Lasalle Investment Management: investment adviser

The newly combined entity was named Jones Lang LaSalle Incorporated (NYSE: JLL) and became the direct parent of LaSalle, which it remains today. Description of Advisory Services LaSalle’s primary business is to advise clients on real estate-related investments (e.g., through direct and indirect investments in real estate, investments in LaSalle-managed real estate funds, joint ventures with real estate partners, real estate loans (including subordinated or “mezzanine” loans), and direct equity investments in real estate assets through the purchase of all or substantially all of the issued securities of real estate investment trusts (“REITs”) and similar structures) and to manage those investment portfolios. LaSalle’s client base is comprised generally of private investment funds (“Private Funds”) it sponsors, as well as separate accounts, which LaSalle refers to as “Custom Accounts.” The investors in the Private Funds and the owners of the Custom Accounts are predominantly institutional investors including government plans, pension plans and insurance companies. The LaSalle Global Solutions (“LaSalle GS”) division within LaSalle is focused on building indirect investment portfolios by partnering with real estate operators across the world and pursues investments in private equity real estate globally for its clients. LaSalle GS focuses on investment opportunities across private, public, debt and equity segments through investment in third-party and in-house funds, joint ventures, co-investments and secondaries. LaSalle GS’s global team is comprised of managers and team members located in Chicago, Baltimore, New York, London and Singapore. The team members are employed regionally based on the appropriate jurisdiction in which they reside, where they receive full compliance supervision within such regions and are subject to applicable regulatory obligations. LaSalle GS’ investments broadly fall into three types: primary investments into existing open-end funds, newly formed closed-end vehicles or identified co-investment or joint venture opportunities; secondary investments in private equity real estate vehicles that are acquired from existing investors; and recapitalizations of an asset or portfolio where new capital is typically needed to de-leverage such investment or provide operating capital. In performing advisory services, LaSalle may utilize the talents of investment professionals of non-U.S. affiliated investment advisory firms to manage a particular investment strategy or product. In keeping with applicable regulatory guidance, each such affiliate will have entered into a memorandum of understanding agreement with LaSalle through which the affiliate is considered a “Participating Affiliate” of LaSalle as that term is used in relief granted by the staff of the Securities and Exchange Commission. This allows LaSalle, as a U.S. registered investment

adviser, to use the resources and professional expertise of its non-U.S. affiliates, i.e., Participating Affiliates, to render portfolio management, research or trading services to clients of LaSalle. The arrangement with its Participating Affiliates allows LaSalle to offer investment management styles and strategies that it otherwise may not manage under the framework of U.S. regulations. In partnering with its overseas affiliates, LaSalle offers management and related services to U.S. clients provided by investment management personnel associated with Participating Affiliates, who are considered to be best positioned to provide the expertise required to manage a particular strategy or product for the client. Other services provided by LaSalle include providing strategic research, guidance on investment strategy, acquisitions and dispositions, portfolio and asset management, cash management, financial reporting, accounting, due diligence and client services. Additionally, LaSalle is the investment advisor to a non-listed, daily valued, perpetual life public REIT, JLL Income Property Trust (“IPT”). IPT’s investors are mainly retail investors but also include institutional and high net worth investors. Private Funds, IPT and Custom Accounts are referred to generally in this brochure as “clients.” LaSalle accepts engagements on both a discretionary and non-discretionary basis. In the case of discretionary engagements, LaSalle is given full authority to acquire and dispose of real estate-related assets and to manage the real estate-related assets owned by the client. Clients in non-discretionary engagements withhold some or all of the authority otherwise granted to LaSalle in discretionary engagements. For example, non-discretionary clients often require LaSalle to obtain client approval before purchasing or selling a property. Tailoring Advisory Services and Client Restrictions on Advisory Services Other than with respect to commingled investment funds (whose investment objectives and strategies are set forth in the Private Fund’s Governing Documents), LaSalle tailors its advisory services to the individual needs of clients, to the extent LaSalle can accommodate such needs and not adversely affect the services LaSalle provides to other clients. LaSalle generally provides investment advice related to four primary real estate strategies: core, core-plus credit, value-add, and opportunistic (further described in Item 8 “Methods Analysis, Investment Strategies and Risk of Loss”). LaSalle can also further tailor a strategy to limit investments to certain geographic locations or types of real estate. In the case of Private Fund clients, LaSalle will create the investment objectives and determine the real estate strategy or strategies used to achieve those objectives. In the case of Private Funds and Custom Accounts that LaSalle manages on a nondiscretionary basis, the Client is often involved in strategy determinations and approvals for investments. Due to the nature of Private Funds and IPT, LaSalle does not provide individualized investment advice to the investors in Private Funds or IPT and such investors are expected to participate in the overall investment program for the applicable Private Fund or IPT. However, certain investors may be excused from a particular investment due to legal, regulatory or other applicable constraints or for other agreed upon reasons. Co-investment funds may be formed from time to time to invest alongside LaSalle’s Private Funds. In the case of Custom Account clients, the owners of the Custom Account can choose the investment objectives and real estate strategy or strategies and, thus, are able to restrict on the types of investments of the account. A Private Fund client may enter into side letters or other similar agreements with its investors that have the effect of establishing rights under, supplementing or altering such Private Fund’s partnership agreement or an investor’s subscription agreement. Such rights or alterations

could be regarding economic terms, fee structures, excuse rights, information rights, co-investment rights (including the provision of priority allocation rights to limited partners who have capital commitments in excess of certain thresholds to one or more Private Funds), or transfer rights. Furthermore, pursuant to a Private Fund’s Governing Documents, some of such rights, terms or conditions may be elected by certain sizeable investors with “most favored nations” or “MFN” rights. Wrap Fee Programs LaSalle does not provide services to wrap fee programs. Assets Under Management LaSalle, as of December 31, 2025, managed $23,529,981,089 in client assets on a discretionary basis and $4,273,699,076 in client assets under management on a non-discretionary basis.

In circumstances where LaSalle sponsors a Private Fund, LaSalle will establish the base fees under which LaSalle will be paid for providing services to the fund. These fees are generally based on the type of services LaSalle will perform for the Private Fund and the fund’s investment strategy or strategies. In the case of LaSalle’s Custom Accounts, LaSalle generally charges a management fee based on the size of the real estate-related investment portfolio and an acquisition fee. Some Custom Accounts also have a disposition fee and incentive fee structure in place. The type and amount of fees charged by LaSalle are individually negotiated with each Custom Account client. Manner of Fee Payment The manner by which LaSalle is paid for its services varies by client and the type of service and is documented in the advisory agreement with each client. LaSalle generally bills in arrears for fees for its Custom Accounts. In the case of LaSalle-sponsored Private Funds, fees owed to LaSalle and its affiliates are payable in accordance with the fund’s Governing Documents. Fund documents typically do not require LaSalle to generate an invoice; instead, the Governing Documents require the Private Fund to calculate the fees payable by the fund and disburse the funds from the client’s account to LaSalle.

Fees are payable periodically depending on the nature of the fee. For example, management fees are generally payable quarterly, transaction fees (such as acquisition fees) are payable within a certain period of time following the closing of the transaction and incentive fees are payable on a periodic basis (annually or longer) only if performance exceeds the specified hurdle rate (as further described below in Item 6 “Performance-Based Fees and Side-by-Side Management”). Other Fees and Expenses Clients May Incur In addition to those fees described above, LaSalle’s clients will be charged fees payable to third-party service providers (including affiliated service providers), which will be documented in each client’s investment advisory agreement or other applicable Governing Documents (including conflicts guardrails associated with any affiliate fees). These fees are primarily comprised of services related to the operation of the client’s property portfolio. In the case of property management fees, LaSalle hires property managers on behalf of the client to manage the individual properties a client owns. Such management agreement may include a separate allocation for the reimbursement of salaries of employees dedicated to the property, as well as other administrative costs. Fees payable to the property manager are generally sourced from the income generated by the property. The client is also responsible for fees associated with bank accounts opened on behalf of the client, which would generally be comprised of general account maintenance fees, statement delivery charges and bank transaction charges. Other fees that can arise over the course of a client relationship include:

real estate transaction fees, such as costs and fees associated with the purchase or sale of a property (taxes, attorney fees, brokerage commissions, title insurance); financing fees, mortgage broker fees, loan origination fees, loan administration fees and any lender expenses;

fees associated with transacting leases;

property level marketing materials and events;

due diligence fees, due diligence software or database subscriptions;

annual audit review fees;

fees associated with tax advisory services, structuring, preparation and filings for properties and investment structures; fees payable to or associated with applicable state / local tax authorities for properties or investment structures; insurance premiums at property and fund level (environmental, hazard, etc.) and insurance broker costs and commissions; technology expenses including software, platforms, data analytics tools, and subscriptions used for property management, accounting, investor reporting, customer relationship management, and administration purposes; sustainability and ESG-related expenses including tracking tools, assessments, consulting and reporting;

developer fees;

costs related to construction oversight and construction management;

administrative servicing fees; legal fees at the property level (leasing counsel, etc.) or other entities owned or controlled by the client; legal entity establishment in relation to the client and its owned or controlled entities and ongoing maintenance fees; director, officer, and board member fees and expenses (including for LaSalle personnel serving in such capacities) in respect of the client's investment vehicles and portfolio investments; broken deal expenses; fees paid to consultants, finders, broker-dealers, investment banks and other intermediaries in connection with sourcing investment opportunities; costs associated with attending, sponsoring or exhibiting at industry conferences and events; hedging costs and expenses related to swap transactions and other derivative arrangements;

expert network and specialized research service fees;

accounting fees and bookkeeping services;

fees for outside appraisers and valuation services;

fees for architectural engineering, environmental, or other studies or reports related to proposed or existing investments; fees and expenses of unaffiliated parties incidental to the preparation and distribution of reports; travel expenses and other out-of-pocket expenses incurred with the evaluation, negotiation, operation or sale of proposed or existing investment and operations of portfolios;

cash management and treasury services fees;

depositary, custodian, and administrative agent fees;

cybersecurity and data protection compliance costs;

regulatory compliance expenses including costs related to applicable investment fund regulations, anti-money laundering, know-your-customer, sanctions screening, and anti-terrorism compliance measures; costs associated with structuring, maintaining, and operating investment vehicles and structures in various jurisdictions (including REIT and ERISA operating company structures); costs incurred in connection with indemnification obligations under the Governing Documents; expenses associated with investor meetings, annual meetings, and investor conferences including venue, catering, travel, and related meeting costs;

costs related to co-investment vehicles and structures to the extent not borne by coinvestors; expenses related to establishing, administering and operating profit participation arrangements for LaSalle personnel where permitted by Governing Documents; and costs associated with feeder funds that invest in LaSalle-managed vehicles, to the extent not paid by feeder fund investors.

LaSalle’s Private Funds and IPT also generally bear their own operating expenses and other expenses (in addition to those listed above) including, but not limited to: (i) marketing expenses; (ii) legal expenses; (iii) internal and external accounting, audit and tax preparation, advisory and structing services expenses; (iv) insurance; and (v) operating expenses. When LaSalle or its affiliates provide such services for the benefit of LaSalle’s Private Funds and IPT, they may receive fair and reasonable fees (subject to conflicts guardrails in the Governing Documents) or, alternatively, may receive reimbursement of allocated overhead expenses [(including rent, utilities, office maintenance, office supplies, storage, software, technology, and other general and administrative expenses)] and employee compensation costs [(including salary, benefits, bonus, and other personnel costs based on time expended by employees rendering such services)] for services provided, as permitted by the applicable Governing Documents. Clients are not required to reimburse LaSalle for LaSalle’s general overhead and operating expenses except as otherwise specified in the Governing Documents or client consent is obtained. Where LaSalle and/or more than one client intend to invest in a deal, then such due diligence costs will typically be charged to the investment vehicle pursuing acquisition of the asset. These due diligence costs can include, among other things, legal, environmental diligence, travel expenses, etc. Where such due diligence costs are incurred but the acquisition does not complete (for any reason) then such due diligence costs will be allocated in accordance with the applicable Governing Documents. Receipt of Compensation for Sales Certain LaSalle supervised employees are awarded an annual bonus that recognizes such employee’s success in attracting capital to the firm, although the bonus considers other qualitative factors. Generally, no bonus for any LaSalle employee is guaranteed; however, occasionally, LaSalle will guarantee a bonus for certain new hires. The LaSalle bonus pool is a single pool derived from the revenue generated by LaSalle’s advisory activities and no commission is charged to any LaSalle client or any Private Fund investor.

structures comprised solely of fixed fee arrangements. For example, an account with a performance-based fee could incentivize LaSalle to focus greater attention on that account at the expense of other non-performance-based fee accounts in order to maximize the fees for LaSalle. Side-by-side management could also incentivize LaSalle to cause the account to pursue greater risks in order to achieve higher fees for LaSalle. LaSalle believes the following factors help mitigate this conflict:

LaSalle co-invests through an affiliate in its sponsored Private Funds and, in some cases, alongside Custom Accounts, which further aligns LaSalle’s interests with those of the investors and clients, respectively; LaSalle employees invest in its sponsored Private Funds and, in some cases, alongside Custom Accounts, which further aligns LaSalle’s interests with those of the investors and clients, respectively, on a personal level; LaSalle’s ability to raise future capital and its success as an investment manager on a go-forward basis is dependent upon the success of its overall investment program for all of its Private Funds and Custom Accounts; LaSalle allocates potential investments among its accounts generally on a rotational basis and in an open-book format, which allows clients to review the decisionmaking process (see more detail below); investment guidelines often restrict how LaSalle can allocate monies with respect to the type (i.e., industrial, office, apartment, retail), strategy (i.e., core, value-add, opportunistic) and geographic region; each account presents an annual strategic plan to the applicable LaSalle Investment Committee; and LaSalle’s Investment Committees monitor the purchase and sale of properties and the performance of client assets on a regular basis.

A particular investment opportunity may be appropriate for more than one account. LaSalle has adopted an allocation policy which is designed to help ensure it allocates potential real estate investments among its clients in a fair and equitable manner over time, considering the differences in mandates and uniqueness of individual investment opportunities. LaSalle’s general policy is to allocate investment opportunities in an open-book process so that each actively investing client is treated fairly regarding the available allocations, including properties that ultimately are acquired. Exceptions will exist to this general policy from time to time, with a current example reflected in the Allocation Policy being LaSalle’s value-add Private Fund series having priority for value-add real estate investments over other accounts. In some cases, portfolio managers may have responsibility for more than one client. To the extent possible, LaSalle assigns portfolio managers clients with different strategies in order to mitigate the potential for conflicts resulting from one portfolio manager having more than one client eligible to participate in a given investment opportunity. In addition, LaSalle believes its allocation process and investment committee also help mitigate any resulting conflicts and results in a fair allocation of investments over time. Under certain circumstances, with respect to direct equity mandates, LaSalle’s Head of U.S. Transactions, Americas Chief Investment Officer and Americas Chief Operating Officer may

determine that a property otherwise appropriate for allocation should not be allocated through LaSalle’s standard allocation process as described in the following paragraph. From time to time, a client may source a proposed investment to LaSalle’s attention. In these circumstances, the investment opportunity will not be subject to LaSalle’s standard allocation process. In addition, LaSalle allocates transactions to a client without requiring that client to use their pick and move back down in the rotational process when portfolio managers other client accounts do not show interest I the transaction. Any such transactions are recorded and reported as part of the allocation process.

LaSalle imposes investment minimums for its Private Funds on a fund-by-fund basis depending on, among other things, the target amount the fund intends to raise and the types of entities investing in the Private Fund. The minimum investment amount in Private Funds generally is $5,000,000, although LaSalle has discretion to accept a lower investment amount. Custom Account clients are generally expected to invest at least $500,000,000 with LaSalle, although LaSalle has discretion to accept a lower investment amount. Shares of IPT are offered with a $10,000 minimum initial investment.

The returns will come from a blend of income and appreciation. Leverage is generally limited to 65% loan to value. A “value-add” strategy generally involves some amount of capital investment in the asset to grow property income. an “opportunistic” strategy seeks to invest in real estate assets with high-risk attributes; returns are often largely dependent on future appreciation. Leverage can

be up to 75% loan to value or greater. Investments in operating companies and development will also be considered. These strategies define the types of properties LaSalle will purchase on behalf of a client. LaSalle’s process for identifying assets for a private equity and Custom Accounts client is generally consistent across all strategies. Each client account is staffed with a fund or portfolio manager. In some cases, depending on the size of the client, these individuals may have responsibility for more than one client. The fund or portfolio manager is responsible for ensuring that the investment objectives of the client are being executed properly. LaSalle’s primary groups supporting portfolio manager decisions are its Research and Strategy Team, Transactions Team, Due Diligence Team, Asset Management Team, Accounting Team and Investment Committee. The Research and Strategy Team guides the investment process at both the macro (top-down) and micro (bottom-up) levels. A top-down approach is used to monitor local, regional, national and global economic and investment trends and to guide overall investment strategy. Certain databases and econometric forecasting models developed by LaSalle are also used to coordinate strategy and guide decision-making. Once appropriate investment opportunities have been identified, a bottom-up approach is used to closely examine the fundamentals impacting the potential real estate opportunity at a “micro” or submarket level. The bottom-up approach is also used, in some cases, to uncover and identify investment opportunities or risks that may not otherwise be known to the wider marketplace. LaSalle’s Transactions Team is responsible for identifying potential acquisitions for clients. During the acquisitions process, LaSalle conducts physical, environmental, economic and legal due diligence on all potential investments as part of the underwriting process. Legal due diligence, including title and survey work, is conducted by external counsel and overseen by LaSalle’s Transactions Team. Physical and environmental due diligence is conducted by thirdparty consultants under the scope and direction of LaSalle’s Due Diligence Team. In addition, sustainability considerations are incorporated into the investment process where the financial performance of an asset could be impacted. The acquisitions officer responsible for sourcing the investment opportunity, working in conjunction with the Transactions Team, Asset Management Team, fund or portfolio manager, and legal counsel, leads the economic due diligence process. Economic due diligence includes, but is not limited to, a review of all leases, tenant receivables, operating expenses, real estate taxes, recent capital expenditures and any pending litigation. The Investment Committee is comprised of no more than seven senior executives of LaSalle. The Investment Committee approves the annual strategic plans of all clients and funds as well as property transactions above a minimum value prior to execution. Private Debt Platform In addition to direct and structured real estate strategies, the firm provides advice to clients with respect to the issuance of debt secured by real estate. The firm’s debt strategy generally is to issue first mortgage debt of single purpose limited partnerships and limited liability companies that are structured for the purpose of holding the underlying real estate assets which serves as collateral (i.e., the physical property) for the debt instrument. The strategy may also invest in debt participations. The firm has not made and does not intend to make investments in any asset in which any member of the Investment Committee, or in which JLL has a direct or indirect investment.

The debt team identifies potential investment opportunities through a variety of sources and bases a portion of its investment analysis on information obtained from working with industry professionals such as industry consultants, property management and leasing professionals, other investors, brokers, and other professionals within the real estate sector. The investment process involves several steps that vary depending on the type of real estate securing the proposed loan. In all cases, a written memorandum is prepared for the investment that, among other points, describes the due diligence conducted on the proposed investment. An investment committee comprised of an independent representative and senior executives of LaSalle, some of whom are dual employees of its affiliate, LaSalle Debt Investors, Inc., approves the annual strategic plans of all LaSalle clients and funds whose primary investment strategy is the origination of debt as well as property transactions above a minimum value prior to execution. LaSalle Global Solutions Platform (“LaSalle GS”) The LaSalle GS business provides Custom Account clients with global and regional indirect real estate investments in Private Funds, joint ventures, co-investments and secondaries (each individually a “GS Mandate”). LaSalle GS leverages shared resources of LaSalle and LaSalle’s global affiliates for the benefit of LaSalle’s clients who invest under a GS Mandate. LaSalle GS business investment review process generally employs both a regional investment committee and global investment committee review. The LaSalle GS Structured Investments Investment Committee (“Structured Investment Committee”) is comprised of four LaSalle employees and is charged with reviewing the client investments in the “Structured Investments” vertical of LaSalle Global Solutions. The Structured Investment Committee functions as a first line of analysis and approval, before major investment decisions are presented to the Global Solutions Global Structured Investments Investment Committee (“GS Global IC”). The GS Global I C is comprised of eight senior employees of LaSalle and LaSalle affiliates. The GS Global IC carries out a portfolio review of all active mandates (i.e. all mandates apart from those which are in wind down or where investment/divestment has been suspended) on an annual basis. The portfolio review assesses matters such as performance, investment issues, client issues, investment activity and investment strategy. In some cases, however, the GS Global IC delegates decisions and/or action to the Structured Investment Committee or a LaSalle GS client manager to carry out a review of all investments pursuant to certain established levels of authority to do so. The Structured Investment Committee also performs a review of all investment under the GS Mandate every six months. This review process considers the fund profile, financial performance, concentration, liquidity, environmental, social or governance (“ESG”) factors and other aspects that affect how performance is assessed. Risks Associated with Investing in Real Estate and/or LaSalle-Sponsored Private Funds Investing in real estate and securities involves risk of loss that all clients should be prepared to bear. Although LaSalle’s clients generally do not invest in securities, investors in LaSalle’s Private Funds generally would be deemed to be investing in a security, and they should be prepared to bear the associated risk of loss associated with investments in Private Funds. Impact of Real Estate Cycle

Historically, real estate has experienced significant variations and cycles in value and local market conditions, which may result in reductions in the value of real property and, possibly, the income generated by real property. All real estate-related investments are subject to the risk that a general downturn in either the national or the local economy will weaken real estate prices and revenues. Economic turmoil may adversely affect investments in real estate by, among other things: (i) a decline in the value of real estate and real estate securities, which may continue for a prolonged period, resulting in higher volatility and an uncertain business environment for investors, and (ii) a lack of available credit, lack of confidence in the financial sector and reduced business activity. LaSalle may not be able to timely anticipate or manage existing, new or additional risks or developments, including regulatory changes and trends in new products and services. Real Property Risks Investments in real property are subject to differing risk levels. The yields available from equity investments in real estate depend on a variety of factors including the amount of income earned and capital appreciation generated by properties as well as the expenses incurred. If real estate assets do not generate enough income to meet their operating expenses, including debt service and capital expenditures, the ownership of such real estate could be adversely affected. Income from, and the value of, real estate is affected by the general economic climate, local conditions such as oversupply or a reduction in demand for such properties, attractiveness to potential tenants, competition from other properties, increases in maintenance, insurance and operating costs (including insurance premiums, utilities and real estate taxes). In addition, revenues and real estate values are affected by such factors as the cost of complying with regulations and the potential for liability under applicable laws, including changes in tax laws, and interest rate levels and the availability of financing. Income from real estate investments is adversely affected if a significant number of tenants are unable to pay rent or if properties are vacant and cannot be rented on favorable terms. Certain considerable expenditures associated with an investment in real estate (such as mortgage payments, real estate taxes and maintenance costs) generally do not decline when circumstances cause a reduction in income from the property. Highly competitive market for investment opportunities There is significant competition for real estate investment opportunities. Some competitors may have a lower cost of funds and access to funding sources that are not available to clients. As a result of this competition, LaSalle may not be able to take advantage of attractive investment opportunities from time to time. No assurance can be given that LaSalle will be able to acquire properties, and real estate-related debt investments on terms, including financing, favorable to LaSalle clients. Possible Inability to Complete Renovation, Expansion or Development on Advantageous Terms One strategy employed by LaSalle to varying degrees depending on the client is to invest in renovation, expansion and development opportunities. Investments involving renovation, expansion and/or development of real estate involves significant risks in addition to those involved in the ownership and operation of properties, including the risks that favorable financing may not be available and that construction may not be completed on schedule or within budget, resulting in increased debt service expense and/or construction costs and delays in leasing and generating cash flow. Substantial renovation, expansion and development activities are also subject to risks

relating to the inability to obtain, or delays in obtaining, all necessary zoning, land-use, building, occupancy and other required governmental permits and authorizations. Once completed, new, expanded or renovated properties may perform below anticipated levels and produce cash flow below forecasted amounts. In addition, substantial renovation and expansion, as well as new development activities, regardless of whether they are ultimately successful, typically require a substantial portion of management’s time and attention, which could divert management’s time from the other investment activities. Renovation, expansion or development activities may be financed through construction loans, in which case there is a risk that, upon completion of construction, permanent financing may not be available or may be available only on disadvantageous terms. Concentration of Investment in the Real Estate Sector LaSalle provides investment advice exclusively with respect to real estate and real estaterelated investments. Only a portion of an investor’s overall portfolio should be allocated to real estate and real estate-related investments. Real Estate Investments are Illiquid Because private real estate investments are relatively illiquid, LaSalle’s ability to sell properties or diversify a portfolio in response to changing economic, financial and investment conditions is limited. Illiquidity may result from the absence of an established market for the investments, as well as legal or contractual restrictions on their sale. Dispositions of investments also may be subject to contractual and other limitations on transfer (including prepayment penalties with respect to property-level debt) or other restrictions that would interfere with the subsequent sale of such investments or adversely affect the terms that could be obtained upon any disposition thereof. The possibility of partial or total loss of capital will exist and entities advised by LaSalle must be able to bear the consequences of such loss. Even if the investments are successful, they may not produce a realized return for an unspecified duration of time. Investments in the Private Funds are Illiquid There is a limited private market for secondary investments in the Private Funds. Investors in our closed-end Private Funds have no redemption rights and limited transfer rights. Investors in our open-end Private Funds have limited rights to redeemed as described in such funds’ Governing Documents. Adverse economic and other conditions can negatively affect occupancy levels and lease rates Adverse economic or other conditions would be expected to lower real estate occupancy levels and limit the ability of property owners to increase rents. The following factors, among others, may negatively affect real estate investments:

local or regional real estate property leasing market conditions; period of economic slowdown, recession or rising interest rates or the public perception that any of these events may occur;

increased operating costs;

changes in supply of, or demand for competing properties in an area;

the impact of environmental protection laws;

acts of gods, terrorist acts, civil disturbances or acts of war that may result in uninsured or underinsured losses or render such properties less desirable in the marketplace; and changes in tax, real estate and zoning laws.

Leasing delays or tenant bankruptcies impact real estate cash-flows Real estate investments are dependent upon the payment and performance of lease obligations by tenants, such as property maintenance, payment of taxes, utilities and other charges and maintenance of insurance. Property owners do not have control over the success or failure of their tenants’ businesses, and, at any time, a tenant may experience a decline in its business that may weaken its financial condition. As a result, tenants may delay lease commencement or renewal, fail to make lease payments or declare bankruptcy. Any of these events could result in the termination of the tenant's lease. If a tenant is unable to satisfy the terms of its leases, the property owner may be forced to modify the lease to the owner’s detriment. Alternatively, the failure of a tenant to satisfy a lease or to renew a lease could require the owner to declare a default, repossess the property, find a suitable replacement tenant, operate the property or sell the property. Any bankruptcy filings by, or relating to, a tenant could bar all efforts to collect prebankruptcy debts from that tenant or seize its property, unless the creditor receives an order permitting such collection from the bankruptcy court, which it may be unable to obtain. A tenant bankruptcy could also delay the property owner’s efforts to collect past due balances under the relevant leases and could ultimately preclude full collection of these sums. If a tenant assumes the lease while in bankruptcy, all pre-bankruptcy balances due under the lease must be paid to the property owner in full. However, if a tenant rejects a lease while in bankruptcy, the owner would have only a general unsecured claim for pre-petition damages. Any unsecured claim may be paid only to the extent that funds are available and only in the same percentage as is paid to all other holders of unsecured claims. Debt Financing LaSalle employs the use of leverage to the extent permitted by the specific client. LaSalle may cause the clients to incur secured, unsecured, recourse and non-recourse debt. Clients that employ leverage are subject to risks normally associated with debt financing, including the risk that cash flow after debt service will be insufficient to accumulate sufficient cash for distributions, the risk that existing indebtedness (which is unlikely to be fully amortized at maturity) will not be able to be refinanced, that the terms of available refinancing will not be as favorable as the terms of existing indebtedness or that the loan covenants will not be complied with. If principal payments due at maturity cannot be refinanced, extended or paid with proceeds of other capital transactions, such as new debt or equity capital, it is possible that the client’s cash flow may not be sufficient in all years to repay all such maturing debt. Furthermore, if prevailing interest rates or other factors at the time of refinancing (such as the reluctance of lenders to make commercial real estate loans) result in higher interest rates upon refinancing, the interest expense relating to such refinanced indebtedness would increase. If a property is mortgaged to secure payment of indebtedness and the client is unable to meet mortgage payments or otherwise comply with loan covenants, the property could be foreclosed upon or otherwise transferred to the mortgagee, with a consequent loss of income and asset value. Debt Investments

LaSalle may originate, participate in and/or acquire real estate loans on a Client’s behalf that are non-recourse to the borrower including subordinated or “mezzanine” loans. Mortgage investments have special inherent risks relative to collateral value. To the extent the client makes or acquires subordinated or “mezzanine” debt investments, LaSalle does not anticipate having absolute control over the underlying collateral as the client will be dependent upon third-party borrowers’ payments of debt service and performance of other obligations under the mortgage loan documents and will have rights that are subordinate to those of senior lenders. In certain circumstances, the client’s loans may not be secured by a mortgage but instead by partnership interests or other collateral that may provide weaker rights and remedies for defaults than a mortgage. In any case, in the event of default, the client’s source of repayment will be limited to the value of the collateral and may be subordinate to other lien holders. The collateral value of the property may be less than the outstanding amount of the client’s investment. In cases in which the client’s collateral consists of partnership or similar interests, the client’s rights and level of security may be less than if it held a mortgage loan. Returns on an investment of this type depend on the borrower’s ability to make required payments, and, in the event of default, the ability to foreclose and liquidate the collateral or sell the note. Hedging against interest rate exposure may result in losses Subject to Governing Documents, LaSalle enters into currency derivatives and interest rate swap agreements to hedge interest rate risk, currency exchange risk or pursue other hedging strategies from time to time, which generally take the form of forward contracts, future contracts, swaps, caps, or collars where appropriate. In addition, certain clients require currency hedging and as such LaSalle would be required to enter into currency hedging agreements in accordance with the terms of the Governing Documents. Where discretion is employed, Clients’ hedging activity will vary in scope based on the level and volatility of interest rates, the type of portfolio investments held, the jurisdiction where the client asset is located and other changing market conditions. In any case, hedges may fail to protect or could adversely affect clients because, among other things:

interest rate hedging can be expensive, particularly during periods of rising and volatile interest rates; available interest rate hedging may not correspond directly with the interest rate risk for which protection is sought; the duration of the hedge may not match the duration of the related liability; the credit quality of the party owing money on the hedge may be downgraded to such an extent that it impairs the client’s ability to sell or assign its side of the hedging transaction; the party owing money in the hedging transaction may default on its obligation to pay; and the client’s hedging activity may adversely impact the asset’s total return in the absence of the hedge.

Generally, only a small amount of the full value of a given hedging instruments (the “notional amount”) is necessary to enter into these transactions. As such, a change in the value of the instrument will magnify the amount of gains and losses experienced. Such hedging arrangements may also cause a client to be exposed to the creditworthiness of the selected hedging provider(s) from time to time. If the hedging arrangements are terminated at any time in accordance with their terms, the client may be liable to make a payment to or receive a payment from the hedging provider in connection with such termination reflecting the market value of the transactions comprising such hedging arrangements. If a client is required to make such a payment, it may be required to liquidate investments to do so. LaSalle may also invest a client’s assets in money market funds and/or other liquid, short term securities for cash management purposes. Where discretion is employed, the decision to enter a hedging transaction is predicated on the expectation of future movements of currency rates or interest rates, as applicable, and changes in such rates may result in poorer overall investment performance than if the client had not engaged in any such hedging transactions. In addition, the degree of correlation between price movements of the instruments used in a hedging strategy and price movements in the portfolio positions being hedged may vary. Moreover, for a variety of reasons, LaSalle may not seek to establish a perfect correlation between such hedging instruments and the portfolio holdings being hedged. Any such imperfect correlation may prevent a client from achieving the intended hedge and expose the client to risk of loss. 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). Cyber Security Risk Cybersecurity incidents and cyber-attacks have been occurring globally at a more frequent and severe level than ever before, and are likely to only increase in the future. LaSalle and its affiliates collect and store sensitive data in their data centers, on their networks and or third-party systems of service providers, including proprietary business information of its Clients, and other business partners and personally identifiable information of tenants, investors and employee representatives of Clients and investors. LaSalle’s service providers may process, store and transmit such information as well. The secure processing, maintenance and transmission of such information is critical to our operations. Despite security measures, information technology and infrastructure may be vulnerable to attacks by hackers or breached due to employee error, malfeasance or other disruptions. Any such breach could compromise our networks, as well as those of our affiliates and our service providers, and the information stored there could be accessed, publicly disclosed, lost or stolen. Any such access, disclosure or other loss of information could result in legal claims or proceedings, liability under laws that protect the privacy of personal information and regulatory penalties, disrupt operations, damage LaSalle’s reputation and cause a loss of confidence in our services and disclose sensitive competitive information of our Clients and investors, which could adversely affect our business and competitive position. Asset Values and Real Estate Market Cyclicality Real estate markets demonstrated a significant degree of volatility and cyclicality during the economic downturn of 2008. Current valuations of underlying investments of clients are high relative to historic averages. If there is a reversion to the historic mean valuation of such cashflows

during the holding period of an investment, a client may incur a substantial loss on such investment whether or not the business plan was successfully implemented. Pandemics and Other Public Health Crisis Pandemics and other health crises, such as the outbreak of an infectious disease such as severe acute respiratory syndrome, avian flu, H1N1/09 flu and COVID-19 or any other serious public health concern, together with any resulting restrictions on travel or quarantines imposed, could have a negative impact on the economy, and business activity in any of the areas in which client investments may be located. Such disruption, or the fear of such disruption, could have a significant and adverse impact on revenues, results from operations, financial condition, liquidity, overall business prospects and ultimately result in risk of loss to the client and the ability of a client to make distributions to its underlying investors could be adversely affected. Properties Owned Through Partnerships and Joint Ventures LaSalle may cause its clients to invest in joint ventures with developers or other unaffiliated persons or entities active in the real estate business. Joint venture investments involve the risks that the joint venture partner might become bankrupt (in which event the client could remain liable for the obligations of such joint venture), that such joint ventures might have economic or other business interests or goals that are inconsistent with the business interests or goals of the client, and that such joint ventures may be in a position to take actions contrary to LaSalle instructions or requests or contrary to the client’s policies or objectives. In addition, agreements governing joint ventures often contain restrictions on the transfer of a joint venture’s interest, “buy-sell” or similar provisions that may result in a requirement that the client purchase or sell its interest at a disadvantageous time or on disadvantageous terms. Government Property Regulations Governmental authorities at the federal, state and local levels are actively involved in the promulgation and enforcement of regulations relating to land use, zoning restrictions and environmental protection. Such regulations may hinder or prevent planned renovation, expansion or development. Even with respect to improved real estate, regulations may be promulgated which would have the effect of restricting or limiting certain usages of existing structures or requiring that such structures be renovated or altered in some fashion. Such regulations could have the effect of increasing the expenses or lowering the profitability of any of the affected properties. One example of such regulation is the institution of rent controls or other economic controls. Environmental Regulation LaSalle engages environmental experts to conduct on-site studies and studies of the history and current usage of properties, as it deems appropriate. Under various federal, state and local laws, ordinances and regulations, an owner of real property may be liable for the costs of removal or remediation of certain hazardous or toxic substances or petroleum products on, under or in such property. Such laws often impose liability whether or not the owner or operator knew of, or was responsible for, the presence of such hazardous or toxic substances. In addition, the presence of, or the failure to properly remediate, such substances may adversely affect the owner’s ability to borrow using such real property as collateral or to sell such property. In connection with the ownership (direct or indirect), management and development of an investment, or one of the entities that holds title could be considered an owner or operator of the investment and may be liable for removal or remediation costs, as well as certain other potential costs relating to such hazardous or toxic substances or petroleum products.

Although each investment will be subject to environmental assessments before acquisition, no assurances can be given that the environmental assessments reveal all environmental liabilities, or that any fund sponsored by LaSalle has established adequate reserves for such liabilities, or that no prior owners created any environmental condition not disclosed in the environmental assessment for such investment. Environmental claims with respect to a specific investments may exceed the value of such investment, and under certain circumstances, could subject other assets of funds sponsored by LaSalle to such liabilities. The presence of such hazardous or toxic substances (including medical and biohazard substances common in assisted living facilities or similar medical facilities), or the failure to properly remediate contamination from such substances, may adversely affect the ability to sell the real estate or to borrow using such property as collateral and may have a significant adverse effect on the value and returns from such property. Sustainability Risks When considering investment opportunities and making ongoing decisions with respect to investments, including decisions relating to follow-on investments, LaSalle may consider certain sustainability factors as part of the overall mix of considerations as to whether the investment opportunity is suitable for an account and otherwise meets the account’s investment criteria. The consideration of sustainability factors may increase the costs and expenses as compared to sustainability factors which were not included in the consideration of an asset, and while such costs and expenses may be material, they would be undertaken with the expectation of achieving accretive or defensive returns via value creation and/or lessening the potential of an expected diminution of value. LaSalle may also determine in its discretion to acquire an investment and avoid the implementation of sustainability initiatives for any number of reasons, including cost, timing, or other considerations. It is also possible that market dynamics or other factors will make it impractical, inadvisable, or impossible for LaSalle to adhere to all elements of our investment strategy, including with respect to sustainability risk and opportunity management, whether with respect to one or more individual investments. It is also possible that certain investments are unable to obtain or realize the intended sustainability outcomes. LaSalle’s efforts to integrate sustainability within the investment process will be subordinated by our fiduciary responsibility to achieve investment returns. Further, sustainability integration and responsible investing practices as a whole are evolving rapidly and there are different principles, frameworks, methodologies, and tracking tools being implemented by asset managers, and LaSalle’s adoption of and adherence to such principles, frameworks, methodologies, and tools may vary over time. Any sustainability-related initiatives which LaSalle is or becomes a signatory, member, or supporter may not align with the approach used by other asset managers (or preferred by prospective investors) or with future market trends. There is also no guarantee that LaSalle will remain a signatory, supporter, or member of or continue to report at the intended cadence or at all under or in alignment with such initiatives or other similar industry frameworks. Moreover, in recent years anti-ESG sentiment, of which sustainability is a part, has gained momentum across the U.S., with several states and Congress having proposed or enacted “antiESG” policies, legislation, or initiatives or issued related legal opinions. Additionally, asset managers have been subject to recent scrutiny related to ESG-focused industry working groups, initiatives, and associations, including organizations advancing action to address climate change or climate-related risk. Such anti-ESG policies, legislation, initiatives, litigation, legal opinions, and scrutiny could result in the Advisor facing additional compliance obligations, becoming the

subject of investigations or enforcement actions, or sustaining reputational harm, or require certain investors to divest or discourage certain investors from investing in the Fund. Climate Change and Sustainability Regulations Climate change and related regulations intended to mitigate its impact may affect the value of our investments in real assets. Real assets in particular may face risks associated with climate change, including risks stemming from the physical impacts of climate change, such as the increasing frequency or severity of extreme weather events and rising sea levels and temperatures, as well as risks related to the impact of climate-related legislation and regulation (both domestically and internationally), and risks related to climate-related business trends. LaSalle cannot predict the impacts on its investments from climate change or related regulations. Laws enacted to mitigate climate change could increase energy costs, could make some buildings obsolete or cause property owners to make material investments in their properties, which could materially and adversely affect its value. Climate change also may have indirect effects on property owners by increasing the cost of (or making unavailable) property insurance. Moreover, compliance with new laws or regulations related to climate change, including compliance with “green” building codes or tenant preferences for “green” buildings, may cause assets to incur additional costs. Additionally, regulatory and voluntary initiatives launched by international, federal, state, and regional policymakers and regulatory authorities as well as private actors seeking to reduce greenhouse gas (“GHG”) emissions may expose real assets to so-called “transition risks” in addition to physical risks, which may include: (i) political and policy risks (e.g., changing regulatory incentives and legal requirements, including with respect to GHG emissions, that could result in increased costs or changes in business operations); (ii) regulatory and litigation risks (e.g., changing legal requirements that could result in increased permitting, tax and compliance costs, changes in business operations, or the discontinuance of certain operations, and litigation seeking monetary or injunctive relief related to impacts related to climate change); (iii) technology and market risks (e.g., declining market for assets, products and services seen as GHG intensive or less effective than alternatives in reducing GHG emissions); and (iv) reputational risks (e.g., risks tied to changing investor, customer or community perceptions of an asset’s relative contribution to GHG emissions). There can be no assurance that climate change will not have a material adverse effect on the properties, operations or business of the Fund. Litigation A Client, its subsidiaries, and or LaSalle, may be subject to litigation in connection with the investments acquired, held or sold from time to time by LaSalle on behalf of the Client. For example, any defaults by tenants on lease payment obligations with respect to a Client’s directly or indirectly held properties will cause the Client to lose or otherwise delay the revenue associated with the relevant lease and the Client may incur substantial costs (including attorneys’ fees) in enforcing its rights as the owner of such properties to secure payment, evict the defaulting tenant and/or pursue other remedies. In addition, the acquisition, ownership and disposition of properties entail certain litigation risks. Litigation may be commenced with respect to a property acquired by the Client or its subsidiaries in relation to activities that took place prior to the Fund’s acquisition of such property. Further, at the time of disposition of a property, a potential buyer may claim that it should have been afforded the opportunity to purchase the asset or alternatively that such buyer should be awarded due diligence expenses incurred or statutory damages for misrepresentation relating to disclosures made, if such buyer is passed over in favor of another.

Similarly, buyers of Client assets may later sue the Client, its subsidiaries and or LaSalle under various damage theories, including those sounding in tort, for losses associated with latent defects or other problems not uncovered in due diligence. The outcome of any such proceedings may materially adversely affect the value of the Client’s account and its properties and may continue without resolution for long periods of time. The expense of defending claims against the Client, its subsidiaries and/or LaSalle by third parties and paying any amounts pursuant to settlements or judgments would be borne by the Client (excepting situations where the governing documents except such indemnification of LaSalle), and would reduce net assets. Any litigation may consume substantial amounts of LaSalle employees’ time and attention, and that time and the devotion of these resources to litigation may, at times, be disproportionate to the amounts at stake in the litigation. Property Management and Leasing LaSalle relies on third party property managers and leasing agents to manage and lease client properties. The third-party property managers have decision-making authority with respect to the management of our properties in accordance with the terms outlined in legal agreements with those service providers. LaSalle’s ability to direct and control how client properties are managed on a day-to-day basis may be limited because third parties are engaged to perform specific duties on behalf of the owner. Any adversity experienced by property managers or leasing agents could adversely impact the operation and profitability of client properties. Reliance on Key Employees LaSalle depends on the efforts and expertise of its senior management and personnel. The loss of these persons’ services could have a material adverse effect on the firm, both from a human resources perspective and from a Client perspective where the Client has negotiated “key man” provisions that would allow the Client to limit future investments under the applicable Governing Documents until, for example, a new employee is identified as a replacement. LaSalle employs experienced individuals who manage its operations, and its success depends on, among other things, its ability to retain these individuals and attract additional qualified personnel.

LaSalle Investment Management Distributors, LLC. LaSalle engages LaSalle Investment Management Distributors (“LIMD”) to distribute and/or market the securities of LaSalle-sponsored funds. The registered representatives of the broker-dealer are dual employees of LaSalle. Some dual employees are engaged in both LaSalle’s advisory activities and the brokerage activities of LIMD. Other dual employees dedicate 100% of their time to LIMD’s selling activities associated with the Private Wealth Group. LaSalle assumes the compensation costs of the registered representatives in accordance with an expense sharing agreement that is consistent with NASD Notice to Members 03-65. Registered representatives of LIMD are incentivized to solicit investors for investments in LaSalle-sponsored Private Funds. LaSalle believes this risk is mitigated in part through its internal review processes of the marketing materials that are presented to investors. LaSalle-sponsored funds are targeted generally to major institutional investors that have experience, or hire consultants who have experience, with real estate investing. LaSalle itself is also motivated to maintain its strong reputation in the real estate investment community and incentivized to ensure investors understand LaSalle’s investment strategies, processes and capabilities prior to accepting subscriptions. Lastly, potential investors have the ability to meet with and request additional information from senior members of the management team.

2.

Jones Lang LaSalle Incorporated. LaSalle obtains investment real estate research from its sister affiliate entities operating under the Jones Lang LaSalle Incorporated (“JLL”) family of subsidiaries. In addition, if permitted under the applicable investment management agreement or other Governing Documents, LaSalle may engage its affiliates to perform property management and real estate related transaction services. In accordance with client documentation, LaSalle is generally required to hire affiliates on competitive terms and conditions and often as a result of a competitive bidding process and such transactions are generally required to be disclosed in accordance with such documentation. Some clients also require affiliate transactions to be terminable upon thirty days’ notice. LaSalle believes that the affiliation with JLL and access to its platform is a benefit that its clients expect. However, LaSalle endeavors to always engage the best service providers in an applicable market (whether affiliates or unaffiliated third parties) with competitive fees, rates and quality of service. However, having multiple affiliates that are in the real estate services business may give rise to an actual or perceived conflict of interest if LaSalle has discretion to select, or is responsible for recommending to a client, service providers that are affiliates.

3.

LaSalle Debt Investors. LaSalle’s investment advisory affiliate, LaSalle Debt Investors (“LDI”), is an SEC registered Investment Advisor. Employees of LDI are dual employees that are seconded from LaSalle to LDI to source first mortgage debt opportunities for both LaSalle and LDI clients investing in debt opportunities.

4.

LaSalle forms special purpose entities to serve as general partners and/or managing members of its private investment funds and Custom Accounts. These entities may share common owners, officers, partners, employees, consultants or persons occupying similar positions. All of these entities are under common control and subject to LaSalle’s Code of Ethics (defined below) and compliance program adopted pursuant to the requirements of the Advisers Act.

Requirements Related to Confidentiality: LaSalle employees are prohibited from transacting in any security if the decision is based on material non-public information.

Limitations, and Reporting of, Gifts and Entertainment

Reporting of Political Contributions

Pre-Clearance and Reporting of Employee Personal Securities Transactions: LaSalle employees are prohibited from purchasing interests in any private offering, initial public offering, or any real estate security (including a publicly offered REIT) without prior approval of the Chief Compliance Officer. o Personal Securities Trading Restriction for Global Solutions: Employees of the Global Solutions Group are prohibited from purchasing securities of any issuer whose primary business is investment in real estate.

Pre-Clearance of Outside Business Activities

Protection of Persons who Engage in “Whistle Blowing” Activities from Retaliation

Additionally, the Code requires all LaSalle employees to make initial (upon becoming subject to the Code) and annual securities holdings reports to LaSalle that identify all brokerage accounts in which the employee has any direct or indirect beneficial interest. These reports contain information about the securities held in such brokerage accounts. The Code also requires its employees to provide quarterly transaction reports to LaSalle or to instruct their brokers to provide duplicate confirmations for all securities transactions to LaSalle. LaSalle will provide any current or prospective client with a copy of the Code upon request. LaSalle or its personnel may, from time to time, come into possession of material non-public or

other confidential information about public companies which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, LaSalle and its personnel are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any person, regardless of whether such person is a client of LaSalle. Accordingly, should LaSalle or its personnel come into possession of material non-public or other confidential information with respect to any public company, LaSalle is prohibited from communicating such information to clients and has no responsibility or liability for failing to disclose such information to clients as a result of following its policies and procedures designed to comply with applicable law. Potential Conflicts of Interest LaSalle offers many different products and services and there are several potential conflicts of interest which may arise, including, but not limited to, those identified in Item 10 – Other Financial Industry Activities and Affiliates and below. LaSalle has adopted, and continues to adopt, policies and procedures to address such potential conflicts of interest. LaSalle sponsors Private Funds that invest in real estate and originate first mortgage loans, and serves as the advisor to such funds. Depending on the structure, a LaSalle affiliate would act as the general partner or managing member of the fund and/or its employees would serve in certain key capacities with the general partner. LaSalle would also be engaged to act as the adviser to the Private Fund. During the fund-raising stage, senior LaSalle employees dedicated to the fund participate in the solicitation process. However, the compensation structure of its fund management team is based in part on the overall performance of the fund itself not pure solicitation activities. LaSalle also prepares its marketing materials consistent with the Advisers Act, and requires the information presented in its materials to be supported by data. LaSalle employees dedicated to marketing and client engagement are also registered representatives of LaSalle’s affiliated brokerdealer, LIMD, and these individuals also participate in the solicitation process in a “finder” capacity. As explained above, the registered representatives are incentivized to recommend LaSalle’s Private Funds to institutional investors because of the indirect compensation they may be awarded in the form of an annual bonus. These conflicts are addressed in part by LaSalle’s general motivation to admit only sophisticated investors, which are primarily institutional, to the applicable fund given the long-term investment horizon such a commitment requires. Entities managed by LaSalle or an affiliate of LaSalle have co-invested in LaSallesponsored funds, as well as some Custom Accounts structured as partnerships. For certain coinvestments, an affiliate of LaSalle owns approximately 49% of the co-investment entities and for others affiliates also co-invest directly in LaSalle-sponsored Private Funds and Custom Accounts. LaSalle employees also invest in LaSalle-sponsored funds, certain Custom Accounts where the investment structure provides for such co-investment, and in more limited cases, individual real estate investment opportunities where additional capital is sought by the applicable client for the investment. All co-investments are on terms and conditions comparable to those of the Custom Account client or other Private Fund investors. LaSalle notes that some major investors in Private Funds and many Custom Accounts condition their investment upon LaSalle’s co-investment in the Private Fund or alongside the Custom Account. In these cases, LaSalle has an indirect interest in the fund and also serves as the adviser to the fund. In some cases, investors in Private Funds and

Custom Accounts also require co-investment by employees involved in management of the account. LaSalle believes the co-investment structure aligns the interests of LaSalle and its employees with those of the investors and clients. A conflict that may arise in this structure could be an event that causes the interest of LaSalle and its affiliates and/or employees to diverge from those of the Private Fund investors or the Custom Account. LaSalle believes these conflicts are mitigated generally through LaSalle’s fiduciary obligations to act in the best interest of its clients, as well as the allocation process and investment committee. LaSalle believes that contractual limitations in the investment management agreements that govern LaSalle’s activities as advisor and the necessity of maintaining LaSalle’s strong reputation in the real estate investment advisory marketplace also serve to ensure that LaSalle appropriately address conflicts. LaSalle engages in cross transactions on a sporadic basis and generally does not engage in principal activities. If LaSalle were to engage in principal or cross transactions (i.e., where LaSalle serves as the advisor to both clients and therefore has decision-making authority on each side of the transaction), LaSalle would not, without obtaining the consent of any impacted client, or in the case of a Private Fund, the fund’s advisory board, prior to the settlement of such transaction: (i) as principal, sell an asset to, or buy an asset from, any client; or (ii) cause the client(s) to participate in a cross transaction in which LaSalle arranges for a client to buy an asset from, or sell an asset to, another client. In particular, LaSalle would not engage in such transactions without providing appropriate disclosure and obtaining the prior informed consent from the client(s). LaSalle recommends to clients from time-to-time investments in commercial paper, certificates of deposit and/or U.S. government securities for short-term cash management activities, which could be the same investments in which LaSalle may invest to manage cash proceeds received by LaSalle as a result of LaSalle’s co-investment initiatives with its clients. LaSalle views this activity as a ministerial and administrative portion of its overall services and as a mechanism to protect client funds from bank failure risks. LaSalle generally does not charge any additional fees for its cash management activities. In more limited situations, LaSalle may also direct client funds to purchase equity investments in the private real estate sector and opportunistic investments in private real estate loans, including participating loans. Similar to the paragraph immediately above, LaSalle’s coinvestment vehicle would also be the beneficiary of the advice that LaSalle would be providing to the fund. Certain types of insurance protecting client assets are generally purchased on an aggregate basis and covers the clients, the Advisor and certain of its affiliates, and/or potential other parties at interest including certain other clients of the Sponsor or its affiliates. These policies’ coverage limits generally apply on either a per occurrence/claim or on an annual aggregate basis and, therefore, losses experienced by one or more of the Sponsor and/or its Affiliates and/or the Advisor’s clients may limit aa client’s ability to collect for certain losses and in such cases could increase the expenses borne by the client. The methodologies used by LaSalle to allocate such costs and expenses associated with the insurance coverage generally include, but are not limited to, allocating based on: (i) net invested capital, net asset value, or available capital; (ii) total insurable value of each individual property, the type of assets in each account or the number of investors in each account, with or without a base allocation to the Sponsor, and guidance from the Sponsor’s insurance broker; (iii) the number of applicable transactions attributable to each account and the Sponsor; (iv) equal apportionments among the applicable accounts; and/or

(v) combinations of the above. Subject to the factors described herein, the allocation of such expenses may not be proportional. Furthermore, when the total loss of all properties affected in a shared insurance program by a single event exceeds the policy limit, the insurance proceeds would be allocated based on the proportion of the premium paid by each affected property to the sum of the premium paid by all affected properties. This percentage would then be multiplied by the available insurance proceeds to determine the recovery for each location. As a general matter, LaSalle does not recommend securities to clients, or buy or sell securities for client accounts, at or about the same time that LaSalle or its related persons buys or sells the same securities for LaSalle’s or the related person’s own account. In certain circumstances, LaSalle or its related person will co-invest in an investment or Private Fund alongside a client. In order to provide the quality of services that clients expect, LaSalle believes it is necessary for us to establish, maintain and enhance relationships with professionals in the real estate industry, such as attorneys, consultants, title companies, real estate developers and operators, brokers and other service providers and professionals (collectively, “Professional Relationships”). Establishing meaningful and long-term relationships can be important factors in our ability to provide a high level of service to our clients. LaSalle, and many Professional Relationships, value important and longstanding relationships, and as such, LaSalle and its employees from time to time invite, or are invited by, Professional Relationships to participate in activities, such as sporting and networking events, concerts, golf and other outdoor outings and other recreational activities, and give or receive gifts related to attendance or participation in such activities (collectively, “Activities”). The primary benefits that LaSalle and our clients receive from our sponsorship and participation in these Activities is to establish and further strengthen our relationships within Professional Relationships. LaSalle believes that working to have such relationships is important to help ensure that we are provided with the opportunity to capitalize upon active sources of investment opportunities, as well as to receive critical and reliable services and information. While LaSalle believes employee sponsorship or participation in these Activities is beneficial to clients for the reasons described above, our subsequent selection and retention of such Professional Relationships as service providers could be perceived as a form of reimbursement for participating in such Activities, and we have an incentive to select service providers based on the expectation of receiving gifts or invitations to future Activities. Notwithstanding that potential conflict of interest, LaSalle recognizes and acknowledges our fiduciary duty to our clients and has adopted policies and procedures designed to help prevent any Activities from influencing our decision to hire or retain a service provider or to engage in any transaction on behalf of a client. Our policies and procedures require all gifts and entertainment valued in excess of certain thresholds to be preapproved in writing by our Chief Compliance Officer, or their designee, and the manager of the attending LaSalle employee.

key initiatives to be accomplished during the upcoming year.

In addition to the annual plans described above, LaSalle’s client teams prepare quarterly written reports to clients. The reports include unaudited financial statements, which are prepared and reviewed by internal accounting professionals. In the substantial majority of cases, year-end financial statements are audited by certified public accountants, most of which are one of the “bigfour” accounting firms and all of which are AICPA independent of LaSalle and the account they are auditing. Capital items, including paid in capital, invested capital and distributions are reviewed by internal accounting professionals as transactions occur to ensure they are completed in accordance with the Custom Account or fund agreements and/or bylaws. In general, written quarterly reports and financial statements are issued to clients between 45 and 60 days after quarter-end. Quarterly reports contain a high-level executive summary, financial schedules, property profiles and fair value based financial statements. Client financial statements detail the contributions, distributions and ownership amounts of each client’s investment. Electronic quarterly reports and financial statements are provided to clients via a secured website. Email notifications are sent to clients when reports and statements are available. Hard copies are made available upon request.

dual employees will not be acting as supervised persons of LaSalle at such times they are acting as registered representatives of the broker-dealer. LaSalle may enter into placement agreements or solicitation arrangements pursuant to which it compensates third parties for referrals that result in a potential investor becoming an investor in a Private Fund. When LaSalle enters into such agreements or arrangements, it generally expects that any fees payable to any such placement agents would generally be borne by LaSalle directly or indirectly through an offset against the applicable Private Fund’s management fee, except in cases where the Governing Documents provide for specific authority to allocate such costs to the Private Fund.

In addition, LaSalle arranges for surprise examinations of client accounts by an independent public accountant for those client accounts (i) over which LaSalle has custody of both client securities and cash and (ii) which do not otherwise qualify for an exemption under Rule 206(4)-2 of the Advisers Act. LaSalle notes that in all cases client cash is held at banks that are qualified custodians as defined by Rule 206(4)2 of the Advisers Act. Clients may also require LaSalle to provide quarterly statements (please see Item 13 “Review of Accounts” above) that provide transactional and financial information about the account. In addition to carefully reviewing the bank statements themselves, clients should and are directed to compare the bank statements with the quarterly account statements that are received from LaSalle.

LaSalle customarily does not execute other documentation to evidence its authority to execute transactions on behalf of the client’s account.

LaSalle’s proxy voting policies and procedures seek to ensure that LaSalle votes proxies in the best interest of its clients and consistent and in a manner consistent with its fiduciary duties, including where there may be material conflicts of interest. Clients may obtain a copy of our proxy voting policies and procedures as well as the voting records relating to proxies upon request.