIM-managed and controlled real estate equity properties, we have developed our proprietary MetZero™ program which uses an innovative Carbon Cascade™ approach to lower greenhouse gas emissions. This approach focuses on energy efficiency with a graduated set of investment tranches, including: 1) energy efficient and cost-effective energy management solutions; 2) on-site renewable energy; and 3) off-site renewable energy. Pooled Investment Vehicles The Firm is the investment manager to pooled investment vehicles that invest in real estate equity and commercial mortgage debt. Information about these funds is disclosed in their respective offering documents. These pooled investment vehicles do not meet the definition of “private fund” as defined on Form ADV Part 1, Item 7B. As such, they are not required to be disclosed on Schedule D. Additional information on why each of these funds is not required to be disclosed on Schedule D is available by contacting the Firm. In addition to the investment strategies described above, the Firm can also overlay the following insurance asset management strategies and services. The Firm leverages its global scale and footprint, insurance asset management expertise, risk management and credit culture to create value for its insurance clients and offers such clients the following investment mandates:

Single investment mandates

Multiple investment mandates

Outsourced CIO mandates

Insurance core mandate solutions leveraging the Firm’s global asset origination and portfolio management platforms

The Firm’s insurance asset management services focus on portfolio analytics that include asset allocation advice, risk analysis, stress testing, and hedge modeling. This is customized to the needs of the individual client. The Firm leverages its in-house resources to review client data and provide custom analyses and solutions, which is used to shape the advice offered to the client. Additionally, the Firm produces white papers and other forms of client research and education, which can be tailored to the needs of the client, including asset class diversification, information about hedging strategies, use of derivatives, or other topics at the client’s request. The Firm is also able to provide portfolio advisory services, which includes portfolio design and ongoing strategic asset allocation across multiple strategies. The investment management activities would be conducted by the asset class specialists within the Firm, with oversight from its insurance asset managers providing ongoing recommendations for how to strategically rebalance the portfolio. Use of Derivatives The Firm uses derivatives (such as U.S. Treasury and currency options, futures and forwards, overthe-counter (“OTC”) cleared interest rate and credit default swaps, total return and equity swaps and

options on swaps) to hedge investments in a client’s portfolio or seek to enhance returns. In implementing certain investment strategies, derivatives are used as a substitute to take a position in the underlying asset and/or as part of a strategy designed to manage exposure to other risks and used to attain leverage in an account. Risk of Loss for All Investments MIM RE’s investment strategies may not achieve their performance objectives and can result in losses. MIM RE has summarized below certain important risks for clients and prospective clients to consider with respect to its strategies. Information about the risks related to additional investment management units of the Firm is provided in separate disclosure brochures. For purposes of the risk factors included herein, the term ”Client,” as context requires, should be read to include both a separate account client or an investor in a fund or other pooled investment vehicle managed by the Firm. References to actions taken or investments made by a “Client” should be understood to mean, as context requires, that such actions are taken or investments made by the Firm or its affiliates acting on behalf of Client. Risks Related to Investments in Mortgage Loans Mortgage Loans Generally. Certain Clients invest in mortgage loans and are subject to all of the risks inherent in mortgage loan investments, including:

Client is at risk of defaults by the borrowers on those mortgage loans. These defaults can be caused by many conditions beyond MIM RE’s control, including interest rate levels as well as local and national economic conditions affecting real estate values. MIM RE will not know whether the values of the properties securing the mortgage loans will remain at the levels existing on the dates of origination of those mortgage loans. If the values of the underlying properties drop, the risk to Client’s investment in the mortgage loans on those properties, generally increases.

A defaulted mortgage loan can also become subject to workout negotiations or restructuring, which may entail, among other things, a substantial reduction in the interest rate, a substantial write-down of principal and a substantial change in the terms, conditions and covenants with respect to the loan. Such negotiations or restructuring can be extensive and protracted over time and could result in substantial uncertainty with respect to the ultimate recovery on Client’s investment in the loan.

If interest rates rise, the market value of fixed rate long-term mortgage loans generally decline. If interest rates decrease, Client could be adversely affected to the extent that mortgage loans are prepaid because Client may not be able to generate equivalent returns upon reinvestment of the funds.

Declines in real estate values can induce mortgagors to voluntarily default on their loans, increasing the risk of foreclosure and loss of capital.

Delays in liquidating defaulted mortgage loans could reduce Client’s investment returns. If there are defaults under those mortgage loans, it is possible that MIM RE (or its agent) could not be able to repossess and sell the underlying properties quickly. The resulting time delay could reduce the value of Client’s investment in the defaulted mortgage loans. An action to foreclose on a property securing a mortgage loan is regulated by state statutes and regulations and is subject to many of the delays and expenses of other lawsuits if the defendant raises defenses or counterclaims.

Commercial Mortgage Loan Risk. Certain Clients invest in or originate commercial mortgage loans. The value of Client’s commercial mortgage loans can be influenced by the historical rate of delinquencies and defaults experienced on the commercial mortgage loans and by the severity of

loss incurred as a result of such defaults. The factors influencing delinquencies, defaults and loss severity include: i.

economic and real estate market conditions by industry sectors (e.g., multifamily, retail, office);

ii.

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Through MIM RE, the Firm provides its advisory services to institutional clients including corporate entities, pension and profit sharing plans (including government, Employee Retirement Income Security Act of 1974, as from time to time amended (“ERISA”), and Taft-Hartley plans), insurance companies, charitable institutions, foundations, and endowments, sovereign funds, limited partnerships, and MetLife general and separate affiliated accounts which includes MetLife’s domestic insurance company subsidiaries (the “MetLife Accounts”), registered investment companies, pooled investment vehicles (including private funds), and public and government entities. With respect to any pooled investment vehicle, the Firm provides investment advice and other services directly to such vehicle and not individually to the investors in such vehicle.

As disclosed in response to Item 5, MIM RE provides services for performance-based compensation. This gives MIM RE an incentive to take additional risks in these accounts or allocate to them more favorable investment opportunities. MIM RE has implemented policies and procedures, including an allocation policy, which is designed to manage the allocation of investment opportunities among all clients on a systematic basis. MIM RE believes this mitigates the conflicts that typically arise with performance-based compensation. Performance-Based Fees. Clients of the Firm pay various types of fees for investment advisory services. For example, institutional account fees can be determined on a fixed rate, sliding scale, or incentive basis. Most client accounts are charged fees based on a percentage of assets under management, book value or principal balance outstanding. Certain accounts are charged an

incentive or performance-based fee or carried interest together with, or in lieu of, an asset-based fee. Generally, performance-based fees are calculated on the appreciation of a client’s assets or performance relative to a specified benchmark. Side-by-Side Management and Potential Conflicts of Interest. Certain portfolio managers of the Firm simultaneously manage accounts that are charged performance-based fees and accounts that are charged asset-based fees. Frequently, the portfolio managers of these accounts utilize substantially similar investment strategies and invest in substantially similar assets for both account types. This portfolio management relationship is often referred to as side-by-side management. Accounts that pay performance-based fees reward the Firm and its portfolio managers based on the performance in those accounts. As a result, performance-based fee arrangements create incentives for portfolio managers to make investments that present a greater potential for return but also a greater risk of loss and that can be more speculative than if only asset-based fees were applied. On the other hand, compared to a performance-based fee account, the Firm will likely have an interest in engaging in relatively safer investments when managing accounts that pay asset-based fees. The side-by-side management of accounts that pay performance-based fees and accounts that only pay an assetbased fee creates a conflict of interest because there is an inherent incentive for the portfolio manager to favor accounts with the potential to receive greater fees. For example, a portfolio manager will be faced with a conflict of interest when allocating scarce investment opportunities given the possibility of greater fees from accounts that pay performance-based fees as opposed to accounts that do not pay performance-based fees. To address these types of conflicts, the Firm has adopted policies and procedures pursuant to which investment opportunities will be allocated among similarly situated clients in a manner that the Firm believes is fair and equitable over time.

As disclosed in response to Item 4, the Firm is a subsidiary of MetLife, Inc. The Firm is under common control with other registered investment advisers, broker dealers and insurance companies. Any relationship between the Firm and another MetLife affiliate material to a prospective client’s evaluation of MIM Real Estate, including conflicts of interest, is disclosed as appropriate within this Disclosure Brochure or in applicable offering documents. Relationship with MetLife Investment Management Affiliates The Firm is part of MetLife’s institutional investment management business, MetLife Investment Management, which is affiliated with various U.S. and non-U.S. financial service providers, including other investment advisers, broker-dealers and insurance companies. The Firm utilizes the services of the following advisory affiliates to provide trading, research, and/or management services to clients. US - Securities and Exchange Commission (“SEC”)

PineBridge Investments, LLC is a registered Investment Adviser with the SEC

US - Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Adviser or Associated Person

PineBridge Investments, LLC is registered as a commodity pool operator and commodity trading adviser under the Commodity Exchange Act.

Canada – Ontario Securities Commission (“OSC”)

MIM I, LLC (“MIM I”) is a wholly owned subsidiary of MIM, LLC that is registered with the Ontario Securities Commission (as its primary regulator) in Canada to provide portfolio management services to certain Canadian institutional investors. While MIM I has a limited number of employees, it leverages the capabilities of MIM, LLC. MIM I’s activities are limited to portfolio management for fixed income separately managed accounts.

UK – Financial Conduct Authority (“FCA”)

MetLife Investment Management Limited (“MIML”) is authorized by the FCA as an investment adviser and investment manager.

PineBridge Investments Europe Limited is authorized by the FCA as an investment adviser and investment manager.

PineBridge Benson Elliott, LLP is authorized by the FCA as an investment adviser and investment manager.

Europe – Central Bank of Ireland (“CBI”)

MetLife Investment Management Europe Limited (“MIM Europe”) is authorized by the CBI as a manager for alternative investment funds (“AIFs”) and undertakings for the collective investment in transferable securities (“UCITS”). MIM Europe also has additional regulatory permissions to provide investment services to separately managed accounts, nondiscretionary investment advice and the reception and transmission of orders (“MiFID Services”).

PineBridge Investments Ireland Limited (“PineBridge Ireland”) is authorized by CBI the as a manager for AIFs and undertakings for the collective investment in transferable securities UCITS. PineBridge Ireland extended its AIFM´s authorisation to include management of portfolios of investments, investment advice and reception and transmission of orders in relation to financial instruments.

Germany – Bundesanstalt für Finanzdienstleistungsaufsicht (“BaFin”)

PineBridge Investments Deutschland GmbH is registered with BaFin to conduct investment services brokerage.

Switzerland – Swiss Federal Financial Services Act (“FinSA”)

PineBridge Investments Switzerland BmbH provides investment management services in Switzerland.

Hong Kong – Securities and Futures Commission (“SFC”)

MetLife Investments Asia Limited (“MIAL”), is licensed by the SFC to carry on Type 1 (dealing in securities), Type 4 (advising on securities) and Type 9 (asset management) regulated activities in Hong Kong.

PineBridge Investments Asia Limited is licensed by the SFC to carry on Type 1 (Dealing in Securities), Type 4 (Advising on Securities) and Type 9 (Asset Management) regulated activities in Hong Kong.

India

PineBridge Investments Private Limited provides non-discretionary investment advisory services only to its overseas affiliates.

Japan – Financial Services Agency (“FSA”)

MetLife Investment Management Japan, Limited (“MIM Japan”), is an FSA registered discretionary investment manager located in Japan.

PineBridge Investments Japan Co., Ltd. is an FSA registered discretionary investment manager.

Korea – Financial Supervisory Service (“FSS”)

PineBridge Investments Asia Limited is also licensed by the to provide Cross-Border Discretionary Investment Management (CB-DIM) and Cross-Border Investment Advisory (CB-IA) services to Qualified Professional Investors in Korea.

Singapore – Monetary Authority of Singapore (“MAS”)

PineBridge Investments Singapore Limited has been regulated by the Monetary Authority of Singapore and holds a Capital Markets Services License under the Securities and Futures Act to conduct fund management activity and is an Exempt Financial Adviser under the Financial Advisers Act.

Malaysia – Securities Commission Malaysia (“SC”)

PineBridge Investments Malaysia Sdn Bhd is registered with the Securities Commission in Malaysia to conduct portfolio management.

Taiwan – Securities & Futures Bureau under Financial Supervisory Commission ("SFB")

PineBridge Investments Management Taiwan Limited is licensed in Taiwan for (i) securities investment trust business, (ii) discretionary investment services, (iii) security-investing advices and (iv) other services as approved by the Financial Supervisory Commission.

Latin America

MetLife Latin America Asesorias e Inversiones Limitada (“MILA”) provides investment management services in the Latin America region.

PineBridge Investments Latin America SPA provides investment management services in the Latin America region.

The Firm has also entered into arrangements with certain of the above investment advisory affiliates pursuant to which certain employees of the affiliate have been designated to provide investments services to the Firm with respect to the Firm’s clients commonly referred to as “participating affiliate arrangements.” These designated employees are deemed “associated persons” of the Firm as defined under the Investment Advisers Act of 1940, as amended, and, in this capacity, are subject to the oversight of the Firm and its Chief Compliance Officer. The Firm remains responsible for the advice and services provided by the designated employees of the participating affiliate. Each participating affiliate arrangement is structured in accordance with a series of SEC no-action letters mandating that participating affiliates remain subject to the regulatory supervision of both the Firm and, in certain respects, the SEC. In addition, the Firm also may delegate a portion of its investment management responsibilities to, and receives investment services from, certain affiliates, including trading execution services and receipt of investment research. The use of an affiliates to provide these services is a potential conflict of interest because there is an incentive for the Firm to favor the services of its affiliates over unaffiliated third parties. In addition, the Firm provides investment research and sub-advisory services to certain of these affiliates. When the Firm is managing an affiliate’s client account through a sub-advisory relationship, such client will be treated as a client of the Firm for purposes of investment allocations. Some Firm employees also are directors, officers and/or employees of some of these affiliates and are likely to recommend the same security to clients of both the Firm and the affiliate. Both the Firm and these affiliates have adopted trade allocation policies to address this particular conflict of interest where it arises, as further discussed below in response to this Item 10. Relationship with Broker-Dealer Affiliates MetLife Investments Securities, LLC. The Firm’s affiliate, MetLife Investments Securities, LLC (“MISL”), is a FINRA registered broker-dealer. MISL is limited to providing marketing and distribution support related to the offering and selling of securities of certain private funds managed by the Firm to institutional clients. Certain of the Firm’s personnel are also registered representatives of MISL, however, they do not receive any sales commissions for these activities. PineBridge Securities LLC. The Firm’s affiliate, PineBridge Securities LLC is a FINRA registered broker-dealer. PineBridge Securities LLC serves as a placement agent for certain private investment funds sponsored and/or managed by the Firm and its affiliates. MetLife Investors Distribution Company. MetLife Investors Distribution Company (MLIDC) serves as the principal underwriter of MetLife, Inc.’s, variable contracts. The Firm provides investment advisory services on behalf of the US Insurance business whose products are sold by MLIDC. Relationship with Affiliated or Sponsored Investment Vehicles

Private Funds. The Firm serves as the investment adviser to multiple private funds and other pooled investment vehicles. Affiliates of the Firm serve as the general partner or manager to these funds. Mutual Funds. The Firm serves as investment adviser to mutual funds which the Firm sponsors. Collective Investment Trust Funds. The Firm serves as investment adviser to certain trust companies organized under the Pennsylvania Banking Code that are sponsored by the Firm. The Firm, its affiliates, and its employees could have an ownership interest in these affiliated or sponsored investment vehicles. Relationship with Commercial Mortgage Loan Originator MetLife Real Estate Lending, LLC (“MREL”), an affiliate of the Firm, can from time to time provide the Firm’s clients (including MetLife Accounts) with the opportunity to acquire participation interests in certain mortgage loans it originates. In addition, from time to time, the Firm, on behalf of the MetLife Accounts, could offer certain participation interests in loans originated by MREL to the Firm’s other clients on a secondary sale basis. The Firm will manage the loans that have been originated for MREL. The Firm will have responsibility to provide the participants with reports and other information summarizing the activity of these loans in exchange for a reporting and advisory fee. Conflicts of interests will exist where loan participation opportunities are appropriate for more than one participant from which differing fees are paid to the Firm. This presents a conflict of interest for the Firm as there are competing benefits it and its affiliates derive depending upon which participant is allocated a specific investment opportunity. As an SEC registered investment adviser, the Firm is committed to addressing conflicts of interest and in that regard has adopted policies and procedures designed to appropriately manage this conflict, including its allocation policy. Property Management Affiliates The Firm as the manager of each real estate equity joint venture receives an advisory fee (the “MIM Advisory Fee”) and generally selects a property management company to provide services with respect to each property owned by the venture. For certain properties, the Firm has selected (and is likely to select in the future) MIM Property Management, LLC (“MIM PM”), a wholly-owned subsidiary of the Firm. In such instances, the venture pays MIM PM a property management fee (the “MIM PM Fee”). MIM PM in turn typically delegates, and is expected in the future to delegate, some of its responsibilities to a third party property management company (each, a “sub-manager”) and pays the sub-manager a fee (the “Sub-Manager Fee”). Any MIM PM Fee in excess of the SubManager Fee is received by MIM PM and used to reduce the MIM Advisory Fee, otherwise payable by the clients in the venture, on a dollar-for-dollar basis. The Firm and its affiliates do not receive a financial benefit from this arrangement; however, the client benefits through a reduction in the MIM Advisory Fee. Though it has not happened to date and the Firm views it as an unlikely occurrence, should the balance of the MIM PM Fee (after paying the Sub-Manager Fee) exceed the MIM Advisory Fee so that it cannot be 100% used to offset the MIM Advisory Fee payable by the venture, any such excess would be paid to each of the clients in the venture on a pro rata basis. Neither the Firm nor MIM PM would be entitled under any circumstances to retain any portion of any excess or to benefit from any such amounts in excess of the MIM Advisory Fee. Lastly, because selecting its affiliate to perform these services raises a conflict of interest, the Firm either obtains the client’s consent to this activity with respect to each property or includes the right to engage in this arrangement in the joint venture agreement with the client. With respect to the Firm’s commingled core real estate equity fund, the Firm has retained an affiliated property management company (indirectly owned by the fund) to service one of the fund’s real estate properties (and may do so for future real estate properties). This affiliated property manager has engaged a third party property sub-manager and would expect to hire a third party property submanager for any future real estate properties of the fund for which it acts as property manager. Any fees paid to the affiliated property manager in excess of the fees paid to the third party property submanager inure to the benefit of the fund and its investors. Lastly, because selecting its affiliate to

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Personal Trading The Firm has implemented a Code of Ethics (the “Code”) pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The Firm holds its employees to a high standard of integrity and business practice and has an obligation to act in the best interest of its client. The Code establishes the principles, standards, roles and responsibilities for incorporating this commitment into the Firm’s practices globally and sets forth personal trading requirements and restrictions. A copy of the Firm’s Code of Ethics is available to any client or prospective client upon request. In addition to its Code of Ethics, the Firm:

Maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information (“MNPI”) by the Firm or any of its employees.

Has implemented information barrier policies and procedures to limit the receipt of MNPI to personnel who often have access to confidential information, such that the investment activities of the rest of the Firm are not otherwise restricted due to the imputation of such MNPI to the rest of the Firm (as described in further detail below).

Has implemented policies and procedures that prohibit favoring any MetLife Account over a third party client’s account (as described in further detail in response to Item 10 above).

Has adopted policies that prohibit asset transfers between client portfolios unless such transactions are executed in accordance with the requirements of the Advisers Act.

Has adopted policies and procedures reasonably designed to address potential conflicts of interest, including guidance relating to gifts and entertainment, political contributions, charitable contributions, and outside interests.

Receipt of MNPI and Information Barriers. In the ordinary course of business, the Firm and its affiliates receive MNPI under varying circumstances. As a result, the Firm has established policies and procedures that are designed to control the receipt of MNPI and appropriately manage related trading issues. These policies and procedures include information barriers between the Firm’s and its affiliates’ business units primarily investing in private asset sectors (collectively, “private asset classes”) and the Firm’s business units primarily investing in public asset sectors (collectively, “public asset classes”). The Firm relies upon these information barriers to ensure that the public asset classes are not exposed to the MNPI, protect the integrity of its investment process, comply with fiduciary duties and regulatory obligations, and mitigate potential conflicts. The Firm’s information barriers include, where appropriate, information system separation, physical separation of employees from different departments, and written policies and procedures. As a result of information barriers in place between the Firm’s and its affiliates’ public asset classes and private asset classes, the public asset classes will make investment decisions independently of the private asset classes. Notwithstanding the policies and procedures in place, conflicts of interest arise among and between the public asset classes and private asset classes of the Firm. In certain cases, the investment objectives and programs of the Firm’s public asset classes or its clients are similar to, or overlap with, the investment strategies and objectives of the firm’s private asset classes or its clients. The Firm’s public asset classes could invest in the same securities or issuers in which

a Firm’s private asset classes is invested. In addition, the Firm’s public asset classes and private asset classes could invest in a particular security or entity at substantially the same time. The information barrier could result in differences in price, terms and amount of leverage (if any), and associated transaction costs between investments. In addition, the Firm’s public asset classes likely will not dispose of such an investment at the same price or time as the Firm’s private asset classes. The Firm’s private asset classes could also make investments or engage in other activities that express views inconsistent with those of the Firm’s public asset classes, which could reduce the value of client investments managed by the Firm’s public asset classes. The Firm’s public asset classes could also invest in entities or assets in which the Firm’s private asset classes have an existing investment. Similarly, the Firm’s private asset classes could later invest in entities or assets in which the Firm’s public asset classes are invested, which could have an effect (either positive or negative) on the market prices. This would potentially result in the Firm’s private asset classes’ clients being senior to the Firm’s public asset classes’ clients in the capital structure of an issuer, which could mean that, in a workout or other distressed scenario, the interests of private asset classes clients will be different from and potentially adverse to public asset classes’ clients and the Firm’s private asset classes’ clients might recover all or part of the investment while public asset classes’ clients may not receive any recovery. The Firm’s private asset classes will not be required to take any action or withhold from taking any action to mitigate losses by public asset classes’ clients in such a scenario. In addition, the Firm’s private asset classes could seek to exercise creditor’s rights under the applicable loan agreement or other documents in a manner which could be detrimental to other investors, including the Firm’s public asset classes’ clients. The Firm maintains Restricted Lists for issuers about which the Firm, its affiliates, or its employees possess MNPI (or securities issuer confidential information) as well as Watch Lists for issuers about which a select group of employees have MNPI (or securities issuer confidential information), such as in connection with a confidential project or transaction. The Restricted Lists extend across MIM, meaning the Firm’s private asset classes and/or public asset classes can be restricted from transacting in issuers about which one of its affiliates’ public or private asset class teams, respectively, has received MNPI. The Restricted Lists and Watch Lists are maintained by the Firm’s Compliance department, which monitors firm level and personal investments against these lists. The Firm’s Restricted Lists and Watch Lists are aligned to the Firm’s information barriers, as described above. Personal Trading. The Firm’s Code governs the personal trading activities of our employees as well as their household members, dependents, and securities accounts over which they have discretionary control. Subject to certain limited exceptions, Access Persons (as defined in the Advisers Act and other applicable rules) are required by the Code to:

Report securities holdings, including annual certifications

Report securities transactions, including quarterly certifications

Pre-clear personal securities transactions

Maintain brokerage accounts only with certain approved brokers that report transaction information to the Firm’s Compliance department

Access persons are subject to additional restrictions under the Code, including but not limited to, blackout periods and holding period requirements. Principal Transactions. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. These transactions present conflicts of interest because the adviser is transacting directly with client accounts. The Firm effects principal transactions with clients in accordance with Rule 206(3)-2 under the Advisers Act and in accordance with the Firm’s policies and procedures on such transactions, which are reasonably designed to mitigate the conflicts of interest associated with such transactions.

Cross-Transactions. From time to time, the Firm will sell a security from a client account and purchase the same security in another client account through a so called “cross transaction” in accordance with the Firm’s procedures. The Firm could also purchase and sell a security between a client of the Firm and a client of an affiliate. The Firm will affect these cross transactions only if the Firm deems the transaction to be in the best interest of each participating client and is permitted by applicable client’s investment management agreement, other constituent fund documents and regulatory requirements. Cross transactions for an Investor subject to ERISA requirements are made in accordance with applicable Department of Labor requirements. The Firm seeks to assure that the price paid, or proceeds received by Investors in a cross transaction is fair and appropriate to both parties. Where a U.S. registered fund client participates in a cross transaction, the Firm will comply with procedures adopted pursuant to Rule 17a-7 under the Investment Company Act. An inherent conflict of interest often exists when engaging in these types of transactions.

MIM RE generally does not engage in transactions on behalf of clients that are required to be executed through a broker or dealer, although it can rely on real estate brokers in connection with the purchase, sale or financing of real estate investments. MIM RE evaluates the services and compensation of brokers on a transaction-by-transaction basis and seeks to select the broker who is best able to provide services at a reasonable rate of compensation. To the extent any of MIM’s other business units engage in transactions on behalf of clients that are required to be executed through a broker or dealer, the brokerage practices related to those activities are disclosed in the applicable Disclosure Brochure.

In certain instances, the Firm pay solicitors a referral fee for client introductions in accordance with regulatory requirements. Any referral fee is paid by the Firm does not result in any additional charge to the client. Solicitors will provide clients with a copy of the Firm’s written disclosure brochure which meets regulatory requirements and a copy of the solicitor’s disclosure statement containing the terms and conditions of the solicitation arrangement.

The Firm does not have disciplinary events that would require a response to this Item.

The Firm monitors account portfolios on an ongoing basis and conducts regular account reviews on at least a quarterly basis. Such reviews are conducted by investment professionals assigned to the Firm’s respective asset class. The Firm contacts ongoing advisory clients at least annually to review its separate account services and/or recommendations and to discuss the impact resulting from any changes in the client’s investment objectives. In addition to periodic reviews, the Firm performs reviews as it deems appropriate or otherwise required. Additional reviews of client accounts can be triggered by client request, compliance monitoring, industry factors, market developments, statutory and regulatory changes, and any issues identified with respect to a client account. Events that trigger reviews of client accounts are generally directed to the attention of portfolio management. The Firm provides clients with supplemental reports that can include such relevant account and/or market-related information. The content of those reports, as well as the frequency with which they are delivered by the Firm, are set forth in the applicable agreement between the Firm and the client.

As discussed in Item 13, the Firm prepares periodic supplemental reports. Any supplemental reports should be carefully reviewed and compared against statements received directly from the client’s account custodian to the extent the account contains the types of investments that would be held with a custodian. Other than as described below, the Firm does not generally accept custody of clients’ securities. To the extent the Firm has the authority to request a financial institution to debit its advisory fee from a client’s account and remit the fee directly to the Firm, the Firm ensures that it has written authorization from the client and that any such debit is done in accordance with applicable custody rules. For clients where the Firm is authorized to carry out certain actions on behalf of the client that could be deemed to constitute custody, the Firm has policies and procedures in place to comply with applicable custody rules. Surprise Examination Requirement. Where applicable, the Firm has contracted with an independent accountant to obtain a surprise examination of any assets over which it may be deemed to have custody (as required by applicable custody rules. In addition, these assets are maintained with a qualified custodian, and the Firm ensures it has a reasonable belief that the custodian is sending the client quarterly statements. Delivery of Audited Financial Statements. The Firm obtains and distributes US GAAP audited financials, as applicable, for pooled investment vehicles it manages to the funds’ investors within the required timeframe for each such vehicle to comply with applicable custody rules.

For certain client accounts, the Firm has the authority, without obtaining specific client consent, to determine any purchases and sales to be made within an account. This discretionary authority is, however, subject to the terms of the investment management agreement or offering documents, which can limit the scope of the Firm’s discretionary authority. In the case of loan participations, these investment opportunities are offered to each client on a non-discretionary basis and accordingly, each client must affirmatively consent to each investment.

MIM RE generally does not provide investment management services on the type of investments that generate proxies. However, MIM RE is typically granted voting authority in its advisory agreement with respect to all matters involving the property or loan, subject to any major approval rights the client may negotiate. In such instances, MIM RE will vote in the best interest of each client based on the individual facts and circumstances. In the case of loan participations, the client typically has no voting rights with respect to the management of the loan. To the extent that other areas of the Firm votes proxies on behalf of clients, it is disclosed in the applicable Disclosure Brochure. Clients can obtain a copy of the Proxy Policies and information regarding how the Firm voted securities held in their accounts, by contacting Israel Grafstein, Chief Compliance Officer of the Firm, at (973) 437-0869.

The Firm does not require or solicit fees of more than $1,200 per client, six months or more in advance. In addition, the Firm does not have any financial conditions reasonably likely to impair its ability to meet contractual commitments to clients. Lastly, the Firm has not been the subject of a bankruptcy petition in the past 10 years.