Heitman Real Estate Securities LLC: investment adviser

Other Related Entities Section 7.A of Schedule D in the Firm’s Form ADV, Part 1, which is accessible by following the directions on the Cover Page of this Brochure, discloses entities that are subsidiaries of the Firm’s parent entity (hereafter collectively, “Heitman Affiliates”). This disclosure includes all registered investment adviser and broker dealer Heitman Affiliates. Heitman Affiliates utilize limited partnerships or other pooled investment vehicles (the “Heitman Funds”) for investment purposes that are structured for clients of Heitman Affiliates that principally consist of institutional investors. Heitman Affiliates also act as general partner, manager, or in other similar capacities and serve as the investment advisers of these Heitman Funds. As a matter of practice, Heitman Affiliates provide prospective investors in a Heitman Fund with the fund’s private placement memorandum or comparable offering document, which contains information specific to that investment opportunity. Additionally, in certain cases, Heitman Affiliates create special purpose entities, including limited partnerships or similar vehicles that are comprised of one or more investors, but which are not organized as Heitman Funds (“Client SPV Entities”). Similar to Heitman Funds, in these cases, Heitman Affiliates may act as general partner, managing member, or in a similar capacity and also serve as the investment adviser for the Client SPV Entities. As a practical matter, these entities are created to facilitate certain investments in real estate on behalf of one or more clients. These structures are common for real estate investments and are generally utilized for tax efficiency and to protect stakeholders from potential liabilities and third-party claims associated with the underlying real estate.

Advisory Services The Firm provides investment advice and investment management services with respect to investments in equity, convertible and debt instruments of publicly traded real estate related companies, including real estate investment trusts (“REITs”), REIT-like entities and real estate operating companies (“REOCs”). In connection with the provision of the services described above, the Firm provides advice to clients regarding the investment of client funds based on each client’s stated objectives and strategies. Through direct discussions

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with each client, from which investment goals and objectives are identified, the Firm implements an investment policy that is documented in a separately negotiated investment management agreement or other comparable agreement or document (“IMA”). The Firm provides advisory and sub-advisory services to institutions. Examples of such advisory and subadvisory clients are registered investment companies, investment advisers, pension and profit-sharing plans, including government pension plans, sovereign wealth funds and pooled investment vehicles. The Firm manages these advisory clients on a discretionary and non-discretionary basis. Clients may impose reasonable restrictions on investing in certain securities, types of securities, industry sectors, or other factors. The Firm’s investment management is generally limited to securities of publicly traded real estate related companies as well as managing currency exposure to facilitate our trading activity, as required. Such securities are typically in one or more of the following categories: Exchange-listed securities in both US and developed foreign markets; Securities traded in over-the-counter markets; Newly issued securities by domestic and foreign issuers; or Rights and warrants. Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended when consistent with the client’s stated investment objectives. For example, the Firm may use a covered call strategy to derive more income for a client’s portfolio; however, selling covered calls can impart more risk to the portfolio. Please see Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for more information. The Firm’s discretionary investment advisory services include a variety of investment strategies from which clients may select. These strategies include US Real Estate Securities Total Return, US Real Estate Securities Focused, US REIT Asset Value Growth, US Preferred REIT, Global Real Estate Securities, Global Real Estate Securities Concentrated, Global Prime, European Tactical Income , and Japan Real Estate Securities Total Return. The Firm also provides variations of certain of these strategies to accommodate, among other things, country exclusions or targeted yields. From time to time, the Firm establishes vehicles or managed accounts funded by Heitman or its employees to establish new strategies. Such strategies do not overlap with existing investment strategies managed for clients. Collective Investment Trust. The Firm serves as the discretionary investment manager to the Heitman Global Prime Collective Investment Trust, Heitman Global Real Estate Collective Investment Trust, and the Heitman US Diversified Collective Investment Trust (the “Trusts”). The Trusts are bank collective trusts offering units of beneficial ownership to qualified and eligible investors. Benefit Trust Company, a Kansas trust company, is the Trustee of the Trust. The Firm also serves as the discretionary sub-adviser of the Heitman US Real Estate Securities Focused Collective Investment Trust. This trust is a bank collective trust that offers units of beneficial ownership to

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qualified and eligible investors. Great Gray Trust Company, LLC, a Nevada retail trust company, is the trustee of the trust. The trusts are only offered to certain eligible investors that are qualified plans, such as pension, profit sharing and 401(k) plans. More information is available upon request by contacting the Firm’s Client Service and Marketing department at 312-855-5700.

Other Services HRES also provides, on a limited basis, other investment advisory services on a non-discretionary basis. These services include providing model portfolios to certain institutional clients or sponsors and licensing one or more of its strategies for a fee. The Firm exercises no discretion over the assets in either situation. The institutional client or sponsor have the discretionary responsibility for the determination of securities to be purchased or sold and effects all security transactions in connection with such determination. In these cases, the Firm generally does not have any knowledge as to which securities were ultimately purchased or sold or the ending portfolio weighting of the resultant portfolios.

Amount of Managed Assets As of December 31, 2025, the Firm managed approximately $1,821,428,968of client assets on a discretionary basis and approximately $1,631,156,449 of client assets on a non-discretionary basis.

Annual Fee (USD) 0.65% on the first $25 million

US Real Estate Securities Total Return

0.50% on $25-$100 million 0.45% on $100-$250 million 0.40% over $250 million

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0.65% on the first $25 million US Real Estate Securities Focused

0.60% on $25-$100 million 0.55% on $100-$250 million 0.50% over $250 million 0.65% on the first $25 million

US REIT Asset Value Growth

0.50% on $25-$100 million 0.45% on $100-$250 million 0.40% over $250 million

US Preferred REIT

0.51% 0.65% on the first $25 million 0.55% on $25-$100 million

Global Real Estate Securities

0.50% on $100-$250 million 0.45% over $250 million

0.80% on the first $25 million Global Real Estate Securities Concentrated

0.70% on $25-$100 million 0.60% on $100-$250 million 0.55% over $250 million

European Tactical Income

0.50%

Global Prime

0.30%

Advisory fees may vary. Asset management fees are negotiated on a client-by-client basis. Client requirements, and other facts and circumstances are considered in determining the fee schedule. These include, but are not limited to, the inception date of the account, the complexity of the client mandate, amount of assets to be placed under management, anticipated future additional assets, related clients, portfolio style and composition, types of securities held, portfolio customization and the nature of reporting requested, among other factors. The asset-based fees that the Firm receives from model portfolio providers, sponsors or third parties to whom the Firm licenses its strategies are separately negotiated with each party. The terms and conditions, including fees for services, are mutually agreed to with clients prior to entering into the IMA and are paid quarterly in arrears. The Firm’s customary practice is to provide quarterly invoices to the client, or other party, as directed by the client. Such fees are typically paid to the Firm through the custodian or other client designee. Upon termination of any IMA, any unearned fees will be promptly refunded, and any earned but unbilled fees will be invoiced. The Firm may group certain related client accounts for the purpose of determining the annualized fee. Clients should note that similar advisory services might be available from other registered (or unregistered) investment advisers for lower fees.

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Product-Specific Fees. The Firm provides investment advisory services to the Trusts. The fees paid to the Firm are disclosed in their applicable offering documents. The Firm also provides sub-advisory services to one or more registered investment companies at terms and conditions including fees for services mutually agreed to with those advisors. Fees paid by these funds for investment advisory services are described in each fund’s prospectus.

General Information Additional Fees and Expenses. In addition to the Firm’s advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers and/or local exchanges, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for clients’ portfolios. These charges, fees and brokerage commissions are exclusive of, and in addition to, the Firm’s advisory fees. The Firm shall not receive any portion of these commissions, fees, or charges, except for research or brokerage products and services as permitted under the safe harbor of Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). For more information about brokerage commissions and commission sharing, please refer to the “Brokerage Practices” section (Item 12) of this Form ADV for additional information. ERISA Accounts. The Employee Retirement Income and Securities Act (“ERISA”) and regulations under the Internal Revenue Code of 1986 (the “Internal Revenue Code”), respectively, deem the Firm to be a fiduciary to its clients that are employee benefit plans. As such, the Firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, the Firm only charges fees for investment advice regarding products for which the Firm and/or its “related persons” do not receive any commissions or 12b-1 fees, or conversely, investment advice regarding products for which the Firm and/or its “related persons” receive commissions or 12b-1 fees, however, only when such fees are used to offset the Firm’s advisory fees.

Some examples of why a performance or incentive-based fee structure may be perceived as a conflict for the Firm include instances where the Firm may:

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Favor clients with performance-oriented compensation over other clients of the Firm that have different fee arrangements; Recommend a riskier or more speculative investment that is projected to result in higher fees to the Firm; or Time dispositions or control other factors particular to a security position that have the potential to generate additional fees. The Firm has the following protections in place to mitigate the potential for conflicts caused by performance- or incentive-based fee structures: The Firm’s investment recommendations are created in accordance with the investment guidelines as defined in the client’s IMA; The Firm recommends the same or similar investments for clients participating in the same strategy, regardless of the fee structure; Purchase and sale orders are placed by the portfolio managers across all portfolios in the same strategy at the same time, barring other limiting circumstances, such as individual client restrictions, size of the portfolio, or cash inflows or outflows, which may create differences; All transactions are reviewed by portfolio managers; and The Firm performs a regular review of performance dispersion among portfolios that participate in the same strategy to measure balance across each portfolio within each strategy. INCENTIVE OR PERFORMANCE-BASED FEES WILL ONLY BE CHARGED IN ACCORDANCE WITH THE PROVISIONS OF RULE 205-3 OF THE ADVISERS ACT.

Minimum Account Size The minimum dollar amount for establishing a separate account is generally as follows: Investment Strategy

Minimum Portfolio Value

US Real Estate Securities Total Return US Real Estate Securities Focused US REIT Asset Value Growth US Preferred REIT Global Real Estate Securities

$10,000,000

Global Real Estate Securities Concentrated European Tactical Income Japan Real Estate Securities Total Return Global Prime

$50,000,000

The foregoing minimum portfolio amounts can be waived by the Firm in its discretion to permit smaller investments.

This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis. The Firm analyzes past market movements and applies that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement.

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Quantitative Analysis. The Firm uses mathematical models in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share and predicts changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Qualitative Analysis. The Firm subjectively evaluates non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predicts changes to share price based on that data. A risk in using qualitative analysis is that the Firm’s subjective judgment may prove incorrect. Risks for all forms of analysis. The Firm’s securities analysis methods rely on the assumption that the companies whose securities it purchases and sells, the rating agencies that review these securities, and other publicly available sources of information about these securities are providing accurate and unbiased data. While the Firm is alert to indications that data may be incorrect, there is always a risk that its analysis may be compromised by inaccurate or misleading information. Investment Philosophy. The Firm provides investment management and advisory services for institutional investors wishing to invest in publicly traded real estate related companies listed on various exchanges. The Firm provides clients with an experienced, disciplined, and in-depth investment approach, which includes fundamental securities analysis. It seeks investments that will outperform established benchmarks by purchasing securities of companies with superior growth prospects or securities that it deems undervalued. The Firm generally evaluates securities using an intermediate to long-term investment horizon, which is dictated by the nature of the underlying real estate assets. However, the Firm frequently reevaluates each position in terms of national and local economic conditions, rents, occupancy levels and competition, and changes in management strategies. Sustainability Analysis. As part of its risk analysis, the Firm, when appropriate, may conduct a risk assessment that includes consideration of sustainability factors that can facilitate consistency in the projection of financial returns and positive impact in the valuation of listed real estate equities, where opportunities exist for increasing net income, due to lower expenses, as well as higher valuations resulting from lower risk premiums and capitalization rates. Sources of Information. An important part of the Firm’s analysis is individual property site visits. Properties are analyzed to determine underlying economic values, the consistency and quality of cash flow, the potential for growth through re-leasing or physical enhancement, and their ability to employ leverage to positively enhance results. The Firm maintains contact with industry sources such as bankers, real estate brokers, property managers, local real estate investors and appraisers to access individual properties and local real estate trends. In addition, Heitman Affiliates’ experience in private equity real estate and debt investment, in combination with information from sector specialists within Heitman Affiliates’ research team, provides the Firm with insight into trends, market turns and investment strategy execution across the spectrum of real estate investing.

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Investment Strategies The Firm uses the following strategies in managing client portfolios, provided that such strategies are appropriate to the needs of the client and consistent with a client’s investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. The Firm may purchase securities with the idea of holding them in a client’s portfolio for a year or longer. Typically, the Firm employs this strategy when it believes the securities to be currently undervalued; and/or it wants exposure to a particular asset class over time. Risks associated with a long-term purchase strategy are described below. Short-term purchases. When utilizing this strategy, the Firm may purchase securities with the idea of selling them within a relatively short time. The Firm does this in an attempt to take advantage of conditions that it believes will soon result in a price swing in the securities it purchases. Risks associated with a short-term purchase strategy are described below under Risk of Loss – Trading.

Risk of Loss Investing in real estate securities may be subject to the principal risks summarized below. These risks could adversely affect the investment’s value, yield, and total return. It is possible to lose money by investing in these securities. Moreover, the Firm’s parent has a Compliance Committee that reviews and evaluates compliance issues and potential risks deemed to affect the Firm and its Heitman Affiliates. The Compliance Committee seeks to ensure such issues are addressed. These compliance issues include, among other things, matters involving Know Your Customer, Anti Money Laundering, Privacy and Pay-to-Play issues. Controls are evaluated, enhanced, and/or established to manage such risks. All IMAs are reviewed by a member of the legal and compliance team prior to execution. Customized checklists are prepared to address IMA requirements and these checklists are periodically audited. Real Estate Securities. The Firm concentrates its investments in real estate securities. An investment made by the Firm on behalf of its clients will not constitute a diversified investment program for purposes of applicable mutual fund regulation. Real estate securities are susceptible to the risks associated with direct ownership of real estate, including, without limitation, declines in property values; increases in property taxes, operating expenses, interest rates or competition; overbuilding; zoning changes; risks related to general and local economic conditions; eminent domain; fluctuations in rental income; changes in neighborhood values; the appeal of properties to tenants; and losses from casualty or condemnation. Real estate companies may be affected by changes in the value of the underlying property they own and by the quality of credit extended. Such companies also are subject to heavy cash flow dependency, defaults by borrowers, self-liquidation, and the possibility of failing to qualify for tax-free pass-through of income under applicable income tax regulations in the jurisdiction of the companies. REITs are dependent upon specialized management skills, have limited diversification and are generally dependent on their ability to generate cash flow to make distributions to shareholders. The requirements for qualification as a REIT are extremely complex. It is possible that a real estate company that purports to be a

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REIT may fail to qualify as such. In that event, the purported REIT would be subject to corporate level taxation, which would significantly reduce the return on investment in such enterprise. REITs in non-traditional real estate assets, such as data centers, self-storage or cell-phone towers, may not perform in a manner correlated to their underlying assets or may perform in a manner unrelated to factors, such as interest rates or federal tax law that typically have an impact on more traditional REITs. Concentration of Portfolio. The various strategies executed by the Firm may result in the concentration in a limited number of securities, or one security may constitute a significant percentage of a particular portfolio. A decline in the value of a security or securities in which the portfolio holds a concentrated interest could substantially affect the overall value of the portfolio. Stock Market Risk. The value of the stocks and other securities held as investments fluctuate depending on the performance of the companies that issued them, general market and economic conditions, and investor confidence. The market may also fail to recognize the Firm’s determination of an investment’s value, or the Firm may misgauge that value. Industry and Sector Risk. Companies that have similar lines of business are grouped together in broad categories called industries. Certain industries are grouped together in broader categories called sectors. The Firm concentrates its investments in certain real estate related industries, which may cause the investment’s performance to be susceptible to the economic, business, or other developments that affect those industries. Real estate industries are particularly sensitive to the following economic factors: decreases in demand due to economic recessions; increases in supply due to overbuilding; interest rate changes; changes in zoning laws; changes in neighborhood values; increases in property taxes; casualty and condemnation losses; and regulatory limitations on rents. Risks of Investing in Foreign Securities. Some of the Firm’s strategies require investing in foreign securities that are subject to risks not typically associated with domestic securities. Although ADRs and GDRs are alternatives to directly purchasing the underlying securities in their national markets and currencies, they are also subject to many of the risks associated with investing directly in foreign securities. Foreign investments can be riskier and more volatile as a result of varying custody, brokerage and settlement practices, difficulty in pricing of securities, less public information about issuers of such securities, less governmental regulation and supervision of the issuance and trading of securities, the possibility of expropriation or nationalization, adverse political, social or diplomatic developments, the imposition of withholding and other taxes, limitations on the movement of funds between different countries, and difficulties in invoking legal process abroad and enforcing contractual obligations. Changes in the value of foreign currencies can make it more difficult for the portfolio holding such securities to sell its securities and could reduce the value of an investment in the portfolio. Currency Risk and Exchange Risk. Because foreign securities generally are denominated and pay dividends or interest in foreign currencies, the value of the investments in foreign securities as measured in each security’s local trading currency are affected favorably or unfavorably by changes in exchange rates. Generally, when the local currency rises in value against a foreign currency, a security denominated in that local currency loses value because the currency is worth fewer foreign dollars. Conversely, when the local currency decreases in value against a foreign currency, a security denominated in that currency gains value because the currency is worth more local dollars. This risk, known as “currency risk,” means that a stronger local currency reduces returns for

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clients while a weak local currency increases those returns. In a global equity strategy, there can be exposure to multiple currencies in the portfolio and, as such, weakness in one currency versus the currency in which the portfolio is denominated may be partially or completely offset by strength in another currency. Portfolio Turnover Risk. The Firm may sell its investment securities, regardless of the length of time that they have been held, if the Firm determines that it would be in the best interests of clients to do so. These transactions increase the investment’s “portfolio turnover.” High turnover rates generally result in higher brokerage costs for those clients and higher net taxable gains that reduce their returns. Credit Risk. Real estate companies may be highly leveraged, and financial covenants may affect the ability of real estate companies to operate effectively. The companies in which the Firm invests are subject to risks normally associated with debt financing. In addition, a real estate company’s obligation to comply with financial covenants, such as debt-to-asset ratios and secured debt-to-total asset ratios, and other contractual obligations may restrict the company’s range of operating activity. A real estate company in which the Firm invests, therefore, may be limited from incurring additional indebtedness, selling its assets, and engaging in mergers or making acquisitions, which may be beneficial to the operation of the company. Interest Rate Risks. Investments in real estate result in exposure to interest rate risks, meaning that changes in prevailing interest rates could negatively affect the value of investments (e.g., interest rate changes may affect, among other items, the cash flows of an investment directly and the cost of leverage). Changes in the general level of interest rates can introduce additional volatility into the market and impact a client’s return by affecting the spread between the income on its assets and the expense of its interest-bearing liabilities, as well as, among other things, the value of its interest-earning assets and the capitalization rate at which its assets are valued in the market. Small and Medium Capitalization Companies. Even the larger real estate companies in the industry tend to be small to medium-sized companies in relation to the equity markets as a whole. There may be less daily trading volume in a smaller company’s stock, which means that buy and sell transactions in that stock could have a larger impact on the stock’s price than is the case with larger company stocks. Further, smaller company stocks may perform in different cycles than larger company stocks. Accordingly, real estate company shares can be more volatile than, and at times will perform differently from, the shares of “blue chip” companies. Conflicting Interest of Clients. The Firm’s clients may have conflicting tax and other interests with respect to their investments. The conflicting interests of individual clients may relate to or arise from, among other things, the timing of investments by the Firm and the taxable or tax-exempt status of individual clients. As a consequence, potential conflicts of interest may arise in connection with decisions made by the Firm, including decisions with respect to the timing of making or disposing of investments, that may be more beneficial for one client than for another client, especially with respect to each client’s individual tax situation. Volatility of Investment Results. As with any investment in equity securities, the value of an investment in any of the Firm’s strategies and the total return on a client’s investment are subject to the possibility that the subject portfolio of investments experiences sudden, unpredictable drops in value or long periods of decline in value. This may occur because of factors that affect the securities markets generally, such as adverse changes in economic conditions, the general outlook for corporate earnings, interest rates, or investor sentiment. The Firm’s

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investments may also lose value because of factors affecting an entire industry or sector, such as increases in production costs, or factors directly related to a specific company, such as decisions made by its management. Long-Term Purchases. A risk in a long-term purchase strategy is that by holding the security for a longer period of time, the Firm may not take advantage of short-term gains that could be profitable to a client. Moreover, if its predictions are incorrect, a security may decline in value before the Firm makes the decision to sell. Trading. As noted above, the Firm sometimes purchases securities with the idea of selling them very quickly (typically within 30 days or less). The Firm does this in an attempt to take advantage of its predictions of brief price swings. The Firm considers its investment strategy longer-term in nature, and trading on a short-term basis is not the primary focus. Utilizing a short-term trading strategy creates the potential for sudden losses if the anticipated price swing does not materialize. Moreover, under those circumstances, the Firm is left with few options: either having a long-term investment in a security that was designed to be a short-term purchase; or the potential of having to take a loss. In addition, because this strategy involves more frequent trading than does a longer-term strategy, there is a resultant increase in brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Strategy May Not Be Successful. No guarantee or representation can be made that the investment strategy utilized on behalf of any client will be successful, that there will be profits, or that losses will be avoided. There is no assurance that the Firm or its affiliates will correctly evaluate the nature and magnitude of the various factors that could affect the prospects of the Firm’s trading. Potential Loss of Invested Capital. A client could lose all or substantially all of its investment managed by the Firm. Investments in the previously described strategies are only suitable for clients willing to accept this risk. Prospective clients should carefully consider their portfolio objectives and their need to minimize the risk of large losses in evaluating their portfolio(s). Past investment performance should not be construed as an indication of future results. Dependence on Affiliated Advisers and their Officers. The Firm and/or Heitman Affiliate advisers may have discretionary investment authority over clients’ investments. The success of these investments depends upon the ability of the Firm and its Heitman Affiliate advisers that are utilized to implement their investment strategies successfully. A client’s investment performance is dependent on the services of a limited number of officers of the Firm and the Heitman Affiliate advisers. If the services of the officers were to become unavailable to the Firm and the Heitman Affiliate advisers, the result of such a loss of key management personnel could be losses for the Firm’s clients. Insurance Considerations relating to Real Estate Securities. Certain real estate related companies may, in connection with the issuance of securities, have disclosed that they carry comprehensive liability, fire, flood, terrorism, extended coverage and rental loss insurance with policy specifications, limits and deductibles customarily carried for similar properties. Such insurance is not uniform among real estate companies. There are certain types of extraordinary losses that may be uninsurable, or not economically insurable. Should any type of uninsured loss occur, such real estate related company could lose its investments in, and anticipated

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profits and cash flows from, a number of properties, which, as a result, would adversely impact the company and its value. Environmental Considerations. In connection with the ownership (direct or indirect), operation, management and development of real properties that may contain hazardous or toxic substances, a real estate company may be considered an owner or operator of such properties or as having arranged for the disposal or treatment of hazardous or toxic substances and, therefore, potentially liable for removal or remediation costs, as well as certain other costs, including governmental fines and liabilities for injuries to persons and property. The existence of any such material environmental liability could have a material adverse effect on the results of operations and cash flow of any such real estate company and, as a result, the amount available to make distributions on its shares could be reduced. Real properties and their values may also be subject to risks associated with acts of God, including earthquakes, fires, climate risks of cyclones, storm surge/sea-level rise, floods, wildfires, heat stress and water stress (which may result in uninsured losses and could negatively impact the direct or indirect operation, management or development, occupier demand, operating expenses and capital exposures); manmade exposures such as wars, riots or acts of terrorism, energy and supply shortages, uninsured losses or delays from casualties or condemnation, or risks from operating problems arising out of the presence of certain construction materials. Climate Change Risk. Climate change and regulations intended to control its impact may impact real estate investments. Laws enacted to mitigate climate change could increase energy costs, could make some buildings of property owners obsolete or cause such owners to make material investments in their properties, which could materially and adversely affect the value of investments in older properties. Climate change may also have indirect effects on property owners by increasing the cost of (or making unavailable) certain types of property insurance. In addition, various federal, state, and local governmental bodies may adopt measures to address the effects of climate change, and such measures may be financed through increased levies to businesses and property owners, potentially resulting in higher operating costs for owners on an ongoing basis. In these scenarios, owners could be operating properties with less competitive cost structures than initially contemplated at the time of investment, which over time, could potentially lead to less adverse impacts on rental/income streams and other economic features related to property ownership. Moreover, compliance with new laws or regulations related to climate change, including compliance with “green” building codes or tenant preferences for “green” buildings, may raise costs associated with renovating older properties. In addition, the physical effects of climate change could have an impact on properties located in certain geographical locations. To the extent climate change causes changes in weather patterns, properties in these markets could experience increases in storm intensity and other precipitous events such as flooding, mudslides, earthquakes, or rising sea-levels. These conditions could result in a decline in demand for properties located in such locations or could result in loss or damage to such properties, not all of which may be covered by insurance. Differences in Client Performance Results. There may be differences in client performance results for any given strategy based upon factors such as the amount of the investments made for each client portfolio and the timing associated with when such investment is made. Risk Characteristics of the Trading Strategy. The risk characteristics for an actual portfolio for any given strategy (standard deviation, beta, Sharpe Ratio, etc.) could vary substantially from those shown for a model analysis. There is no assurance that any desired risk characteristics will actually be achieved for an actual

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portfolio following any given strategy. This is particularly the case since the Firm may invest in real estate investments that are neither REIT nor REOC interests. Reliance on Portfolio Models. If there is an error in the design of a portfolio model that is not detected, there is a risk that client portfolios would not be traded in accordance with the clients’ investment objectives. Possession of Material Non-Public Information and Contractual Restrictions on Trading. The Firm may come into possession of material non-public information (“MNPI”) in connection with securities transactions that would prevent it from buying or selling securities about which the MNPI relates until such time as the information is no longer material or the material information is released publicly. Similarly, the Firm may agree by contract to refrain from trading in certain securities. This can occur, for example, if it buys a security and as a pre-condition to the purchase, the Firm signs an agreement that prevents it from selling the security or buying more of that security, or a related security covered by such agreement, until the restrictions imposed by the agreement expire. Additionally, the Firm may come into possession of MNPI as a result of a securities transaction through discussions with the issuer or by contract. In any of these types of circumstances, the Firm will be bound by applicable law or the contract. In those cases, the Firm will be prohibited from selling an existing position, even if it is declining in value, and the Firm will be prohibited from buying more of that position (or securities of related companies, if covered by an agreement or the MNPI is about related companies) even if the value of such company’s stock is increasing. Accordingly, client portfolios could be frozen in a security position for a prolonged period of time, or client portfolios could be prevented from owning a security position as a result. Geopolitical Risk and Ongoing Foreign Conflicts. As economies and financial markets worldwide have become increasingly interconnected, there is an increased likelihood that events or conditions in one country or region (such as the foregoing conflicts, or others that develop in the future) as well as other geopolitical developments (including, but not limited to, terrorism, trade war and tariff arrangements and sanctions and social unrest) will adversely impact markets or issuers in other countries or regions, including in ways that are difficult to predict or foresee. For example, local or regional/international armed conflicts (such as the UkraineRussia war) have led to significant sanctions against certain countries and persons and companies connected with certain countries by the United States, Europe, the Middle East and other countries. Such sanctions and other armed conflicts (such as the Israeli-Hamas conflict in the Gaza Strip or the conflict in the Middle East) as well as other local or regional geopolitical developments can exacerbate global supply and pricing issues, and result in other adverse developments and circumstances, as well as increased general uncertainty, for markets, economies, issuers, businesses and societies globally. This impact may include reductions in revenue and growth, unexpected operational losses and liabilities among a client’s borrowers and reductions in the availability of capital. It may also limit the ability of a client to source, diligence and execute new investments and to manage, finance and exit investments in the future. Although these types of events have occurred and could also occur in the future, it is difficult to predict when similar events or conditions affecting the U.S. or global financial markets and economies may occur, the effects of such events or conditions, potential retaliations in response to sanctions or similar actions and the duration or ultimate impact of those events. Developing and further governmental actions (military or otherwise) related to these conflicts or others may cause additional disruption and constrain or alter existing financial, legal and regulatory frameworks and systems in ways that are adverse to the investment strategy that the client pursues, all of which could adversely affect a client’s ability to fulfill its investment objectives.

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General Investing Risks. Investments in any asset class, including real estate, are subject to a variety of risks. These risks may include market, legal, regulatory, reputational, and other factors, including unforeseen events, that may adversely affect investments and market participants. Certain risks may arise from public health events, such as serious outbreaks of infectious diseases, epidemics or pandemic outbreaks. Other risks may relate to cybersecurity incidents, the use of emerging technologies (including artificial intelligence), or broader economic conditions. Inflation and rapid fluctuations in inflation rates have had, and may continue to have, negative effects on economies and financial markets. As a result of risks associated with inflation and other market conditions, it is possible that the growth of economies could contract, leading to a recession. While the occurrence and impact of any of these risks cannot be predicted, any of them individually or collectively could adversely affect investments, restrict the ability to acquire, sell or liquidate investments at favorable times and/or prices and impair the ability to achieve investment objectives.

Heitman International HK Limited (“HI HK”), which is a SEC registered investment adviser, provides research and discretionary advisory or sub-advisory services to the Firm. HI HK also provides private equity and debt investment advisory services. HI HK is also registered with the Hong Kong Securities and Futures Commission.

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From time to time, the Firm will draw upon the market research capabilities of the Firm’s parent in making its portfolio selections.

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HIRES Research Limited provides research services to the Firm and Heitman Affiliates.

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Heitman Securities LLC (“HSL”) is a registered broker-dealer and member of the Financial Industry Regulatory Authority. Heitman UK Limited (“HUK”) is an investment firm registered with the United Kingdom’s Financial Conduct Authority. From time to time, the Firm or its affiliates may utilize the services of HSL, HUK, or HIRES Pty for security offerings of Heitman Funds. To the extent that these entities can

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trade in public securities, none of these entities will engage in any transactions as a broker-dealer for advised clients of the Firm. 

Several personnel of the Firm and Heitman Affiliates are registered representatives or approved persons of these registered broker-dealers. These persons do not receive direct compensation for their brokerdealer or placement agent duties.

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Heitman Capital Management (“HCM”) and Heitman International LLC (“HI”) are private equity and debt investment advisers that are registered with the SEC. As described further below, HI maintains a branch office in Tokyo, Japan that is also registered with the Kanto Local Finance Bureau (“KLFB”), which was delegated administrative responsibility and oversight for this branch from Japan’s Financial Services Agency. These entities conduct global advisory business managing private equity and debt real estate investments for pooled investment vehicles and separate account clients. These entities may also provide research services to the Firm.

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Heitman International – Japan Branch (“HI Japan Branch”) is a branch office of HI, located in Tokyo, Japan. As mentioned above, HI Japan Branch is registered with KLFB and is licensed to provide certain investment management services and related client support activity. This location also acts as an operational liaison and assists in various reporting, client service and marketing and investment oversight matters for Heitman clients and investments that are in the Asia Pacific region generally and Japan, in particular.

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Heitman International – Seoul Branch (“HI Seoul Branch”) is a branch office of HI that is located in Seoul, South Korea. HI Seoul Branch conducts basic client service and relationship oversight activities, such as building Heitman’s name/brand recognition in the geographic region and acting as the relationship manager and liaison in respect to existing Korean based clients.

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The Firm’s parent provides certain central office support functions such as compliance and anti-money laundering monitoring, human resources, information technology, and other similar enterprise-wide activities.

In the event that any of its affiliations present potential conflicts of interest, the Firm will either resolve the conflict of interest or follow established written policies and procedures for disclosing such conflicts of interest to its clients.

Other Pooled Investment Vehicles As described in Item 4, Heitman Affiliates create limited partnerships or similar pooled investment vehicles referred to as “Heitman Funds” and “Client SPV Entities.” Heitman Affiliates serve as investment adviser to such entities. As described earlier in this section, the Heitman Affiliates solicit investors to invest in these entities through affiliated broker-dealers. Further, unaffiliated third parties may, in some cases, be utilized to solicit investors to invest in these entities, as described in Item 14.

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The Firm designed the Code to ensure that the personal securities transactions, activities, and interests of its employees will not interfere with: (i) making decisions in the best interest of clients, and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. The Code includes policies and procedures for the review of quarterly securities transactions reports and initial and annual securities holdings reports submitted by all of the Firm’s Access Persons and their Family Members. The Code requires the prior approval or prohibition of certain securities transactions. It also contains oversight, enforcement, and recordkeeping provisions. Further, Access Persons certify on a quarterly basis and Supervised Persons certify on an annual basis that they have complied with the requirements of the Code. In addition, the Firm has implemented mandatory compliance training that is conducted periodically. Compliance topics address policies applicable to all employees of the Firm, such as conflicts of interest, fiduciary duty, pay-to-play, and anti-money laundering. It is possible that “related person(s)” will have an interest or position in certain securities that the Firm recommends to a client. The Firm’s express policy is that no employee may purchase or sell any security prior to implementing a transaction for an advisory account. This policy is intended to prevent employees from benefiting financially from transactions placed on behalf of advisory accounts. The Code further includes the Firm’s policy prohibiting the use of material nonpublic information for personal trading or on behalf of itself or others. A copy of the Firm’s Code of Ethics is available to its advisory clients and prospective clients. Clients may request a copy by email sent to compliance-us@heitman.com or by calling 312-855-5700. As an investment adviser, the Firm has fiduciary responsibilities with respect to each of its clients. This means that the Firm is required to act in each client’s best interests and to deal with client assets in such a manner as to benefit the client. Compliance with the Firm’s fiduciary duty can be achieved by trying to avoid conflicts of interest and by fully disclosing all material facts concerning any conflict that may arise with respect to any client. The Firm’s employees are required to try to avoid situations that have even the appearance of conflict or impropriety.

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Senior officers of the Firm (or their functional equivalent) may also be senior officers or “related persons” of affiliated investment advisers and/or limited partnerships and other similar entities that serve in the capacity of or in a similar capacity to a General Partner of a Heitman Fund. The General Partner has designated the Firm or an affiliate of the Firm as having primary responsibility for investment management and administrative matters, such as accounting, tax, and periodic reporting that pertain to the entities. The Firm and its affiliates and their managers, officers and employees will devote as much time as necessary and appropriate to manage the entities’ business. However, the Firm and its affiliates form additional investment funds, enter into other investment advisory relationships, and engage in other business activities, even though such activities may be in competition with the entities and those other activities may involve substantial time and resources of the Firm and its affiliates. Potentially, such activities could be viewed as creating a conflict of interest in that the time and effort of the Firm’s management personnel and employees will not be devoted exclusively to the business of the entities but allocated between the businesses of the entities and those of the Firm’s other affiliates. Certain entities (“Firm Related Entities”) have been established by the Firm’s affiliates to invest in commingled funds or other real estate related investment vehicles sponsored or created by the Firm’s parent entity or one of its direct or indirect subsidiaries to develop, acquire, own and/or operate, finance, and ultimately sell interests in office, multi-family residential, industrial, specialty sector, and/or retail properties located principally in North America, Europe and the Asia Pacific region. The beneficial owners of the Firm Related Entities, in all cases, consist of past and present employees of the Firm’s parent entity or a Heitman Affiliate.

Commission Sharing The Firm utilizes research, research-related products and other brokerage services on a commission sharing basis. The Firm’s commission sharing policy is to make a good faith determination of the value of the research and brokerage products or services in relation to the commissions paid. The Firm maintains commission sharing arrangements for those research and brokerage products and services that assist the Firm in its investment decision-making process. The Firm and/or affiliated public securities investment advisers have agreements with several brokers to obtain, in return for directing to such brokers securities transactions for which commissions are paid, various research

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and brokerage products and services eligible pursuant to the safe harbor provision of Section 28(e) of the Exchange Act of 1934. Certain of these agreements provide for “commission sharing” credits whereby a commission sharing credit pool will be generated from total commission costs. The Firm can then exchange eligible research and brokerage products and services from credits that accumulate within this pool. Over the past several years, the Firm has obtained and continues to obtain various eligible services in exchange for commission sharing credits. To the extent these uses are not considered strictly research-related (i.e., a “mixed-use” product), the Firm makes an appropriate allocation of the cost between that portion which is eligible as a research or brokerage service and that portion which is not so qualified. The portion eligible as a research or brokerage service will be paid for with discretionary client commissions from the commission sharing credit pool, and the portion which is not eligible for the safe harbor under Section 28(e) of the Exchange Act will be paid for with Firm’s own funds. For any mixed-use products or services, the Firm maintains appropriate records of its reviews and good faith determinations of its reasonable allocations. Clients should be aware that the Firm might have a conflict between its obligations to obtain the best price and execution of the fewest necessary securities transactions and its desire to acquire research services with commission sharing from brokers. The Firm may also have an incentive to minimize its allocation of the mixeduse category, from the 100% commission sharing category since the portion of mixed-use assets allocated to non-research or brokerage services increases the Firm’s expenses. Notwithstanding agreements with brokers to obtain research and brokerage services, the Firm will not direct commissions to brokers in recognition of their having provided research, statistical or other related services in excess of commissions that other qualified brokers would have charged for handling comparable transactions. However, subject to the requirement of seeking best execution, the Firm may, in circumstances in which two or more brokers are in a position to offer comparable prices and execution, give preference to brokers that have provided research, statistical and other related services to the Firm for the benefit of its clients. The Firm may even pay more than the lowest available commission rate in return for research and brokerage products and services, so long as the Firm makes a good faith determination that the amount of commission paid is reasonable in comparison to the value of research and brokerage products and services provided. The brokers with whom the Firm has such agreements may change from time to time. The Firm considers which broker dealer is best able to execute an order based on the type of order and circumstances surrounding the order. In selecting broker dealers and in negotiating commissions on agency transactions, the Firm considers a number of factors, including, but not limited to: the nature of the security being traded; the size and type of the transaction; the nature and character of the markets for the security to be purchased or sold; the desired timing of the trade; the activity existing and expected in the market for the particular security; confidentiality, including trade anonymity; liquidity; the quality of the execution, clearance and settlement services; the existence of actual or apparent operational problems of any broker or dealer; and financial stability of the broker or dealer. In addition, the Firm may consider the value of research and brokerage products or services provided by a broker. Research and brokerage services received from such brokers and dealers cover a wide range of topics and services including basic economic data, prices of various government securities, company specific information including the EDGAR filings of securities issuers, economic indices, economic outlook, political environment,

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demographic and social trends, industry analysis, electronic communication of allocation instructions and trade routing. Research and brokerage services obtained with commission sharing credits are not necessarily utilized for the specific client that generated the credit. The Firm does not attempt to allocate the relative costs or benefits of research and brokerage services among clients because it believes that, in the aggregate, the research and brokerage services it receives benefits clients and assists the Firm in fulfilling its overall duties to its clients. The Firm uses the products or services provided or paid for by broker dealers in return for execution of securities transactions to service clients managed by the Firm and its affiliates, including clients of Heitman Affiliates, and not just the clients whose transactions paid for particular products or services. Moreover, it is possible that the clients whose transactions generate brokerage commissions used to pay for products or services may not benefit in any way from them. However, the Firm expects that each client receives an overall benefit by this practice because each receives the benefit of research and brokerage services that it might not otherwise receive. To the extent the Firm uses broker dealers that generate commission sharing credits in order to supply it with research and brokerage services, a potential conflict of interest may occur since the Firm may be incentivized to utilize those broker dealers in order to minimize research expenses for which it would otherwise be responsible. The Firm may supply proprietary research to the HLLC Client Service - Marketing and Research groups (collectively, the “Support Group”) if the Support Group uses the proprietary research to assist the Firm in carrying out its investment decision-making responsibilities for the Firm’s clients. Investment decision-making responsibilities refers to the quantitative and qualitative processes and related tools used by the Firm in rendering investment advice to its clients, including, but not limited to, financial analysis, trading and risk analysis, securities selection, asset allocation, and suitability analysis.

Directed Brokerage The Firm discourages requests by clients to direct brokerage transactions to a particular broker selected by the client. Although the client may in such circumstances receive products and services from the brokers that benefit the client, the Firm cannot assure the client that it will receive brokerage commissions equally as competitive as the commission rates the Firm has negotiated with its brokers. Moreover, the client may forego any benefit from savings on execution costs that the Firm has obtained for its other clients due, for example, to such factors as the ability to negotiate lower rates and the volume of transactions. In such instance, the client directing the brokerage may receive different prices on executions in the same security for the same transaction effected through other brokers. In agreeing to satisfy a client’s directions to executed transactions for its portfolio through a directed broker, the Firm understands that it is the client’s responsibility to ensure that; (i) all services provided by the Directed Broker will inure solely to the benefit of the client and may properly be provided in consideration for brokerage commissions or other remuneration provided to the directed broker; (ii) using the directed broker in the manner directed in the best interests of the client and any beneficiaries of the portfolio, taking into consideration the services provided by the directed broker; (iii) its directions will not conflict with any obligations that persons acting on behalf of the client’s portfolio may have to the client, its beneficiaries or any third parties, including any fiduciary obligations that persons acting for the client’s portfolio may have to obtain the most favorable price and

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execution; and (iv) persons acting for the client’s portfolio have the requisite power and authority to provide the directions on behalf of the client’s portfolio and have obtained all consents, approvals, or authorizations from any beneficiaries and third parties that may be required under applicable law or instruments governing the portfolio.

Global Strategy Brokerage Practices The Firm will delegate investment discretion for certain Global Real Estate Strategy, Global Real Estate Securities Concentrated Strategy, European Tactical Income, Japan Real Estate Securities Total Return Strategy, and Global Prime clients to a Heitman Affiliated adviser to make the investment decisions and/or recommendations with respect to publicly traded real estate securities in the European and Asia Pacific regions. The Firm may also delegate brokerage discretion for those clients to a Heitman Affiliate, and, therefore, the Heitman Affiliate will have the discretionary authority to determine which broker dealers will be used when purchasing and selling principally European and Asia Pacific securities on behalf of those clients. In the instances that a Heitman Affiliate is recommending transactions in publicly traded real estate securities, the Firm or another Heitman Affiliate may retain the investment discretion. In selecting brokers to effect purchase and sale transactions, Heitman Affiliates take into consideration a number of factors, including the overall best execution results to a client, the broker’s commissions, financial strength, stability, trade efficiency and other factors, as described above in “Selection of Brokers.” For trades executed in a currency other than the currency in which a portfolio is denominated, a Spot FX transaction is necessary to facilitate trade settlement. The Firm uses an unaffiliated third party to execute those Spot FX transactions.

Order Execution and Allocation The Firm and Heitman Affiliates often purchase and sell the same security at the same price and time for more than one client because: (i) the Firm typically makes similar trade recommendations for similar strategies that it manages, (ii) the Firm only recommends a limited number of real estate related securities, and (iii) numerous clients have similar investment objectives and similar portfolios. The Firm generally allocates orders among participating clients on a pro rata average price basis. Consistent with its best execution obligations and the terms of its investment advisory agreements, the Firm typically aggregates or “bunches” multiple client orders for the purchase and sale of the same security and allocates such transactions as previously described with each participating client’s proportionate share of such order, reflecting the average transaction price with respect to the total order placed for that day. Aggregate or bunched transactions may result in better prices, including lower commission costs and/or better execution for larger orders than single orders with smaller volumes. As mentioned above, clients that request the Firm direct trades to a particular broker may not benefit from aggregate transactions, as the Firm does not generally “step out” a portion of aggregated trades to clients’ directed brokers. Some of the Firm’s clients are investment advisers of wrap programs, for which the Firm acts as a nondiscretionary subadviser. The Firm considers these as “rotational clients.” In those instances, HRES provides a model portfolio to the wrap program adviser, and the wrap program adviser is responsible for applying the model and trading the corresponding orders. As a general matter, the Firm will rotate the placement of orders; either providing the model to the rotational clients first or placing orders for the non-rotational clients first. This means that at times orders are built and are partially filled for the Firm’s non-rotational clients before providing the

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models for the rotational clients to the wrap program advisor, and then the rotation will change so that the models are provided to the wrap program sponsors before orders are built and filled for the Firm’s non-rotational clients. The Firm has implemented compliance policies and procedures to test client portfolios on a regular basis to ensure that investment opportunities are allocated over time in a fair and equitable manner. The Firm periodically reviews the Heitman Affiliated advisers’ trading policies and procedures and trade activities for the Heitman Affiliated advisers that have been delegated brokerage discretion from the Firm.

Trade Allocation The Firm has implemented compliance policies and procedures to test client portfolios on a regular basis to ascertain whether any clients are being treated unfairly. For example, Compliance regularly reviews partial trade allocations to confirm that one category of clients is not being advantaged or disadvantaged, and portfolio managers review performance dispersion, which may occur over time among clients with a similar strategy. Proprietary accounts and clients that have a performance-based fee are treated the same as other clients when trade allocations are made, unless otherwise prohibited by regulation. IPOs and secondary offerings (“Offerings”) of securities frequently are of limited size and availability. The Firm participates in IPOs or secondary offerings for discretionary clients. Some Offerings may become “hot issues,” which are offerings that trade at a premium above the initial offering price. In the event the Firm participates in an Offering, the Firm’s policy and practice is to allocate shares in the Offering fairly and equitably on an overall basis among eligible clients according to a specific and consistent basis so as not to advantage any Firm or related account and so as not to favor or disfavor any client, or group of clients, over any other.

Principal and Cross Transactions The Firm and individuals associated with the Firm are prohibited from engaging in principal transactions with clients. The Firm may affect an agency cross transaction for an advisory client, provided that the transaction is consistent with the Firm’s fiduciary duty to the client and that all requirements outlined in Rule 206(3)-2 under the Advisers Act are met. However, the Firm generally does not engage in cross transactions as a normal course of business. It is possible that a broker dealer through whom the Firm places transactions may cross the orders.

Trade Errors In the event any error occurs in the handling of any client transactions, due to Heitman’s actions, or inaction, or the actions of others, Heitman’s policy is to seek to identify and correct such errors as promptly as possible.

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In addition to the statements and confirmations of transactions that clients receive from their custodians, the Firm provides monthly and/or quarterly reports summarizing performance, balances, and holdings pursuant to the obligations set forth in each client’s IMA. The Firm will provide reports on a more frequent basis to discretionary clients upon request.

Accordingly, the Firm has implemented procedures that are reasonably designed to avoid or mitigate these potential conflicts, such as ensuring that referral fees will not affect the level of the advisory fee paid by the client and that any such arrangements will otherwise comply with Rule 206(4)-1 under the Advisers Act. As described in Item 10, the Firm may use Heitman Affiliates for security offerings of Heitman Funds. It is the Firm’s policy not to accept or allow its “related persons” to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services it provides to its clients.

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The Firm will not begin the management of client assets without a written IMA. For Global Real Estate Securities, Global Real Estate Securities Concentrated, Japan Real Estate Securities Total Return, and Global Prime clients, the Firm may retain Heitman Affiliates to make the investment decisions with respect to publicly traded real estate securities in the Asia Pacific region.

The Firm utilizes the services of an independent unaffiliated proxy voting recommendation firm. The proxy firm is responsible for: notifying the Firm in advance of the shareholder meeting; providing the appropriate proxies to be voted; providing independent research on corporate governance, proxy and corporate responsibility issues;

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recommending actions with respect to proxies; and maintaining records of proxy statement received and votes cast. Pursuant to the Firm’s Proxy Voting policy, the voting recommendations from the proxy voting firm are deemed to be in the best interest of the shareholders. The Firm’s policy is to follow the proxy firm’s recommendations unless compelling reasons not to do so are identified and approved by the Firm’s Proxy Voting Committee. There may also be occasions when the Firm determines, contrary to the proxy firm recommendation, that not voting such proxy may be in the best interest of clients, such as: (i) when the cost of voting such proxy exceeds the expected benefit to the client, or (ii) if the Firm is required to re-register shares of a company in order to vote a proxy and that re-registration process imposes trading and transfer restrictions on the shares, commonly referred to as “blocking.”