PGIM, Inc.: investment adviser

In addition, any references to “our employees” or “our officers” mean officers or employees of PGIM, PGIM Fund Management, PGIM Luxembourg and their affiliates who work in PGIM Real Estate. In addition to PGIM Real Estate, the other advisory units within PGIM are PGIM Credit (an adviser primarily focused on public and private fixed income investments) and PGIM Strategic Capital Group (an advisor providing multi-asset and portfolio-level investment advisory services). These units have a separate brochure that has been filed with the SEC and provides information about the applicable advisory businesses. PGIM was formed in June 1984 and was registered with the SEC as an investment adviser in December 1984. PGIM’s predecessor companies began managing fixed income portfolios for affiliates in 1875. In addition to being a registered investment adviser, PGIM, Inc. is also registered with the U.S. Commodity Futures Trading Commission as a commodity trading advisor and commodity pool operator and is a member of the National Futures Association. PGIM Fund Management was incorporated in 1996 and is authorized and regulated by the UK Financial Conduct Authority (“FCA”) as an Alternative Investment Fund Manager and permitted to manage and market discretionary mandates, provide investment advice, and receive and transmit orders in relation to financial instruments. PGIM Luxembourg was founded in 1988 and is authorized and regulated by the Luxembourg Commission de Surveillance du Secteur Financier (“CSSF”) as an Alternative Investment Fund Manager for the purposes of the European Alternative Investment Fund Managers Directive (“AIFMD”). In addition to managing and advising alternative investment funds, its authorization by the CSSF allows it to perform discretionary portfolio management services, provide investment advice, and receive and transmit orders in relation to financial instruments, in accordance with Article 5, paragraph 4 of the Law of 12th July 2013 of alternative investment managers. PGIM, PGIM Fund Management and PGIM Luxembourg, along with their affiliates referenced herein are indirect, wholly owned subsidiaries of Prudential Financial, Inc., a publicly held company (“Prudential Financial”) (NYSE Ticker: PRU) headquartered in the State of New Jersey, U.S.A. None of Prudential Financial, PGIM, PGIM Private Fund Management, PGIM Luxembourg or any of their affiliates referenced herein is affiliated in any manner with Prudential plc, incorporated in the United Kingdom, or with The Prudential Assurance Company Limited or Prudential Distribution Limited, subsidiaries of M&G plc, incorporated in England and Wales.

PGIM Real Estate PGIM Real Estate is a global real estate investment advisor, headquartered in Newark, New Jersey. We have offices across the United States as well as in Abu Dhabi, Amsterdam, Frankfurt, London, Luxembourg, Munich, Milan, Paris, Mexico City, Hong Kong, Seoul, Singapore, Shanghai, Sydney and Tokyo. As of December 31, 2025, PGIM Real Estate managed approximately $95.4 billion in gross assets $60.2 billion (net) on investors worldwide. Of this net amount, approximately $59.3 4 PGIM Real Estate FORM ADV PART 2A

billion is managed on a discretionary basis, and $0.8 billion (net) is managed on a non-discretionary basis. The investment strategies that we employ for our clients span private real estate, private real estate debt and publicly traded real estate securities across the risk and return spectrum (from core through core plus and value add to opportunistic) and geographically across the United States, Asia Pacific, Europe and Latin America. Our investment products generally comprise separately managed accounts and open- and closed-ended commingled private funds and are typically structured as limited partnerships, private REITs, insurance company separate accounts and other taxefficient vehicles. We also provide discretionary and non-discretionary investment advisory services to affiliated and unaffiliated clients both directly, through express contractual relationships, and indirectly, pursuant to sub-advisory arrangements with affiliated and unaffiliated investment advisers. In addition to offering investment products and advisory services, we also prepare research, reports, and investment papers dealing with investment matters that are distributed to clients, certain prospective clients and affiliates. Our investment advisory business does not include the private commercial real estate finance business carried on by PGIM Real Estate Finance, LLC (“PGIM REF”), which is an affiliate of PGIM but is not a registered investment adviser and does not provide investment advice regarding securities to any PGIM clients. Through an internal arrangement with PGIM Real Estate, PGIM REF sources and originates commercial real estate loans on behalf of certain accounts managed by PGIM Real Estate. Several officers of PGIM REF are also officers of PGIM and provide services to PGIM Real Estate in their capacities as officers of PGIM that are separate and distinct from the services they provide as officers of PGIM REF.

Fees and other compensation are generally negotiable, so it is possible for one client to pay a different amount of fees or other compensation than another client with similar investment objectives or goals, though clients invested in the same investment fund typically pay fees based on the same rate schedule. Compensation structures will at times include base management fees, acquisition fees, disposition fees and cash management fees. They will at times also include incentive or performance-based compensation (also referred to as promote and carried interest) in the form of fees, dividends or other forms of distributions or interest payments. Our base management fees for investments in funds that we manage are customarily offered in tiered schedules with breakpoints linked to, for example, the amount of assets invested in or committed to the fund, so that the fee rate paid by a client decreases as the client’s assets under management increase. In circumstances where a single client has or related party clients have multiple accounts with us, we will at times agree with such client to aggregate the client’s assets within those accounts to enable the client to benefit from a lower fee rate. Similarly, where a discretionary investment consultant advises more than one client who in turn have more than one account with us, we will at times aggregate the assets held by the consultant’s clients within their accounts with us to enable those clients to benefit from a lower fee rate. Our performance-based compensation arrangements are structured to comply with Rule 205-3 under the Investment Advisers Act of 1940 and our internal policies addressing such arrangements. Fees and other compensation paid by clients that pay performance-based compensation will at times be higher than those paid by clients who do not, due to the fact that performance-based compensation will at times increase based on the performance of a portfolio. 5 PGIM Real Estate FORM ADV PART 2A

Payment of Fees and Other Compensation We either bill a client for our fees or deduct fees from the client’s account. Base management fees are typically payable monthly or quarterly in arrears. Performance-based fees and compensation are only paid after the applicable performance has been achieved and the related fee or other compensation is due. We do not require or solicit clients to pay fees in advance. If a client were to pay fees in advance and the client’s contract were to terminate before the end of a billing period, any prepaid fees that do not otherwise represent amounts due and payable by the client would be refunded on a pro-rata basis.

Compensation of Our Investment Professionals Generally speaking, the compensation of our investment professionals (including, among others, portfolio managers and research analysts) includes a combination of base salary, a performance-based annual cash incentive bonus, and a long-term incentive grant. Investment professionals sometimes also participate in performance-based fees or compensation payable by our clients. The base salary component is based on market data relative to similar positions within the industry as well as the past performance, experience, and responsibility of the individual, and the annual cash incentive bonus is paid from an annual incentive pool. Each investment professional's incentive compensation, including both the annual cash incentive bonus and the long-term incentive grant, is primarily determined by how significantly he or she has contributed to delivering investment performance to clients consistent with relevant objectives, guidelines, and risk parameters, as well as the individual’s qualitative contributions to the organization. Our incentive compensation program is designed to align the interests of each investment professional with those of our clients. The performance of our clients’ accounts, of our overall business, and of the individual employee are all important factors in determining the size of the annual cash incentive bonus and long -term incentive grant awarded to each individual. Total compensation is designed to be competitive with the market, but an individual’s actual compensation will at times vary. Long-term incentive grants to investment professionals are made in the form of 80% deferred cash that tracks the performance of funds tied to the grant and 20% in restricted stock units (RSUs) of Prudential Financial, Inc. These long-term incentive grants vest over a three-year period. Investment professionals are all covered by the same general compensation structure, although they will at times manage multiple accounts. Generally, all compensation is paid by PGIM Real Estate, not from any client assets. However, where a portion of the performance-based fees and other compensation that we earn is typically shared with relevant investment professionals and members of senior management, such amounts will be paid to the individuals concerned directly or indirectly from such performance fees paid by the relevant client. The head of PGIM Real Estate and certain senior members of the management team also receive performance shares which represent the right to receive shares of Prudential Financial common stock conditioned upon, and subject to, the achievement of specified financial performance goals by Prudential Financial. Each of the long-term incentive plan grants and performance shares are subject to vesting requirements.

Operating Expenses The funds and vehicles that we manage or advise, and therefore the investors in those funds and vehicles, will also be generally responsible for operating expenses which might include some or all of the following: (i) fees, costs and expenses relating to the operation of the fund or product, including those of all specialist professionals and advisers, such as accountants, auditors, appraisal management firms, fund administrators, lawyers, brokers, compliance firms, investment and financial advisers and consultants and other third party service providers engaged to provide services to or in respect of the fund or product; (ii) fees, costs and expenses relating to the researching, analyzing, investigating, evaluating, negotiating, structuring, acquisition, ownership and disposition of investments or potential investments, including fees, costs and expenses related to holding, leasing, financing, refinancing, development, due diligence, property management, 6 PGIM Real Estate FORM ADV PART 2A

repairs, improvements, asset monitoring, insurance, consulting, engineering, environmental inspection, indemnification, appraising, dead deal costs, structural and environmental studies, investment banking, reporting, projections, valuation, tax and accounting expenses and other similar fees, costs and expenses of the general partner, manager or third parties engaged to perform such functions related to any investment, regardless, in the case of potential investments, of whether any potential investment is actually consummated (including any travel, accommodation and meal expenses); (iii) brokerage commissions, transfer agent expenses, custodial fees, costs and expenses and other fees, costs and expenses incurred in connection with investments; (iv) principal, interest on and any fees, costs expenses and liabilities arising out of all borrowings, financing, or refinancing arrangements; (v) fees, costs and expenses for maintaining bank accounts and of any depositary, custodian, administrator, and other firms providing any other back-office services; (vi) fees, costs and expenses related to offering and sale of units or other interests (including legal fees, travel expenses and the costs and expenses incurred in preparing and periodically updating a private placement memorandum or equivalent documents or in obtaining tax and legal opinions); (vii) fees, costs and expenses related to developing, implementing or maintaining information technology services, systems and software for the benefit of the fund or product, including databases, data subscription services, license based services, research publications and materials and computerized systems for specialized or customized services and document management functions; (viii) fees, costs and expenses arising from investor record-keeping and financial reporting and requests for information; and (ix) other fees, costs and expenses incurred in the formation, operation and maintenance of the fund or product and of related entities (including legal and accounting expenses, filing fees and expenses, printing costs, and investment advisory services or reporting performed by third-party vendors at our direction and under our supervision). Such fees, costs and expenses will include amounts incurred by us and which are then reimbursed to us by the relevant fund or other client. A more detailed discussion of the operating expenses associated with a particular fund or vehicle offered by us can be found in the offering documents for such product, which are available upon request.

Operating and Joint Venture Partners Expenses Operating or joint venture partners or co-investors investing in assets in conjunction with a client, or assisting with the sourcing, management or disposition of investments for a client, will at times receive management fees, acquisition fees, disposition fees or incentive fees or other compensation for their services as a means to further align the interests of those partners with the relevant clients. Such fees are typically paid as an operating expense by the relevant client.

Allocation of Private Real Estate Investments PGIM Real Estate allocates investment opportunities among investors and funds using rotational investment allocation procedures that are intended to ensure the fair and equitable allocation of investment opportunities among competing client accounts over time. Subject to any priority allocation rights that exist, private real estate investment opportunities are typically offered to those clients for whom the investment is a suitable one (taking into account that client’s investment objectives and strategy) in the order in which they sit in a queue at the relevant time. Where we agree to allocate certain types of investments sourced by us in priority to a particular client, the relevant 7 PGIM Real Estate FORM ADV PART 2A

investments would only be offered to other clients for whom the investment is a suitable one once the portfolio manager for the client with the priority allocation right has turned down the relevant investment opportunity. Priority allocation rights are typically only agreed to in relation to more specialized investment types (such as senior housing, data centers, certain higher yielding investments and impact investing), where a new investment has an economic or other connection to an existing investment such that offering the new investment to the same investor as the existing investment is reasonably appropriate, or where we are satisfied that the granting of such rights will not adversely impact our ability to identify and allocate relevant investments to other clients for whom such investments would be suitable. We disclose any priority allocation rights in advance to new clients from whom we subsequently secure mandates in respect of the relevant type of investment.

Allocation of Aggregated Orders of Publicly Traded Real Estate Securities Neither the PGIM Fund Management nor PGIM Luxembourg entities participate in allocation decisions for the public securities portfolios we manage. When we place an aggregated order in respect of a particular security on behalf of more than one client, the securities purchased are typically allocated pro-rata, subject to account restrictions or guidelines or based on the relative size of the relevant client portfolios. Under such pro-rata allocation, each client pays the average unit price and bears its pro-rata share of transaction costs. Deviations from a pro-rata allocation will at times be made on the basis of certain specified conditions including if (i) an allocation would cause a client to receive an odd lot or “de minimis” amount, (ii) the portfolio manager determines that the relevant client portfolio’s cash flow does not support an allocation, (iii) a client portfolio has a specialized investment mandate or style, or specific investment restrictions, (iv) a client has unique tax considerations, (v) positions for multiple clients need to be balanced or (vi) clients are excluded due to client directive or regulatory requirements. Any allocation that is not pro-rata must still be consistent with fair and equitable treatment of all clients and is approved by the portfolio manager signing off on the allocation rationale as soon as possible and typically not later than the opening of the applicable securities market on the following trading day. In addition, any allocation rationale is memorialized in writing and is retained consistent with our record-keeping requirements.

estate investment trusts (or FIBRAs), Mexican pension funds (or Afores), Undertakings For The Collective Investment of Transferable Securities (UCITs), Societes d’Investisement a Capital Variable (SICAVs), and high net worth individuals. The minimum account sizes vary by investment strategy, with separately managed accounts and funds of one typically having higher investment minimums than investments in commingled funds. We can waive these minimums at our discretion. Affiliated clients and certain other clients can request and receive greater transparency, operational support, training, or other resources, as permitted under applicable law.

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The Investment Research Team then works closely with the Portfolio Management Teams in an ongoing and cooperative fashion, developing portfolio strategy, investment underwriting, sector and market targets, real estate cycle, hold/sell analysis and market analysis in support of the investment program for a client. Private real estate equity and debt investments span the risk spectrum from core through core plus and value add to opportunistic. These labels are not necessarily consistently used across the real estate industry. The key characteristics of each such type of investment are set out below.

Core Core investment strategies generally target the major property types (office, industrial, residential, and retail) to provide investors with returns driven primarily by stabilized income. Core real estate equity strategies focus on properties with sustainable income from the property and credit quality tenants on longer -term leases. Such properties include assets undergoing minor renovation or expansion where there is a relatively low impact on the property’s occupancy or operation. Core real estate debt strategies fund properties that offer stabilized income by focusing on more conservative credit profiles in terms of loan-to-value, debt service coverage, sponsor quality and strength.

Core Plus Core Plus investment strategies target higher income-focused returns for investors. Core Plus real estate equity strategies identify opportunities to increase net operating income over time and will likely include elements of light income transition. For instance, upcoming lease expiries that provide an opportunity to increase rents. Core Plus real estate debt strategies provide enhanced income from funding stabilized and light transitional real estate and typically feature an elevated credit profile as compared to Core real estate debt investments or some element of subordination, for instance when providing junior loans.

Value Add Value Add investment strategies target higher total returns, typically with a greater element of capital growth. Value Add real estate equity investments seek to meet under-served market needs through asset transition strategies such 9 PGIM Real Estate FORM ADV PART 2A

as lease-up, renovation or development. They will at times target emerging property types or markets where significant new demand is anticipated and employ higher leverage to enhance investor returns. Value Add real estate debt investments fund similar types of real estate while offering downside collateral protection with preferred returns that are structured in priority to sponsor equity. Typical investment structures include mezzanine, junior debt or preferred equity investments that will at times include some element of upside participation through loan fees, incentive fees or equity co-investment.

Opportunistic Opportunistic investment strategies target capital growth and move even further up the risk spectrum, with the anticipation of even greater returns. Opportunistic strategies typically target specific market niches and will at times focus on recovering, developing or emerging markets and include investments in speculative developments, private real estate companies or other investment opportunities such as non-performing loan portfolios. Significant leverage will at times also be employed for such strategies to enhance returns.

Public Real Estate Securities Our investment analysis for publicly-traded real estate securities employs a top- down, bottom-up value-oriented approach based upon real estate fundamentals. We emphasize both quantitative and qualitative investment analysis and adhere to a disciplined, research-intensive approach. We focus on valuation relative to the company’s underlying real estate assets (NAV) as well as the company’s on-going concern valuation. Through detailed company research that includes regular management visits, property tours and financial analysis, we analyze the quality and sustainability of real estate asset cash flows and growth of company dividends. We also evaluate the company’s strategy and its management’s track record and incentives. Our Real Estate Securities (“Real Estate Securities”) team establishes geographic portfolio allocations across Europe, Asia and North America and approves risk characteristics and parameters for each portfolio regularly. The Real Estate Securities investment strategies combine top-down fundamental company research with bottom-up stock selection and a focus on risk management. Investment strategies are determined based on income and capital appreciation objectives and typically invest in real estate investment trusts (REITs) or real estate operating companies (REOCs) that will at times pursue a combination of the investment strategies identified above.

Risks Set forth below are some of the primary risks that we believe are representative of investments in commercial and agricultural real estate equity, debt and securities or primary risks of engaging PGIM Real Estate to manage or advise on those investments. A more detailed discussion of the specific risks associated with investing in a particular product offered by us can be found in the offering documents for such product, which are available upon request. However, it is impossible to identify all of the risks associated with investing and the tolerance for particular risks applicable to an investment will depend on the nature of the client, its investment strategy and the types of investments held. While we seek to manage accounts so that the risks are appropriate to the strategy, it is impossible- and typically not desirable- to fully mitigate all risks. Any investor contemplating direct or indirect investment in real estate, real estate debt or real 10 PGIM Real Estate FORM ADV PART 2A

estate securities must recognize that such investments are not guaranteed and involve potentially significant risk of loss, which the investor must be prepared to bear. An investor in a particular investment or portfolio of investments could not achieve its investment objective or even receive any return on its investment. Performance can be volatile, and an investor can lose their entire investment. Past performance and activities provide no assurance of future results. In addition, fees and expenses will also reduce investment returns.

Value of Real Estate Investments Generally The value of commercial real estate and agricultural real estate can be calculated several ways: discounted projected cash flows, net income divided by a cap rate, and price per square foot or unit as compared to similar properties in the same market. Assumptions used to calculate values are somewhat subjective and can evolve over the life of the ownership of an asset due to changes in the market or in the individual asset. The value of an individual property can be positively or adversely affected by any number of applicable factors, including, without limitation:

the age, design and construction quality of the property;

perceptions regarding the safety, convenience and attractiveness of the property;

the proximity and attractiveness of competing properties;

the adequacy and effectiveness of the property’s operations, management and maintenance;

increases in operating expenses at the property and in relation to competing properties;

an increase in the capital expenditures needed to maintain the property or make improvements;

costs associated with environmental liabilities or other legal liabilities;

the dependence upon a single tenant, or a concentration of tenants in a particular business or industry;

a decline in the financial condition of a major tenant;

an increase in vacancy rates;

a decline in rental rates as leases are renewed or entered with new tenants; and

development or construction risk such as entitlements or other approvals to build not being obtained or not being obtained in a timely manner, or the development or construction not being completed on time, within budget, or in accordance with plans and specifications, and the availability of financing on favorable terms.

Other more general factors that can adversely impact the value of a real estate investment include:

national, regional or local economic conditions;

local real estate conditions (such as an oversupply of competing properties, rental space or multifamily housing and tenant demand);

demographic factors;

technology;

decreases in consumer confidence;

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changes in prices for key commodities or products;

changes in consumer tastes and preferences, including the effects of adverse publicity;

retroactive changes in building codes, or other changes in governmental regulations, fiscal policy, zoning or tax laws;

force majeure acts, terrorist events, natural disasters, climate change, public health emergencies, including existing or new epidemic diseases, and other factors which are beyond our reasonable control; and

cyber-attacks including, for example, malware, ransomware or theft of sensitive data.

The volatility of the net operating income of a property will be influenced by many of the foregoing factors, as well as by:

the property’s resiliency to technological, environmental, social and governance factors,

the length of tenant leases;

the creditworthiness of tenants;

the level of tenant defaults;

rent control laws, affordable housing mandates or other laws impacting operating costs;

the number and diversification of tenants;

the availability of trained labor necessary for tenant operations;

the availability of financing;

changes in interest rate levels;

the rate at which new rentals occur;

the property’s operating leverage;

the ratio of fixed operating expenses to those that vary with revenues; and

the level of capital expenditures required to maintain the property and to retain or replace tenants.

A decline in the relevant real estate market or in the financial condition of a major tenant will tend to have a more immediate effect on the net operating income of a property with short-term revenue sources (such as a hotel or other property with short-term or month-to-month leases) and can lead to higher rates of delinquency or defaults under mortgage loans secured by such a property. Newly constructed or recently opened properties have a limited operating history. There can be no assurance that a property, whether newly constructed or recently opened or otherwise, will perform as anticipated. Real Estate Debt Investments Generally Net Operating Income Commercial real estate loans1 and agricultural loans are typically secured by or supported by the cash

References to “commercial real estate loans” and “real estate debt investments” in this section entitled “Real Estate Debt Investments Generally” are intended to include not only loans secured by first-priority mortgages but also subordinate financing structures (including mezzanine loans and preferred equity), construction loans and other real estate-related debt investments.

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flows from the underlying collateral property. As there is generally very limited recourse against the borrower’s or sponsor’s assets other than the underlying collateral, the ability of a borrower to satisfy the debt service on a loan typically is dependent primarily upon the successful operation of the related income-producing property. If the net operating income of the related property dips or fails to reach expected levels, the borrower’s ability to satisfy the debt service on the loan will be impaired and the value of the property will likely decline, which will negatively affect the borrower’s ability to refinance the loan or generate sufficient proceeds from the liquidation of the property to be able to repay the loan. If the loan is intended to pay for the costs of developing and constructing projects on real property (i.e., a construction loan) and therefore either does not yet generate cash flow or generates income insufficient to cover debt service, the risk of borrower default is typically heightened. Valuation of underlying collateral In addition, there is a risk of loss of investment principal to the extent of any deficiency between the underwritten value and actual value of the collateral securing or supporting the real estate debt investment since, in the event of a liquidation of the collateral, the proceeds would be insufficient to cover the outstanding principal balance of the real estate debt investment. Therefore, a commercial real estate loan with a higher loan-to-value (LTV) ratio, meaning the ratio that the size of the investment bears to the value of the collateral securing or supporting such investment, will carry a higher risk of loss. Commercial mortgage loans and agricultural loans The risk of loss on an investment in a commercial mortgage loan or agricultural loan will be largely dictated by whether the borrower is delinquent in its payment obligations or otherwise defaults on the loan and the severity of losses incurred as a result of the same. Factors influencing defaults and the resulting severity of losses include a broad range of factors, including (i) economic and real estate market conditions and their corresponding effects on property values, (ii) the terms and structure of the loan itself, and (iii) the lender’s ability to realize upon the real property collateral securing the loan. In addition, agricultural loans are further exposed to unique risks such as weather and technology. The performance of any given commercial mortgage loan or agricultural loan will be materially affected by the ability of the underlying property to attract and retain tenants and the ability of tenants to make their lease payments. PGIM’s failure to properly underwrite the value of the underlying real property when making loans will impact the likelihood of a loan default and loss on investment. Subordinate financing and leveraged loans Subordinate financing (including mezzanine loans and preferred equity) and levered loans (loans which have been funded in part by borrowed monies) are subordinated to any senior debt on the underlying property which secures or supports the subordinate financing or levered loans, meaning the holders of such subordinate financing or levered investments could lose their entire investment before the senior debt suffers any losses. These subordinated financing positions therefore pose a greater credit risk than any loans senior to them. In addition, mezzanine loans will at times not be protected by financial or other covenants typically found in a senior mortgage loan and will at times have more limited liquidity. A subordinate lender’s and levered loan holder’s ability to foreclose on any collateral securing its loan (or otherwise exercise remedies to protect its investment) will be subject to the rights of senior lenders and potentially contractual restrictions, particularly the rights of senior lenders and, in the case of preferred equity, the rights of common equity holders. A subordinate lender will typically have the right to cure senior loan defaults and to purchase loans senior to it as a means of protecting its investment (and a levered loan holder will similarly typically have the right to pay the leverage facility provider off), but the rights and protections available to any holder of subordinate financing or levered loans will be subject to commercial negotiation and market convention, including overseas market norms to the extent 13 PGIM Real Estate FORM ADV PART 2A

investments are permitted outside of the U.S. Even if available, however, these rights will at times not be meaningful to a subordinate financing investor or levered loan holder because it does not have sufficient capital available or is unwilling to invest more capital to protect its investment. Construction loans Construction loans are subject to unique risks, including cost overruns, completion delays, the unavailability of materials or labor and lien priority issues. The lender will typically seek to mitigate these risks by, among other protections, staggering the disbursement of funds across multiple advances upon borrower’s satisfaction of specific conditions at each advance, holding interest reserves, and taking a completion guaranty from a creditworthy borrower affiliate. Construction loans typically require more active administration and monitoring by the lender than a loan secured by a stabilized property, and there can be no assurance that PGIM can in all cases protect the investment through such activities. In addition, it is common for a construction lender to be subject to restrictions on its ability to assign or sell the construction loan until its disbursement obligations have been satisfied or the loan is in default. “Balloon” payment risk Commercial real estate loans and agricultural loans are generally not fully amortizing and therefore will have a significant principal balance or “balloon” payment due on maturity. Such loans involve a greater risk to a lender than fully amortizing loans because the ability of a borrower to make a balloon payment typically will depend upon its ability either to fully refinance the loan or to sell the property securing the loan at a price sufficient to permit the borrower to make the balloon payment. The ability of a borrower to accomplish a refinancing or sale will be affected by a number of factors, including the value of the property, interest rates, the availability of replacement financing at the time of sale or refinancing, the borrower’s equity in the property, the financial condition and operating history of the property and the borrower, tax laws, prevailing economic conditions and the availability of credit for loans secured by the specific type of property. Non-recourse lending Commercial real estate loans and agricultural loans generally are non-recourse to borrowers and their owners. In the event of foreclosure (or exercise of remedies) on an investment, the value at that time of the collateral securing or supporting the loan can be less than the principal amount outstanding on the loan and the accrued but unpaid interest thereon. Although recourse in the U.S. is typically allowed against a borrower affiliate guarantor with respect to certain actual losses and, in some cases, the entirety of the outstanding obligations to the lender, will a the terms and scope of such recourse guaranties are subject to substantial commercial negotiation and can be practically difficult to enforce in a court of law. Limitations on remedies Although the provider of commercial real estate loans or agricultural loans will have certain remedies upon a borrower default, including foreclosing on the underlying property, certain contractual requirements, legal requirements and borrower defenses have limited the ability of the lender to effectively exercise such remedies. The laws with respect to the rights of debtors and creditors in certain jurisdictions in which an account is permitted to invest will at times not be comprehensive or welldeveloped, and the procedures for the judicial or non-judicial enforcement of such rights will at times be of limited effectiveness resulting in the potential for losses on defaulted loans. If the lender acquires title to an asset through foreclosure, it will be subject to the burdens of ownership of real property, which include paying expenses and taxes, maintaining the asset, and ultimately disposing of the asset. No assurance can be given that there will be a ready market for the sale of any real property acquired by a 14 PGIM Real Estate FORM ADV PART 2A

lender pursuant to a foreclosure or, if the property can be sold, that any such sale will be made at a price sufficient to over all of the borrower’s obligations to the lender under the defaulted loan. Interest rate risks to lenders The level and volatility of short-term and long-term interest rates significantly affect the lending industry. For example, a decline in interest rates will require a lender to make loans at lower interest rates or can hinder a lender’s ability to find investments at acceptable pricing levels. A rise in interest rates could affect a lender’s cost of drawing on a line of credit and cause the value of its existing loan portfolio to decline. Increased interest rates can also harm a borrower’s ability to make its payments and to refinance a loan at maturity. Volatility in interest rates could harm a lender’s ability to achieve its profitability objectives or cause it to achieve less favorable results than other investments. Interest rates are influenced by a number of factors that are beyond a lender’s control and are difficult to predict. Prepayments Commercial real estate loans and agricultural loans will be subject to prepayment, whether permitted or otherwise. If prevailing interest rates for similar loans fall below the interest rates on such loans, borrower prepayments would generally be expected to increase. Certain loans will have lockout periods during which prepayment is prohibited or require prepayment premiums to be paid as a condition to prepayment, while other loans will at times be subject to other prepayment requirements, including payment of minimum interest. There can, however, be no assurance that any such features will preclude a prepayment from occurring or that the lender will be able to enforce its prepayment rights in all circumstances. Lender liability A number of judicial decisions in the United States have upheld the right of borrowers to sue lenders on the basis of various legal theories founded upon the premise that a lender has violated an implied or contractual duty of good faith and fair dealing or has assumed a degree of control over the borrower resulting in a fiduciary duty being owed to the borrower, its creditors or its shareholders. Any such lawsuits could result in financial losses, increased costs or the subordination or invalidation of the loan made by the lender. Borrower insolvency Although borrowers are typically required to satisfy certain lender requirements designed to isolate the borrower from the credit risk of its owners, if a borrower is nevertheless the subject of a bankruptcy or other insolvency proceeding under the laws applicable to a borrower (including non-U.S. law in the case of a non-U.S. borrower), payments to the lender will at times be delayed or diminished as a result of the exercise of various powers of a bankruptcy court including the following: (i) an “automatic stay,” under which the lender will not be able to institute proceedings or otherwise enforce its rights against the borrower without permission from the court;

(ii) conversion by the bankruptcy court of the loan into more junior debt or into an equity obligation of the borrower thereof or obligor thereon;

(iii) modification of the terms of the loan by the bankruptcy court, including reduction or delay of the interest or principal payments thereon; and

(iv) grant of a priority lien to a new money lender to the borrower of, or obligor on, the loan. 15 PGIM Real Estate FORM ADV PART 2A

Fraudulent conveyance and preference If a court in a lawsuit brought by a creditor or representative of creditors of a borrower, such as a trustee in bankruptcy, were to find that the borrower did not receive fair consideration or reasonably equivalent value for incurring indebtedness evidenced by a loan and granting a security interest over its assets to secure such loan, and, after giving effect to such indebtedness, the borrower: (a) was insolvent; (b) was engaged in a business for which the remaining assets of such borrower constituted unreasonably small capital; or (c) intended to incur, or believed that it would incur, debts beyond its ability to pay such debts as they mature, such court could invalidate, in whole or in part, such indebtedness as a fraudulent conveyance (or similar concept under the laws of a non-U.S. jurisdiction in the case of a non-U.S. borrower), subordinate such indebtedness to existing or future creditors of the borrower or recover amounts previously paid by the borrower in satisfaction of such indebtedness. Similarly, in the event of the insolvency of a borrower, payments made on a loan could be subject to avoidance by a bankruptcy court as a “preference” (or similar concept under the laws of a non-U.S. jurisdiction in the case of a non-U.S. borrower) if made within a certain period of time (which can be one year and one day) before insolvency. No Independent Credit Ratings Credit ratings are typically not assigned to private commercial real estate loans or agricultural loans by an independent rating agency. PGIM will assign internally determined credit ratings to certain loan investments, which track the letter rating scale utilized by one or more independent rating agencies, to some but not all loans to reflect a view of the credit quality of the loan. To the extent PGIM assigns a rating to a loan, such ratings are in all cases, however, internally determined and will not have been approved by any independent rating agency. Furthermore, any credit ratings provided are not a guarantee of quality. While credit ratings attempt to evaluate the safety of principal and interest payments, they do not evaluate the risks of fluctuations in market value and will at times not fully reflect the true risks of an investment. PGIM can fail to make timely changes in its internally assigned credit ratings necessary for the ratings to give an accurate view of the credit quality of a loan, including in response to events subsequent to the closing of a loan. Therefore, the actual financial condition of the borrower, the property securing the loan, tenants or the relevant market in which the collateral property is located will at times be better or worse than its ratings indicate. Any credit ratings assigned to investments by PGIM necessarily rely in part on subjective inputs. Although certain models currently used by PGIM in determining internal credit ratings for certain commercial mortgages are licensed from an independent rating agency, no independent rating agency has any role in approving any of the credit ratings assigned by PGIM and PGIM can cease using such models in its discretion. Notwithstanding the foregoing, some debt investments managed by PGIM can be expressly rated in specific instances by an independent rating agency typically where the investor is subject to statutory accounting requirements and depend on independent credit ratings to calculate the appropriate regulatory capital charges on a debt investment. In such specific cases, PGIM would expect to arrange for the independent credit ratings to be obtained and provide access to such information as the independent rating agency needs to calculate the applicable ratings, but in all cases independent ratings are not endorsed or supported by PGIM and investors should rely on the same only to the extent they are comfortable looking to the ratings as an indication of credit quality. Such independent ratings are not typical in our business. Fraud, Illegal Conduct, Misrepresentation or Omission The value of any investment in a commercial real estate loan or agricultural loan will at times be affected by fraud, illegal conduct or a material misrepresentation (or material omission of information otherwise necessary to make a representation true) on the part of the borrower, by parties related to the borrower or 16 PGIM Real Estate FORM ADV PART 2A

by other parties related to the loan (e.g., tenants). Such fraud, illegal conduct, misrepresentation or omission can adversely affect the value of the real property collateral securing the loan and the borrower’s ability to satisfy its obligations under the loan. A lender’s best, and in certain cases only, recourse in such a situation will at times be to seek recourse against a borrower affiliate guarantor which can be challenging (see discussion of “Non-recourse lending” above).

General Market Risk and Risks Related to General Economic Conditions Real estate prices and revenues and the financial performance of an investment can be adversely affected by general local, national and international economic conditions and factors, by conditions within one or more real estate markets. Interconnectivity of global markets and economies increases the likelihood that events in one market or economy can adversely impact other markets or economies.

Reliance on Partners and Other Third Parties Investments will at times be made through joint venture or other co-investment arrangements, the results of which are highly dependent on the credit, acumen and behavior of the relevant partners or other entities or individuals that they retain, such as property managers, construction managers or general contractors. Reliance on third parties to manage or operate investments presents significant risks, including that the third party can have financial difficulties or economic or other business interests or goals which are inconsistent with those of the PGIM Real Estate client. The client can have limited rights with respect to the development or operation of the property. If the applicable venture or management arrangements are terminated for any reason, or if key personnel leave or otherwise become unavailable, it can be difficult to find a suitable replacement. In addition, agreements governing joint ventures often contain restrictions on the transfer of a partner’s interests, including “buy-sell” or similar provisions which could result in the requirement that a partner, including the client, purchase or sell its interests at a disadvantageous time or on disadvantageous terms.

Third Party Fee Rates There is no assurance that we will be able to obtain or apply in all instances advantageous fee rates (i) from a given service provider negotiated with respect to services provided to PGIM Real Estate or our funds or other clients; or (ii) that were negotiated by other PGIM businesses, other PGIM-advised funds or affiliates of PGIM based on their relationship with the service provider, or that we will be aware of certain negotiated fee rates.

Reliance on PGIM Real Estate Professionals The success of investments depend, in substantial part, upon the skill and expertise of certain PGIM Real Estate professionals. The death, disability or departure of a key PGIM Real Estate professional can adversely affect the performance of investments that we manage or advise on. In addition, certain associates can have greater demands on their time, especially at senior levels, and therefore will not be able to spend all of their time focusing on specific portfolios.

Competitive Markets Competition for investment opportunities can be high, and such competition can limit the ability to acquire desirable target assets, affect the underwriting or pricing of assets or adversely impact investment returns.

Portfolio Concentrations A real estate investment portfolio that is concentrated in a particular country, region, market, industry sector or asset 17 PGIM Real Estate FORM ADV PART 2A

class could be more susceptible to loss due to adverse occurrences in the relevant country, region, market, industry sector or asset class than a more diversified real estate investment portfolio. For example, properties located in California are more susceptible to certain hazards such as earthquakes, drought or widespread fires than properties in other parts of the country, and properties located in certain coastal states are more susceptible to hurricanes than properties in other parts of the country.

Operational Processes Portfolios can suffer losses arising from shortcomings or failures in operational processes, procedures, or systems.

Valuation Valuation of real estate and real estate debt is subject to numerous assumptions and is not a precise measure of realizable value. The value of a portfolio as of a particular date can be materially greater than or less than the value that would be determined if a portfolio’s investments were to be liquidated as of such date. Volatile market conditions or illiquidity of real estate investments could result in liquidation values that are materially less than the values of such assets as reflected in a portfolio.

Real Estate Equity Securities Investments in publicly traded real estate equity securities can be more volatile than other forms of real estate investment. Prices of equity securities can increase or decrease because of changes in the markets more broadly or specifically because of changes in a company’s financial condition, sometimes unpredictably. The value of real estate equity securities often is subject to the same risks as direct investments in real estate and their value can be influenced by factors including the value of the underlying properties or underlying loans. The value of real estate equity securities can rise or fall in response to many factors including economic conditions, demand for rental property, interest rates and creditworthiness of the issuer. The values of equity securities can decline when interest rates rise or can also be affected by the underlying properties. Real estate equity securities can be more illiquid than other equity securities.

Use of Leverage We can incur leverage at a fund or portfolio level, subject to specified constraints determined by PGIM Real Estate, and certain funds and clients can also leverage individual assets. Incurring substantial debt could subject the relevant investments to a number of risks, including the risks that:

portfolio or property cash flow will be insufficient to make required payments of principal of and interest on the debt;

the borrowing entity will be unable to comply with all the material covenants imposed by the lender;

such debt will increase the relevant portfolio’s or investment’s vulnerability to adverse economic and industry conditions;

a substantial portion of the portfolio’s or property’s cash flow is utilized for payments on debt, thereby reducing funds available for property operations, investor distributions or other purposes; and

the borrower will be unable to refinance debt that matures on favorable terms, or at all.

18 PGIM Real Estate FORM ADV PART 2A

Defaults under such financing could lead to (i) acceleration of such debt (and under any other debt facility containing a related cross-default or cross-acceleration provision), (ii) an inability to borrow unused amounts under other financing arrangements, (iii) the loss of some or all of the relevant fund’s or other client’s investments to foreclosure or sale, or (iv) one or more lenders being unwilling or unable to provide the relevant fund or client with financing. In addition, if regulatory capital requirements imposed on a lender changes, they can be required to limit, or increase the cost of, financing they provide. In general, this could potentially increase financing costs and reduce available capital, thereby affecting decisions to buy, hold or sell a specific investment. These financing arrangements involve the risk that the market value of the properties declines in value, or that other loan covenants are breached, in which case the lender can require the borrower to provide additional collateral or to repay all or a portion of the funds advanced. The borrower could not have the funds available to repay or pay down the debt at that time, which could lead to a default. In the case of debt funds, although the use of leverage (in the form of debt) can increase returns on invested capital, it also increases the potential for loss. Lenders to debt funds can call defaults under certain declining market conditions or make margin calls that require the debt fund to repurchase pledged loans or post additional cash or collateral as security for a loan, typically requiring the fund to act on a very short time frame, thereby resulting in significant impairment of value and potentially risking losses on performing loans simply due to the debt fund having insufficient cash on hand to repurchase such loans or satisfy such margin calls. A leverage provider’s recourse is not always limited to specific assets of the debt fund, creating a situation where performing loan assets could also be adversely impacted to the extent the debt fund incurs liabilities under recourse guaranties.

Interest Rates To the extent that floating-rate financing is employed in debt financing, changes in interest rates, particularly short-term interest rates, can immediately and significantly decrease the results of property operations and cash flows and the market value of relevant investments. If fixed-rate financing is employed and interest rates subsequently decline, this can result in the borrower paying interest rates at above-market rates for significant period of time. PGIM Real Estate can enter into interest rate swap or cap agreements for the purpose of hedging interest rate risk or pursue other hedging strategies. These activities are not guaranteed to fully protect the borrower from the impact of interest rate risk and hedging costs can be expensive and adversely impact investment performance.

Rate of Inflation Certain investments are subject to inflation risk, which is the risk that the value of assets, or income from investments, will be less in the future as inflation decreases the present value of money. Inflation rates can fluctuate rapidly and significantly on account of various factors, such as economic policy changes or unexpected shifts in global or the United States economies. Inflation in the United States and elsewhere has increased in recent years, and it remains uncertain whether substantial inflation will be sustained over time. Efforts by the United States Federal Reserve Board to curb inflation can lead to increased interest rates. There can be no assurance that governmental efforts to curb inflation will not have negative effects on the economy. As a result, inflation could negatively affect the performance of our accounts and their investments. Foreign Investments With any investment outside the United States, there exist certain economic, political and social risks that might not be found in a similar investment in the U.S. Investments are generally denominated in the currency of the jurisdiction where the investments are located and thus can be subject to fluctuation in currency exchange which can affect the value of the assets. In addition, laws, regulations and conditions in foreign countries can impose 19 PGIM Real Estate FORM ADV PART 2A

restrictions or risks that would not exist in the United States and require financing and structuring alternatives which differ from those customarily used in the United States. Foreign countries can also impose taxes on the funds and their investors which differ from those imposed in the US.

CFIUS; Foreign Investor Risk The Committee on Foreign Investment in the United States (“CFIUS”) is concerned with a foreign person’s acquisition of control of a US business that might raise national security concerns. If a client account makes an investment in a business that operates, or is otherwise connected to or involved in, an industry where national security is implicated (for example, certain technology-related investments or those involving sensitive data), or in real estate where national security interests are relevant (such as land in close proximity to a US military installation), the investment could be subject to review and approval by CFIUS (and/or foreign regulators that are responsible for reviewing and approving such investments). If such a regulator reviews such an investment for an account, there is risk that the investment could become subject to restrictions that could limit or otherwise alter the nature of the investment, or that the investment could be altogether prohibited (or, for existing investments, will at times need to be unwound). These restrictions could prevent us from making certain types of investments, or cause investments to be subject to less advantageous terms than they otherwise would be.

Financial Institution Risk Real estate investments and financial markets generally are subject to the risk that a U.S. bank or other financial institution (each, a “Financial Institution”) experiences insolvency, closure, seizure, receivership or other financial distress or difficulty. Such events can be caused by a variety of factors, such as eroding market sentiment, significant withdrawals, fraud, malfeasance, poor performance, undercapitalization, market forces or accounting irregularities. If a Financial Institution experiences such an event, we or the accounts we manage could be unable to access deposits, borrowing facilities or other services. Such events can have adverse effects on our ability to manage the accounts and their investments, and on a fund’s ability to maintain operations, which could result in operational burdens, significant losses, and unconsummated investment acquisitions, dispositions and transaction closings. While assets held by regulated Financial Institutions in the United States frequently are insured up to stated balance amounts by organizations such as the Federal Deposit Insurance Corporation (in the case of banks), amounts in excess of the relevant insurance are subject to risk of total loss, and any non-U.S. Financial Institutions that are not subject to similar regimes pose potentially increased risk of loss. While governmental intervention can result in additional protections for depositors and counterparties in connection with such events, there can be no assurance that any intervention will occur, be successful or avoid the risks of loss, substantial delays, or negative impact on banking or brokerage conditions, or financial markets.

Data Source Risk We use a variety of proprietary and non-proprietary data to evaluate real estate and formulate investment advice. If a data source is incorrect or unexpectedly becomes unavailable or unreliable, client assets could be negatively impacted. We also subscribe to external data sources for various purposes and functions, including in making investment decisions. While we believe those third-party data sources to be generally reliable, we do not guarantee that the data received will be accurate or complete and is not responsible for errors by these sources. See also discussion below regarding artificial intelligence.

REIT Investments Entities that elect to be taxed as a REIT do not pay federal income taxes if they meet the requirements to qualify as a REIT. If any REIT were to fail to qualify as a REIT in any taxable year, it could have adverse tax consequences, creating a risk that an investment in that REIT could perform negatively.

Environmental Risks 20 PGIM Real Estate FORM ADV PART 2A

Investments in real estate can be subject to liability under environmental statues, rules and regulations. The cost of investigation, remediation, management or removal of hazardous or toxic substances is potentially substantial and could adversely affect the ability to sell or lease such property or obtain financing. In addition, the account could be subject to substantial risk of loss from environmental claims arising with respect to real estate acquired with environmental problems, and the loss could exceed the value of the investment. Changes in environmental laws or the environmental condition of the property can create liabilities that did not exist at the time of acquisition and could not have been foreseen. In addition, real estate investments are subject to natural disasters such as earthquakes, fire, windstorms, hurricanes, floods as well as man-made disasters such as riots, civil unrest, terrorism or acts of war.

Environmental, Social and Governance Risks The global regulatory environment applicable to ESG strategies is evolving and will lead to increased complexity and potentially conflicting regulatory regimes applying to us and the accounts (including funds) we manage. Further, certain ESG-related regulations (including the European Union’s Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector), contain elements of subjectivity, which could lead to our regulatory and legal interpretation differing from that of others and could also result in the regulatory reclassification of products that we manage, changes to our account-level disclosures and changes to our internal policies, procedures and processes. Compliance with ESG-related regulations could lead to increased costs for relevant accounts. ESG investing is qualitative and subjective by nature, and there is no guarantee that the criteria utilized by us, or any judgment exercised by us will reflect the beliefs or values of any particular client, and our proprietary internal ESG impact rating of a particular investment could differ from the view of others. An account’s ESG strategy, which could select or exclude investments for reasons other than financial risk/return considerations (where consistent with applicable law or regulation), could have lower returns than accounts whose investment criteria are solely focused on seeking the highest risk-adjusted returns. The application of this strategy could affect the account’s exposure to certain sectors or types of investments, which could negatively impact the account’s performance. In evaluating an investment or in assigning an internal ESG impact rating to an investment, we are sometimes dependent upon information and data obtained through third-party reporting that could be incomplete, inaccurate or unavailable, which could impact or impair our ability to assess an issuer’s business practices with respect to ESG practices. Additionally, a client could disagree with the classification of an issuer by our data provider. Socially responsible norms differ by region, and an issuer’s ESG practices or our assessment of an investment’s ESG practices can change over time. Accordingly, it is possible that we would have assigned a different ESG impact rating to an investment had we had access to additional or more accurate information. If the addition of a new screen or an update to the existing list of ineligible or prohibited investments from a third-party agent or a change to an internal ESG impact rating (in each case where applicable to a client account) causes an investment held by a client account to not comply with the ESG constraints or considerations applicable to the client account, we could be required to sell the investment at a disadvantageous price or time, causing the client account to incur losses that would not otherwise be realized in the absence of such ESG constraints or considerations. The screens or constraints related to certain ESG strategies could result in an account forgoing opportunities to make certain investments when it might otherwise be advantageous to do so. Successful application of an account’s ESG strategy will depend on our skill in identifying and analyzing material ESG issues and there can be no assurance that the strategy or techniques employed will be successful. In the case of debt assets, while the assets are monitored and reviewed to help PGIM Real Estate monitor changes to the ESG risk profile of the investment as they are presented, there is no assurance that a property’s decline in competitiveness or value due to an ESG risk occurring, including a climate-related change in applicable law, will afford a lender any particular rights or remedies under the terms of the applicable loan documents or that we will elect to pursue any particular right or remedy as a result thereof. We could, however, seek to discuss findings with the applicable borrower subject always to the terms of the governing loan documents, applicable law and our overall assessment of a 21 PGIM Real Estate FORM ADV PART 2A

particular investment. Although PGIM Real Estate’s ESG implementation seeks to incorporate the potential impact of ESG related risks, ESG related considerations are not necessarily weighted greater than any other aspect of our assessment of a particular investment. In the future, we could seek to adopt specific ESG-related objectives into a client’s investment criteria, but even if we do so, we would generally not expect a fund or account to have any greater ability to dictate the operation of any property. As such, there can be no assurance that such objectives result in better investment decisions or performance or otherwise satisfy any one investor’s ESG expectations.

Sustainability Risk Sustainability risk means an environmental, social, or governance event or condition, that, if it occurs, could potentially or actually cause a negative material impact on the value of investments. Sustainability risk can represent a risk on its own, and can contribute significantly to other risks, such as market risks, liquidity risks or operational risks. For example, climate change could lead to increasing intensity and instances of severe weather, leaving real estate owners vulnerable to financial hardships such as work stoppages, decreases in revenues and increased insurance premiums. Further, if property owners underestimate or fail to adequately assess sustainability risks, negative impacts of sustainability-related events on their business would be heightened. For example, with regards to an environmental event or condition, real estate could be severely damaged or destroyed by physical climate risks, including climate change that could materialize as either singular extreme weather events (for example floods, storms and wildfires) or through long-term impacts of climatic conditions (such as precipitation frequency, weather instability and rise of sea levels). Furthermore, transition risks can affect real estate assets through the adjustment to a low carbon economy. Political decisions could for example increase energy prices or lead to higher investment costs due to necessary refurbishments of real estate to meet enhanced energy efficiency requirements (caused by local, national, regional or global legislation). Transition risks could also lead to a reduction in demand for energy inefficient real estate. Epidemics and Public Health Emergencies Occurrences of epidemics and pandemics, depending on their scale, can cause different degrees of damage to national and local economies that could affect the value of real estate investments. Global economic conditions can be disrupted by widespread outbreaks of infectious or contagious diseases, and such disruption could adversely affect real estate valuations, investments, and account performance. There can be no certainty as to how long the effects of such outbreaks will continue, particularly as markets grapple with unintended consequences of fiscal and monetary policies designed to curb any related economic impact (such as inflation).These economic disruptions could negatively impact the value and performance of investments in funds and accounts, and there is no way to predict the extent of any such future consequences for clients.

Uninsured Loss Certain types and magnitudes of potential losses at real estate investments are not insured because it is not economically feasible (or coverage is simply not available) to insure against such losses or are subject to certain insurance limitations, including large deductibles or co-payments. There can be no assurance that insurance will be available (or available at commercially reasonable rates) or sufficient to cover any such risks. Insurance against certain risks, such as fires, earthquakes, floods, hurricanes, windstorms, pollution, environmental factors, wars, riots, looting and vandalism that can result from civil unrest, nuclear reactions, biological agents (e.g., mold) or damage by terrorism, could be commercially unavailable, available in amounts that are less than the full market value or replacement cost of investment properties, subject to large deductibles or loss retentions or not economically insurable. In addition, there can be no assurance that the particular risks that are currently insurable will continue to be insurable on an economic basis. In 22 PGIM Real Estate FORM ADV PART 2A

general, losses related to terrorism, fire and certain weather events are becoming harder and more expensive to insure against. Should an uninsured loss or a loss in excess of limits occur, the portfolio could lose its capital invested in such investments as well as future revenue, while remaining liable for any debt or other financial obligations related to such investments.

Illiquid Investment Risks Equity and debt real estate assets are relatively illiquid. The ability to dispose of real estate assets in a timely or favorable manner is subject to many factors beyond PGIM Real Estate’s control, including, but not limited to, general economic conditions, supply and demand, the availability of capital (whether from lenders or investors) and interest rates.

Performance-Based Compensation Performance-based compensation creates an incentive to make investments that are riskier or more speculative than would be the case in the absence of such compensation. Geopolitical Risk Geopolitical risks arising from political instability, regulatory changes, trade disputes, tariffs or other restrictions on trade, or economic sanctions could lead to market volatility, asset devaluation, restricted access to investments, or loss of value. In addition, war, conflict, and civil disturbances around the world can have negative economic effects given the interconnectedness of financial markets across the world. These events can increase the threat of full-scale war, cyberattacks, and further regional or global conflicts. Geopolitical and global conflicts can cause significant disruptions to the global financial system and international trade, such as by impacting supply chains and commodity prices, leading to inflation. These events could also impact the ability of accounts to source, diligence and execute investments or adversely affect the liquidity, pricing or market for such investments. Further, these events have resulted, and could result in the future, in sanctions against impacted countries, having various negative consequences as explained under “Sanctions and Related Considerations.” The ultimate impact of events such as these, including their effects on global economic and commercial activity and conditions, and on the operations, financial condition and performance of the accounts and their investments, is impossible to predict. There is no guarantee that any steps taken by us to mitigate any adverse impact of these conflicts will be successful. Sanctions and Related Considerations Economic sanction laws in the United States and other jurisdictions prohibit us, our personnel and accounts we manage from investing in or transacting with certain countries, companies and issuers. Such sanctions, and other similar and related laws and regulations, make it difficult for an account to pursue certain investment opportunities, which could adversely impact client accounts, cause increased volatility and illiquidity, impact the accuracy of valuations and prevent the receipt of interest and principal payments. In the United States, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) administers and enforces laws, executive orders and regulations establishing U.S. economic and trade sanctions, which restrict or prohibit, among other things, direct and indirect transactions (including receipt of interest and principal payments) with, and the provision of services to and the receipt of services from, certain non-U.S. countries, territories, individuals and entities. These types of sanctions could significantly restrict or completely prohibit investment activities in certain jurisdictions or industries, and violation of any such laws or regulations could result in significant legal and monetary penalties, as well as reputational damage. OFAC sanctions programs change frequently, making it more difficult to ensure compliance. Trade Tensions International trade tensions and trade disputes including tariffs, trade restrictions, economic sanctions, export controls, retaliatory measures, or the threat of potential of one or more of such events and developments, could give rise to concerns about economic and geopolitical instability. Such tensions have had and will likely have various adverse consequences to global markets, such as market fluctuations, global trade disruption, price reductions, oversupply of manufactured goods, currency fluctuations, and introductions of further trade barriers and frictions, thereby adversely affecting the financial performance of funds and other accounts. 23 PGIM Real Estate FORM ADV PART 2A

Extraordinary Events Extraordinary events such as natural disasters, epidemics and pandemics, power outages, terrorism, war, geopolitical disputes, conflicts and social and political unrest, or the threat or potential of one or more of such events, can have significant impacts on issuers, industries, governments and other systems, including the financial markets. As global systems, economies and financial markets are becoming increasingly interconnected, events that once had only local impact are now more likely to have regional or even global effects. These impacts can be exacerbated by failures of governments and societies to appropriately respond to, and by public fear of, such an event or threat. Periods of such disruption can reduce investment opportunities, credit available to borrowers, accuracy of projections or valuations, value of portfolio holdings, our operational effectiveness or that of key service providers, or disrupt systems and processes necessary or beneficial to the management of accounts. Investing in Greater China Risk Investments in securities of issuers located or operating in the Greater China involve risks arising from: greater government control over the economy; political, legal and regulatory uncertainty; nationalization, expropriation, or confiscation of property; difficulty in obtaining information necessary for investigations into and/or litigation against such issuers, as well as in obtaining and/or enforcing judgments; limited legal remedies for shareholders; alteration or discontinuation of economic reforms; military conflicts, either internal or with other countries; inflation, currency fluctuations and fluctuations in inflation and interest rates that could have negative effects on the economy and securities markets in Greater China; and Greater China’s dependency on the economies of other Asian countries, many of which are developing countries. There is also the risk that the U.S. government or other governments could sanction Chinese issuers or otherwise prohibit U.S. persons (such as a fund or other account) from investing in certain Chinese issuers, which could negatively affect the liquidity and price of their securities and/or cause the government of the People’s Republic of China (“PRC”) to take retaliatory measures. Further, changes to the political and economic relationships between Taiwan, Hong Kong, and the PRC could adversely impact an account’s investments in Taiwan or Hong Kong. Certain Risks Related to Cybersecurity, Technology and Systems Investment advisers must rely in part on digital and network technologies to conduct their businesses and to maintain substantial computerized data relating to client account activities. These technologies include those owned or managed by us, as well as those owned or managed by others, such as custodians, financial intermediaries, transfer agents, and other parties to which we or they outsource the provision of services or business operations. Like all businesses that use computerized data, we, our affiliates, our third-party service providers, and their affiliates and service providers, and the systems we use are subject to a variety of cybersecurity related risks, such as cyber-attacks involving social engineering, ransomware, or the use of artificial intelligence; vulnerabilities in software or hardware used by us and our third-parties service providers; and other risks that lead to the unauthorized disclosure of confidential, personal, proprietary, or other non-public data. We are also subject to business operations and technology disruptions, such as those caused by system failures, human error or misconduct, or cyber-attacks against supply chain and other third-party service providers. Various actors, such as for-profit criminal hackers, politically motivated actors, and nation-state sponsored or affiliated actors, engage in cyberattacks against the financial services sector. We could experience cybersecurity attacks from such actors and other sources. We and our affiliates have implemented and maintain an information security program designed to preserve the confidentiality, integrity, and availability of information owned by us and in our care and to address the information security practices of our third-party service providers. We take commercially reasonable measures to limit risks associated with cybersecurity incidents or similar events, and to protect data from inadvertent disclosure or wrongful misappropriation or destruction. Nevertheless, despite reasonable precautions, cybersecurity and other technology incidents can occur and might, in some circumstances, result in unauthorized access to or acquisition of sensitive information about us or our clients. In addition, such incidents could cause damage to client accounts, data or systems or affect account management. Furthermore, our systems could fail to operate properly or become disabled as a result of events or circumstances wholly or partly beyond our or others’ control. Technology failures, whether deliberate or not, including those arising from use of third24 PGIM Real Estate FORM ADV PART 2A

party service providers (such as the third party investment management platform we utilize) or client usage of systems to access accounts, could have a material adverse effect on our business or our clients and could result in, among other things, financial loss, reputational damage, regulatory penalties, litigation or the inability to transact business. Risks of Artificial Intelligence (AI) Artificial intelligence technologies, including machine learning and generative artificial intelligence (collectively, “AI Technology”), their potential future applications, and the laws, regulations and standards governing their use continue to rapidly evolve. We do not use AI Technology to make investment decisions or provide investment advice, and it does not influence the investment advice we provide. However, we utilize AI Technology to enhance certain operational aspects of our business, such as data processing, client reporting, and compliance monitoring. In addition, we work with third-party service providers who utilize AI Technology. It is also likely that your fund assets or other account will be invested in investments that utilize AI Technology. While we conduct diligence on such potential investments and third-party service providers, we cannot control how they develop or maintain AI Technology. Use of AI Technology could exacerbate existing, or create new and unpredictable, risks to us and your fund assets or other account, including competitive, operational, reputational, legal, and regulatory risks. For example, disruptions in the complex software and hardware systems used by AI Technology could impair our ability to use that AI Technology, process data, generate reports, or perform operational tasks. Further, the models used by AI Technology, and/or the data sets on which those models are trained, could be flawed, function in an unexpected manner, or otherwise reduce these tools’ effectiveness. Additionally, malicious use of AI Technology could also result in harm to us, including reputational harm, enablement of fraudulent activity, generation of misinformation, and increased cybersecurity threats, such as generation of deep-fakes and enablement of long-term and persistent phishing attacks. We maintain a robust governance framework to evaluate risks associated with AI Technology. Despite these precautions, the novelty and rapid evolution of AI Technology increases the likelihood of associated risks materializing. Further, it is not possible to predict the full nature or extent of current or future risks related to the use and development of AI Technology. Social Media and Internet-Based Information Risk In recent years, social media platforms have become a means for instantaneous information sharing. Given the relative lack of regulation of these platforms, they can be used as vehicles for dissemination of inaccurate information. Any such information related to issuers could negatively impact the value of their securities. Risks Related to Regulation We operate in a heavily regulated environment, and are subject to regulation by various government entities. The laws and regulations affecting our business change from time to time. Further, political changes in the U.S. and globally can lead to uncertainty in the legal and regulatory environments applicable to a client account. Currently, we are operating in an environment of significant global regulatory reform in which such changes are frequent. New or revised laws or regulations could adversely impact a client account’s abilities to pursue applicable investment strategies, increase the costs of investing and trading activities, or increase compliance costs (some of which could be borne by market participants). Changes in laws, regulations or executive policies governing foreign relations, trade, development, and investment with respect to countries in which the client account invests could adversely impact account performance. We cannot predict the effects of future legal and regulatory changes on our business or the services we provide.

CFTC Exemptions PGIM, Inc. is registered as a commodity trading advisor and a commodity pool operator, and certain of our management persons are our associated persons when we act in those capacities. Notwithstanding such registration, PGIM relies on exemptions from registration as a commodity pool operator with respect to certain accounts and pools. In addition, we rely on an exemption for relief from certain reporting and recordkeeping requirements applicable to commodity trading advisors.

Our Relationships with Affiliates As an indirect wholly-owned subsidiary of Prudential Financial, Inc., we are part of a diversified, global financial services organization. We are affiliated with many types of U.S. and non-U.S. financial service providers, including insurance companies, broker-dealers, commodity trading advisors, commodity pool operators and other investment advisers. Some of our employees are officers of and/or provide services to some of these affiliates.

Relationships with Affiliated Broker-Dealers PIMS provides marketing support in connection with the offer and sale of securities of certain commingled vehicles that we advise or sub-advise. As noted above, some of our management persons and other employees are registered representatives of PIMS.

Relationships with Affiliated Investment Vehicles. Insurance Company Separate Accounts. As described below, we provide advisory services to the separate accounts of certain of our insurance company affiliates, including PICA. These separate accounts can serve as stand-alone single-client or commingled funds or can serve as feeders into master funds we manage. Private Funds. We form and manage investment vehicles which are exempt from the Investment Company Act of 1940. Interests in these private funds are typically sold through private placements, meaning they need not be registered under applicable securities laws so long as we do not engage in a general solicitation or general advertising in connection with the offering of interests in such vehicles. We typically provide discretionary advisory services to these private funds and earn compensation in consideration of the same. 26 PGIM Real Estate FORM ADV PART 2A

Relationships with Affiliated Investment Advisers. General. In addition to PGIM Investments, which is described above, other affiliated investment advisers include other companies registered with the SEC as well as companies which are not engaged in regulated activities and therefore are not registered with the SEC. We provide sub-advisory services with respect to accounts managed by affiliates and certain of these affiliates provide sub-advisory services with respect to accounts managed by us. We also have service agreements with some of these affiliates under which we perform services for them, or they perform services for us. Fee Sharing Arrangements. As part of a large investment management organization, we sometimes enter into fee sharing arrangements pursuant to which we share fees with our affiliates. Notwithstanding this arrangement, the internal fee sharing arrangement does not result in additional fees or expenses to our client. Participating Affiliate Arrangements. Within the guidance set forth under applicable law, relevant no-action letters and related SEC staff guidance, SEC-registered investment advisers are permitted to access, under prescribed conditions, the services of unregistered affiliates (“participating affiliates”). The prescribed conditions include that the participating affiliate provide the SEC access to trading and other records, observe specific recordkeeping rules, submit to the jurisdiction of U.S. courts and cooperate with the SEC as it relates to relevant accounts. We have arrangements whereby the following Participating Affiliates provide services to us in connection with our management and marketing of certain funds and client investments: PLA Services Manager Mexico, LLC • PGIM (Singapore) Pte. Ltd • PGIM Real Estate Germany AG • PGIM Australia Pty, Ltd.

Relationships with Affiliated Insurance Companies. We provide advisory services with respect to the general accounts of some of our affiliated insurance companies, including PICA (and certain of its subsidiaries) in the U.S. We also provide advisory services with respect to the insurance company separate accounts described above. Assets of the general accounts of affiliated insurance companies constitute a material portion of our assets under management. Certain of these separate accounts are investment options under the Prudential Employee Savings Plan. In addition, we provide management services with respect to assets of certain benefit and welfare plans sponsored by an affiliated insurance company.

Relationships with Affiliated Limited Partnerships and Limited Liability Companies. As described above, we manage certain commingled investment vehicles, including limited partnerships and limited liability companies, for which our affiliates serve as general partner or managing member.

Recommendations of Investment Advisers We do not currently select other investment advisers for our clients.

Conflicts Related to Affiliations Conflicts Related to Investment of Client Assets in Affiliated Funds. We invest client assets in funds that we manage or sub-advise for one or more affiliates. In choosing to invest client assets in such affiliated funds, we could have a financial incentive to prefer investing client assets in such funds instead of in funds, investments or products managed or sponsored by parties that are not affiliated with us. For example, investments in affiliated funds could benefit us and/or our affiliates through increasing assets under management and/or fees. Under certain conditions, we offset, rebate or otherwise reduce our fees or other compensation with respect to investments in affiliated funds; however, this offset, reduction or rebate, if available, will not necessarily eliminate conflicts, as we could have a financial 27 PGIM Real Estate FORM ADV PART 2A

incentive to favor investing client assets in affiliated funds (because, for example, the fee applicable to the affiliated fund is higher than the amount of any fee waiver, investing in such funds would increase assets under management of such funds or could be viewed as being undertaken solely for the purposes of supporting the commercial growth of our or our affiliates’ funds, products or lines of business). Further, if our affiliates provide initial funding to or otherwise invest in affiliated funds, we are incentivized to invest client assets in such funds to facilitate the redemption of all or part of our affiliates’ interest in such affiliated fund. We also invest cash collateral from securities lending transactions in some of these funds. These investments benefit us and/or our affiliate through increasing assets under management and/or fees.

Conflicts Related to Referral Fees to Affiliates. From time to time, we have arrangements where we compensate affiliated parties for client referrals. We also have arrangements with an affiliated entity or person which provide for payments to our affiliate if certain investments by others are made in certain of our products or if we establish certain other advisory relationships. These investments benefit both us and our affiliates through increasing assets under management and fees.

Conflicts Related to Co-investment by Affiliates. Our affiliates provide initial funding to or otherwise invest in certain vehicles managed by us. When certain of our affiliates provide “seed capital” or other capital for a fund, they generally do so with the intention of redeeming all or part of their interest at a future point in time or when they deem that sufficient additional capital has been invested in that fund.

The timing of a redemption by an affiliate could benefit the affiliate. For example, the fund could be more liquid at the time of the affiliate’s redemption than it is at times when other investors might wish to withdraw all or part of their interests. In addition, a consequence of any withdrawal of a significant amount, including by our affiliate, is that investors remaining in the fund will bear a proportionately higher share of fund expenses following the redemption. We would also face a conflict if the interests of an affiliated investor in a fund we manage diverged from those of the fund or other investors. For example, our affiliates, from time to time, hedge some or all of the risks associated with their investments in certain funds we manage. We might provide assistance in connection with this hedging activity.

We believe that the conflicts related to our affiliations described above are mitigated by our allocation policies and procedures. From time to time, Funds and other clients of PGIM co-invest with one or more other funds, investment vehicles and/or accounts managed by PGIM and/or its affiliates in investments through sidecars, joint ventures or other joint investment vehicles (each, a “Joint Investment Vehicle”). Such Joint Investment Vehicles can also include third parties as co-investors. PGIM and/or its affiliates earn fees and incentive compensation in connection with such co-investment arrangements as set forth in the governing documents related thereto. Typically, each investor in Joint Investment Vehicles will bear its share of fees and other compensation charged by or payable to third party service providers and other third parties (including incentive compensation payable to third party operating partners) to or with respect to such Joint Investment Vehicle and all other expenses borne by such Joint Investment Vehicle (which may also, in each case, include amounts initially paid by PGIM and/or its affiliates and reimbursed by such Joint Investment Vehicle). In order to facilitate co-investments, PGIM can, at its sole discretion, modify its allocation policies with respect to the manner in which investments are allocated between the applicable PGIM clients, including in a manner that results in a client receiving fewer investment opportunities and/or receiving investment opportunities that require co-investment with a co-investor that would otherwise have been offered to such client in their entirety. PGIM and its affiliates have conflicts of interest with respect to such co-investments, including, without limitation, with respect to whether to make such co-investments, how to allocate investments and expenses between the clients, how to exercise a client’s rights with respect to such co-investments and if and when to exit such co- investments. PGIM has adopted policies and procedures that will be applied by PGIM to mitigate the conflicts of interest relating to such co-investments.

Conflicts Arising out of Legal and Regulatory Restrictions. 28 PGIM Real Estate FORM ADV PART 2A

In certain instances, our ability to buy or sell or transact for one or more client accounts will be constrained as a result of our voluntary or involuntary receipt of MNPI (see Item 11), various insider trading laws and related legal requirements. For example, we would generally be unable to invest in, divest securities of or share investment analyses regarding companies or other securities issuers for which we possess MNPI, and such inability (which could last for an uncertain period of time until the information is no longer deemed material or non-public) can result in us being unable to buy, sell or transact for one or more client accounts or to take other actions that would otherwise be to the benefit of one or more clients. We face conflicts of interest in determining whether to accept MNPI. For example, we have sought with respect to the management of investments in certain loans for clients to retain the ability to purchase and sell other securities in the borrower’s capital structure by remaining “public” on the loan. In such cases, we will seek to avoid receiving MNPI about the borrowers to which an account can or expects to lend or has lent (through assignments, participations or otherwise), which could place an account at an information disadvantage relative to other accounts and lenders. Conversely, we have chosen to receive MNPI about certain borrowers/issuers for our clients that invest in bank loans, securities, or private debt instruments, which has restricted our ability to trade in other securities of the borrowers/issuers for our clients that invest in corporate bonds or other public securities. (See Item 11 for additional information on the receipt of MNPI.) Our holdings of a security on behalf of our clients are required, under certain regulations, to be aggregated with the holdings of that security by other PFI affiliates. These holdings could, on an aggregate basis, exceed certain reporting or ownership thresholds. These aggregated holdings are centrally tracked, and we or PFI can choose to restrict purchases, sell existing positions, or otherwise restrict, forgo, or limit the exercise of rights to avoid crossing such thresholds because of the potential consequences to us or PFI if such thresholds are exceeded. In some cases, these restrictions or sales could have an adverse impact on client account performance. Legal and regulatory constraints could limit certain client accounts from participating in specific investment transactions with others. Consequently, we might allocate these opportunities in a manner that excludes some accounts, even if they could benefit. While this could impact the performance of affected accounts and create a conflict of interest, we are committed to our allocation policy which is to seek to distribute investment opportunities fairly and equitably over time.

Conflicts Related to Investment Consultants. Many of our clients and prospective clients retain investment consultants (including discretionary investment managers and OCIO providers) to advise them on the selection and review of investment managers (including with respect to the selection of investment funds). We have dealings with these investment consultants in their roles as discretionary managers or nondiscretionary advisers to their clients. We also have independent business relationships with investment consultants. We provide investment consultants with information about accounts that we manage for their clients (and similarly, we provide information about funds in which such clients are invested), in each case pursuant to authorization from the clients. We also provide information regarding our investment strategies to investment consultants, who use that information in connection with searches that they conduct for their clients. We often respond to requests for proposals in connection with those searches. Other interactions we have with investment consultants include the following:  we provide advisory services to the proprietary accounts of investment consultants and/or their affiliates, and advisory services to funds offered by investment consultants and/or their affiliates;  we invite investment consultants to events or other entertainment hosted by us;  we purchase software applications, market data, access to databases, technology services and other products or services from certain investment consultants; and  we sometimes pay for the opportunity to participate in conferences organized by investment consultants. We will provide you with information about our relationship with your investment consultant upon request. In general, we rely on the investment consultant to make the appropriate disclosure to its clients of any conflict that the investment consultant believes to exist due to its business relationships with us. 29 PGIM Real Estate FORM ADV PART 2A

Please note that your relationship with an investment consultant could result in restrictions in the eligible securities or trading counterparties for your account. For example, accounts of certain clients (including clients that are subject to ERISA) can be restricted from investing in securities issued by the client’s consultant or its affiliates and from trading with, or participating in transactions involving, counterparties that are affiliated with the investment consultant. In some cases, these restrictions could have a material impact on account performance.

Conflicts Related to Service Providers. At times, we will have incentives to hire an affiliate, an affiliate of a client or a service provider who has provided something of value to us or to one of our affiliates, in each case to provide services to a client and regardless of whether an unaffiliated service provider could provide the same service to the same standard or at a lower cost. To manage this conflict, we seek to ensure that there is appropriate disclosure in writing to the relevant client(s) and underlying investors and take reasonable steps to consider whether the fees and other amounts to be paid to the affiliated service provider, and the affiliate’s capabilities as well as the other terms on which it is engaged, are comparable to those generally available in the market. We retain third party advisors and other service providers to provide various services for our firm as well as for funds that we manage or sub-advise. Some service providers provide services to us or one of our funds while also providing services to our affiliates or other funds managed by us or our affiliate, and negotiate rates in the context of the overall relationship. We can benefit from negotiated fee rates offered to our funds and vice versa. There is no assurance, however, that we will be able to obtain or maintain advantageous fee rates from a given service provider negotiated by our affiliates based on their relationship with the service provider, or that we will know of such negotiated fee rates.

Conflicts Arising Out of Employee Affiliations. We could limit or restrict trading of an issuer in client accounts where the portfolio manager is related to a person who is senior management or a director of a public company.

Conflicts Arising Out of Affiliations of Our Affiliates. As part of a global financial services group that includes insurance companies, other investment advisers and broker-dealers, we face conflicts when a client has a relationship with one of our affiliates or when the advice or management services we provide relate to an entity that has relationships with one or more of our affiliates. Such relationships could affect or influence decisions that we make, including decisions whether or not to take certain actions. In certain situations, our relationship with an affiliate will also give rise to legal, regulatory and contractual restrictions on particular investment activity made on behalf of a client or on the timing of such activity. There will be circumstances in which we will be prohibited from engaging in transactions with our affiliates even when such transactions could be beneficial for client accounts. Certain transactions with affiliates are permitted in accordance with procedures we have adopted and subject to applicable law. As part of a large investment management organization, there are situations in which we intend to enter into revenue sharing arrangements with certain of our affiliates pursuant to which we will make payments to an affiliate on an ongoing basis to accommodate the interrelated nature of PGIM’s multi-asset solutions efforts. This revenue sharing is intended to reimburse the affiliate for amounts that it foregoes as part of a larger multi-asset mandate with its affiliated advisers who will act as subadvisers or managers to funds or products that our affiliate allocates to under the mandate. Notwithstanding this arrangement, a client will pay the rates negotiated with the relevant affiliate that includes, as applicable, sub-advisory fees and underlying fund or product fees and expenses, and the internal revenue sharing arrangement will not result in additional fees or expenses to a client. Certain of our affiliates develop and intend to publish research that is independent from the research that we develop and 30 PGIM Real Estate FORM ADV PART 2A

publish. At times, we expect we will hold different opinions on the investment merits of a given property, security, issuer or industry such that there will be times when we will be acquiring or holding an investment for a client when an affiliated entity will be selling or recommending a sale of the same or a similar investment. Conversely, there will be times when we will be disposing of an investment for a client when an affiliated entity is acquiring or recommending an investment in the same or similar investment. In addition, we expect an affiliated broker-dealer or investment adviser will be executing transactions in the market in the same publicly traded real estate securities as we are. Certain of our affiliates (as well as directors or officers of our affiliates) are officers or directors of issuers in which we currently invest in or expect to invest in the future or engage as a service provider from time to time. At times, our affiliates also expect to invest in or engage these issuers as service providers. Supplemental Loans. With respect to commercial real estate loans, borrowers commonly seek additional loan proceeds (“supplemental loans”) from their existing lender and, where we determine a supplemental loan presents an attractive investment opportunity to the existing lender client or the borrower is otherwise contractually entitled to receive the supplemental loan, we will either invest the client into the supplemental loan or, if that client lacks commitment capacity at the time or is otherwise unavailable to fund its share of the supplemental loan, invest another account managed by us into the supplemental loan alongside the client. Because a supplemental loan will typically be secured by the same lien securing the client’s investment, the client will not be compensated for a corresponding increase in risk in its investment if it does not take an allocation of a supplemental loan. In all such situations, we will seek to manage all conflicts in its reasonable discretion. Refinancings. We are a large, global asset manager that advises numerous affiliated and third-party capital sources with respect to multiple commercial real estate debt investment strategies. For this reason, we actively invest clients into loans to borrowers that are used to refinance loans held by other PGIM clients. The opportunity to refinance a debt investment will have significance to us because we will be commercially and financially incentivized to keep the asset with a PGIM-managed account. All of our originators generally have access to information about all loans originated by us and will at times be financially incentivized to utilize such information to retain refinancing opportunities, including by monitoring loan maturities. In addition, there will be times when we expect to cause the terms of a client’s debt investment to include provisions which seek to retain the refinancing opportunity with a PGIM-managed account. If used, such terms will impose a general obligation on the borrower to consider a PGIM bid on the refinancing opportunity or include a waiver of fees payable to the client in exchange for us being awarded the refinancing opportunity and the corresponding financial compensation for the same. In all cases involving such conflicts, we will be guided by our good faith judgment as to fairness to the client and will seek to manage all conflicts. Terms of Investments. Private credit assets are evidenced by loan documents that are typically negotiated in our discretion. At times, the terms of such documents will present conflicts between the manager and the client and between the client and other PGIM-managed clients, including PGIM-affiliated clients, particularly on co-investments where the respective interests of the parties will not always be aligned in all cases. In addition, the terms of such documents are typically customized for the applicable circumstances and will be subject to commercial negotiation with the applicable counterparty. Where we are expected to implement contractual and similar arrangements between clients, the terms of which have not been settled upfront, we will use our knowledge and experience to seek to cause the terms of the same to be commercially reasonable and consistent with market standards and convention then-applicable, all as determined in our reasonable discretion in view of all circumstances. There can be no assurance, however, that we will be able to do this effectively or that all clients will view such terms and conditions to be fair or reasonable to them, or that the basic bargain set forth in the investment documents are fairly or accurately captured. In all situations, we will be guided by our good faith determination as to reasonableness under the circumstances and by its policies and procedures designed to mitigate conflicts of interest. Competing Interests. Other than specific contractual restrictions that in certain circumstances will exist, including as a result of being required by investors, there are no restrictions on us or our affiliates from forming, sponsoring, owning, managing or advising additional investment vehicles or clients that have overlapping investment objectives or investment criteria. There can be no assurance that we or our affiliates will not devote more time, attention or resources to some of these potentially competing investment vehicles and clients than to others or present an opportunity to some investment vehicles or clients that we do not or cannot present to all. In certain cases, this will have a material adverse effect on an investment vehicle’s or 31 PGIM Real Estate FORM ADV PART 2A

client’s ability to acquire assets, generate cash flow and income, and make or receive distributions. Now or in the future, we intend to engage in marketing or support activities for or on behalf of investments offered by other affiliates. In the event an investor sourced by PGIM Real Estate enters into an investment relationship with another affiliate, PGIM Real Estate intends to be compensated for its efforts either by participating in the fees paid to the other affiliate by the affected investor, or in such other manner as the parties agree. Warehousing of Investments. In certain situations, we will face a conflict in relation to the price or other terms on which an investment that is held either on our balance sheet or the balance sheet of one of our affiliates for some period of time is subsequently transferred to a fund or client managed or advised by us. Where so warehoused, these assets are generally expected to be transferred or syndicated at a price equal to PGIM warehouse’s cost plus a “cost of carry”, but pricing could also rise or fall from the original closing price at which the asset was initially acquired by us or our affiliate depending on market movements. We manage this conflict by relying on appropriate disclosure to the fund investors or client concerned (or investor consent where applicable) and on appropriate independent advice being provided to the fund or client that the warehoused investment is being transferred to. Transactions between Clients; Investments in PGIM Funds. At times, we expect one or more of our clients to co-invest in investments through one or more sidecars, joint ventures or other joint investment vehicles (each, a “Joint Investment Vehicle”). Such Joint Investment Vehicles can also include third parties and/or other funds or investment vehicles or accounts managed by us or our affiliates as co-investors. The clients will generally bear their share of fees and other compensation charged by or payable to third party service providers and other third parties (including incentive compensation payable to third party operating partners) to or with respect to each Joint Investment Vehicle and all other expenses borne by each Joint Investment Vehicle (which can also, in each case, include amounts initially paid by us and/or our affiliates and reimbursed by such Joint Investment Vehicle). The specific terms of Joint Investment Vehicles will vary, and it is expected that certain Joint Investment Vehicles will pay fees to us or our affiliates if permitted under the governing documents of the client investing in the Joint Investment Vehicle. We have adopted policies and procedures that will be applied to address the conflicts of interest relating to such co-investments. Where two or more PGIM-managed clients are involved in a transaction, it will be difficult for us to satisfy our fiduciary duty to both clients in respect of the transfer of an investment between, or joint acquisition of an investment by, two managed accounts. Relatedly, where a PGIM-managed client is invested as part of a broader mandate into a PGIM-managed account, fiduciary duties to the client would be qualified by those fiduciary duties owed to the fund and to investors in the fund as a whole. To manage this, we have policies and procedures in place and would rely on appropriate disclosure to and, when appropriate, consent from the clients concerned, and/or on appropriate independent advice being provided to both clients. Affiliated Clients. At times, we have an incentive to provide preferential treatment to an affiliated client or investor as compared to an unaffiliated client or investor. In addition, we and our affiliates expect to have certain intergroup financial arrangements which will have the effect of giving affiliates that are our clients or investors preferential economic terms as compared to unaffiliated clients or investors. Furthermore, an affiliated client will at times have access to information or reports that are not available to equivalent unaffiliated investors. For example, individuals who are responsible for managing Prudential Financial’s enterprise investment risk can have access to certain information about our assets under management, including for third parties, that is not typically made available to unaffiliated clients (although this access does not include specific unaffiliated client identifying information or portfolio information for our clients who have asked for confidentiality with respect to sharing of information with our affiliates). Despite this, we seek to ensure that any such treatment, financial arrangements and information rights, and the manner in which we manage our relationships with affiliated clients are consistent with our ability to act in the best interests of all our clients. Certain Fees Retained by Manager. Upon the acceptance of a loan application or term sheet, borrowers commonly pay nonrefundable fees to compensate us for undertaking the processing activities associated with moving real estate loans to closing. These fees (“Application Fees”) are typically due upon acceptance of a loan application or term sheet and are earned at that time by PGIM. Subsequent to the acceptance of a loan application or term sheet and completion of the aforementioned processing activities, we will allocate the investment opportunity in the applicable loan to an eligible investor managed by us. Currently, Application Fees on all U.S. core commercial mortgage loans are charged at 10 basis points (0.10%) of the expected loan amount. 32 PGIM Real Estate FORM ADV PART 2A

Application Fees are dictated (and can change) in the Investment Manager’s discretion. Application Fees will be received by us or our affiliates prior to the loan being allocated to the client or after but in no event will be shared with the client except to the extent expressly agreed with the client in writing. Borrowers also commonly pay fees commensurate with market standards and practice to compensate us for undertaking due diligence relating to the loan (“Due Diligence Fees”), as well as various activities necessary to move the loan to closing (“Origination Fees”). Origination Fees may be (i) offset by any Application Fee already paid upon acceptance of a loan application or term sheet, (ii) paid entirely at loan closing, or (iii) structured with all or a portion of the Origination Fees deferred for payment by the borrower after loan closing as “exit fees”. Currently, Due Diligence Fees are charged as a fixed amount equal to $25,000 or more and collected at the point of acceptance of a loan application or term sheet, while Origination Fees are charged at 10 basis points (0.10%) or more of the expected fixed-rate loan amount or 50 basis points (0.50%) or more of the expected floating-rate loan amount. In all cases, Due Diligence Fees and Origination Fees are dictated (and can change) in our discretion and will be received by us or our affiliates prior to the loan being allocated to the client or after. Origination Fees will be shared with the client in our discretion, except to the extent expressly agreed with the client in writing to be paid to the client. Loans with Potential Exit to PGIM’s Agency Originations Business. We and our affiliates originate loans secured primarily by properties undergoing transitioning with the expectation that such loans would be good candidates to subsequently be refinanced by PGIM’s agency business in accordance with applicable agency (e.g., Fannie Mae) criteria once the underlying property has achieved stabilization. Because of these ties to PGIM’s agency business, one of the features of such loans is that the borrower typically agrees to pay the lender an exit fee in the event the borrower elects to pursue a refinancing of the loan (whether by an agency takeout or otherwise), provided that the lender will be required to waive or reduce this exit fee under the terms of the loan if either (i) the borrower pursues an agency refinancing originated by a PGIM affiliate or (ii) parties related to the borrower pursue agency financing opportunities originated by a PGIM affiliate. In all cases where the exit fee is so waived or reduced by the lender, PGIM affiliates will be separately compensated for origination and related work. If we decide to pursue such a loan for the client, we will make an investment decision based solely on the best interests of the client without taking into account the value of a potential exit fee (which would be subject to waiver or reduction in accordance with the terms disclosed to the client at allocation) or the potential financial benefit to any PGIM affiliate. In our view, doing so is beneficial for the client because such loans provide the client with another source of potential investment opportunities with an attractive risk-return profile that at times will not otherwise be available to the client; however, the client’s ownership of such loans also could present certain conflicts between its interests and ours and our affiliates because of the compensation arrangements discussed above which will not be shared with the client. We will at all times seek to manage any conflicts arising from these arrangements, including in the manner discussed above. Earnings on Bank Accounts and Other Accounts. Subject to applicable law, payments received from borrowers under investments held the client can be collected by us or our affiliates into bank accounts or investment accounts (“Collection Accounts”) owned and maintained by us or our affiliates. Such payments can be commingled with funds received for the benefit of other clients or parties unrelated to the client, including accounts which are affiliated with us. In addition, subject to applicable law, certain investments will at times impose an obligation on the applicable borrower to fund escrow reserves (e.g. to fund taxes or insurance premiums or to fund certain permitted capital expenditures at the collateral property) which will serve as additional collateral for the subject investment, and at times such escrow reserves will also be held in accounts (“Escrow Accounts”) owned and maintained by us or our affiliates. Funds held on deposit in Escrow Accounts will also be commingled with funds which are being escrowed under loans unrelated to a client, subject to applicable law. We, our affiliates, or a designee thereof will receive interest, income, proceeds, or other fees or earnings in respect of amounts held in Collection Accounts and Escrow Accounts, and the client shall not be entitled to such amounts. Co-Lending. The client can expect to be a co-lender with other third-party clients managed by us, including in loans in which our affiliates are not a co-lender. In any such co-lending transaction in which each co-lender is in a direct lending relationship with the borrower, a co-lending agreement (or other contract including similar provisions) will be entered into by all co-lenders to the transaction, and we will use our knowledge and experience to seek to cause the terms of the same (including with respect to transfer restrictions, voting and deadlock) to be commercially reasonable and consistent with market standards and convention then-applicable, all as determined in our reasonable discretion in view of all circumstances. Pursuant to the co-lending agreement, 33 PGIM Real Estate FORM ADV PART 2A

the client will be caused to appoint us or our affiliates to provide loan servicing and administration services with respect to the loan. The co-lending agreement will typically require that we continue to perform all loan servicing at all times with respect to the loan. The size of the client’s stake in a co-lending transaction will be dictated by our allocation policies and protocols, and the client will at times have the same percentage ownership in the loan as other co-lenders or at other times have a greater or lesser stake than other co-lenders. Depending on the size of a co-lender’s stake in a co-lending transaction, the terms of the co-lender agreement will afford the co-lender different rights to approve matters affecting the loan, including potentially no rights at all. Generally, if all co-lenders in a transaction are clients of ours, we will utilize a co-lender agreement form that requires all colenders to approve certain major decisions but would only require the holders of a super-majority in interests in such transaction (66.67%) to approve other major decisions. In such case, in the event that the client is allocated less than 66.67% of such colending transaction, the PGIM portfolio manager for the client would not be able to block certain decisions by the PGIM portfolio manager for the other co-lenders in the same transaction. Enforcement of remedies, including foreclosure, with respect to a commercial mortgage which is the subject of a co-lending agreement can result in unique risks and conflicts, particularly in situations in which one or more co-lenders are located outside of the U.S. while one or more other co-lenders are based in the U.S. For example, if a co-lending transaction goes into default, then we (or our designee) will be expected to maximize recovery on the asset, seeking to act in the best interests of all co-lenders in view of their respective pro rata ownership interests in the loan and subject in all cases to the rights of the co-lenders under the terms and conditions of such co-lending agreement, including potentially the rights of co-lenders which are not affiliated with or managed by us or our affiliates. The resolution of loans in default can be complicated and take significant time and expense to work through. The available options to the co-lender group in any given situation will be heavily dependent on the applicable facts and circumstances pertaining to the collateral property and its ownership at the time, the relative commercial leverage of the parties, and numerous tax and legal considerations, and this can lead to highly customized loan restructurings or other loan workout solutions. These solutions will at times require some further investment in the asset or delay recovery on some or all of the investment until a future point in time. Where it is determined that foreclosure (or otherwise acquiring title to the collateral property) is the optimal remedy available to the co-lender group, the tax, legal and accounting considerations for the co-lenders will at times not be aligned, and we will at times be expected to implement a recovery plan that would entail all co-lenders holding a pro rata equity ownership interest in an asset-holding vehicle governed by the terms and conditions of a joint venture agreement to be put into place at some point in the future. In such a situation, the terms of such joint venture agreement will be determined by us with a view towards accomplishing the objectives of all co-lenders and the applicable colender agreement. There can be no assurance that we will be able to do this effectively or that all co-lenders will view such terms and conditions to be fair or reasonable to them (particularly in light of the aforementioned potential lack of alignment in interests), or that the basic bargain set forth in the client’s investment documentation are fairly or accurately captured in such joint venture agreement. In all situations, we will be guided by its good faith determination as to reasonableness under the circumstances and by its policies and procedures designed to mitigate conflicts of interest.

34 PGIM Real Estate FORM ADV PART 2A

Receipt of Material Non-Public Information (MNPI) and Information Barrier Standards In the ordinary course of our business, we receive MNPI. MNPI can be received voluntarily or involuntarily and under varying circumstances, including upon execution of a non-disclosure agreement, typically as a result of engaging in investment transactions with public companies or their affiliates. Our personnel are prohibited from improperly sharing or using MNPI for their personal benefit or for the benefit of any other person, regardless of whether that person is a client of ours. PFI’s information barrier standards, which apply to us, and our related procedures are designed to prevent the communication of MNPI across the various PFI asset management investment sectors, and the misuse of MNPI. Under the standards, an employee of one PFI asset management investment sector, including us, is not permitted to communicate MNPI to an employee of another PFI asset management investment sector without approval from the relevant compliance team. This could limit information flow available to certain personnel. The information barrier standards also restrict, as appropriate, physical access to an investment sector’s offices by employees of a different investment sector in addition to the electronic, system, and network access mentioned above. Due to our involvement in managing or advising on portfolios of publicly traded real estate securities, we maintain an information barrier between the personnel involved in advising on or managing those portfolios and those personnel that manage or advise on private real estate investments. This permits our private-side business to engage in real estate transactions with issuers of publicly traded real estate securities that might otherwise restrict our Real Estate Securities team from investing in those securities for relevant clients if no barrier were to exist. In addition, in connection with evaluating private market opportunities (e.g., real estate acquisition/disposition and financing, private equity, direct lending, and other private transactions), as well as potential transactions in public securities which have not yet been publicly announced, we erect internal information barriers on an ad hoc or indefinite basis, as applicable, around a small number of our employees (and, in some cases, employees within other PFI asset management sectors) involved in evaluating such opportunities, so that MNPI received by such employees is not attributed to the rest of our employees. Employees inside the barrier are segregated from investment decision-making on public securities. Similar to the PFI information barrier standards, the internal information barriers restrict, as appropriate, physical and electronic access to certain offices/areas by other of our employees. In addition, we maintain restricted lists of issuers and borrowers (and their affiliates) about whom we have MNPI. Restricted issuers and borrowers are also added directly into the trading system so that our trading activities are screened against our restricted lists. Investment personnel must receive an override from our compliance unit prior to transacting for client accounts in the securities of any issuers or, in some cases, loans of any borrowers that are restricted in the trading system. Overrides are granted only when legally permissible and appropriate under our policies. Our restricted lists limit investment opportunities available to our clients, and client accounts that hold restricted securities and/or loans are not permitted to sell or buy securities or, in some cases, loans until such time as the related issuers or borrowers are removed from the restricted lists. (See Item 10 at “Conflicts Arising Out of Legal and Regulatory Restrictions” for further information about how our ability to buy, sell, or transact is limited as a result of our receipt of MNPI.) Under certain circumstances, contractual obligations owed by us to third parties to maintain confidentiality and legal and regulatory requirements prevent us from sharing (or could limit our ability to share) MNPI, information based on MNPI (including, but not limited to analyses), or other confidential information with our clients and others.

Personal Investing Personal trading by our employees can create a conflict of interest when they are trading in the same securities or types of securities that we or our affiliates recommend to clients. To manage such potential conflicts, we maintain personal investing standards that govern the trading activities of our employees as well as their household members and dependents. Subject to certain limited exceptions, employees are required by the standards to:  report personal securities transactions;  pre-clear personal securities transactions; 35 PGIM Real Estate FORM ADV PART 2A

maintain brokerage accounts exclusively with designated, approved brokers who are required to provide regular transaction reporting, ensuring transparency and compliance with internal monitoring standards; and annually confirm securities holdings.

Our access persons and investment personnel are subject to additional restrictions under the standards, including the following (which are subject to exceptions for certain de minimis transactions):  all personnel are generally prohibited from purchasing securities in initial public offerings;  access persons are prohibited from knowingly trading any security on the same day that we trade such security for client accounts;  investment personnel are prohibited from knowingly trading any security within seven days before or after we trade such security for client accounts;  access and investment personnel who invest in covered securities (including proprietary and certain non-proprietary mutual funds and ETFs) must hold such investments for a period of at least 60 days, with certain exceptions; and  access and investment persons are prohibited from writing uncovered call options or buying uncovered put options on a security held in a client account. Our compliance team monitors personal trading activity and checks for matches against firm trading and restricted list content. The team investigates any such matches to avoid adverse alignment with client positions. An ethics committee meets regularly to consider possible violations and take disciplinary action where appropriate. All employees receive routine training regarding our personal securities trading and information barrier standards. In addition, employees must annually confirm that they have read and understand our code of ethics, including the personal securities trading and information barrier standards.

Gifts and Entertainment Policy Our employees occasionally give or receive gifts, meals or entertainment of moderate value, subject to compliance with applicable laws and regulations, and rules of self-regulatory organizations. We have adopted a gift and entertainment policy to address the conflicts of interest related to gifts and entertainment, such as the appearance of having given or received something of value that influenced our business decisions or the business decisions of our clients. The policy requires the reporting and preclearance of gifts, meals and entertainment given or received which exceed certain thresholds, with additional procedures in place to ensure compliance with (i) the Employee Retirement Income Security Act (“ERISA”) regulations, (ii) the Foreign Corrupt Practices Act (“FCPA”), and (iii) rules related to employees of local, state or federal governments. PGIM associates employed or representing PGIM’s European entities must also pay due regard to the local inducements rules. PGIM’s MiFID entities are generally prohibited from giving or receiving any gifts or entertainment which is of a scale and nature that it could be judged to impair PGIM’s duty to act honestly, fairly and professionally and in the best interest of PGIM’s clients. In addition, our employees are prohibited from soliciting such receipt of gifts, meals or entertainment. In addition, our employees are prohibited from soliciting the receipt of gifts, meals or entertainment. Senior management periodically reviews summaries of gifts and entertainment activity to detect trends of abuse, conflicts of interest, or possible violations of the policy.

Political Contributions Due to the potential for conflicts of interest, we, along with PFI, have established policies and procedures relating to political contributions that are designed to comply with applicable federal, state and local law. Under our political contributions policy, all employees (including spouses, partners, and dependent children) must obtain preapproval before making any U.S. political contribution. This policy also prohibits our employees from making any political contributions with the intent of influencing a public official regarding the award of a contract to us or our affiliates.

Outside Business Activities From time to time, certain of our employees or officers engage in outside business activity, including outside directorships. 36 PGIM Real Estate FORM ADV PART 2A

Any outside business activity is subject to prior approval pursuant to our personal conflicts of interest and outside business activities policy, and may be restricted or denied if conflicts cannot be managed. Actual and potential conflicts of interest are analyzed during such approval process. We could be restricted in trading the securities of certain issuers in Client portfolios in the unlikely event that an employee or officer, as a result of outside business activity, obtains material, nonpublic information regarding an issuer.

Compensation of our Investment Professionals Compensation of our Investment Professionals Generally speaking, the compensation of our investment professionals (including, among others, portfolio managers and research analysts) includes a combination of base salary, a performance-based annual cash incentive bonus, and a long-term incentive grant. Investment professionals sometimes also participate in performance-based fees or compensation payable by our clients. The base salary component is based on market data relative to similar positions within the industry as well as the past performance, experience, and responsibility of the individual, and the annual cash incentive bonus is paid from an annual incentive pool. Each investment professional's incentive compensation, including both the annual cash incentive bonus and the long-term incentive grant, is primarily determined by how significantly he or she has contributed to delivering investment performance to clients consistent with relevant objectives, guidelines, and risk parameters, as well as the individual’s qualitative contributions to the organization. Our incentive compensation program is designed to align the interests of each investment professional with those of our clients. The performance of our clients’ accounts, of our overall business, and of the individual employee are all important factors in determining the size of the annual cash incentive bonus and long -term incentive grant awarded to each individual. Total compensation is designed to be competitive with the market, but an individual’s actual compensation will vary. Long-term incentive grants to investment professionals are made in the form of 80% deferred cash that tracks the performance of funds tied to the grant and 20% in restricted stock units (RSUs) of Prudential Financial, Inc. These long-term incentive grants vest over a three-year period. Investment professionals are all covered by the same general compensation structure, although they will at times manage multiple accounts. Generally, all compensation is paid by PGIM, not from any client assets. However, where a portion of the performance-based fees and other compensation that we earn is typically shared with relevant investment professionals and members of senior management, such amounts will be paid to the individuals concerned directly or indirectly from such performance fees paid by the relevant client. Certain senior managers also receive performance shares which represent the right to receive shares of Prudential Financial common stock conditioned upon, and subject to, the achievement of specified financial performance goals by Prudential Financial. Each of the long-term incentive plan grants and performance shares are subject to vesting requirements.

Conflicts Related to Compensation Performance-based fees and compensation, whether paid to the enterprise or to individual employees, can create an incentive for us or a supervised person to make or recommend investment decisions that are riskier, more speculative or otherwise different than those that would be made or recommended in the absence of such a compensation structure. To manage this, we have policies and procedures designed to ensure that each of our client’s investments are managed in a manner that is consistent with our fiduciary obligations, as well as with the client’s investment objectives, investment strategies and restrictions. Those procedures include independent internal review of investment decisions.

37 PGIM Real Estate FORM ADV PART 2A

Conflicts Related to our Trading Conflicts Related to Employee/Investment Professional Trading Personal trading by our employees creates a conflict when they are trading the same securities or types of securities as PGIM trades on behalf of its clients. A portfolio manager for a strategy targeting publicly traded real estate securities that personally owns a security could decide to buy or sell the same security for client accounts. Similarly, an analyst for a strategy targeting publicly traded real estate securities that personally owns a security could recommend the security to be purchased or sold for client accounts. Conflicts could also arise for portfolio managers and other employees involved in our private commercial real estate investment business to the extent such individuals personally own a security and have the ability to influence a fund or client’s investment decisions in a manner that could have an actual or perceived benefit to such personally-held security. Additionally, our employees could purchase private investments that could become eligible for purchase for or to be recommended for purchase for client accounts when the investment becomes publicly traded in the future. Our personal trading policy and procedures, described above, seek to mitigate these conflicts.

Other Employee Interests Similarly, a conflict of interest is created when employees have a personal interest in the same investments or types of investments as we manage on behalf of clients, whether the investment is an equity interest in a particular commercial real estate property or a sponsor that owns that property, for example. A portfolio manager could also be related to a person who is senior management or a director of a public company. Our personal trading and personal conflicts of interest and outside business activities policies and other procedures seek to mitigate these conflicts.

Side-by-Side Management of Accounts See Item 6 for a description of conflicts of interest related to our side-by-side management of accounts.

Conflicts Related to the Offer and Sale of Securities Certain of our employees offer and sell securities of, and interests in, commingled funds that we manage. Employees offer and sell securities in connection with their roles as registered representatives of PIMS, agents of PICA, approved persons of PGIM Limited or other roles related to such commingled funds. (See Item 10 for more information about these affiliations.) There is an incentive for our employees to offer these securities to investors regardless of whether the investment is appropriate for such investor since increased assets in these vehicles will result in increased advisory fees to us. In addition, such sales would likely result in increased compensation to the employee. (See “Other Compensation” in Item 5).

Conflicts Arising out of Securities Holdings Prudential Financial, PICA’s general account, our proprietary accounts and accounts of other affiliates of ours (collectively, affiliated accounts) could, at times, have various levels of financial or other interests in companies whose securities we could hold, purchase or sell in our client accounts. This could occur because affiliated accounts hold public and private debt and equity securities of a large number of issuers and might invest in some of the same companies as our client accounts. Additionally, investments of affiliated accounts and our client accounts can be at different levels in the capital structure of a company. At any time, these interests could be inconsistent or in potential or actual conflict with positions held or actions taken by us on behalf of other client accounts. For example, we could invest client assets in the equity of companies whose debt is held by an affiliate. Additionally, to the extent permitted by applicable law, we are also able to invest client assets in offerings of securities the proceeds of which are used to repay debt obligations held in affiliated accounts or other client accounts. Our interest in having the debt repaid creates a conflict of interest. We have adopted policies and procedures to address this conflict. While these conflicts cannot be eliminated, we have implemented policies and procedures, including adherence to Prudential Financial’s information barrier standard, described above, that seek to provide that, notwithstanding 38 PGIM Real Estate FORM ADV PART 2A

these conflicts, investments of our clients are originated and managed in their best interests. We could be unable to invest client assets in the securities of certain issuers as a result of the investments of our affiliates described above.

Real Estate Securities Business Conflicts of interest arise regarding proxy voting. To address this, a senior PGIM Real Estate portfolio manager oversees the proxy voting process in accordance with our proxy voting policy (further details of which are set forth at Item 17). It is our policy not to engage in principal transactions with affiliated broker-dealers for unaffiliated institutional accounts that we manage. We cause transactions to be executed for a client’s account concurrently with authorizations to purchase or sell the same publicly traded real estate securities for other accounts we manage, including proprietary accounts or accounts of affiliates. In these instances, the executions of purchases or sales, where possible, are allocated equitably among the various accounts. We buy or sell or in some cases will direct or recommend that one client buy or sell, investments of the same kind or class that are purchased or sold for another client, at prices which can be different. In addition, we can execute trades of publicly traded real estate securities of the same kind or class in one direction for an account and trade in the opposite direction or not trade for any other account due to differences in investment strategy or client direction. Conflicts of interest arise in connection with the investment or other activities of PGIM and its affiliates, or through the relationships of such parties with issuers of public securities. One or more of our affiliates can at times hold various levels of financial or other interests, including but not limited to portfolio holdings in companies whose securities can be held or purchased or sold in third party client accounts. These financial interests can be in potential or actual conflict with the interests of our client accounts or can be inconsistent with positions we hold or actions we might take on behalf of our client accounts. These interests can include debt or equity financing, strategic corporate relationships or investments and the offering of investment advice in various forms. Thus, PGIM invests client assets in the securities of companies with which we or an affiliate can have a financial relationship, including investment in the securities of companies that are our advisory clients. At times, we will be unable to invest client assets in the securities of certain issuers as a result of these investments or relationships. A client account can have an investment in securities of an issuer, including an equity interest in a joint venture or another entity that is engaged in a business that competes with issuers whose securities are held in other client accounts, or that competes directly with our business or that of an affiliate. Examples could include investments in publicly-traded securities of insurance or financial services companies that are competitors of Prudential Financial; or certain investments of one or more of our clients in entities that are engaged in commercial mortgage lending and related activities, a business in which one or more of our affiliates are actively engaged. While these types of conflicts cannot be eliminated, we have implemented policies and procedures designed to seek to ensure that all investments of our clients are originated and managed in their best interests. Our holdings of a security on behalf of our clients are required, under certain regulations, to be aggregated with the holdings of that security by other Prudential Financial affiliates. These holdings could, on an aggregate basis, exceed certain reporting or ownership thresholds. Prudential Financial tracks these aggregated holdings and we will seek to restrict purchases, sell existing positions, or otherwise restrict, forgo, or limit the exercise of rights to avoid crossing such thresholds because of the potential consequences to us or Prudential Financial if such thresholds are exceeded.

Other Conflicts Client Relationships and Side Agreements. At times, we agree to provide certain of our clients with a different or greater level of information, reporting, operational support, other resources or overall services than we generally provide to other clients. In doing so, we would not do anything that was inconsistent with the best interests of all our clients and in all events we would only do so in compliance with applicable law. In addition, we sometimes enter into side agreements with investors in the funds and other investment vehicles that we manage that include, among other things, supplementary rights, including with regard to matters such as advisory committee membership, access to co-investment opportunities, special investment restrictions, information rights and reporting requirements. We do not enter into side agreements with investors that, in our judgment, would materially adversely affect the interests of other investors in the same fund or investment vehicle, unless 39 PGIM Real Estate FORM ADV PART 2A

otherwise permitted under the relevant legal documents. Any such rights are afforded to investors in compliance with applicable law. Investment Allocations. We have numerous affiliated and unaffiliated clients who are seeking the same type of investment opportunities resulting in potential conflicts of interest in allocating such investment opportunities. For example, we could have an incentive to favor clients that pay higher fees or generate more income for us than other clients. In some cases, we have and intend to provide one or more clients preferred allocation rights with respect to certain types of investment opportunities. To address these conflicts, we have adopted rotational investment allocation procedures as well as supervisory procedures that, combined with disclosure, are intended to ensure the fair allocation of investment opportunities among competing client accounts over time. Valuation of Investments. Our fees are at times based on the value of assets under management which include illiquid or difficult to value investments and potentially cash. We seek to address the resulting conflict of interest that we have in valuing client assets by seeking to ensure that our valuation policies and procedures enable us to value such assets fairly and in a manner that is consistent with the best interests of our clients. Clients should review our valuation policies applicable to their investment strategies to understand how fair value calculations are determined by us and at what frequency and manner an independent valuation provider is engaged in our valuation process.

The Real Estate Securities team conducts reviews of broker performance during quarterly Best Execution Committee Meetings. Committee members include PGIM Real Estate professionals from multiple areas, including, Compliance and Portfolio Management. The Real Estate Securities team also employs guidelines regarding trading with counterparties.

B.

Soft Dollars/Research Services

The Real Estate Securities team receives a broad range of proprietary and third-party research from broker-dealers in the form of written reports, periodicals, investment seminars, software, computer databases, and access to corporate management and industry spokespersons, security analysts, economists and government representatives. Under the safe harbor provided under Section 28E of the Securities Exchange Act of 1934, our equity business pays for these research and brokerage services with our equity clients’ brokerage commissions. These non-execution services can aid in our investment decision making or trade execution. We exclude from use under these arrangements those products and services that are not eligible under applicable regulatory interpretations even when a portion of “mixed use” products or services would be eligible if accounted for separately. The use of soft dollars to pay for this research is a benefit for us because we do not have to pay for this research using our own money. The receipt of soft dollar benefits creates a conflict of interest because it creates an incentive to select or recommend a brokerdealer based on our desire to receive research or brokerage services rather than our clients’ interest in receiving best execution. In order to mitigate this conflict, when selecting a broker to execute client transactions in return for soft dollar benefits, we seek the best execution and most advantageous price in light of the overall quality and reliability of brokerage taking into 40 PGIM Real Estate FORM ADV PART 2A

account the factors outlined above. In some instances, entities provide research services but have not entered into commission sharing agreements with us (“Bundled Provider”). In these instances, to the extent that any broker or research provider provides proprietary research, we cannot place an explicit value on that research. In other instances, we could enter into commission sharing agreements with brokers and entities who provide research services (each, a “CSA Provider”) whereby a portion of the commission expense is allocated to the provision of third-party research. In both cases, we make a good faith determination that the higher commission is reasonable in relation to the value of research and brokerage services provided, viewed in terms of either that particular transaction or our overall responsibilities with respect to all of our clients’ accounts. Finally, we have arrangements with certain brokers who provide “execution only” services. We have policies and procedures to address and track the use of client commissions to pay for eligible soft dollar services. In accordance with the procedures, we have a comprehensive CSA program (described below) and regularly review the amount of brokerage allocated to brokers that provide us with soft dollar services.

Commission Sharing Arrangements Real Estate Securities makes payments for permissible soft dollar benefits either via a portion of the commissions paid to the executing broker, or through a commission sharing arrangement (“CSA”). CSAs enable us to effect transactions, subject to best execution, through brokers who agree to “unbundle” their commission rates in order to allocate a portion of eligible commissions into a pool that can be used to pay for research from providers with which Real Estate Securities does not have a brokerage relationship. In the event of a broker-dealer’s default or bankruptcy, commissions allocated through CSAs could become unavailable for the benefits described below. Real Estate Securities pays for proprietary research that is not paid through a CSA by trading directly with the broker that produced the proprietary research (“Research Trades”). Real Estate Securities also pays for brokerage services such as execution management services by trading with the broker that provides the brokerage services. These commissions do not separate out the cost of research or brokerage service from the cost of execution and are considered bundled commissions. Orders are generally aggregated across all accounts purchasing or selling the same security at the same time pursuant to the Real Estate Securities Allocation Policy. Accordingly, all accounts participating in a CSA or Research Trades pay the same commission rate for trades and share pro rata in the costs of the particular transaction. In consultation with a client, the Real Estate Securities team could consider alternative aspects of its CSA program. For example, the Real Estate Securities team could agree to a cap on its accumulation of CSA credits to some agreed amount. Any incremental trading cost benefit for transactions beyond this budgeted amount would accrue to the client in the form of reduced commission costs. Participation in CSAs enables Real Estate Securities to consolidate payments for brokerage and research services through one or more channels using accumulated client commissions or credits from transactions executed through a particular brokerdealer to obtain brokerage and research services provided by other firms. Such arrangements also help Real Estate Securities strengthen its relationships with key brokers while still maintaining relationships with research providers which facilitates our ability to seek best execution in the trading process. Real Estate Securities believes CSAs are useful in its investment decisionmaking process by, among other things, providing access to a variety of high quality research, individual analysts, and resources that enable Real Estate Securities to select the research services it feels are the most valuable to its research process and in turn most beneficial to its clients.

Allocation of Soft Dollar Benefits We use soft dollar research to benefit one, a few or all of our clients, including accounts of our affiliates that we manage. We also use soft dollar research to benefit client accounts other than the client accounts that paid the soft dollar commissions. Research is not generally allocated to client accounts proportionately to the soft dollar credits that the accounts generate. 41 PGIM Real Estate FORM ADV PART 2A

Products and Services Acquired with Client Brokerage Commissions We use soft dollars to pay for a broad range of proprietary and third-party research that is used to supplement our internal research and aid in investment decision-making. Research is received in the form of written reports, periodicals, investment seminars, software, computer databases, access to corporate management and industry spokespersons, security analysts, economists and government representatives. We do not currently but could in the future utilize expert networks. To the extent that we receive both administrative benefits and research and brokerage services provided by brokers, we make a good faith allocation between the administrative benefits and the research and brokerage services and pay for the administrative benefits in hard dollars. From time to time, we independently acquire for uses other than its investment management of client accounts the same services as those provided by a broker. In such instances, we pay hard dollars for those services. In the case of Bundled Providers or CSA Providers, we could pay or be deemed to have paid, commission rates higher than we would have, notwithstanding our determination that the commission paid is reasonable or otherwise been paid in order to obtain such non-execution services. In that regard, the receipt of research and other non-execution services creates a conflict of interest because it creates an incentive to select or recommend a broker-dealer based on our desire to receive research and other non-execution services rather than our clients’ interest in receiving best execution. Generally speaking, the Real Estate Securities team receives research services in connection with trading across all of its strategies, including accounts that use an execution-only broker. For example, research that is paid for through one client’s commissions could be unused in managing that client’s account but used in managing other accounts (including accounts that could use execution-only brokers). The value of the research cannot reasonably be allocated to any particular account, and there can be instances where research disproportionately benefits some accounts relative to other accounts based on the relative amount of commissions paid. We believe that the blend of “execution-only”, Bundled Providers and CSA Providers enhances our investment research and trading processes and results in a competitive overall commission rate. Where Real Estate Securities clients contract directly with PGIM Fund Management and/or PGIM Luxembourg, Markets in Financial Instruments Directive II (“MiFID II”) does not permit them to pay for research using soft dollars. Any research that it receives must be paid for on a hard dollar basis, either from its own account or via a separate research payment account that is funded by its clients. PGIM Fund Management and PGIM Luxembourg have taken the decision to pay for all research received from third party research providers (including broker-dealers) from its own account. The amount that it pays for research varies according to the third party provider. It is still permitted to receive certain types of research for free where it constitutes a permissible minor non-monetary benefit under MiFID II. In respect of wider research services (for example, corporate access) these must also be paid for by PGIM Fund Management, unless they fall within the defined list of acceptable minor non-monetary benefits.

C.

Periodic Broker Review

When selecting a broker to execute client transactions in return for research, we seek the best execution and most advantageous price considering the overall quality and reliability of brokerage considering multiple factors. For this purpose, our Real Estate Securities team has established an evaluation process pursuant to which portfolio management personnel and traders rate broker-dealers regardless of their provision of research services. Subject to our duty to seek best execution and applicable laws and regulations, we generally allocate trading among broker-dealers in accordance with the outcome of this evaluation process.

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D.

Cross Trading

The Real Estate Securities team can engage in cross trading where permissible under applicable law, if we determine that such action would be favorable to both clients and the conditions for the transaction are fair to both parties. Upon a client request or direction, we could also engage in trades between two accounts owned by a client or affiliated clients using a broker-dealer.

As part of the approval process, the suitability of the investment being made for, or the appropriateness of the disposition of the investment by, the particular account is confirmed, taking into consideration the account’s investment guidelines, restrictions and other requirements. Investment guidelines are initially reviewed and approved for each account at the time of account formation by the applicable risk and product approval committees. The Real Estate Securities business does not review individual transactions in publicly traded real estate securities but establishes for each portfolio and then reviews, on a regular basis, the geographic portfolio allocations among Europe, Asia and North America and the other risk characteristics and parameters that will be applied.

Periodic Review of Portfolios PGIM Real Estate has supervisory procedures governing its investment advisory activities which require our investment officers to review, on a periodic basis, the accounts of our advisory clients. All portfolios of private real estate debt and equity investments are reviewed with senior members of the firm, including the Co-Chief Executive Officers and Global Head of Risk on a semi-annual basis. During these meetings, compliance with the investment guidelines for the relevant portfolio is reviewed and feedback regarding the portfolio’s performance, challenges, client feedback, and priorities (among other items) are discussed. Publicly traded mutual fund portfolios subadvised by us are monitored on a daily basis. Additionally, we are subject to oversight by the manager and Board of Directors of each mutual fund.

Additional On-Going Review of Accounts With respect to portfolios of publicly traded real estate securities, control functions such as our compliance team review and assess data and processes relating to our management and trading and report the results of these analyses independently to our senior management. Examples of these independent reviews include a daily compliance review of accounts to assess consistency with guideline restrictions, periodic review of trading to examine allocation, timing and periodic review by the appropriate groups of individuals charged with oversight responsibility for our investment management, trading and related activities. With respect to private real estate and real estate debt portfolios, Compliance is responsible for monitoring fund guidelines on 43 PGIM Real Estate FORM ADV PART 2A

a transactional basis, periodically performing forensic testing on such portfolios and playing an oversight role with committees such as the Allocation and Investment Committees.

MiFID II Requirements As PGIM Fund Management and PGIM Luxembourg are each a manufacturer and distributor of financial products, should either entities activities fall within the purview of MiFID II, the product governance rules require that they understand the products they manufacture and distribute to clients and ensures that (i) the products that they manufacture are designed to meet the needs of the target market of end clients they have identified for that product, and (ii) the distribution strategy is compatible with, and the products are distributed to, that identified target market. As applicable, MiFID II also requires that PGIM Fund Management and PGIM Luxembourg to notify its clients in the event that the value of their portfolio decreases by 10% or more and further multiples of 10% from the value notified in the previous report.

Investor and Client Reporting Investors receive regular reports covering the assets and liabilities and net profit or net loss of a fund or other investment vehicle in which they have invested, as well as a review of the significant investments or dispositions made on behalf of the relevant fund or other investment vehicle. Some funds and investment vehicles that we manage or advise also have advisory councils, comprised of investors, which meet annually or semi-annually to discuss issues with the portfolio management team. Reports of these meetings are distributed to all investors. As applicable to activities that fall within the purview of MiFID II, PGIM Fund Management and PGIM Luxembourg are required to provide clients with ex-ante and ex- post disclosure of all costs and charges associated with the services they provide and the costs of the financial instruments to be recommended or marketed to the client. This information is provided to clients prior to the provision of services and on an annual ex-post basis. Quarterly and annual performance reports, which could include summaries of investment and disposition activity, are made to our advisory clients. We occasionally provide additional information and reports to our affiliated and unaffiliated clients, including pursuant to specific arrangements that we put in place with a specific client or in relation to a particular investment fund that we manage.

Investor and Client Meetings Senior investment professionals are made available on an as needed basis for meetings with clients, including underlying investors in investment funds and vehicles that we manage or advise. The frequency of meetings is at the client’s discretion, although we encourage face-to-face meetings at least once each year. Meetings are tailored to the client’s needs and typically include a review of the economic outlook, a review of portfolio performance and an overview of future investment objectives. Generally, client meetings are attended by a member of the fund’s management team and a designated marketing and client service representative.

There are certain other circumstances under which the SEC deems us to have custody of client assets as well, such as when an affiliated company serves as a general partner of a limited partnership or a managing member of a limited liability company or an affiliated company provides loan servicing services to a fund or client account. Investors in such funds will receive the vehicle’s annual audited financial statements and should review them carefully. PGIM Real Estate also issues account statements for the value of the units of the overall investment client’s assets and any cash positions. With respect to cash balances, where applicable, we urge each investor to periodically compare the account statements received from the qualified custodian with those they receive from PGIM Real Estate. With respect to certain clients that are private funds managed by PGIM Real Estate, such funds are subject to an annual independent audit and the audited financial statements are distributed to investors within 120 days of the end of the applicable funds’ fiscal year. With respect to these funds, we are not required to engage an independent public accounting firm to conduct an annual surprise audit of our operations, as would otherwise be required by rules under the Investment Advisers Act of 1940. A client’s custody agreement with its custodian could contain authorizations with respect to the transfer of client funds or securities broader than those in the client’s written investment management agreement with us. In these circumstances, our authority is limited to the authority set forth in our written investment management agreement with the client regardless of any broader authorization in the client’s custody agreement with its custodian. The custodian’s monitoring, if any, of the client’s account is governed by the client’s relationship with its custodian. In certain cases, where we are deemed to have custody of client assets, our clients will receive account statements from their custodians no less frequently than quarterly. Clients should carefully review those statements. Where our fees are deducted from the client’s custodial account, the statements will show those deductions, among other information. As described in Item 13, we also generally provide statements or reports to our clients for the value of the units of the overall investment client’s assets and any cash positions. Some of the types of information we provide in those statements or reports are comparable to information in the account statements clients receive from their custodians. Clients should compare the account statements they receive from their qualified custodians with the statements that they receive from us and alert us to any differences. PGIM Real Estate has engaged an affiliated servicing business, PGIM Real Estate Loan Services (“PRELS”) to provide loan servicing and administration services to the loan portfolios of certain clients of PGIM Real Estate. In all instances in which PRELS provides such services, bank accounts are established with an unaffiliated bank for purposes of collection and disbursement of funds relating to the client’s investments. As a result of PRELS’ authority to receive and disburse funds or for other reasons, PGIM Real Estate could be deemed to have custody over the accounts holding such funds. To the extent such deemed custody applies, the vehicle holding loans that are serviced by PRELS is subject to an annual audit in accordance with GAAP and its financial statements are delivered to applicable investors within 120 days following such vehicles’ fiscal year end. Investors who fail to timely receive their financial statements, or who have any questions about those financial statements, should contact PGIM Real Estate. 45 PGIM Real Estate FORM ADV PART 2A

For registered investment companies, our authority to trade securities can also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. In the case of a separate account, a client’s investment guidelines and restrictions must be mutually agreed with PGIM Real Estate in writing as part of an investment advisory or management agreement. For our public securities portfolios, prior to onboarding, we obtain all necessary information to ensure that the account, and all relevant restrictions, are properly established in applicable trading and accounting systems.

These guidelines reflect our judgment of how we can best further the economic interests of our clients through the shareholder voting process. From time to time, ballot issues arise that are not specifically addressed by our policy, or circumstances suggest a vote not in accordance with our established guidelines. In these cases, our voting decisions are made on a case-by-case basis taking into consideration our fiduciary duty to our clients. We do not receive all ballots in advance of voting deadlines, but when ballots are received in a timely fashion, we strive to meet our voting obligations within industry standards. We cannot, however, guarantee that every proxy will be voted prior to its deadline. There are also other situations where we could be unable to vote a proxy or choose not to. For example, with respect to international holdings, we take into account additional restrictions in some countries that might impair our ability to trade those securities or have other potentially adverse economic consequences. We generally vote foreign securities on a bestefforts basis if we determine that voting is in the best economic interest of our clients. 46 PGIM Real Estate FORM ADV PART 2A

On an annual basis, proxy voting issues are discussed with senior management. During this discussion, proxy voting policy interpretations, conflicts of interest, and the policy’s effectiveness are reviewed. We currently use the services of a third-party proxy voting facilitator and, upon receipt of proxies, will direct the voting facilitator to vote in a manner consistent with our established proxy voting guidelines described above (assuming timely receipt of proxy materials from issuers and custodians). We provide disclosure of our proxy voting policy, guidelines and procedures to our clients who authorize us to vote proxies, generally at the time that we are negotiating our investment management or advisory agreement. Any client is permitted to obtain a copy of these items, as well as the proxy voting records for that client’s securities, by contacting the client service representative responsible for their account.

Note with Respect to the Voting of Certain Securities Some of our clients are permitted to participate in securities lending programs in their accounts. We do not control or participate in any way in these programs and do not know when or which securities in our clients’ accounts are in these programs. We cannot vote securities that are out of our clients’ portfolios on loan or are otherwise excluded from voting privileges.

Client Direction of Voting Although most of our clients for whom we vote proxies authorize us to vote in accordance with our proxy voting policy, a client has the ability to request that we vote their proxies in accordance with a different policy. We try to accommodate such requests. In addition, a client has the ability to direct us to vote its securities in a particular way on a particular proposal and we will seek to do so, assuming timely receipt of the instruction. However, if the ballot pertains to the client’s own meeting, the ballot will be voted in accordance with our third-party proxy vendor’s policy. (See “Conflicts of Interest in the Voting Process” immediately below.)

Conflicts of Interest in the Voting Process Occasionally, a conflict of interest arises in connection with proxy voting. For example, the issuer of the securities being voted could also be a client of ours. When we identify an actual or potential conflict of interest between our firm and our clients that we are unable to resolve, the matter is referred to the Real Estate Securities team for resolution, which includes abstaining from a particular vote or voting in accordance with the policy of our proxy voting facilitator rather than our own policy.

Accounts for Which We Do Not Vote Securities Some of our clients elect to retain voting authority for themselves. Those clients receive proxies and other solicitation materials from their custodians, and if we receive these materials for the account of such a client, we will forward them to the client’s custodian. If a client has a question about a particular solicitation, the client can contact its client service representative and we will try to address the client’s question. We will not, however, disclose how we intend to vote on an issue for other clients’ accounts.

Class Actions and Corporate Actions In addition to voting rights with respect to securities held in our clients’ portfolios, there could be other rights associated with those securities, including the right or opportunity to participate in class actions and corporate actions. We have agreed with some of our clients to file proofs of claim for class action lawsuits relating to securities held, or formerly 47 PGIM Real Estate FORM ADV PART 2A

held, in their portfolios while managed by us. Other clients can have their custodians handle proofs of claim or handle such matters themselves. Where we have agreed to handle proof of claim filings for a client, we will generally seek and use our best efforts to file such notices in all class action lawsuits in which the client is eligible to participate. In so doing, we will not inquire into the particular circumstances of any client. As a result, we will not seek to determine on an individual basis whether facts and circumstances relevant to that client would suggest that non-participation in the class action is appropriate or more advantageous to that client. For example, a client on whose behalf a proof of claim is filed could, as a result of having joined the class, waive or relinquish other claims that it could have against the target of the class action. The client will at times also have an interest or position with respect to the nature of the class action claim that is averse to that of the class of plaintiffs. We would generally not be aware of those circumstances. Had the client elected to handle class action lawsuits for itself, it might have determined not to file the proof of claim in such a class action. We do not provide any legal advice or services in connection with class actions. With respect to corporate actions (such as an issuer’s merger, tender offer, dividend distribution), we participate on behalf of clients who authorize us to do so, taking such action as we deem to be in the best interest of the clients’ accounts.