PPM America, Inc.

Principal Owners Founded in 1990, PPM America, Inc. (PPM) is a US-based institutional asset manager providing clients with investment solutions across markets, including public fixed income, private and structured credit, private equity, commercial real estate debt and collateralized loan obligations (“CLOs”). Initially providing investment solutions for affiliates, PPM has expanded both its client base and investment offerings over time. PPM’s first accounts were insurance mandates, and now include institutional offerings across separate accounts, commingled funds, private investment funds, and structured vehicles. PPM continues to support its clients’ expanding needs and seek superior investment results through a consistent investment philosophy rooted in fundamental, bottom-up research and prudent risk management. PPM is a direct subsidiary of PPM Holdings, Inc. and an indirect, wholly owned subsidiary of Jackson Financial Inc. (JFI), a publicly traded company (NYSE: JXN) and parent company of Jackson National Life Insurance Company (“Jackson”).

Types of Advisory Services PPM serves as the investment adviser to Jackson and as the primary U.S. institutional investment adviser for certain other affiliated insurance company accounts as well as JFI. PPM also acts as a sub-adviser to certain US mutual funds for which Jackson National Asset Management LLC serves as investment adviser. PPM also provides investment services to other institutional clients globally, which include non-US pooled investment vehicles, structured vehicles such as CLOs, private equity funds, and separately managed accounts. (See Items 7 and 10). Generally, PPM provides clients with investment advice across a range of investment strategies which include, but are not limited to:

Public Fixed Income

Core Fixed Income

Core Plus Fixed Income

Emerging Markets 

Diversified



Frontier



Investment Grade



Local Currency Supranational

High Yield

Intermediate Credit

Investment Grade CLO Debt

Investment Grade Credit

Investment Grade Credit Plus

Investment Grade Public and Private Credit

Liability Driven Investing

Private and Structured Credit

Investment Grade CMBS

Investment Grade Private Credit

Private Equity

Primary Funds

Co-Investments

Secondaries

Commercial Real Estate Debt

Core Debt

Core Plus Real Estate Debt

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Depending on the strategy, PPM provides advice on a wide variety of securities and instruments, including both investment grade and below investment grade. Many of the strategies are invested primarily in US dollar-denominated investments; however, the Emerging Markets strategies may include hard and local currency-denominated securities. Such security and instrument types include, but are not limited to:

Collateralized debt obligations

Collateralized loan obligation debt (“CLOs”)

Commercial mortgage loans (“CMLs”)

Commercial paper

Contingent convertible securities

Corporate debt (public and private bonds and securities)

Derivatives (including, but not limited to options, futures, options on futures, swaps (including single name and index), options on swaps, FX forwards, and other similar transactions)

Equity securities (including exchange-listed and over-the-counter, both US and foreign issuers and preferred stock)

Exchange traded funds (ETFs), money market funds and other collective vehicles

Municipal securities (taxable and tax-exempt)

Private equity investments (including debt and interests in partnerships or other entities)

Real estate investment trusts (“REITs”) (debt)

Sovereign and quasi-sovereign bonds

Structured securities and instruments (public and private)

Asset-backed finance

Lease-backed notes

Mortgage-backed (residential and commercial)

Project finance/infrastructure debt

Supranational bonds

Syndicated bank loans

US government securities (Treasuries and Agencies)

PPM also provides advice to clients regarding the workout or restructuring of troubled or defaulted investments. Information regarding the investment strategies and the instruments utilized in each strategy is included in Item 8 of this brochure entitled “Methods of Analysis, Investment Strategies and Risk of Loss.” PPM focuses primarily on investment management for its clients and generally does not provide other types of services to advisory clients (for example, investment accounting or custodial services). However, for certain clients PPM provides various support services, including portfolio valuation and performance analysis; commercial mortgage loan origination and servicing; marketing and distribution support; assistance with regulatory inquiries; and analysis of existing and proposed statutes and regulations governing certain investments. On a limited basis, PPM also provides services to third parties that are not advisory clients, including commercial mortgage loan origination and servicing, and facilitation of private equity co-investments.

Investment Restrictions PPM designs each of its investment strategies based on an investment objective and risk appetite, as described in more detail in Item 8. However, to meet the needs of our clients, PPM will work with clients to tailor a strategy to a client’s mandate, including specific investment guidelines and restrictions. Generally, all investment guidelines and restrictions are incorporated into each client’s investment advisory agreement or, in the case of pooled investment vehicles, a prospectus or other governing disclosure document. We seek to minimize performance dispersion among accounts within the same strategy and manage them as identically as practicable. Client-imposed investment guidelines or restrictions that vary from PPM’s established strategies may affect an account’s performance, which in turn, may result in performance that is better or worse relative to other client accounts in the same investment strategy with differing guidelines or restrictions. If a client requires guidelines that direct PPM to avoid investments based on common socially responsible investment themes (e.g., alcohol, tobacco or gambling) or other governmental imposed sanctions (e.g., Syria and Iran), and the client does not otherwise provide a specified list of restricted issuers or investments, PPM will use a third-party service provider to identify the universe of restricted 5 | PPM America, Inc.

securities. Absent a client providing specific direction on prohibited securities or issuers, PPM’s interpretation of the socially responsible restriction will control.

Wrap Fee Programs PPM does not currently provide portfolio management or other services in connection with wrap fee programs.

Class Actions In addition to investment advisory services, PPM may assist its clients with class action claim filings throughout the course of a client’s contractual relationship with PPM. In this regard, pursuant to an agreement with the client or other client direction, PPM will process class action claim filings on behalf of the client (with the cooperation and assistance of the client or its custodian), whereby PPM arranges (directly or through a service) for the filing and monitoring of such claims on behalf of the client. Absent client direction, PPM will have no obligation to recommend to a client whether the client should submit a claim, opt-in to a lawsuit, opt-out of a settlement or otherwise participate in litigation, and accordingly, the client and/or its custodian or other client agent would be responsible for handling such claims.

Assets Under Management As of December 31, 2025, PPM managed approximately $93,734,800,000 in assets under management (“AUM”)1 for its 46 clients. Of this amount, approximately $92,804,300,000 was managed for 39 clients on a discretionary basis and approximately $930,500,000 was managed for 7 clients on a non-discretionary basis.

Fee Schedules Client fees for separately managed accounts are generally computed based on a percentage of the market value, book value or principal amount of assets under management in a client’s account, as applicable and agreed. PPM may bill fees based on its own books and records, the client’s books and records, or the records of the client’s custodian. PPM values assets from independent pricing sources or, in the event that such independent valuations are unavailable, internally derives valuations based upon relevant security attributes and current market conditions, in accordance with its internal policies and procedures. PPM typically uses an average of assets under management for the billing period as the basis for fee calculation and pro-rates fees for partial billing periods, though PPM may use a different basis, as specifically agreed with certain clients. Pro rata adjustments in advisory fees may be made for material contributions and withdrawals made during the billing period. Fees for separately managed accounts may be subject to a minimum fee charge per annum and a minimum account size. Clients are responsible for verifying the accuracy of fee calculations. PPM also charges certain clients a performance fee. Additional information on performance-based fees is included in the section of this brochure entitled “Performance-Based Fees and Side-by-Side Management.” PPM’s standard fee schedule for separately managed accounts, which may be modified from time to time and is subject to negotiation, is as follows:

Public Fixed Income Strategy

Annual Fee (%)

Bank Loan First $100 million Next $150 million Thereafter Core Fixed Income First $100 million Next $150 million Thereafter Core Plus Fixed Income First $100 million Next $150 million Thereafter

Minimum Account Size

Minimum Fee

0.50% 0.45% 0.40%

$50 million

$250,000

0.225% 0.20% 0.175%

$50 million

$112,500

0.30% 0.25% 0.20%

$50 million

$150,000

AUM figures are rounded to the nearest $100,000. AUM includes committed but unfunded capital for PPM's private equity and commercial real estate businesses. Form ADV Part 1 includes disclosure of Regulatory Assets Under Management (“Regulatory AUM”) which differs from the traditional calculation. For example, Regulatory AUM includes uncalled commitments for private accounts outside the investment period that would normally be excluded from PPM’s assets under management disclosure. As of December 31, 2025, PPM’s Regulatory AUM was $93,793,600,000.

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Public Fixed Income (cont.) Strategy

Annual Fee (%)

Minimum Account Size

Emerging Markets Investment Grade First $100 million 0.30% Next $150 million 0.20% $50 million Thereafter 0.15% Emerging Markets Diversified First $100 million 0.45% Next $200 million 0.40% $50 million Thereafter 0.35% Emerging Markets Frontier First $100 million 0.80% Next $150 million 0.70% $50 million Thereafter 0.65% Emerging Markets Local Currency Supranational 0.50% First $100 million 0.45% $50 million Next $150 million 0.40% Thereafter High Yield First $100 million 0.45% Next $200 million 0.40% $50 million Thereafter 0.35% Intermediate Credit First $100 million 0.225% Next $200 million 0.20% $50 million Thereafter 0.175% Investment Grade CLO Debt First $100 million 0.30% Next $200 million 0.20% $50 million Thereafter 0.15% Investment Grade Credit First $100 million 0.225% Next $150 million 0.20% $50 million Thereafter 0.175% Investment Grade Credit Plus First $100 million 0.30% Next $150 million 0.25% $50 million Thereafter 0.20% Investment Grade Public and Private Credit First $100 million 0.25% Next $150 million 0.20% $75 million Thereafter 0.175% Liability Driven Investing (LDI) First $250 million 0.25% Next $150 million 0.20% $50 million Thereafter 0.185%

Minimum Fee

$150,000

$225,000

$400,000

$250,000

$225,000

$112,500

$150,000

$112,500

$150,000

$187,500

$125,000

Structured and Private Credit Strategy

Annual Fee (%)

Investment Grade CMBS First $100 million 0.25% Next $150 million 0.20% Thereafter 0.175% Investment Grade Private Credit First $100 million 0.25% Next $150 million 0.20% Thereafter 0.175%

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Minimum Account Size

Minimum Fee

$50 million

$125,000

$50 million

$125,000

Commercial Real Estate Debt Strategy

Annual Fee (%)

Core Real Estate Debt First $250 million Next $250 million Thereafter Core Plus Real Estate Debt First $250 million Next $250 million Thereafter

Minimum Account Size

Minimum Fee

0.35% 0.30% 0.25%

$100 million

$350,000

1.00% 0.90% 0.80%

$100 million

$1 million

As of the date of this brochure, PPM has not established standard fee rates for Private Equity accounts. Fee rates and minimums are negotiable based on circumstances believed by PPM to be relevant, such as affiliation or other relationships with PPM or its affiliates, asset class, investment strategy, size or future growth potential, and other considerations. Standard fee rates for custom strategies or separate account strategies not listed above have not been established as of the date of this brochure, and typically reflect an asset based fee specifically negotiated with each client. Any performance-based fee charged by PPM will comply with the requirements of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), including, when applicable, Rule 205-3 thereunder. Please see additional information in response to Item 6 below. As noted under “Types of Advisory Services,” in Item 4 above, from time to time, PPM will invest client assets in pooled investment vehicles that are managed by other managers, either affiliated or unaffiliated, in accordance with established investment guidelines. In such instances, the client will normally pay management and performance fees to the pool’s manager. Unless required by applicable law or pursuant to the terms of the specific agreement with the client, PPM typically does not reduce or offset its fees with the fees paid to the managers or advisers of these pooled products. PPM also provides discretionary investment management services to pooled vehicles, including, without limitation, mutual funds, private funds, and non-US funds. PPM receives fees for such services that are disclosed in a fund’s prospectus or other governing documents. In addition to receiving management fees on commercial real estate debt strategies, PPM also provides loan origination and servicing to third parties that are not advisory clients and receives other fees related to commercial mortgage lending activities, such as origination fees, loan servicing fees, inspection fees, exit/extension fees, property management fees, or other administrative fees. These fees are intended to compensate PPM for the costs and expenses for due diligence, credit analysis, servicing activities and other miscellaneous costs incurred in connection with closing and servicing commercial real estate loans. Any such fees will be described in the client’s investment management agreement and/or other client agreements, including loan participation agreements. PPM also receives a fee for its services in the selection and oversight of third-party investment managers that manage a portion of Jackson’s investment portfolio.

Deduction of Fees PPM’s fees are computed and billed on an annual, semi-annual, quarterly or monthly basis and are due from clients upon receipt of the billing statement. Fees are generally paid in arrears. Fees are not typically deducted directly from a client’s account, but may be deducted pursuant to a client’s written request. Other payment arrangements may be agreed upon and set forth in an agreement between PPM and the client.

Other Fees and Expenses Unless otherwise agreed, PPM is not obligated to pay any expenses of a client (or any other investment adviser to the client), including without limitation, expenses of employing lawyers or consultants in connection with the evaluation or restructuring of any investment, interest, and taxes. Where PPM advances payment on behalf of clients for such investment-related fees and expenses of clients, it is entitled to repayment of such advances, subject to the terms of a client’s investment management agreement. Clients will directly bear the costs associated with custodians and other service providers to their separately managed account, as well as brokerage and other transaction costs associated with trading in the client account. Additionally, PPM may seek reimbursement for expenses associated with the use of a customized index in connection with the management of any client account. Investors in mutual funds or other pooled investment vehicles will also bear other fees relating to the pooled investment vehicle as disclosed in the respective prospectus (or other governing document); see “Brokerage Practices” in Item 12 below.. Clients that invest in CMLs may also incur additional expenses, including but not limited to costs associated with the following: pursuit costs, origination fees, loan servicing fees, loan documentation fees, and other ongoing fees paid directly by the client to administer its holdings, such as legal fees, tax preparation fees and fees of other administrative service providers.

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Prepaid Fees As noted in “Deduction of Fees” above, fees due to PPM are generally paid in arrears following receipt of an applicable billing statement. Private equity fund fees are paid quarterly in advance and rebated on a pro-rata basis in the event that the private equity fund is terminated before the end of a billing cycle.

Compensation for the Sale of Securities PPM is not compensated separately for securities transactions or other types of services which might present a conflict. PPM does not buy or sell investment products for client accounts through affiliated brokers or agents and does not receive commissions or other compensation for the sale of investment products recommended to clients. Also, PPM does not charge commissions or markups on the purchase or sale of investment products.

General Description PPM aims to deliver consistent results that our clients can depend on to meet their risk and return expectations. We seek to uncover and identify investment opportunities through a methodical relative value framework where alpha generation is grounded in fundamental bottom-up research. Every contribution to our disciplined investment process is designed to deliver dependable alpha sources per unit of risk for our clients.

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Our collaborative culture is a foundational element of our investment process. It begins with listening to our clients to understand the commitments and constraints critical to their success. Collaboration also drives our investment process which leverages the contributions and continuity of skilled and long-tenured career analysts, portfolio managers and traders. PPM uses a variety of methods of analysis in formulating investment advice and/or managing client assets. Our portfolio management teams are organized by asset class including fixed income, private and structured credit, commercial real estate, and private equity. With inputs from experienced credit research, portfolio management and trading teams, our process is designed to drive long-term outperformance. Security selection begins with idea generation and is further supported with market perspective and risk compensation to identify the best value opportunities for our clients. Contribution to idea generation and relative valuation is grounded in each team’s respective area with measured risks across multiple dimensions. Cross-team collaboration, communication and support are ingrained throughout the process to ensure that in all market environments, we deliver repeatable results that are consistent with each of our client’s goals. The portfolio management teams are supported by shared resources across the organization including credit research, private and structured credit, debt restructuring, trading, risk management, and quantitative research. Risk management is interwoven throughout our investment process to ensure clients are appropriately compensated for portfolio risk. Our independent risk management infrastructure works in collaboration with investment teams to ensure clients’ risk tolerances are well understood and aligned to investment objectives. Additional functional areas within the firm also support the investment process including: operations, administration, investment performance analysis, information technology, and legal and compliance, among others. The experience and continuity of our investment team and our collaborative culture fosters a highly disciplined investment process designed to deliver consistent results our clients can depend on, as more fully described below. Fixed Income and Private and Structured Credit Research Process The cornerstone of our fixed income investment process is rigorous credit research and real-time dialogue. Our team of experienced analysts perform a robust, independent analysis of eligible credits, using both quantitative and qualitative measures to generate internal ratings and relative value recommendations. Organized by industry, our analysts drive and enrich idea generation through their intimate knowledge of their coverage industries and issuers within them. Internal Rating The first step in our research process is the assignment of an internal rating, which represents an analyst’s independent view of the inherent risk of investing in a respective issuer. Internal ratings are derived from an independent and rigorous analysis of various qualitative and quantitative risk factors by our experienced research team whose intimate knowledge of the industries and companies they cover equip them to discern what are the most relevant risk factors. Most significantly, our knowledge of each company which is driven by our analysts specializing by industry, position us to better judge the strength of each management team’s commitment to defending their credit quality. We are extremely diligent in regularly meeting with management teams in order to understand the trajectory of their business and any evolution in their risk appetite. We sometimes supplement our analysis by reviewing other third-party sources of information including rating agency reports and dialogue, sell side fixed income and equity research, and industry and company specific news reports. >

Qualitative Inputs:

Our internal rating process places significant emphasis on a management team’s credit quality targets and commitment to achieve or defend those targets, especially in times of stress. Numerous qualitative inputs are considered, including an assessment of the level of competition in each industry, longer-term secular risk, financial policy and consistency of ratings over cycles. Analysts also consider the stability of the management team and compensation structures. Intimate issuer knowledge is gained through our ‘in the field” research. Analysts regularly seek opportunities for in-person discussions with company leadership, join investor phone calls, and attend conferences. On average, in the field research accounts for approximately 40-50% of our total research, with each analyst meeting with approximately 30-40 companies per annum. >

Quantitative Inputs:

In addition to assessing qualitative factors, internal ratings also include detailed financial modeling of each issuer including an analysis of: 1. 2. 3. 4. 10 | PPM America, Inc.

Revenue cyclicality Recurring cash flows Cash flow volatility; and Balance sheet quality

Inputs are incorporated into a research model to generate an internal rating that encapsulates the analyst’s view of the issuer’s inherent credit risk. While the rating agencies’ opinion is taken into account in the analysis, internal ratings often differ from those of rating agencies. Our process is intentionally designed to encourage our analysts to anticipate and identify rating agency events to create value opportunities for clients. For structured credits, the research process utilizes the same qualitative and quantitative inputs; however, an internal rating is not assigned. Relative Value Recommendation Upon assigning an internal rating, or for structured credits, upon completion of the quantitative and qualitative assessment, analysts also provide a relative value recommendation reflecting their view on whether the issue is overvalued, undervalued or meets their estimate of fundamental value. Analysts formulate their views based on some expectation about how a company will perform in the future following a comparison of current spread levels to the internal rating, or external rating for structured credits, as well as spread levels across the broader sector and of other similar credits. Relative value recommendations are supported with analyst commentary. Many factors influence an analyst’s view, including, among others, conversations with management teams, the economic backdrop, and trends affecting a specific industry or company. Importantly, our investment process does not rely on broad macroeconomic forecasts. In our effort to deliver repeatable results in all market environments; our analysts spend a significant amount of time modeling downside sensitivity scenarios to assess how a company will perform in stress situations. Portfolio Construction Process PPM implements its investment strategies consistent with the investment objectives, guidelines and restrictions of its clients (the “Investment Guidelines”). On an ongoing basis, investments are made by portfolio managers based upon and subject to the Investment Guidelines. The Investment Guidelines stipulate the allowable types of investments and permissible ratings, concentrations and restrictions. Where applicable, and possible, PPM codes the Investment Guidelines into its automated compliance guideline monitoring system, and reviews exceptions on a pre and post trade basis. Information sources Our credit analysts’ research and recommendations form the most important inputs into our security selection process. The portfolio management team also filters market information through daily consultation with credit analysts and traders to identify the best relative value opportunities within the eligible investment universe. We believe our collaborative process is a foundational element to generating the best investment results and allows us to identify dependable alpha sources per unit of risk across all market environments. Security selection Security selection begins with considering our client’s risk and return expectations. Portfolio managers carefully consider historical topdown asset class perspective as they collaborate with credit analysts and traders to discuss new opportunities, the macroeconomic environment and relative value across the fixed income universe. As portfolio managers review potential value opportunities across industries and issuers, they consult in-depth bottom-up research from our analyst recommendations, further enhanced with contributions from asset class specialization coverage, as well as output from sophisticated quantitative tools to assess an investment’s impact on the portfolio’s overall risk profile. Daily consultation with traders provides valued market intelligence regarding sectors and companies, and whether investment ideas are executable. Portfolio managers rigorously examine and discuss any assumptions, conclusions and opinions prior to making any investment decision. Buy discipline Our investment approach is built upon identifying dependable alpha sources that deliver repeatable results in all market environments. Our disciplined and transparent investment process is focused on the risk-return relationship of each position. We seek to overweight asset classes, sectors and securities that are considered to have superior relative value versus other comparable opportunities. We do not avoid risk; instead, we consider the risk of an individual position relative to the rest of the portfolio. Our dispassionate approach leverages forward and backward-looking metrics and monitors implicit correlations to avoid unintended over/underweights to any industry or asset class. Sell discipline We do not have an automatic sell trigger. Through our collaborative, disciplined and repeatable investment process, credit analysts, portfolio managers and traders monitor relative value on an ongoing basis. Our portfolio managers continuously focus on the risk-return relationship of each position relative to the rest of the portfolio when making decisions to either trim or eliminate a position. We will sell out of a position when its price exceeds our estimate of fundamental value, given its history and trading levels on comparable companies. We are typically quick to sell when the fundamental value basis and original investment thesis have changed. Our sell decisions can also be induced by credit concerns. Our process continuously monitors the risk-return relationship of each position. Often, when credits begin to deteriorate, the risk return dynamics change with the downside increasing exponentially. Organized by industry, our credit analysts provide continuous coverage of individual credits across the credit spectrum and capital structure to identify 11 | PPM America, Inc.

potential rating migration. With real-time access to credit analyst views and frequent dialogue between research, portfolio management and trading, our team is positioned to identify deteriorating credit situations and to act quickly when they arise. Holding period Our holding periods are valuation driven. Each strategy typically has a general timeframe to implement long-term sector strategies. However, we also utilize tactical strategies based on short-term market dislocations. We marry our analysts’ long‐term fundamental outlooks with tactical execution focused on our value estimates. This may lead us to sell positions with strong credit outlooks that trade through our value estimates and buy positions with weak fundamentals that trade cheap relative to our estimate of fundamental value. Our disciplined and repeatable investment process has been a significant contributor to the consistency of our results. Trade Execution Portfolio managers communicate their investment decisions to our fixed income trading team for execution. Our traders are not simply order takers. Acting as an extension of the portfolio management team in the market, our experienced trading team is organized by industry, providing continuous market intelligence and effective coverage for crossover credits. The team seeks to execute trades efficiently and effectively utilizing deep market relationships and trading platforms. Use of Derivatives Certain fixed income strategies may use derivatives from time to time to manage duration and yield curve risk, as well as for efficient cash management purposes. Use of derivatives is subject to Investment Guidelines Private Equity Primary funds strategy Sourcing Sourcing for primary funds is conducted primarily through the following channels:

Industry contacts Other limited partners Independent research Intermediaries Placement agents

Preliminary screening and fitness test Upon identification of a potential primary fund investment opportunity, the private equity team forms a new deal team, purposefully structured to align the team members’ asset class expertise and relationship strength with the respective sponsor. This alignment allows PPM to act with speed and efficiency throughout the diligence, documentation, and closing process. The deal team holds an introductory call with the sponsor to learn about the primary fund opportunity and gather initial diligence materials. The deal team then conducts an initial screen (the “Preliminary Screen”) in which the following factors are considered:

Merits of fund’s management team Fund specialty Performance Partner value-add Fund terms Dollar investment proposal

Read the rest in the brochure

PPM is the primary US institutional asset manager for Jackson and also provides investment management services to insurance companies, investment companies, investment advisers, pooled vehicles, pension and profit-sharing plans, trustees of collective investment trusts, family offices, and high net worth individuals. PPM also serves as investment adviser to private investment funds in which certain affiliates and employees of PPM are investors. See Item 10 below. Please see “Fee Schedules” in Item 5 above regarding minimum investment requirements.

As noted under “Fee Schedules” in Item 5 above, PPM charges certain clients a performance-based fee. The amount of a performancebased fee can vary depending on the performance of the applicable fund or account relative to a particular target or benchmark return. For private equity funds, a portion of each fund’s net investment profit in excess of a preferred return hurdle is allocated to the capital of its general partner (GP) or special limited partner (SLP) as “carried interest.” Each GP/SLP is a related person of PPM, and certain private equity team members maintain ownership interests in the GP/SLP entities. While performance-based fees are intended to reward PPM for successful management of a client portfolio, they create an incentive for PPM to take additional risks in the management of the portfolio. PPM often manages multiple accounts with similar investment strategies. If some of these accounts are charged performance-based fees, versus a flat fee or an asset-based fee, this creates a conflict of interest as a portfolio manager may have an incentive to allocate attractive or limited investments to the accounts that are charged performance fees. A portfolio manager may also have an incentive to favor the performance-based fee accounts with respect to trade timing and/or execution price. In addition, there may be other instances where there are different incentives for PPM to implement an investment in one account over another. Certain investments, such as new issuances, may be desired for more than one account or strategy and availability may be limited. In these instances, certain accounts may be excluded from or may not be able to fully participate in the investment opportunity. A portfolio manager may have an incentive to devote more time or resources to, or to implement investment ideas in, one account over another, such as when a new account is being established. Potential conflicts may also arise when different clients invest in different parts of an issuer’s capital structure, such as when a client owns senior debt obligations of an issuer and other clients own junior tranches or equity securities of the same issuer. In such circumstances, decisions over whether to trigger an event of default, over the terms of any workout, or how to exit an investment may result in conflicts of interest. In order to minimize such conflicts, PPM may avoid certain investment opportunities and negotiations with issuers that would potentially give rise to conflicts among its clients, or PPM may enact internal procedures designed to minimize such conflicts, which could have the effect of limiting certain clients’ investment opportunities. PPM has designed and implemented procedures that seek to ensure that all clients are treated fairly and equitably, and to prevent these conflicts from influencing the allocation of investment opportunities among clients.

This brochure discusses only those functions performed by PPM on behalf of its clients and does not discuss the activities of other affiliated entities or related persons on behalf of their respective clients, except to the extent such activities are conducted in connection with the investment advisory activities of PPM. Additional information relating to these related persons of PPM is included on Schedule D to Part 1 of PPM’s Form ADV and, to the extent applicable, in the Form ADV for such affiliated entities or related persons. As of December 31, 2025, eight of PPM’s associated persons are registered representatives of Foreside Financial Services, LLC, a FINRA registered broker/dealer. As of December 31, 2025, none of PPM’s management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. PPM meets the definition of a “commodity trading adviser” pursuant to Section 1a(12) of the Commodity Exchange Act but is exempt from registration with the Commodities Futures Trading Commission (“CFTC”) pursuant to CFTC Regulation 4.14(a)(8). As discussed in response to Item 7 above, PPM is the primary US investment manager for the general insurance account of JFI’s subsidiary insurance companies, including Jackson.

JFI/Jackson

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PPM serves as investment adviser to insurance company subsidiaries of JFI and other related entities, including Jackson, Jackson National Life Insurance Company of New York, Brooke Life Reinsurance Company and Hickory Brooke Reinsurance Company. PPM also executes trades on a non-discretionary basis to facilitate certain corporate hedging activities of Jackson and its insurance subsidiaries. On February 11, 2026, Jackson announced the formation of a strategic partnership with TPG, Inc, a leading global alternative asset management firm. As part of the transaction, Jackson and TPG entered into a non-exclusive investment management agreement pursuant to which TPG provides Jackson Investment Grade Asset Based Finance and Direct Lending investment capabilities to complement the asset management capabilities of PPM. PPM assists Jackson in the oversight of the assets TPG manages for Jackson.

JNAM PPM also serves as investment sub-adviser to certain mutual funds sponsored and advised by JNAM. JNAM is a wholly owned subsidiary of Jackson and an affiliate of PPM.

CLOs PPM Loan Management Company 2, LLC (“PPMLM2”), a Delaware series limited liability company, is an affiliate of PPM. PPMLM2 is a registered investment adviser. PPMLM2 was formed to serve as the collateral manager for CLO transactions sponsored by PPMLM2 or PPM and to act as “originator” and retention holder under the EU/UK risk retention requirements, where applicable. PPMLM2’s Management and Originator Series is 100% owned by PPM. PPMLM2 may from time to time establish one or more Retention Series which will be 100% owned by Jackson or its affiliates. PPM has entered into a services and employee sharing agreement with PPMLM2 to provide advisory and support services to PPMLM2, pursuant to which certain employees of PPM serve as dual employees of both PPM and PPMLM2. These employees remain subject to the same PPM policies and procedures that are designed to address conflicts and ensure that PPM acts in the best interests of its clients. PPM supports the day-to-day management of PPMLM2’s CLO strategy and advises PPMLM2 with regard to all or substantially all of its investment and other activities.

Selection of Other Investment Advisers In limited circumstances, PPM retains an unaffiliated investment adviser to sub-advise a portion of an affiliated client’s private investment portfolio. PPM does not receive compensation from the sub-advisers as part of this arrangement. PPM selects private investment funds for its private equity and commercial real estate clients in the secondary market and through primary commitments. PPM does not, however, receive compensation from the advisers of such private investment funds for such investments.

Affiliations and Conflicts of Interest PPM is committed to providing clients with service of the highest quality and seeks to act in the best interests of its clients. Nevertheless, there are circumstances where client interests conflict with PPM’s interests, the interests of its affiliates, or the interests of other unaffiliated clients. The management of multiple funds and separately managed accounts gives rise to potential and actual conflicts of interest. Some of these conflicts of interest are inherent to PPM’s business and are encountered by other large financial services firms that offer similar services. PPM has policies and procedures that are designed to address conflicts and that seek to ensure that PPM acts in the best interests of its clients; however, there is no guarantee that such procedures will detect each and every situation in which a conflict arises. PPM has established a designated management led conflicts committee and a special conflicts committee of PPM’s Board of Directors to consider and resolve material conflicts related matters on an as needed basis. PPM provides advice to a number of clients, including affiliated entities. PPM may take actions for clients that differ from recommendations or actions taken for other clients. Portfolio managers must divide their time and investment ideas across multiple funds and separately managed accounts. Portfolio managers generally focus on a particular investment discipline; therefore, similarly managed funds or separately managed accounts are in most cases managed using the same or substantially similar investment strategies. However, securities selected for any fund or separately managed account may outperform securities selected for similarly managed separately managed accounts or funds. PPM is not obligated to recommend to any or all clients any investments that it may recommend to, or purchase or sell for, other clients, including affiliated clients. Client accounts at times will invest in the same instruments in which other clients affiliated with PPM invest, which could create conflicts, particularly where investment opportunities in securities or markets are limited or where the liquidity of certain instruments is limited. The allocation of investment opportunities raises conflicts of interest, as PPM could have an incentive to provide favorable treatment to certain accounts, including those of clients affiliated with PPM. As discussed in Item 12, PPM seeks to manage allocation conflicts through the adoption of procedures intended to provide a fair and equitable allocation of buy and sell opportunities among all client accounts over time, considering the facts and circumstances of each transaction. However, the application of PPM’s allocation procedures could result in large, affiliated accounts receiving larger allocations of investments than other smaller accounts. As discussed in Item 6, Performance-Based Fees and Side-By-Side Management, conflicts of interest are also inherent in PPM’s use of multiple strategies. For example, conflicts may arise when different clients, including affiliated clients invest in different parts of an issuer’s 29 | PPM America, Inc.

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Code of Ethics PPM has adopted a written Code of Ethics (“Code”), that, among other things, sets forth standards of conduct expected of PPM’s employees, officers, directors and certain affiliated employees (collectively, “access persons”), addresses conflicts that arise from personal trading, and emphasizes PPM’s fiduciary obligation to put client interests first. The Code is designed to detect and prevent personal conduct that might create an actual or potential conflict of interest with a client. Under the Code, certain personal securities transactions of access persons are prohibited, while others are subject to pre-approval and/or reporting requirements. The Code’s restrictions on personal trading apply to any account over which an access person and certain immediate family members have investment discretion or a beneficial interest. Employees are required to pre-clear most personal securities transactions prior to execution, except as specifically exempted under the Code. Participation in Initial Public Offerings (“IPOs”) is prohibited, and all private placement transactions must be pre-approved by the Chief Compliance Officer. The Code also requires that securities requiring preclearance must be held for a minimum of 30 calendar days after purchase and may not be repurchased for a minimum of 30 calendar days following a sale. Subject to satisfying the Code and applicable laws, PPM access persons may trade for their own accounts in securities that are held in client accounts; however, the Code imposes a “blackout” period whereby employee trading in a security may be prohibited if PPM is transacting in that security for its clients. Exceptions to the Code’s personal trading restrictions are considered on a case-by-case basis and are granted only when PPM’s Compliance Department determines the potential for conflict or harm does not exist or is insignificant. All access persons are required to provide quarterly reports of their securities transactions to PPM Compliance (in the form of confirmations and statements) and to certify that all personal securities transactions have been reported. On an annual basis, access persons are required to confirm they have reported all accounts which can be used to purchase or sell securities. PPM’s Compliance Department reviews each access person’s transactions, confirmations, and other account documentation to look for indications of improper personal transactions. PPM will provide a copy of its Code to any client or prospective client upon request.

Gifts and Business Entertainment PPM has adopted Gift and Business Entertainment Policies and Procedures for PPM employees that places restrictions on receiving and providing gifts and business entertainment, imposes reporting requirements, and requires pre-approval to participate in business entertainment, except as specifically exempted under the Gift and Business Entertainment Policies and Procedures. PPM employees may not give or accept any gift, favor, gratuity or invitation from parties with whom PPM has a business relationship that creates a conflict between the employee’s personal financial interests and the interests of PPM’s clients.

Participation or Interest in Client Transactions PPM does not buy or sell securities to or from client accounts on a principal basis except as permitted by law and in accordance with its compliance procedures. Further, certain employees or PPM affiliates own interests in affiliated entities which are also owned by PPM clients, where such employees and affiliates are entitled to an allocation of such entities’ gains in excess of a preferred return (see Items 6 and 7 above). To the extent permitted by applicable law, client guidelines and restrictions, and in accordance with its compliance procedures, PPM also at times will effect “cross” transactions between client accounts. In these cases, one client will purchase a security held by another client. Neither PPM nor any related party receives any compensation in connection with a “cross” transaction. PPM effects these transactions pursuant to internal procedures and only when it deems the transaction to be in the best interests of each of the buying and selling clients and at prices that PPM has determined reflect fair value. PPM in many instances purchases and sells, pursuant to its discretionary authority, the same securities for the accounts of related and unrelated persons. In those instances, PPM has internal procedures in place to allocate those securities on a fair and equitable basis over time. PPM may purchase privately placed instruments on behalf of its clients, which may include nvolving corporate debt, asset-backed finance instruments, leveraged leases, high yield debt, and private equity. PPM may purchase for a client account different classes of debt of the same issuer, debt and equity of the same issuer for different accounts, and securities of issuers also held by one or more affiliates of PPM. Such investments may be deemed to create conflicts of interest. For example, in the event of a bankruptcy or workout, the terms, standing and security of investments by PPM’s affiliates may be deemed to be more advantageous than those received by unaffiliated accounts. PPM generally addresses this conflict through disclosure in the offering documents or investment advisory agreement for such clients and in this brochure. Similarly, PPM may take certain actions for some clients, including affiliated clients, that may have an adverse effect on other clients. This may mean, for example, that if PPM is on a creditor’s committee and/or enters into a restructuring transaction support agreement in

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the case of a distressed investment and learns of material non-public information, it may be precluded from acting for other clients holding securities of the same or another affected issuer. PPM maintains Policies and Procedures Regarding Material Non-Public Information and Information Barriers that establish barriers around certain internal groups which might be in possession or aware of material non-public information. The policy is designed to block the flow and potential misuse of that information. In addition, PPM has adopted other policies and procedures designed to minimize potential conflicts of interest of this nature and to address such conflicts in a manner which is most equitable to all clients.

Participation or Interest in Personal Trading – Client Recommendations and Client Trading PPM employees regularly share information, perceptions, advice and recommendations about market trends, the valuations of individual securities, and investment strategies, except where prohibited by information barriers established by PPM or by applicable law or regulation. Persons associated with PPM and portfolio managers may themselves have investments in securities that are recommended to clients or held in client accounts. A portfolio manager’s management of personal accounts may give rise to potential conflicts of interest, including conflicts of interest related to the knowledge and timing and potential market impact of trades placed on behalf of clients, as well as current or potential investment opportunities under consideration. As noted under “Code of Ethics” above, PPM has adopted a Code, as well as other policies and procedures, which seek to address potential conflicts involving personal trading by PPM’s access persons. Subject to compliance with such policies and procedures, PPM’s access persons may invest in the same or related securities that are purchased for client accounts. However, the Code imposes limits on such transactions, including generally prohibiting transactions within a blackout period before and after PPM transacts in such securities on behalf of a client. Further, the Code prohibits access persons from purchasing or selling any security where the access person has access to material non-public information relating to the security or the issuer of the security. PPM and its employees, including its portfolio managers, may have material interests in certain accounts PPM manages, including private equity funds. A PPM employee’s interest may be a direct ownership interest in a fund or account. The interests of PPM and its employees in these funds or accounts may present a conflict of interest for PPM and its employees in allocating investment opportunities among such funds or accounts and other client accounts.

Broker Dealer Selection PPM primarily provides investment advice to its advisory clients on a discretionary, and to a lesser extent on a non-discretionary basis. When granted the authority to do so, PPM typically determines which securities are bought and sold, the amount of securities bought and sold, and which broker or dealer (collectively, “Broker Dealer”) will effect such transactions. and, where applicable, the commission rates at which the transactions will be effected. PPM maintains lists of Broker Dealers, futures commission merchants and derivatives and repurchase agreement counterparties that have been reviewed and approved pursuant to its Best Execution Policies and Procedures. Traders generally have discretion to effect transactions with any Broker Dealer on the approved lists. With respect to non-discretionary accounts, PPM may recommend securities trades, but the client must instruct PPM to effect a trade and PPM will not presume a client’s consent to a trade from the client’s silence. PPM seeks to obtain best execution for client transactions with Broker Dealers, that is, to obtain not necessarily the best price, but the best overall qualitative execution under the circumstances. Factors that influence the way PPM selects Broker Dealers for trade execution include but are not limited to the:

Quality of trade execution, including the accuracy and timely execution of trades, clearance and cooperation by the Broker Dealer in resolving errors and disputes;

Reputation, financial strength, reliability, and creditworthiness of the Broker Dealer;

Broker Dealer’s block trading and positioning capabilities;

Willingness of the Broker Dealer to execute difficult transactions;

Willingness of the Broker Dealer to execute a transaction in combination with another transaction or transactions which, in aggregate, provide net benefit to PPM’s client

Willingness and ability of the Broker Dealer to commit capital

Access provided by the Broker Dealer to PPM and its clients to underwritten offerings, including new issues of fixed income securities

Overall costs of trades placed, that is, the net price paid or proceeds received, including commissions, mark-ups, mark-downs, spreads, other transaction costs, and opportunity costs in the context of PPM’s knowledge of negotiated commission rates currently available

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Nature of the security being traded

Size of the transaction

Desired timing of the trade

Existing and anticipated activity in the market for the security

Confidentiality considerations

Research, products, and other services provided for the benefit of PPM and its clients

PPM’s knowledge of actual or apparent operational problems of any broker-dealer considered

PPM will determine the overall reasonableness of the brokerage commissions and other transaction costs on client transactions by considering various factors, including, but not limited to, the following:

Current market conditions

Size and timing of the order

Depth of the market

Per share price

Difficulty of execution

Time taken to conclude the transaction

Extent of the Broker Dealer’s commitment, if any, of its own capital

Amount involved in the transaction

Research and Other Soft Dollar Benefits While PPM selects Broker Dealers primarily on the basis of their execution capabilities, PPM may cause a client to pay a commission to Broker Dealers for effecting a transaction for that client in excess of the amount another broker or dealer would have charged for effecting that transaction, in exchange for certain research and brokerage services. Although the use of client brokerage commissions to obtain research or other products or services inherently benefits PPM because we do not have to produce or pay for the research, products, or services, this is only done when we have determined in good faith that the commission is reasonable in relation to the value of the execution, brokerage and/or research services (“Soft Dollar Benefits”) provided by the broker. Our arrangements for the receipt of research services from Broker Dealers create conflicts of interests, in that we have an incentive to choose a broker or dealer that provides research services, instead of one that charges a lower commission rate but does not provide any research. Soft Dollar Benefits provided to our firm by brokers are reviewed to ensure that they meet the standards of Section 28(e) of the Securities Exchange Act of 1934, as amended. PPM periodically reviews the general level of brokerage allocated to various firms and the services provided by such Broker Dealers. PPM may pay more than the lowest available commission rate in accordance with the “safe harbor” provision of Section 28(e) of the Securities Exchange Act of 1934 in its selection of brokers as noted above; however, PPM typically does not enter into contractual arrangements for the receipt of research or other services to be paid with soft dollar transactions. The use of soft dollars to receive research and services benefits PPM by allowing PPM, at no cost to it, to: i.

Supplement and enhance its own research and analysis activities

ii.

Receive the views and information of individuals and research staff of other securities firms, and

iii.

Gain access to persons having special expertise on certain companies, industries, areas of the economy and market factors.

PPM does not allocate the relative costs or benefits of research received from brokers or dealers among particular clients because we believe that the research received, in the aggregate, assists us in fulfilling our overall responsibilities to our clients. The research may be used in connection with the management of accounts other than those whose commissions paid for the research. Research services paid for with client commissions can include:

Research reports

Specialized financial and industry publications and research compilations

Quantitative, economic, international, and market strategy services

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Compilations of securities prices

Dividends and similar data bases

Market data

Professional seminars

The services of certain economic or financial consultants

Brokerage services received may include access to electronic trading platforms, access to traders with greater familiarity with company trading and market makers, and assistance in effecting securities or performance of other functions incidental to the transaction (such as clearance or settlement). These and other types of brokerage services may be originated by the Broker Dealer performing execution services or by third parties that are paid by the Broker Dealer. For fixed income, currency, and derivative transactions, counterparties do not provide the firm with third party research services. We believe that any proprietary research provided by fixed income, currency, and derivative counterparties is incidental to their execution services. In an effort to achieve best execution for large client cash flows, PPM and/or PPMLM2 may trade fixed income instruments in a basket of several securities for a client, commonly referred to as a “portfolio trade”. In effecting portfolio trades, PPM typically utilizes alternative trading systems that provide access to a broad range of approved brokers to bid on the basket of securities. The agreements PPM enters into with certain alternative trading system providers may include discounts or credit for other services PPM receives from those providers, including discounts on terminal fees that PPM typically pays directly. These discounts are generally based on the volume of trading PPM conducts through the provider’s alternative trading system. The receipt of such discounts or credits creates a conflict of interest for PPM when selecting alternative trading system providers for use in client trades. PPM has established best execution policies and procedures to mitigate this conflict of interest, including a post-trade review of the execution quality of portfolio trades by PPM’s Compliance team and its fixed income trading desk, under the oversight of PPM’s Trade Management Working Group. From time to time, PPM attends certain events sponsored by brokers where it is able to arrange meetings with senior management of corporate issuers. PPM does not allocate client trading to brokers on the basis of providing such access, though may allocate client commission on the basis of other substantive research provided in relation to such an event (research reports, analyst meetings/presentations, etc.). PPM may receive products or services pursuant to soft dollar arrangements that are used both as investment research and for administrative, marketing or other non-research purposes. In those cases, PPM makes a good faith effort to determine the relative proportions of such products or services that constitute "research." PPM has a conflict in making this decision. The portion of the cost of such products or services attributable to research may be paid, in whole or in part, by brokerage commissions on client transactions. PPM pays the costs not attributable to research in hard dollars. Research products or services may benefit any or all of PPM's clients and PPM will not necessarily use such research products or services for the account(s) that paid the commissions used to purchase the research. PPM has not entered into any arrangements to direct client transactions to a particular Broker Dealer in return for Soft Dollar Benefits it has received during the last fiscal year.

Brokerage for Client Referrals When selecting Broker Dealers for trade execution on behalf of client accounts, PPM does not take into consideration any client referrals from a Broker Dealer or third party, either for itself or for a related person.

Directed Brokerage PPM does not routinely recommend, request or require that a client direct it to execute transactions through a specified Broker Dealer. In limited circumstances, PPM will permit a client to direct brokerage to a specified Broker Dealer. The discretionary authority of PPM may be limited by directions from a client to have a transaction effected through a specific Broker Dealer for research and services pertaining specifically to, or to defray expenses incurred by, its account. As with all directed brokerage transactions, PPM may not be able to freely negotiate commission rates or select Broker Dealers on the basis of best price and execution for such transactions. In addition, transactions directed in this manner are typically not batched for execution with transactions in the same securities for other clients. As a result, such client may have to pay higher commissions or receive less favorable net prices or execution than would be the case if PPM were authorized to choose the Broker Dealer through which to execute transactions for the client's account. Some clients may also participate in commission recapture programs, in which a broker-dealer through which transactions for that client are executed or cleared, in return for that business, pays the client a cash rebate, provides products or services to the client, bears some of the client’s expenses, or provides some other kind of benefit to the client. Should a client request that PPM support its use of commission recapture programs, and PPM agrees to do so, PPM will generally determine the extent of available opportunities to direct trades to a client’s recapture program as conditions warrant and only on a reasonable-efforts basis. PPM periodically reviews its trading activities relative to client commission recapture goals. There can be no guarantee that any target or goal will be achieved.

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PPM does not receive an economic benefit from any third party for providing investment advice or other advisory services to any of PPM’s clients. From time to time, PPM enters into arrangements pursuant to which it compensates, directly or indirectly, a person who is not a PPM employee for client referrals. In addition, from time to time, PPM enters into agreements with a third-party placement agent to make investor referrals for a PPM-sponsored private fund. Third-party solicitors and placement agents typically receive a monthly servicing fee, an asset-based success fee or a combination of both. In some cases, PPM also may pay solicitors for ongoing client servicing support. PPM pays such fees directly from its corporate assets, which may be derived from management fees paid by PPM’s clients, or in some cases the compensation will be paid directly by the PPM-sponsored private fund. Solicitation or referral arrangements with third parties to obtain referrals for prospective clients are made pursuant to written agreements and in accordance with the other requirements of Rule 206(4)-1 under the Advisers Act (the “Marketing Rule”). As required by the Marketing Rule, PPM requires each solicitor or placement agent, at the time of the solicitation of a potential client or fund investor, to provide disclosure about its compensation arrangement with PPM, along with a description of any material conflicts of interest raised by the arrangement. Many clients or prospective clients retain investment consultants, or other financial intermediaries, to advise them on selecting and reviewing investment managers. From time to time, PPM also has business relationships with organizations that are, or are affiliated with, investment consultants for purposes that include purchasing index data, paying to be listed in databases, and sponsoring events attended by investment consultants. Any fees paid to these investment consultants by PPM are paid from PPM’s own resources, which may be derived from management fees paid by PPM’s clients.

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There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of PPM’s business or the integrity of its management.

Investment and Portfolio Risk Reviews PPM’s portfolio managers regularly monitor the accounts under their supervision and review each account within their style of management as frequently as deemed appropriate for such account (which may be daily, monthly or quarterly). For public and private fixed income strategies, portfolio managers review accounts on a daily basis for:

Trades, positions, and cash levels;

Compliance with client investment guidelines; and

Portfolio risk positioning.

With respect to the PPM private equity strategies, the private equity team members analyze monthly, quarterly and annual financial reports, participate in sponsor’s quarterly update meetings or periodic client conference calls, attend annual advisory board and other informal meetings, as appropriate. In connection with some investments, a member of the applicable private equity team may also serve on a board observer committee. In addition to fund and co-investment diligence material provided by sponsors, this level of activity provides PPM a breadth of information that enables it to manage existing portfolio investments and make new investment decisions on behalf of private equity clients. With respect to PPM’s commercial real estate debt strategies, PPM’s commercial real estate group (CREG) regularly monitors commercial mortgage loan performance by monthly, quarterly, and annual analysis and reporting, subject to client agreements. The timely receipt of mortgage payments is monitored monthly, and delinquencies are investigated with a final report to the CREG Head. Loans identified for credit monitoring are reviewed at a quarterly meeting. Loans with current risk concerns are discussed at the quarterly meeting, along with loans for which collateral, borrower or market information indicates there is a potential future risk to the mortgage loan. Ad hoc meetings are also held to further discuss any mortgage loans for which an impairment or specific reserve should be considered. Annually, the CREG completes a review of annual financial statements, rent rolls and property inspections to confirm collateral performance is consistent with that anticipated at origination. A collateral valuation is completed based on property operating statements and third-party market data. The foregoing activities support CREG’s approach to proactive management of the mortgage loan portfolio throughout the year and ensures clients are well apprised of any mortgage loan at risk and the overall portfolio’s standing. PPM’s risk management team provides oversight and analysis of portfolio risk across the organization and in each fixed income portfolio. The risk team communicates the results of its analysis to senior management and the investment teams through periodic meetings, which include:

Monthly strategy level review meetings - On a monthly basis, PPM’s Chief Risk Officer (“CRO”) and members of the risk management team meet with PPM's Chief Investment Officer (“CIO”) to review a summary of portfolio risk oversight activities, including performance dispersion, rankings against peers and benchmarks, tracking error and various investment risk metrics.

Quarterly portfolio risk meetings – On a quarterly basis, the CRO and members of the risk management team meet with PPM’s CIO and portfolio management teams to review various performance, risk attribution and portfolio positioning reports across fixed income accounts for the prior quarter. Where potential portfolio risk issues are identified, portfolio managers may, with the guidance of the risk team and CIO, adjust portfolio risk positioning.

Quarterly PPM Risk and Oversight Committee meetings – On a quarterly basis, PPM’s CRO and risk management team presents a summary of the team’s portfolio risk oversight activities related to the fixed income to the PPM Risk and Oversight Committee. The risk team reports on performance dispersion, rankings against peers and benchmarks, tracking error and various other risk metrics. Risk concerns, if any, are noted to the committee.

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Commingled Account Reviews PPM serves as adviser and sub-adviser to commingled accounts such as mutual funds and other pooled investment vehicles. For these accounts, in addition to the investment and portfolio risk reviews described above, PPM is also subject to the oversight of the investment manager and/or the governing body of the respective vehicle (such as the board of directors, trustee or investment committee) and produces regular and periodic compliance and/or risk reports to meet their reporting requirements or in response to their requests.

Additional Functional Reviews Functional areas, such as our compliance team, also review and assess data and processes relating to our management and trading. They report results of these analyses independently to our senior management. Examples of these independent reviews may include:

Periodic review of client investment guidelines and automated pre- and post-trade tests with portfolio management teams to ensure accuracy of guidelines and testing logic

Daily pre- and post-trade compliance review of transactions for consistency with investment guideline restrictions;

Periodic review of trading activity including trade allocations and errors; and

Oversight of other specific investment and trading activities, including reviews by our:

Various Investment Approval Committees

Trade Management Working Group;

CLO Management Working Group

Restructuring Operations Working Group;

New Activity Vetting Committee;

Valuation Committee; and

PPM Risk and Oversight Committee

Reports to Clients Generally, all clients receive, at least quarterly, a written summary outlining the activity in their accounts, including, where applicable, performance information which highlights the portfolio’s return and characteristics as compared to the appropriate benchmarks (as applicable). In addition, PPM generally will hold meetings with clients to review their portfolios on a periodic basis, and upon request by the client. Further, for pooled vehicles such as the CLOs that PPMLM2 advises or manages, the Trustee provides written reports to all investors, and PPM may provide reports to investors (if known to PPM) in such vehicles. The nature and frequency of the Trustee reports are described in the applicable pool's governing agreement and other relevant instrument (such as the indenture or limited partnership agreement). PPM’s reports generally summarize or supplement such reports, as deemed appropriate by PPM.

PPM does not typically maintain custody of client funds or securities and, except as described below, will seek to take the actions necessary to avoid being deemed to have inadvertent custody of client funds and securities. For example, the authority provided to PPM pursuant to its investment management agreements is typically limited to trading related activities. In addition, PPM maintains an authorized signers list granting limited authority to certain employees to provide trading and settlement-related instructions, which is provided to custodians. Notwithstanding anything in a client’s agreement with a custodian or other service provider that purports to give PPM powers that may be construed as custody over such client’s assets, PPM expressly disclaims any such authority. PPM generally is not involved in the process by which a separately managed account client selects its custodian and has no involvement in a client’s negotiation of its custodial arrangements. Clients are therefore responsible for independently arranging for all custodial services, including negotiating custody agreements and fees. Each client should carefully review account statements from its custodian to ensure that they reflect appropriate activity in the account. In limited circumstances, PPM is deemed to have custody of client cash or securities under Rule 206(4)-2 of the Adviser’s Act. All funds and securities of each such custody client are held by a qualified custodian (except uncertificated privately offered securities, subject to certain conditions).

In the case of private funds where PPM is deemed to have custody as a result of its affiliation with a fund general partner or its role as administrator of a client controlled fund, each such fund is subject to an annual audit by a Public Company Accounting Oversight Board (“PCAOB”) registered accountant, and the resulting report and financial statements are distributed to fund investors within the timeframe required by Rule 206(4)(b)(4) and related SEC no-action letters.

In the case of a separate account organized as a “fund of one” vehicle, where PPM is deemed to have custody as a result of its affiliation with the fund’s general partner or managing member, PPM will ensure the fund’s cash and securities are held with an independent qualified custodian that provides the client with account statements. PPM will also engage a PCAOB registered accountant to perform a surprise verification of assets of such a fund on an annual basis, consistent with the requirements of Rule 206(4)-2(a)(4).

Where a client’s portfolio includes CMLs, PPM occasionally acts as the loan servicer or performs loan servicing activities. As part of servicing the loans and processing borrower payments, funds related to CMLs made on behalf of PPM’s advisory clients are typically commingled in one or more clearing accounts, each covering multiple CMLs, prior to further distribution in accordance with the loan servicing arrangements. The funds primarily include principal and interest payments, and also generally include items such as borrower paid reserves (e.g. for taxes and insurance) and other fees. Such clearing account(s) are established with a qualified custodian and may include a combination of affiliated and non-affiliated advisory client funds in a single account. To the extent PPM maintains a clearing account for non-advisory client activity (such as loan origination arrangements), that account is maintained separately from advisory client clearing accounts so that advisory client funds are not commingled with non-advisory client funds. PPM has full authority and control over the clearing account(s) and is deemed to have custody over the client funds held in the clearing account(s). Borrower paid reserves received in the clearing account(s) are typically transferred to separate borrower escrow or reserve accounts held at such qualified custodian to support the CML investment of the relevant PPM client(s).

Clients will not receive custodial statements for the clearing accounts from PPM or from the custodian bank. However, PPM confirms with each client that, in order to receive payments related to their CML holdings, clients maintain their own bank account at a qualified custodian and receive statements directly from that custodian. Accordingly, such clients should ensure that they are receiving and reviewing statements from their own qualified custodians on at least a quarterly basis to ensure that all expected funds are received (based on the client’s or its custodian’s record of the client’s CML holdings) and to contact us with any questions.

Additionally, for the clearing accounts as well as relevant borrower escrow or reserve accounts related to the servicing of CMLs, PPM engages a PCAOB registered accountant to perform a surprise verification of assets on an annual basis, consistent with the requirements of Rule 206(4)-2(a)(4).

PPM generally accepts discretionary authority to manage the accounts of its clients pursuant to investment guidelines and restrictions established by the client or the investment adviser who is delegating sub-advisory responsibilities to PPM. Prior to assuming this authority, PPM will typically enter into an investment management or other similar agreement, which either includes or incorporates by reference the client’s specific investment objectives, restrictions, guidelines, and applicable reference benchmarks. On a limited basis, PPM provides non-discretionary investment management services to certain clients, typically related to private investment strategies. Non-discretionary mandates are typically subject to written agreements which may identify specific client restrictions or guidelines, however for non-discretionary accounts the client approves purchases and sales, and in doing so may waive written guidelines or restrictions. 40 | PPM America, Inc.

PPM also provides real estate loan origination and servicing services to third parties that are not advisory clients. As part of this business, PPM sources and underwrites potential loan transactions pursuant to guidelines provided by the third party. Further investment diligence and the decision to enter into a commercial mortgage loan with the respective borrower are the sole responsibility of the third party.

As required by Rule 206(4)-6 under the Advisers Act, PPM has adopted written policies and procedures in connection with voting proxies for those clients for whom it exercises proxy voting authority. Copies of PPM’s Proxy Voting Policies and Procedures are available by request. Clients may also request copies of voting records for their proxies. PPM’s primary consideration in determining how to vote a proxy or other voting right is the financial interest of its clients. For equity securities, PPM generally votes all proxies in accordance with its U.S. Proxy Voting Guidelines Summary (the “Voting Guidelines”), which is periodically reviewed and updated as necessary. The Voting Guidelines have been established with the assistance of Institutional Shareholder Services, Inc. (“ISS”), a proxy voting and consulting firm, and are designed to further the interests of clients when voting on particular proposals. PPM has generally adopted the ISS guidelines in the Voting Guidelines. Where proposals are not addressed in the Voting Guidelines, or in the event that the portfolio manager recommends a vote contrary to the Voting Guidelines, PPM will vote in the manner believed to be in the best financial interests of its clients. Where the vote conflicts with a stated guideline, it will be subject to the prior review of PPM’s Legal and Compliance team. If necessary, at the recommendation of PPM’s Legal and Compliance team, PPM’s Conflicts Committee will be convened to address any material conflicts of interest identified. If a client desires to do so, they may contact PPM with direction regarding a vote for a holding in their account. PPM performs oversight and assurance reviews of its proxy voting activities, including:

Annual sampling proxy votes to ensure that they were cast in compliance with the PPM Proxy Voting Policies and Procedures;

a review, no less frequently than annually, of the adequacy of the PPM Proxy Voting Policies and Procedures to make sure that the procedures continue to be reasonably designed to ensure that proxies are voted consistent with our fiduciary obligations to our clients;

A due diligence review, no less frequently than annually, over ISS that is consistent with PPM’s third-party supply process, including reviews of due diligence documents and questionnaires provided or completed by ISS. In conducting this diligence, PPM will consider whether there are any identified conflicts of interest or any other factors important in considering the nature and quality of the services provided by ISS.

Because the issues on which PPM votes client debt securities are unique to each borrower and relevant facts and circumstances, and do not lend themselves to broad characterization as do many issues associated with equity related proxies, PPM does not maintain voting policy guidelines regarding categories of issues that may come before debt security holders. All such votes related to debt securities are considered on a case-by-case basis and determined by the applicable investment team with the client’s best financial interest in mind. Because of the familiarity of its staff with issues upon which it votes client debt securities, PPM typically does not retain the services of a qualified independent third party (such as ISS) to provide guidance on such matters. PPM clients may determine not to delegate authority to PPM to vote client securities. In this event, clients will arrange to receive proxies directly from their custodian or transfer agent and may contact PPM with questions regarding any solicitation.

PPM does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance and therefore has not included a balance sheet for its most recent fiscal year. Also, PPM is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients and has not been the subject of a bankruptcy petition at any time during the past ten years.

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PPM Privacy Policies & Notices PPM America, Inc. and PPM Loan Management Company 2, LLC (collectively, “PPM”, “we”, “us” or “our”, as applicable) is committed to compliance with all applicable state and federal privacy laws and regulations. The links below provide details about PPM’s privacy policies. To exercise rights you may have related to your personal information or to manage your personal information, please use this link to submit a request, or email PPMPrivacyOperations@ppmamerica.com.

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Third Party Privacy Policy At PPM we are committed to keeping non-public information about third parties (including clients and potential clients) secure and confidential. We do not disclose your information to anyone except as required by law, described in this policy, or as you otherwise permit. Most importantly, we do not sell your information to anyone.

INFORMATION WE MAY COLLECT AND USE The personal information we collect is in association with our services and is used by PPM and the service providers and contractors we engage to assist us in providing financial services to our clients.

DISCLOSING OR SHARING PERSONAL INFORMATION In order to run our business and provide our services and products, there are occasions where we may disclose or share your personal information with affiliates and non-affiliated vendors that perform support services for PPM (including, but not limited to: fund administrators, placement agents, transfer agents, servicers, custodian banks, legal representatives, etc.). These parties are subject to agreements that require them to maintain the confidentiality of your information and to use it only in the course of providing such services. We will also share information if you so direct or with your consent, if we are compelled by law or regulation, as part of a corporate transaction with a successor or affiliate or in connected with any acquisition, merger or sale of assets, or in other circumstances as permitted by law (for example, to protect your account from fraud). It is important to note that PPM does not share your personal information with third parties for targeted advertising (i.e., cross-contextual advertising). Further, we have no actual knowledge that we collect or share the personal information of individuals under 16 years of age.

SAFEGUARDING INFORMATION PPM recognizes that information security is a crucial topic. To protect information, we utilize an industry-standard information security program with certified and experienced professionals who strive to protect the integrity of our systems and applications. We implement precautions throughout our organization, including, where appropriate, the following: password protection, multi-factor authentication, encryption, Transport Layer Security (TLS), firewalls, and internal restrictions on who may access data to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We restrict access to personal information to authorized employees and in some cases to third parties as permitted by law. In addition to the requirements in this policy, we maintain physical, electronic and procedural safeguards to guard sensitive information. PPM adheres to these standards even after a business relationship ends. To learn more about how PPM protects your personal information, please visit the Cybersecurity page of PPM’s affiliate responsible for PPM’s information security.

INSTRUCTIONS FOR SUBMITTING A REQUEST PPM complies with all applicable laws and regulations governing rights with respect to personal information and administers the rights described in this notice in accordance with specific laws and regulations. Your state may provide for additional privacy protections under applicable laws. PPM will protect your information in accordance with these additional protections. If you would like to act upon your rights regarding your personal information, please use this link to submit a request, or email PPMPrivacyOperations@ppmamerica.com. Upon submission of your request we will take commercially reasonable steps to verify your identity and, if applicable, your authorized agent’s identity before granting access or making any changes to your personal information. You will be required to verify your identity by providing general information such as your first name, last name, and email address. In some instances we may reach out to you directly to provide other information, such as your mailing address. Only you, or an agent authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We will make good faith efforts to provide you with access to your data when you request it, but there may be circumstances in which we need not provide access as allowed by law, including but not limited to instances where the information contains legal privilege, where your identity could not be verified, or where the information may compromise yours or others’ privacy or other legitimate rights. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.

CHANGES TO NOTICE This notice provides a general statement with details to help you understand our current privacy policies and how PPM protects your personal information. You may, however, in connection with specific products or services offered by PPM, be provided with privacy 43 | PPM America, Inc.

policies or statements that supplement this notice. PPM reserves the right to change this notice, its privacy policies, or any supporting or related policies or procedures at any time. If there are any changes to the terms of this notice or PPM’s privacy policies, documents containing the revised notice and policy will be updated, including our website at the PPM Privacy Policies or at https://www.ppmamerica.com/privacy-policy, and will be effective immediately. Contact us at privacy@ppmamerica.com should you have any questions about this notice, our privacy policy, our privacy commitments or our website. This notice was last updated on July 10, 2025.

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California-Specific Privacy Policy PPM maintains compliance with the California Privacy Rights Act (“CPRA”) which affords California residents with certain privacy rights and protections. This section sets out those rights and provides individuals with a form to submit privacy data requests. The below references have the following meanings under the CPRA:

"share" means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for crosscontext behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged. “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to another business or a third party for monetary or other valuable consideration. “third parties” do not include vendors, contractors or service providers who collect or process your personal information on behalf of PPM.

PERSONAL INFORMATION WE MAY HAVE COLLECTED OR USED WITHIN THE PAST 12 MONTHS Below is a list of the categories of personal information we may have collected or used within the past 12 months. We did not necessarily collect or use all the specific pieces of personal information listed for any given person or category. Please note that these personal information categories are as they are set forth under California law.

Category Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Any category of personal information described in Cal. Civ. Code § 1798.80(e): “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Characteristics of protected classifications under California or federal law: sexual orientation; race; national origin; medical conditions; disability (physical or mental); genetic information; military or veteran status; status as a victim of domestic violence assault, or stalking; gender identity and gender expression; color; religion; sex (including pregnancy, childbirth, and related medical conditions); age (40 or older); marital status; political affiliates or activities. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Biometric information. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Any category of sensitive personal information described in Cal. Civ. Code § 1798.140(ae)(1) to (2): “Sensitive personal information” means (1) “personal information” that reveals: a consumer’s social security, driver’s license, state identification card, or passport number; a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; a consumer’s precise geolocation; a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; a consumer’s genetic data; or (2) the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; or personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. Professional or employment related information.

CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED We receive personal information through two primary means: information you or your authorized representative(s) provide us, and information we collect automatically. Information you provide. In the course of serving you as someone associated with a corporate or institutional client, PPM obtains personal information about you principally through requests by email or telephone. Obtaining this information is important to our ability to fulfill your requests and deliver the highest level of service. PPM also works with LinkedIn to collect personal information that you 45 | PPM America, Inc.

provide on its website to access online and mobile advertisements for PPM products and services that we think may be of interest to you. We do not control and are not responsible for the actions or privacy practices of other websites (whether accessed through an advertisement, service or content link) and urge you to review such practices and/or policies prior to submitting any information to such websites. Digital Analytics Information. While we do not collect personal information from anyone who is merely visiting or browsing our website, to enhance our visitors' usability of the PPM website, we use digital analytics tools (e.g. Google Analytics) to understand and optimize performance. This may include, but is not limited to, the collection of IP addresses and information about what pages visited, and average time on pages. To learn more about how Google uses the information, visit Google’s Privacy & Terms at http://policies.google.com/technologies/partner-sites. When interacting with our PPM email marketing materials, our systems automatically log information about your interaction with that email as well as information about your computer or mobile device. For example, our system logs when you open an email from us, what links in our emails you select, your IP address, your computer or mobile device operating system name and version, browser and email client type, how long you spent on a page, and information about your use of and actions on the email newsletter. If you currently receive PPM email marketing materials but wish to stop receiving these communications, please follow the opt-out instructions contained within the email message from PPM. For more information on our website policy please visit Website Privacy Policy.

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