TIAA CREF INVESTMENT MANAGEMENT LLC

TIAA-CREF Investment Management, LLC (“TCIM”) provides investment management and certain administrative services necessary for the operation of the College Retirement Equities Fund (“CREF”), a diversified open-end registered investment management company consisting of eight accounts that issue individual, group and tax-deferred variable annuity contracts. TCIM tailors its advisory services to the needs of CREF, its only client. TCIM’s responsibilities include, without limitation, investment advisory services, research services, recommending and placing of orders for the purchase and sale of securities for the CREF portfolios (based on the investment objectives and needs of each CREF account as documented in the CREF prospectus (the “Prospectus") and statement of additional information (the “Statement of Additional Information”)), supervising relations with custodians, transfer and pricing agents, accountants, auditing, underwriters and other persons interacting with CREF, developing management and shareholder services for CREF, and furnishing reports, evaluations and analysis on a variety of matters. TCIM is a subsidiary of TIAA-CREF Asset Management LLC, which is an indirect subsidiary of Nuveen, LLC (“Nuveen”). Nuveen is a subsidiary and represents the investment management division of Teachers Insurance and Annuity Association of America (“TIAA”), a leading financial services provider. TIAA constitutes the ultimate principal owner of TCIM. For additional information on the ownership structure, please see Form ADV Part 1, Schedules A and B, and Item 10. TCIM was formed on December 17, 1997 and registered with the SEC as an investment adviser on December 31, 1990. As of December 31, 2025, TCIM managed $292 billion in discretionary client assets. TCIM did not manage any non-discretionary client assets as of December 31, 2025.

TCIM provides its investment advisory and administrative services to CREF on an “at-cost” basis. A daily deduction is made from the assets of CREF’s investment portfolios in connection with the advisory and administrative services provided. These rates are designed to reflect the cost of advisory and administrative services and are not intended to include any profit. The rates of these deductions are revised from time to time, based solely on estimates of expenses anticipated to be incurred, with the objective of keeping the deductions as close as possible to actual expenses. As soon as is practicable, after the end of each quarter, adjusting charges or credits are made to correct any difference between the deductions and the expenses actually incurred. Accordingly, the amounts deducted each year as a percentage of the net assets of each investment portfolio may be higher or lower than the current annual deduction rates, depending upon expense experience. For CREF equity accounts managed by TCIM, management fees are expected to range from approximately 4.5 basis points to 9.5 basis points. For the CREF index account managed by TCIM, the management fee is expected to be approximately 1 basis point. For CREF fixed income accounts managed by TCIM, management fees are expected to range from approximately 2.5 basis points to 7.0 basis points. For the CREF specialty/balanced account managed by TCIM, the management fee is expected to be approximately 5.5 basis points. For the CREF money market account managed by TCIM, the management fee is expected to be approximately 1.0 basis points. The Investment Management Services Agreement between TCIM and CREF is subject to approval by the board of trustees of CREF (the “Board of Trustees), including a majority of Trustees who are not parties to the Agreement or “interested persons” of any party to the Agreement. TCIM’s fees under such Investment Management Services Agreement are set forth in the registration statements and other documents of CREF on file with the SEC. The Investment Management Services Agreement between TCIM and CREF may be terminated at any time upon the mutual consent of the parties. To avoid a penalty, the Board of Trustees of CREF must give 60 days’ written notice to TCIM or TCIM must give 60 days’ written notice to the Board of Trustees. TCIM’s Fees in General TCIM’s fees, which are non-negotiable, are exclusive of transactions costs related to the buying and selling of securities such as brokerage commissions, odd-lot differentials, transfer taxes, wire and electronic transfer fund fees, and other fees and taxes on brokerage accounts and securities

transactions. In addition, client accounts may incur other certain charges imposed by third parties. Such fees are charged by custodians, broker-dealers, administrators, and distributors and are exclusive of and in addition to TCIM’s fee. TCIM shall not receive any portion of these commissions, fees, and costs. TCIM is reimbursed for the expenses assumed in connection with its advisory services to CREF through daily payments based on an annual rate agreed upon by CREF and TCIM. The agreed upon rate is an estimate of the costs of the services that TCIM will provide with the objective of keeping the actual payments for the services close to the estimated costs. The daily payment to TCIM is from the net assets of each client account, each valuation day for each calendar day of the valuation period. On a quarterly basis, the amount necessary to correct any differences between the payments to TCIM and the expenses actually incurred by TCIM will be determined. This amount will be paid by or credited to TCIM as the case may be, in equal installments over the remaining days in the quarter. The internal management fees associated with the accounts managed by TCIM and which may be incurred by investors in the accounts are disclosed in CREF’s Prospectus in the section titled “Fee and expense tables of each Contract”. Additionally, an account may purchase shares of other types of investment companies, which may include exchange-traded funds (“ETFs”) principally used for cash management, investment exposure or defensive purposes. Typically, a client account would purchase ETF shares to obtain exposure to all or a portion of the stock or bond market. When a client account invests in another investment company, like an ETF, it typically bears a proportionate share of expenses charged by the investment company in which it invests. Item 12 further describes the factors that TCIM considers in selecting or recommending brokerdealers for client account transactions and determining the reasonableness of their compensation (e.g., commissions).

TCIM uses a variety of different analytic methods and investment strategies depending on the nature of the client account it is managing. This section first describes the analytical methods TCIM uses and then separately the investment strategies and their associated risks. For additional detailed information, please refer to the current CREF Prospectus and Statement of Additional Information.

Methods of Analysis Active Management For the equity client accounts, TCIM looks for stocks that it believes are attractively priced based on an analysis of the company’s prospects for growth in earnings, cashflow, revenues and other relevant measures. TCIM also looks for companies whose assets appear undervalued in the market. In general, TCIM focuses on companies with shareholder-oriented management dedicated to creating shareholder value. TCIM may invest in companies of any size, including small companies. For the fixed income client accounts, TCIM concentrates on security selection, sector allocation, yield-curve positioning, and duration management. TCIM seeks to preserve capital along with a favorable long-term rate of return. TCIM invests in securities rated investment grade or below investment grade (“high yield”), and such investments for certain portfolios may be substantial. Additionally, a taxable fixed income client account may invest a portion of its assets in securities and other instruments that are, at the time of investment, illiquid. A taxable fixed income client account’s assets may also be invested in U.S. dollar and non-dollar denominated debt obligations of non-U.S. corporations and governments, including those located in emerging markets countries. Taxable fixed income client accounts may pursue other strategies or invest in other instruments described in this Brochure. A rating includes the rating given plus or minus. For taxable fixed income, TCIM generally relies on the applicable rating(s) of S&P, Moody’s and/or Fitch. Split rated securities (i.e., those rated differently by different applicable rating agencies) are generally deemed to receive, as applicable: the middle of three ratings or the lower of two ratings. A portion of a client account’s assets may also be invested in securities that are unrated but that TCIM deems to be of comparable quality to a particular rating. Taxable fixed income portfolios may also invest in other types of fixed income securities, such as asset-backed securities, residential and commercial mortgage-backed securities, corporate debt obligations, municipal securities and inverse floating rate securities. Taxable fixed income portfolios may invest in and employ derivatives including, but not limited to, futures; interest rate swaps, caps, collars and floors; index swaps, total return swaps, credit

default swaps and non-U.S. currency swaps; forward currency contracts and non-deliverable forward currency contracts; options on futures, non-U.S. currencies and swaps (as well as selling call options and purchasing put options on individual or a basket of securities, as well as on swaps); and/or other derivatives. The derivatives in which the taxable fixed income client accounts may invest may be exchange traded or traded over the counter. Taxable fixed income client accounts may also invest a portion of their total assets in dollar roll transactions. A taxable fixed income client account may utilize derivatives strategies to enhance return, hedge some of the risks of their investments in securities, as a substitute for a position in an underlying asset, to reduce transaction costs, to maintain full market exposure, to manage or generate cash flows, to manage the effective maturity and duration of portfolio securities, to increase yield or enhance returns, to create debt or non-U.S. currency exposure, to limit exposure to losses due to changes to non-U.S. currency exchange rates, to preserve capital, and/or other reasons to the extent permitted by client account guidelines. The portion of a taxable fixed income client account that is invested in derivatives at times may be substantial. Taxable fixed income client accounts may also invest a portion of their assets in cash and cash equivalents. Additionally, certain taxable fixed income client accounts may invest in equity securities and warrants acquired in connection with investments made in certain fixed income securities. Client accounts may invest in municipal securities that are secured by insurance (including, in certain portfolios, insurance that guarantees the timely payment of principal and interest), bank credit agreements, or escrow accounts. A certain portion of client account’s assets may be invested in taxable bonds. Inflation-protected client accounts seek a current yield that compensates an investor for current inflation expectations, and also seek to mitigate the effect that subsequent increases in inflation may have on the purchasing power of the client account by investing in inflation-linked instruments, such as Consumer Price Index (“CPI”) swaps, in amounts sufficient to approximate the duration characteristics of the client account’s underlying municipal bond portfolio. Certain client accounts select municipal bond securities for interest that is exempt from U.S. federal income tax, and in some cases, state and/or local income tax. Changes in tax laws, adverse interpretations by the Internal Revenue Service or state tax authorities, or noncompliant conduct of a bond issuer, among other events, could lead to declines in the value of municipal bonds and other unfavorable results. Certain client accounts invest in lower quality municipal bonds, including high yield bonds. Municipal bond portfolios may pursue other strategies or invest in other instruments described in this Brochure. CREF should consult its Board of Trustees to consider the suitability of investing in municipal bond securities.

Quantitative Indexing TCIM may use several different investment techniques to build a portfolio of stocks that is structured to resemble and share the risk characteristics of various segments of the benchmark index, while also seeking to outperform that benchmark index. Quantitative strategies often employ proprietary, quantitative modeling techniques for stock selection, country allocation and portfolio construction. Quantitative analysis involves the use of mathematical models and computer programs that attempt to outperform the index by over- and underweighting certain stocks in the index. Pure Indexing TCIM uses investment techniques designed to track various segments of the component indices of a client account’s composite index. When using this technique, TCIM buys most, but not necessarily all, of the securities of the component indices and attempts to closely match the overall investment characteristics of such indices. ESG Nuveen has adopted certain principles on responsible investing at the enterprise level. TCIM generally endeavors to include material environmental, social and governance (ESG) factors as part of the investment research and/or portfolio construction process for public markets securities in active strategies to the extent relevant, as further described below. For strategies that expressly undertake to employ ESG, green, impact or other responsible investing factors, or as otherwise expressly agreed with CREF, TCIM’s approach to ESG is subject to the guidelines and terms relating to such strategies and services. For active public markets strategies, TCIM seeks to make available certain ESG research that investment research and/or portfolio managers may consider in their discretion to the extent ESG factors are deemed financially relevant from an investment perspective. TCIM does not undertake to apply specific requirements in this regard, and the nature and quality of ESG research made available, if any, and whether and the degree to which ESG factors are accessed, reviewed and/or considered largely depends on the particular portfolio management team, strategy and guidelines and requirements, and other factors, and may vary materially. TCIM’s ESG research is generally not available, or is integrated to a lesser extent, in certain strategies, accounts and securities, including, for example and without limitation, distressed bonds, convertible bonds, short selling, certain fixed income holdings below certain size thresholds, as well as passive and quantitative public markets strategies. Unless a strategy expressly undertakes to employ ESG, green, impact, or other responsible investing factors, or as otherwise agreed with CREF, TCIM will not necessarily include in or exclude from portfolios certain securities, industries or sectors based solely on such criteria. CREF should consult its Board of Trustees to consider the suitability and risks of select strategies that expressly pursue ESG, green, impact or other responsible investing objectives. See “ESG Criteria and Impact Risk” below.

Investment Strategies Equity Accounts

Total Global Stock Account Seeks a favorable long-term rate of return through capital appreciation and investment income by investing primarily in a broadly diversified portfolio of common stocks.

Global Equities Account Seeks a favorable long-term rate of return through capital appreciation and income from a broadly diversified portfolio that consists primarily of foreign and domestic common stocks.

Growth Account Seeks a favorable long-term rate of return, mainly through capital appreciation, primarily from a diversified portfolio of common stocks that present the opportunity for exceptional growth.

Index Accounts

S&P 500 Index Account Seeks a favorable long-term rate of return from a diversified portfolio selected to track the overall market for common stocks publicly traded in the United States, as represented by a broad stock market index.

Fixed Income Accounts

Core Bond Account Seeks a favorable long-term rate of return, primarily through high current income consistent with preserving capital.

Inflation-Linked Bond Account Seeks a long-term rate of return that outpaces inflation, primarily through investment in inflation-indexed bonds.

Specialty/Balanced Accounts

Responsible Balanced Account Seeks a favorable long-term rate of return that reflects the investment performance of the financial markets while giving special consideration to certain social criteria.

Money Market Accounts

Money Market Account Seeks high current income consistent with maintaining liquidity and preserving capital.

Description of Material Risks Associated with Investment Strategies Investing in securities involves a risk of loss that client accounts should be prepared to bear. Also, some of the strategies may involve frequent trading which may increase the brokerage and other transaction costs and taxes associated with such a strategy. These increased costs and taxes may negatively affect the performance associated with such strategies. For additional information, refer to the CREF Prospectus and Statement of Additional Information.

Principal Risks of Investing in Equity Accounts In general, the value of equity investments fluctuates in response to the performance and financial condition of individual companies that issue them and in response to general market and economic conditions. Therefore, the value of an investment in a client account that holds equity securities may decrease. The fact that a particular risk below is not specifically identified as being heightened under current conditions does not mean that the risk is not greater than under normal conditions. There is no guarantee that a client account will meet its investment objective. An investment in an Equity Account, the S&P 500 Index Account, or the equity portion of the Responsible Balanced Account, or any client account’s equity investments, typically will be subject to the following principal investment risks described below:

Initial Public Offering Risk – By virtue of its size and institutional nature, an adviser may have greater access to new issues or initial public offerings (“IPOs”) than individual investors. Most IPOs involve a high degree of risk not normally associated with offerings of more seasoned companies. Companies involved in IPOs generally have limited operating histories, and their prospects for future profitability are uncertain. These companies often are engaged in new and evolving businesses and are particularly vulnerable to competition and to changes in technology, markets and economic conditions. They may be dependent on certain key managers and third parties, need more personnel and other resources to manage growth and require significant additional capital. They may also be dependent on limited product lines and uncertain property rights and may need certain regulatory approvals. Investors in IPOs can be affected by substantial dilution in the value of their shares, by sales of additional shares and by concentration of control in existing management and principal shareholders. Stock prices of IPOs can also be highly unstable, due to the absence of a prior public market, the small number of shares available for trading and limited investor information. IPOs will frequently be sold within 12 months of purchase. This may result in increased short-term capital gains, which will be taxable as ordinary income.

Issuer Risk - (often called Financial Risk) – The risk that the issuer’s earnings prospects, credit rating, and overall financial position will deteriorate, causing a decline in the value of the issuer’s financial instruments over short or extended periods of time. In times of market turmoil, perceptions of an issuer’s credit risk can quickly change, and even large, wellestablished issuers may deteriorate rapidly with little or no warning.

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TCIM provides portfolio management services to CREF which provides variable annuities for certain types of retirement and tax-deferred savings plans for employees of colleges, universities, other educational and research organizations, and other governmental and non-profit institutions. CREF’s main purpose is to invest funds for retirement and pay income based on investments in its eight registered investment accounts:

Equity Accounts ▪ Total Global Stock Account ▪ Global Equities Account ▪ Growth Account Index Account ▪ S&P 500 Index Account Fixed Income Accounts ▪ Core Bond Account ▪ Inflation-Linked Bond Account Specialty/Balanced Account ▪ Responsible Balanced Account Money Market Account ▪ Money Market Account The accounts have no minimum account size requirements. CREF Class Eligibility (Class R1, Class R2, Class R3 and Class R4) Class R1 ▪ Institutions with CREF assets under management below $20 million. ▪ Individual and Annuity Products – Individual Retirement Accounts (IRA) and Keogh Contracts. Class R2 ▪ Institutions with CREF assets under management of $20 million or more, but less than $400 million. ▪ Individual and Annuity Products – After-Tax Retirement Annuity (ATRA). Class R3 ▪ Institutions with CREF assets under management of $400 million or more. ▪ Individual and Annuity Products – Immediate Annuity and Accumulation Unit Deposit Option (AUDO). Class R4 ▪ Institutions utilizing Retirement Choice/Retirement Choice Plus Contracts and that have entered into a recordkeeping services agreement with TIAA.

The compensation paid by CREF to TCIM is based on a percentage of assets under management (on an at-cost basis). TCIM does not have any performance-based fee arrangements in connection with its advisory business.

TCIM has arrangements that are material to its advisory business, its client, CREF, or its advisory affiliates or any persons under common control with TCIM (“Related Persons”). Also, certain management persons of TCIM and/or other personnel are registered representatives and associated persons of one or more affiliated broker-dealers. When providing advice relating to commodity interests (e.g., futures, options on futures and swaps), depending on the particular client account, TCIM would be operating under an exemption or exclusion from registration as a CTA. As discussed above, TCIM is a subsidiary of TIAA-CREF Asset Management LLC, which is an indirect subsidiary of Nuveen. Nuveen is a subsidiary, and represents the investment management division of TIAA, a leading financial services provider. TIAA constitutes the ultimate principal owner of TCIM. For additional information on the ownership structure, please see Form ADV Part 1, Schedules A and B. TIAA’s subsidiaries include various financial industry entities, including broker-dealers, other investment advisers, commodity pool operators and/or commodity trading advisors, banking or thrift institutions, insurance companies or agencies, pension consultants, sponsors or syndicators of limited partnerships, and sponsors, general partners, or managing members of pooled investment vehicles, among other entities. For further information on these subsidiaries, please see Exhibit A. TIAA is considered a control person of TCIM, and TIAA’s other financial industry entities may be considered affiliates of TCIM under various other regulatory regimes, including as applicable the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and the Investment Company Act. TCIM is committed to putting the interests of client accounts first and seeks to act in a manner consistent with its fiduciary and contractual obligations to client accounts and applicable law. At times, TCIM may determine, in an exercise of its discretion, to limit or refrain from entering into certain transactions, for some or all client accounts, in order to seek to avoid a potential conflict of interest, or where the legal, regulatory, administrative, or other costs associated with entering into the transaction are deemed by TCIM to outweigh the expected benefits. Further, certain regulatory and legal restrictions or limitations and internal policies (including those relating to the aggregation of different client account holdings by TCIM and its affiliates) may restrict certain investment or voting activities of TCIM on behalf of client accounts. For example, TCIM’s investment and proxy voting activities with respect to certain securities, issuers, regulated industries and non-U.S. markets may be restricted where applicable laws or regulations impose limits or burdens with respect to exceeding certain investment thresholds when aggregated with its affiliates. To the extent permitted by the Advisers Act, the Investment Company Act and other law, as applicable, TCIM may give advice, take action or refrain from acting in the performance of its duties for certain client accounts that may differ from such advice or action, or the timing or nature of such advice or action, for other client accounts.

From a business perspective within Nuveen, TCIM’s business is part of a functional group that seeks to provide alignment and collaboration among certain Nuveen affiliates managing public equity and fixed income asset classes. From an investment perspective within Nuveen, TCIM’s equity, taxable fixed income, and municipal fixed income investment services are part of a broader Nuveen organizational framework that seeks to promote greater collaboration among, and provide leadership to, the respective investment teams. TCIM’s investment teams comprise investment personnel who are “multihatted” as employees (“multi-hatted personnel") across TCIM and/or certain other affiliates. These teams coordinate and share investment and certain trading processes with respect to client accounts in equity, fixed income and municipal bond strategies. These integrated teams are sometimes referred to in the marketplace as Nuveen Equities, Nuveen Fixed Income and Nuveen Municipals, respectively. Multi-hatted personnel face conflicts in providing services for various clients of multiple affiliates, such as in the areas of trade sequencing and allocating opportunities. These conflicts are similar to the conflicts they face in providing services for various clients (including affiliated and proprietary accounts) of a single investment adviser. Through its policies, procedures, and practices, TCIM seeks to provide for the fair and equitable treatment of client accounts. See Item 12. TIAA affiliates market, distribute, make referrals of, use and/or recommend investment products and services (including funds and pooled investment vehicles, and investment advisory services) of other affiliates (including TCIM), and such affiliates may pay and receive fees and compensation in connection thereto. As a result of the potential additional economic benefit to TCIM and/or its affiliates resulting from such activities, there is a potential conflict of interest for TCIM which TCIM seeks to mitigate in a variety of ways, depending on the nature of the conflict, such as through oversight of these activities and/or by disclosure in this Brochure. Affiliated broker-dealers and their personnel act as distributors with respect to and/or promote and provide marketing support to affiliated funds and broker-dealer personnel are internally compensated for those activities. Such distribution activities are subject to the broker-dealer’s own procedures. TCIM’s affiliates or shared services units, including Nuveen Services, LLC, provide it with supplemental account administration, trading, operations, client service, sales and marketing, product development and management, risk management, information technology, legal and compliance, human resources, and other corporate, finance or administrative services. TCIM may likewise provide services for its affiliates. Multi-hatted personnel may perform services for both TCIM and one or more TCIM affiliates. The scope of certain such services and arrangements varies depending on the particular strategy, distribution channel, program, and client size and type. In providing investment advisory services to accounts in certain strategies, TCIM may use portfolio management, research, trading and other resources of one or more non-US affiliates, including Nuveen Hong Kong Limited, Nuveen Singapore Private Limited, Nuveen Investment Management International Limited, Nuveen Japan Co., Ltd, and/or others, that are not registered with the SEC. Certain of such services are provided through a “participating affiliate” arrangement,

as that term is used in relief granted by the SEC staff allowing U.S. registered investment advisers, such as TCIM to use portfolio management resources of advisory affiliates subject to the regulatory supervision of the registered investment adviser.

Transactions and Personal Trading Code of Ethics TCIM has adopted a Code of Ethics, as supplemented, (the “Code of Ethics”). The Code of Ethics is designed to detect and prevent conflicts of interest relating to personal trading by its employees, and to ensure that TCIM effects transactions for client accounts in a manner that is consistent with its fiduciary duty to its client accounts and in accordance with applicable law. TCIM’s employees who wish to purchase or sell most types of securities in their personal accounts may do so only in compliance with certain procedures outlined in the Code of Ethics, such as preapproval of non-exempted securities by compliance personnel and periodic holdings and transaction reporting Employees are required, with limited exceptions, to maintain brokerage accounts with select broker-dealers who provide automated, electronic reporting of transactions and account information to assist the Nuveen Ethics Office in monitoring employee transactions. The Code of Ethics also prohibits the misuse of material nonpublic information and confidential information. Certain employees have been designated as TCIM Investment Persons, as that term is defined in the Code of Ethics. An Investment Person is prohibited from transacting in securities during the period starting 7 calendar days before, and ending 7 calendar days after, any trade in an affiliated fund, or any portfolio or client account advised or sub-advised by Nuveen for which he/she has responsibility. TCIM and its Related Persons may invest in securities for their personal accounts that are also recommended to TCIM client accounts. Potential conflicts arise in this situation because TCIM or its Related Persons may have a material interest in or relationship with the issuer of a security or may use knowledge about pending or currently considered securities transactions for client accounts to profit personally. To address these potential conflicts, employees are required to review and certify securities trading activity quarterly and to provide securities holding reports upon commencement of employment and to review and certify securities holdings thereafter on an annual basis. In addition, employee transactions are subject to limitations regarding the type and timing of transactions, including certain trading prohibitions, and pre-approval and monitoring by compliance professionals and/or certain Related Persons. TCIM, its employees, and its affiliates may give advice and take action in the performance of their duties for some client accounts that may differ from advice given, or the timing or nature of actions taken, for other client accounts or for their proprietary or personal accounts. TCIM employees and others related to TCIM employees and its affiliates can be clients of TCIM (collectively “employee accounts”). TCIM has a potential conflict of interest because it could seek to favor its employee accounts over its other client accounts in the management of employee accounts. Additionally, TCIM can provide special services and/or provide services at no or reduced fees for employee

accounts. TCIM manages employee accounts in a manner consistent with TCIM’s fiduciary duty to its other client accounts. It is TCIM’s policy that employee accounts should not receive special trading advantages or disadvantages, and employee accounts are subject to the firm’s trading policies. Subject to the restrictions described above, TCIM and employee accounts may at any time hold, acquire, increase, decrease, dispose of or otherwise deal with positions in investments in which a client account may have an interest from time to time. TCIM has no obligation to acquire for a client account a position in any investment which it, acting on behalf of another client account, or an employee, may acquire, and the client accounts shall not have first refusal, co-investment or other rights in respect of any such investment. A copy of the Code of Ethics will be provided upon request of any client or prospective client. Please see the cover page to this Brochure for contact information. Subject to certain exceptions (e.g. multi-hatted personnel) TCIM and its advisory affiliates maintain procedures (including certain information barriers) designed generally to provide for independent exercise of investment and voting power. To the extent the Nuveen Ethics Office determines that there is no material conflict of interest, certain employees of TCIM from time to time may engage in outside business activities, including serving on boards of unaffiliated entities. Employees may be offered or receive business gifts, meals, and entertainment from parties with whom TCIM conducts business. Receipt of business gifts, meals, and entertainment may inappropriately influence investment or trading decisions. Similarly, the giving of business gifts, meals, and entertainment could inappropriately influence a person or entity in an effort to gain an unfair advantage in acquiring or retaining CREF. Employees are subject to certain limitations and reporting obligations regarding the receipt/giving of business gifts, meals, and other benefits in the form of entertainment from parties with whom TCIM conducts business. Similarly, employees may from time to time provide or solicit political contributions to certain candidates, officeholders, political organizations, or trade associations. Utilizing political contributions inappropriately to gain an unfair advantage in acquiring or retaining client accounts creates a conflict of interest. TCIM has established procedures designed to comply with applicable federal law. In addition, all applicable contributions require preclearance and employees are required to certify on a quarterly basis that they have reported all applicable political contributions.

Participation or Interest in Client Transactions TCIM may periodically recommend securities to its client accounts that are also recommended by one or more of its Related Persons to their clients. TCIM has policies and procedures such as the fair allocation policies described in Item 12 to address any conflicts that may arise from such transactions.

TCIM may purchase or sell securities for client accounts in which TCIM or a Related Person may have a position of financial or other interests and may buy or sell for itself securities that it also recommends to client accounts. TCIM has established a variety of restrictions, procedures and disclosures designed to address any potential conflicts of interest that may arise as a result of these arrangements. TCIM, when appropriate, may advise its client accounts to invest in securities that are being purchased by its parent, TIAA. TCIM has an established trade allocation policy to seek to ensure that the purchased securities are allocated fairly. See Item 12. Material Non-Public Information From time to time, TCIM receives material non-public information (“MNPI”) and becomes subject to limitations on its investment activities relating to the possession of MNPI. Under applicable law, TCIM and its personnel are prohibited from improperly disclosing or using MNPI for their own benefit or the benefit of their client accounts. Possession of MNPI could limit TCIM’s ability to transact in affected investments, which could be detrimental to client accounts. TCIM, in its discretion, seeks to employ the use of certain approaches or procedures in an effort to minimize such limitations, but there is no assurance that TCIM will employ such procedures or that such procedures will be effective in alleviating the limitations associated with possessing MNPI. Cross Trades A cross trade occurs when an adviser effects a trade between two or more of its advisory client accounts and does not charge a fee for effecting the transaction. Subject to applicable law, TCIM causes a client account to enter into a cross trade only in cases where it believes that the cross trade would be in the best interests of both selling and buying accounts. Given the fiduciary duty owed to both accounts when effecting such trade, the use of cross trades raises potential conflicts of interest. While raising a potential conflict, TCIM believes that cross trading can be beneficial for client accounts managed by TCIM where appropriate. TCIM expects to employ a pricing methodology that reflects readily available market quotations. TCIM may execute transactions between client accounts and certain other client accounts managed by its affiliates (including the registered funds managed by TAL). Any such transactions will be executed in accordance with Rule 17a-7 under the Investment Company Act and procedures adopted by the TCIM’s Boards of Trustees (as applicable). Neither TCIM nor any broker-dealer affiliated with TCIM receives any commission, transaction fees or other transactional compensation in connection with effecting cross trades. Cases may arise where trading or investment personnel do not know or have reason to know the identity of the other side of a trade prior to execution, which may result in TCIM client accounts selling to other TCIM client accounts. For example, in seeking best execution, TCIM trading and investment personnel at times find it advantageous to use electronic trading platforms (e.g.,

Bloomberg Tradebook, MarketAxess, etc.), which generally seek to provide the best price under the circumstances. These platforms typically match buyers and sellers among a large universe of market participants based on price. TCIM users of such platforms generally do not know or have reason to know the identity of the other side of the trade prior to execution. Additionally, trading or investment personnel may operate independently within different teams and/or for different accounts, asset classes or strategies in which such personnel generally do not know or have reason to know the identity of the other side of the trade prior to execution. TCIM considers the foregoing facts and circumstances, and factors such as the liquidity of the securities, uncoordinated timing of sell/buy transactions and no linkage in transaction fees for sell/buy transactions in determining its treatment of such trades under various regulatory regimes. Capital Structure Conflicts will also arise in cases where different client accounts of TCIM or affiliates of TCIM invest in different parts of an issuer’s capital structure, including circumstances in which one or more client accounts may own private securities or obligations of an issuer and other client accounts may own public securities of the same issuer. For example, a client account may acquire a loan, loan participation or a loan assignment of a particular borrower in which one or more other accounts have an equity investment. In addition, different client accounts may invest in securities of an issuer that have different voting rights, dividend or repayment priorities or other features that may be in conflict with one another. In negotiating the terms and conditions of any such investments, or any subsequent amendments or waivers, TCIM or its affiliates may find that their own interests and the interests of client accounts could conflict. For example, a debt holder may be better served by a liquidation of the issuer in which it may be paid in full, whereas an equity holder might prefer a reorganization that holds the potential to create value for the equity holders. Any of the foregoing conflicts of interest will be discussed and resolved on a case-by-case basis. Any such discussions will take into consideration the interests of the relevant client accounts, the circumstances giving rise to the conflict and applicable laws. Service Provider and Relationship Conflicts TCIM and TCIM’s affiliates (including TIAA) employ a variety of service providers for administrative, technological, operational and other functions that support TCIM’s business activities, including back and middle office administrative functions, such as trade settlement, portfolio accounting, custody reconciliation, corporate actions processing and elections. Outsourcing may give rise to additional conflicts of interest in determining which processes or functions to outsource and which service providers to select. TCIM and TCIM affiliates (including TIAA) have an incentive to utilize service providers that minimize costs and expenses or service providers that have other business, financial or other relationships with TCIM, its parent or affiliates. Certain service providers or their affiliates may also be clients or may be involved in the sale and distribution of the services and offerings of TCIM’s affiliates (including TIAA). From time to time, TCIM may purchase the securities of service providers, clients and business partners in client accounts. Investments in such securities will be based on the investment merits and subject to applicable laws, regulations and client guidelines. TCIM maintains policies designed to

mitigate the conflicts described above; however, such policies may not fully address the situations described above.

Broker–Dealer Selection TCIM is responsible for decisions to buy and sell securities for client accounts as well as for selecting broker-dealers and, where applicable, negotiating the amount of the commission rate paid. It is the intention of TCIM to place brokerage orders with the objective of obtaining the best execution. In evaluating best execution for transactions, TCIM considers a number of factors, including, without limitation, the following: best price; the nature of the security being traded; the nature and character of the markets for the security to be purchased or sold; the likely market impact of the transaction based on the nature of the transaction; the skill of the executing broker; the liquidity being provided by the broker; the broker-dealer’s settlement and clearance capability; the reputation and financial condition of the broker-dealer; the costs of processing information; the nature of price discovery in different markets; the laws and regulations governing investment advisers; and other factors deemed appropriate by TCIM. When purchasing or selling securities traded on the over-the-counter market, TCIM generally will execute the transactions with a broker engaged in making a market for such securities. When TCIM deems the purchase or sale of a security to be in the best interests of one or more client accounts, its personnel may, consistent with its fiduciary obligations, decide either to buy or to sell a particular security for the client account(s) at the same time as for funds or accounts that may be managed by its affiliates. In that event, allocation of the securities purchased or sold, as well as the expenses incurred in the transaction, will be made in an equitable manner. Transactions on equity exchanges, commodities markets and other agency transactions involve the payment of negotiated brokerage commissions. Such commissions vary among different brokers-dealer. Transactions in foreign investments also have negotiated commission rates and they are for the most part the same for all brokers in a particular country with a few exceptions. Trades are regularly monitored for best execution purposes by the equity trading desk. TCIM’s fixed income traders select the broker-dealers (sell-side) with whom they do business independent of any research, strategy pieces or trade recommendations provided to TCIM. The vast majority of institutional fixed income trading is conducted over-the-counter rather than on exchanges, with set prices plus commissions. Fixed income trading is based on the risk-taking practice of market making by sell-side firms, which attempt to capture the bid/ask spread on trades where capital is committed (principal model) or on a pre-negotiated spread concession for riskless principal trades (agency model). The directive to TCIM’s fixed income traders, and the conventional trading construct within the fixed income market, is based on the practice of fiduciary efforts to achieve best execution. The research, credit opinions and relative value trade recommendations provided by broker-dealers

are evaluated, but there is no direct linkage between that evaluation and TCIM’s selection of a particular broker-dealer for trade execution. Client referrals do not play a role in TCIM’s brokerdealer selection process. When selecting a broker-dealer, the traders follow established trading protocols for data aggregation, price discovery, inventory mining and information protection and conduct an assessment of counterparty performance. The protocol incorporates TCIM’s knowledge of and experience with select broker-dealers with respect to providing liquidity, namely the highest bid price or lowest offer price for a particular security. Consistent with best execution, TCIM may place orders with broker-dealers providing research and statistical data services even if lower commissions may be available from broker-dealers not providing such services. Best execution is not evaluated on a transaction-by-transaction basis, but on an overall basis over an extended period of time. Centralized Trading Desks TCIM employs the use of shared trading desks and multi-hatted personnel (including most trading for equities, taxable fixed income securities, and municipal bond new issues) that trade for client accounts as well as the accounts of affiliates. These desks and personnel face conflicts, such as in trade sequencing and allocating opportunities in trading for clients of different affiliates. These conflicts are similar to the conflicts they face in providing services to clients (including affiliated and proprietary accounts) of a single investment adviser. Through its policies, procedures and practices, TCIM seeks to provide for the fair and equitable treatment of its and its affiliates’ clients. See Item 10. Best Execution Committee and Risk Management Oversight TCIM exercises oversight and policy making responsibility for TCIM’s equity and fixed brokerage practices through one or more committees that meet periodically. Transaction and broker-dealer metrics are reviewed by the Equity or Fixed Income Best Execution Committee, as appropriate. Additionally, every broker is formally approved by the committee which is comprised of representatives from trading, portfolio management, compliance, and law. Risk management also reviews the creditworthiness of all broker-dealers. Affiliated Broker-Dealers TCIM does not use affiliated broker-dealers to execute any trades or clear any securities on its behalf. Prohibition on Directed Brokerage Arrangements As a practice, TCIM does not engage in directed brokerage arrangements. Transactions for Initial Purchase of Equity or Debt Instruments Transactions involving the initial purchase of equity or debt instruments generally involve an investment banker that charges a fee to the issuer of the equity or debt securities. TCIM does not directly pay a fee or negotiate the fee.

Research and Services Provided by Broker-Dealers TCIM generally has authority to cause a client account to pay a broker-dealer a commission higher than that which another broker-dealer might have charged for effecting the same transaction (a practice commonly referred to as “paying up”), in recognition of the value of the brokerage and research products and services (“Research Services”) the broker-dealer provides. The brokerdealer may directly provide Research Services to TCIM or may purchase them from a third party for TCIM. In such cases, TCIM is in effect paying for the Research Services with client commissions - so-called “soft dollars.” When TCIM uses soft dollars to obtain Research Services, TCIM receives a benefit because it does not have to produce or pay for the Research Services. TCIM will only cause an account to pay up if TCIM, subject to its overall duty to seek best execution, determines in good faith that the Research Services are eligible brokerage and research under Section 28(e) of the Securities Exchange Act of 1934, and the amount of the commission is reasonable in relation to the value of the Research Services provided, viewed in terms of either that particular transaction or the overall responsibilities of TCIM or its affiliates in managing its client’s accounts. TCIM uses commission sharing arrangements administered by its centralized equity trading desk. Under these arrangements, when TCIM pays a commission to an executing broker, a portion of the commission is for execution of the trade (brokerage) and a portion is for Research Services. The broker will allocate the Research Services portion of the commission to a pool of commission credits it maintains. The commission manager, at TCIM’s direction, pays Research Services providers for Section 28(e)-eligible research products and services (“Commission Sharing Arrangements”). An executing broker may or may not be a Research Services provider. TCIM uses Commission Sharing Arrangements to pay for both proprietary and third party Research Services. Additionally, TCIM may pay for Research Services directly with hard dollars. The centralized equity trading desk does not select Research Services. Under TCIM’S Commission Sharing Arrangements, most or all teams within Nuveen Equities (the integrated equity investment team of TCIM and certain affiliates) aggregates commission credits into a single pool and allocates the Research Services among the respective Nuveen Equities investment teams based on factors such as asset size of the team’s equity strategy. Research Services obtained through soft dollars generally consists of products and services including some or all of the following: economic analysis and forecasts, financial market analysis and forecasts, industry and company specific analysis, interest rate forecasts, arbitrage relative valuation analysis of various debt securities, analytical tools for investment research and related consulting services, meetings arranged by broker-dealers with corporate management teams and spokespersons, as well as industry spokespersons, access to broker-dealer conferences, and other reports, meetings and services that assist in the investment decision-making process. TCIM will use Research Services to benefit any client account or its affiliates and at times the Research Services will not directly benefit the particular client account(s) that generated the brokerage commissions used to acquire the Research Services. For example, TCIM uses client

account equity commissions to pay for Research Services that at times will benefit other client accounts of TCIM and its affiliates. Also, some TCIM portfolio management, research and trading personnel are multi-hatted employees of one or more affiliated advisers. These employees use Research Services in providing advisory services to the affiliated adviser’s accounts, and vice versa. The Research Services that TCIM receives from broker-dealers supplement TCIM’s own research activities. As a practical matter, in some cases TCIM could not, on its own, generate all of the Research Services that broker-dealers provide without materially increasing its expenses. Soft dollar arrangements create a potential conflict by giving TCIM an incentive to trade frequently to generate commissions to pay for Research Services, which may not be in the best interests of client accounts. In some cases, TCIM has an incentive to trade actively in certain client accounts to obtain Research Services used primarily by other, less frequently traded client accounts. When TCIM uses soft dollars to obtain Research Services, TCIM receives a benefit because it does not have to produce or pay for Research Services and TCIM may have an incentive to select or recommend a broker-dealer based on its own interest in receiving the research or other products or services rather than on CREF’s interest in receiving the most favorable execution. TCIM may cause client accounts to pay commissions higher than those charged by other broker-dealers in return for softdollar benefits. TCIM attempts to mitigate these potential conflicts through its review and oversight of the use of commissions. In certain instances, Research Services providers provide Research Services directly to TCIM which has been created by an affiliate of the broker-dealer or an independent third-party, so-called “co-branded” research. TCIM also receives Research Services from broker-dealers in connection with certain “eligible riskless principal transactions.” TCIM does not allocate soft dollars to broker-dealers in exchange for so-called “mixed use” products or services. From time to time, a small amount of Research Services is accessed by noninvestment related personnel. TCIM considers such usage by non-investment related personnel to be de minimis. TCIM periodically reviews the usage of all soft dollar arrangements to determine new/on-going mixed-use applicability. At least annually, TCIM reviews the amount, nature and quality of the Research Services, and sets non-binding total commission targets intended to be used to pay for certain research products and services under the Commission Sharing Arrangement. Quarterly, TCIM reviews the amount and nature of Research and sets Commission Sharing Arrangement targets for the Research Services providers on the basis of such considerations. If the Commission Sharing Arrangement target is met for the quarter, commissions default to an execution-only rate. The designation of such targets, and the receipt of soft dollars benefits generally, creates an incentive for TCIM to direct brokerage based on its interest in receiving such soft dollars benefits rather than on its clients’ interest in receiving most favorable execution. TCIM’s policies and procedures, and the disclosure provided herein, seek to mitigate such conflict. TCIM does not acquire Research Services when it trades fixed income (including municipal bond) securities and the broker-dealer is acting as principal. However, at times, a broker will provide

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TCIM does not participate in referral arrangements for its client accounts. In the ordinary course of business, TCIM or a Related Person provides business gifts, meals and entertainment such as tickets to cultural and sporting events to personnel of firms that do business with TCIM or its affiliates. Such gifts, meals and entertainment provided by TCIM, or a Related Person, generate a conflict of interest to the extent that they create an incentive for the recipient or beneficiary to use, recommend, offer or include products or services of TCIM. In the ordinary course of business TCIM employees also are the recipients of corporate gifts, meals, and entertainment. TCIM’s receipt of gifts, meals and entertainment generates a conflict of interest to the extent that they create an incentive for the recipient or beneficiary to use the services of the provider (e.g., in the case of a broker-dealer, brokerage services) of the gifts, meals and entertainment. The giving and receipt of gifts and other benefits are subject to reporting and limitations under internal policies and procedures.

There are no legal or disciplinary events that are material to CREF’s evaluation of, or the integrity of, TCIM or its management persons.

TCIM’s only client is CREF which consists of eight investment portfolios, but which may consist of additional portfolios in the future. The portfolio managers, or their designee, review on a coordinated basis TCIM’s client accounts for which they are responsible. The CREF/VA-1 Oversight Committee (“CREF OC”) is an internal management committee established as a subcommittee of Nuveen Risk Management Committee (the “Nuveen RMC”) to oversee the investment risk, and compliance risk profiles, the design and implementation of risk management and compliance frameworks, and to report up to Nuveen RMC in fulfilling its risk and compliance oversight responsibilities for TCIM. The CREF OC includes representatives from Public Markets Risk Management, Operational Risk, Compliance, Valuations, Legal, Product Management, Fund Administration, and Operations/Information Technology. The portfolio managers are responsible for managing each portfolio according to its specific investment objectives. Portfolio managers review on a continuous basis all CREF investment portfolios for which they are responsible, and the members of the Investment Committee monitor the performance of the portfolios. Analysts and traders may also be part of this review process, as appropriate. When the CREF investment portfolios are reviewed, the portfolio manager considers various matters, including any changes in firm policy or the objectives and needs of the client account; changes in market conditions or changes of security positions; the current structure of the portfolio and the effect on the portfolio of any known additions or withdrawals from the portfolios in the future. In particular, TCIM monitors CREF portfolios daily and reports on the investment performance of CREF to the Board of Trustees at regularly scheduled meetings. TCIM provides CREF and the Board of Trustees with periodic written reports, at least quarterly, that may include, among other information, holdings and transaction information, performance and attribution analysis, brokerage allocation, soft dollar information, accounting data, portfolio reviews, reviews of diversification, and distribution information, as well as additional information or reports as requested by the Board of Trustees. Fund investors receive shareholder or investor reports in accordance with the terms, conditions, and regulatory requirements applicable to the client account.

TCIM does not have custody of client account assets. As mentioned previously, TCIM’s only client is CREF, a registered investment company. The portfolio securities of CREF are held with third-party qualified custodians. From time to time an issuer of a security may make a distribution of a non-traditional asset, such as a digital token. The acceptance of such assets into the client’s custodial account is subject to the ability of the client’s custodian to custody such assets and the terms and conditions thereto, TCIM’s good faith determination of the value of the asset, and other investment, business, legal/regulatory, operational and/or administrative considerations. To the extent that acceptance of such distribution requires TCIM to take certain actions, TCIM reserves the right to take action or refrain from taking action based on its consideration of the foregoing factors and its assessment of the costs and benefits of the distribution.

TCIM is responsible for decisions to buy and sell securities for its client’s accounts. TCIM’s authority is subject to certain limits, including the client account’s investment objectives and policies as well as regulatory constraints. Such investment limitations are set forth in the CREF registration statement filed with the SEC. Also, TCIM’s authority to trade securities for its client, CREF, may also be limited by certain federal securities and tax laws. See Item 4.

TCIM is generally authorized to vote proxies for its client accounts, which includes exclusively registered investment company clients, as part of its duties as a discretionary investment adviser. TCIM does not vote proxies where CREF withholds proxy voting authority or in certain other circumstances summarized below. TCIM votes proxies in accordance with its policies and procedures in effect from time to time. Nuveen’s Proxy Voting Committee (“PVC”) provides a governance framework to facilitate and monitor TCIM’s exercise of proxy voting and to fulfill obligations of reporting and recordkeeping under federal securities laws. TCIM has adopted proxy voting guidelines which are reasonably designed to ensure TCIM votes proxies in the best interests of its client accounts. TCIM leverages the expertise and services of an internal group within Nuveen, the Nuveen Stewardship Group, to provide proxy voting recommendations and administer TCIM’s proxy voting activities. Depending on the issue, the Nuveen Stewardship Group considers the research and recommendations of one or more proxy advisors to help formulate its substantive positions on recurring proxy issues and criteria for addressing non-recurring issues. TCIM maintains the fiduciary responsibility for all of its proxy voting decisions. From time to time, a TCIM portfolio manager or research analyst may initiate action to override the Nuveen Stewardship Group’s recommendation for a particular vote. Any such override will be reviewed for material conflicts. TCIM’s policy permits it to refrain from voting in certain circumstances, including where it determines that it would be in the client account’s overall best interest not to vote (e.g., where proxy voting would result in a financial, legal, regulatory, or operational encumbrance or burden that outweighs the potential benefit to the client account of voting); with respect to securities on loan through a securities lending program; and with respect to legacy securities and securities in accounts where TCIM’s advisory services have been terminated. In special circumstances, TCIM may vote a proxy based on instructions of CREF or its representative. TCIM’s ability to vote proxies is subject to timely receipt of the proxy from CREF’s proxy advisory firm, custodian, or other party, and, in the case of proxies relating to certain nonU.S. securities, subject to the establishment by applicable parties of any necessary local documentation (e.g., power of attorney). Equity Securities - TCIM will vote equity securities in accordance with its policies and procedures discussed above. Fixed Income Securities - A client account may indirectly acquire equity securities that issue proxies. For example, a client account may acquire, directly or through a special purpose vehicle, equity securities of a bond obligor whose bonds are already held in a client’s account when such bonds have deteriorated or are expected shortly to deteriorate significantly in credit quality. The purpose of acquiring equity securities generally will be to seek to prevent the credit deterioration or facilitate the liquidation or other workout of the distressed issuer’s credit problem. In the course

of exercising control of a distressed issuer, TCIM may pursue the client account’s interests in a variety of ways, which may entail negotiating and executing consents, agreements and other arrangements and/or otherwise influencing the management of the issuer. TCIM does not consider such activities proxy voting for purposes of Rule 206(4)-6 under the Advisers Act. In the rare event that a fixed income issuer were to issue a proxy, TCIM would generally vote in accordance with its policies and procedures. TCIM recognizes that there are circumstances where it has a perceived or real material conflict of interest in voting the proxies of issuers. TCIM seeks to vote proxies in the best interest of its client accounts regardless of such real or perceived material conflicts of interest and attempts to minimize this risk by establishing reasonable procedures to identify and monitor such conflicts of interest. If it is concluded that a material conflict exists, the Nuveen Stewardship Group will normally vote the proxy in accordance with a proxy advisory firm’s benchmark recommendation. To the extent the Nuveen Stewardship Group believes there is a justification to vote contrary to the proxy advisory firm’s benchmark recommendation, such requests are escalated to the PVC for evaluation and mitigation. TCIM’s proxy voting policies are available upon written request to: Stuart Brunet, Chief Compliance Officer, TIAA-CREF Investment Management, LLC, 560 Mission Street, 9th Floor, San Francisco, CA 94105. A record of all proxy votes cast is updated weekly and available at: https://vds.issgovernance.com/vds/#/MTIwODY=

TCIM does not require or solicit prepayment of more than $1,200 in fees per client account six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. TCIM is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to CREF, nor has TCIM been the subject of a bankruptcy petition at any time during the past ten years.

Exhibit A Primary Financial Industry Subsidiaries under Nuveen, LLC, the investment management division of TIAA Entity Name

Primary Financial Industry or Related Affiliation* U.S. Registered Investment Advisers & Broker Dealers

Brooklyn Investment Group, LLC Churchill Asset Management LLC Churchill DLC Advisor LLC Churchill NCPE Advisor, LLC Churchill PCIF Advisor LLC Gresham Investment Management LLC

Registered Investment Adviser Registered Investment Adviser Registered Investment Adviser Registered Investment Adviser Registered Investment Adviser Registered Investment Adviser CFTC Registered Commodity Pool Operator CFTC Registered Commodity Trading Adviser Nuveen Alternatives Advisors, LLC Registered Investment Adviser Registered Investment Adviser CFTC Registered Commodity Trading Adviser Nuveen Asset Management, LLC Nuveen Fund Advisors, LLC Registered Investment Adviser Snowhawk LP Registered Investment adviser Teachers Advisors, LLC Registered Investment Adviser TIAA-CREF Investment Management, LLC Registered Investment Adviser Winslow Capital Management, LLC Registered Investment Adviser Nuveen Securities, LLC Registered Broker Dealer Non-U.S. Investment Affiliates Arcmont Asset Management Limited UK FCA Registered Entity Clean Energy Partners LLP UK FCA Registered Entity Glennmont Asset Management Limited UK FCA Registered Entity Glennmont Partners I Limited UK FCA Registered Entity Nuveen Investment Management International Limited UK FCA Registered Entity Nuveen Management AIFM Limited UK FCA Registered Entity Nuveen Alternatives Europe SARL Luxembourg CSSF Registered Entity Nuveen Asset Management Europe SARL Luxembourg CSSF Registered Entity Nuveen Australia Limited Australian ASIC Registered Entity Nuveen Canada Company Canadian Exempt Market Dealer Nuveen Middle East Limited ADGM FSRA Registered Entity Nuveen Japan Co. Ltd Japan FSA Registered Entity Nuveen Hong Kong Limited HK SC Registered Entity Nuveen Singapore Private Ltd Singapore MAS Registered Entity Other Nuveen Affiliates Greenworks Lending LLC Relying Adviser Greenwood Resources Capital Management LLC Forestry Management Nuveen Natural Capital, LLC Forestry, Farmland, Real Estate Management Westchester Group Investment Management, LLC Farmland Management Westchester Group Real Estate, LLC Real Estate Broker or Dealer Symphony Alternative Asset Management LLC Relying Adviser Nuveen Services, LLC Shared Services Entity Other Primary Financial Industry TIAA Subsidiaries TIAA-CREF Individual & Institutional Services, LLC Registered Investment Adviser (aka Advice and Planning Services) Registered Broker Dealer Registered Investment Adviser TIAA-CREF Tuition Financing, Inc. Registered Municipal Advisor TIAA Kaspick, LLC Registered Investment Adviser TIAA Wealth Investment Management, LLC Registered Investment Adviser Teachers Insurance and Annuity Association of America Insurance Company or Agency TIAA-CREF Insurance Agency, LLC Seven30 Re (Bermuda) Co. Limited

Insurance Company or Agency Insurance Company or Agency

Seven30 Insurance (Bermuda) Co. Limited TIAA Trust, N.A.

Insurance Company or Agency Banking or Thrift Institution

*The list above refers to TIAA subsidiaries in financial industry affiliation categories referenced in Form ADV, Part 2A, Item 10.C, excluding numerous entities organized primarily to serve as sponsor, general partner, managing member (or equivalent) or syndicator of one or more pooled investment vehicles or limited partnerships (or equivalent). For a list of such entities that have material arrangements with TCIM, please see the TCIM’s Form ADV, Part 1, Section 7.A. of Schedule D. The list above refers to the primary financial industry affiliation category and certain TIAA subsidiaries listed above may have additional financial industry affiliations, as further described in its respective disclosure documents (Form ADV, in the case of a registered investment adviser).