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Bridge Investment Group: investment adviser

Bridge Multifamily Fund Manager LLC, doing business as Bridge Investment Group, is an investment adviser registered with the SEC (file 801-72790, CRD 159127). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$49.3B
Discretionary
99%
Accounts
188
Employees
610
In advisory roles
205
Disclosures
3

SEC adviser record · Full Form ADV (PDF)

The firm reports that it or a related person has custody of client cash and securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles151$48.2B97.8%
Other: Joint ventures and smas37$1.1B2.2%

How it is paid

  • A percentage of assets under your management
  • Performance-based fees

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)
  • Other: PORTFOLIO MANAGEMENT FOR JOINT VENTURES

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Bridge Fund Management Holdings LLCCompany (U.S.)MemberE 75% or moreJan 2012Yes
Dean Anthony AllaraPersonVice chairmanA 5% to 10%Sep 2011Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
Adam Bernard O'FarrellO'Farrell, Adam,PersonF General partner, trustee or managing memberYes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

What the firm disclosed under Item 11 of Form ADV. A disclosure is the firm's own report: pending matters are allegations, not findings, and many settlements are made without admitting or denying them. Text is quoted from the filing, set in sentence case.

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

  • Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
  • Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: entered an order against you or any advisory affiliate in connection with investment-related activity?
  • Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?

Actions about affiliates (2)

  1. Jan 8, 2021
    Civil Judicial Action FinalAbout an affiliate: Apollo Management GP, LLC; the full record is on the affiliate's own Form ADVSanctions: Money Damages (Private/Civil Complaint); Injunction; attorney's fees and related costs · Begun Aug 24, 2018 · Resolved Jan 8, 2021 · Judgment Rendered

    Plaintiff brought a securities class action on behalf of all those who purchased ADT inc. ("ADT") common stock in or traceable to ADT's January 19, 2018 initial public stock offering (the "IPO"), seeking to pursue remedies under the Securities Act of 1933 (the "1933 act") against the issuer, ADT, and a number of other defendants, including Apollo management, L.P., the applicant, and several of its advisory affiliates. The plaintiff alleges, among other things, that the defendants violated several provisions of the 1933 act. As it relates to Apollo management, L.P. and several of its advisory affiliates, plaintiff asserts a claim for violation of section 15(a) of the 1933 act as a result of the alleged misstatements and omissions in the registration statement and in the preparation of the prospectus for the IPO.

    The court's order and judgment dismissing the action terminated all claims against the Apollo entities without any admissions or findings of liability and without imposing any fees, costs, damages, or sanctions on the Apollo entities.

  2. Jan 8, 2021
    Civil Judicial Action FinalAbout an affiliate: Apollo Global; the full record is on the affiliate's own Form ADVSanctions: Money Damages (Private/Civil Complaint); Prejudgement and post-judgement interest, plus attorney's and expert fees and related costs · Begun May 21, 2018 · Resolved Jan 8, 2021 · Dismissed

    Plaintiff brought a securities class action on behalf of those who purchased ADT inc. ("ADT") common stock in or traceable to ADT's January 19, 2018 initial public stock offering (the "IPO"), seeking to pursue remedies under the Securities Act of 1933 (the "1933 act") against the issuer, ADT, and a number of other defendants, including Apollo management, L.P., the applicant, and several of its advisory affiliates. The plaintiff alleges, among other things, that the defendants violated several provisions of the 1933 act. As it relates to Apollo management, L.P. and several of its advisory affiliates, plaintiff asserts a claim for violation of sections 11 and 15(a) of the 1933 act as a result of the alleged misstatements and omissions in the registration statement and in the preparation of the prospectus for the IPO.

    The court's order and judgment dismissing the action (1) terminated all claims against the Apollo entities without any admissions or findings of liability and without imposing any fees, costs, damages, or sanctions on the Apollo entities; and (2) barred similar claims from being asserted against the Apollo entities in future actions.

Disclosures filed elsewhere

The firm's Form ADV names these and the kind of action only; the details are on the named firm's own filing.

  • 1 regulatory action disclosure about Apollo Management, L.P.

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Bridge Investment Group - ADV Part 2 Brochure (March 2026), filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

or co-investment partners will not reduce or offset the management fee payable by any Client that has also invested in such investment. The terms of such joint venture arrangements are negotiated on a case-by-case basis, subject to the respective Governing Documents. Certain joint venture partners receive incentive fees (including profits interests or other equity interests) or other compensation in an investment or intermediate holding company that would have a dilutive impact on the Fund's ownership in the investment.

Read the rest of Item 4 (5,064 more words)

In accordance with common industry practice, each Fund, its General Partner, any of the Investment Advisers or Bridge routinely enter “side letters” or similar writings, agreements or understandings with Fund Investors which have the effect of establishing favorable rights, benefits, or privileges under, or altering or supplementing, the terms of the respective Governing Documents without any further act, approval or vote of any other Fund Investors. These rights include, but are not limited to, certain “most favored nations” processes, economic rights, liquidity, withdrawal or transfer rights, different performance hurdles, minimum investment amounts, co-investment allocation or participation rights, voting rights, management fee offsets for certain fees, information rights, additional or modified reporting obligations, excuse or exclusion rights, agreements to assist with the taking or defending of certain tax positions, obligations and restrictions on the applicable General Partner with respect to its discretion on certain matters and other rights or terms including those that are requested in light of particular investment, legal, regulatory or public policy characteristics of a Fund or a particular Fund Investor. Any rights established, or any terms of the respective Governing Documents so altered, modified, or supplemented in a side letter with a Fund Investor, will govern with respect to such Fund Investor notwithstanding any other provision of the respective Governing Document. Additional benefits provided to a Fund Investor via a side letter will not necessarily be available to other Fund Investors. By their nature, side letters will give preferential treatment to those who have entered into such arrangements. For example, if the Governing Documents of a Fund provide that expenses incurred in connection with the compliance of side letter provisions be borne as organizational or partnership expenses, all investors of such Fund would bear such expenses and not solely the Fund Investor that entered into that specific side letter. Further, side letters can have adverse effects on other investors within the Fund, such as placing limitations on certain investments or permitting such investors to act on the basis of information not available to other Fund Investors that do not have the benefit of such side letters. Except as otherwise agreed with a Fund Investor or required by law, a side letter with one Fund Investor is not required to be disclosed to other Fund Investors. The Investment Advisers tailor their advisory services to the needs of Clients as set forth in the applicable Governing Documents. The Governing Documents generally set forth certain limitations on investments that can be made by the applicable Fund, including but not limited to limitations on the type of securities, assets or concentration or geographical limitations that may be acquired by the applicable Fund. Additionally, Apollo and its affiliates provide investment advisory services to various clients, including certain vehicles, funds and accounts managed by Apollo (collectively, “Apollo Clients”). Further information regarding Apollo Clients is available in the respective offering and governing

Page 7 of 75

Item 5 – Fees and Compensation

documents for such Apollo Clients as well as the Form ADV brochure for the respective Apollo investment adviser. Item 5 – Fees and Compensation The Investment Advisers and the General Partners earn fees and other compensation in connection with the services provided to the Clients. Affiliates of the Investment Advisers perform various additional services for Clients for which they receive additional fees, which creates a conflict of interest. The description below is intended to provide a summary of typical fee structures of our Clients and is not intended to depict every particular scenario where such fee structures differ. Fund Investors in Clients that make secondary investments in private fund interests bear their share of multiple distinct layers of management fees, carried interest, performance fees or performance allocations, and expenses, as described below and in the applicable Governing Documents. Fund Investors should carefully review the Governing Documents of each Client for information on the fees and compensation payable by Fund Investors with respect to a particular Client. For a more detailed description of fees and expenses paid, including fees for certain affiliate transactions, please refer to the applicable Governing Documents or other applicable Client agreements. Management Fees and Carried Interest Clients are subject to different fees as compensation for the investment advisory services provided to each applicable Client. The precise amount and manner of calculation of the fees are intended to reflect the underlying investment mandate and associated risks and are set forth in the respective Governing Documents. The fees paid by a Client are directly or indirectly borne by the underlying Fund Investors. Management Fees. The Investment Advisers generally earn management fees based on a defined percentage of total commitments, invested capital, or net asset value, in each case as defined in the applicable Governing Documents, which set forth the precise amount and calculation of the management fees and the full list of terms under which a management fee will be reduced, offset or otherwise limited. Investors should expect to bear the full specified management fee in the relevant Governing Documents until reduced in the circumstances and on the date(s) specified therein. Management fees generally range from 0.85% to 2.5% per year (which may be less or more, in certain circumstances). Fund Investors with larger capital commitments generally pay a lower management fee rate. For closed-end funds, management fees are generally based on committed capital during the commitment period for the applicable Fund and on deployed capital contributions (generally capital contributions net of returned capital) thereafter. For open-ended funds, management fees are generally based on each Fund Investor’s proportionate share of net asset value. Generally, Fund Investors are assessed the management fee on an annual basis, payable quarterly in advance to the relevant Investment Adviser or its designated affiliate (and in the case of Clients that make secondary investments in private fund interests, such management fees may be payable two quarters in advance). Determinations of committed capital, deployed capital, and returned capital forming the basis for the management fee calculations are made at

Page 8 of 75

Item 5 – Fees and Compensation

the discretion of the respective Investment Adviser. Certain fees and expenses relating to acquiring investments are generally capitalized as transaction costs of the investments, including but not limited to legal fees, debt placement fees, financing fees, acquisition fees, and due diligence fees. Capitalizing such fees and expenses results in an increase to the management fee base when management fees are charged based on net invested capital or capital contributions. With some Clients, such transaction-based fees and expenses are paid to affiliates of the Investment Advisers. Capitalizing such fees and expenses paid to affiliates of the Investment Advisers creates a conflict of interest because it increases the management fee base and management fees payable with respect to amounts paid to affiliates of the Investment Adviser. Impact of Valuations on Management Fees. Except where the Governing Documents expressly provide to the contrary, the amount of management fees with respect to a closed-end Fund generally will not correspond with fluctuations in the Fund’s net asset value. Therefore, management fees generally will not be reduced (in whole or in part) in the event of partial writedowns that are not considered permanent at the discretion of the General Partner. Subject to the Governing Documents, each General Partner is entitled to make its own determination considering all facts and circumstances it deems relevant. As a general matter, the standards for determining whether an investment is permanently written down are intended to be high and not to apply to investments experiencing partial or temporary declines in value. There are many factors that cause temporary declines in value, particularly with respect to real estate debt and equity investments (e.g., cap rates, occupancy), that would not be expected to result in a permanent write-down. This discretion on whether a write-down is considered permanent creates a conflict of interest due to the financial impact of decreasing the management fees payable to affiliates of the General Partner upon a determination that a write-down is considered permanent. Carried Interest. The General Partners earn carried interest, performance fees or performance allocations that are generally calculated as a percentage of the profits earned during a defined performance period, subject to defined performance thresholds set forth in the applicable Governing Documents. Carried interest or performance fees, incentive fees or performance allocations generally range from 15% to 20% over a preferred return ranging from 5% to 8%. In some cases, carried interest includes a “catch-up” provision that provides that once the performance threshold has been met, the General Partner receives up to 100% of the subsequent profits until they have satisfied the carried interest percentage. Variation of Fees; Waivers. The applicable Investment Adviser and/or General Partner of each Fund has sole discretion to negotiate or waive all or any portion of any management fee, carried interest or incentive fees payable in respect of any Fund Investor’s interest in such Fund, including Fund Investors that make substantial capital commitments or capital commitments at the first closing of the respective Fund, or Fund Investors that are affiliated with the Investment Adviser, Apollo or their affiliates (including employees, owners, business associates and certain family and other relationships of Apollo or Bridge), or to aggregate the commitments of one or more Fund Investors into one or more Clients for the purposes of determining whether any applicable fee break threshold has been met. The applicable General Partner and/or Investment Adviser routinely agrees with certain broker/dealers or other intermediaries that assist in raising capital

Page 9 of 75

Item 5 – Fees and Compensation

commitments for a Fund to offer reduced management fees or carried interest to the clients of such broker/dealers or other intermediaries. The investment terms for separately managed accounts and for joint ventures, including management fees, carried interest/performance fees and expenses, are negotiated on a case-by-case basis. Additionally, Apollo Clients are permitted to invest in certain Clients as limited partners and, as such, the applicable General Partner and/or Investment Adviser of such Client is incentivized to grant certain consent rights or preferential treatment to, or waive certain obligations of, such Apollo Clients, which creates a conflict of interest. In addition, Bridge has entered into, and will again in the future enter into, arrangements with Apollo Clients with the effect that such funds pay, or otherwise bear, higher, lower or no carried interest or Management Fees with respect to such Client. The preferential terms provided to such Apollo Client as contemplated by this paragraph are not subject to the “most favored nation” provisions under the applicable Client’s Governing Documents. Such Clients should refer to their specific Governing Documents for information regarding fees and expenses. Fee Billing Management fees are typically billed quarterly in advance and are not refundable. For certain Clients, we are authorized under the Governing Documents to charge and deduct fees directly from the Fund at the times and in the amounts set forth in the Governing Documents. Management fees can be billed directly to each Fund Investor or can be deducted from such Fund Investor’s share of proceeds from Fund investments, if applicable. In our open-ended Funds, some management fees are billed quarterly in advance and others are billed quarterly in arrears, in each case as set forth in the applicable Governing Documents. In the open-ended Funds that permit withdrawals or redemptions during a period for which management fees have already been paid, the Investment Advisers generally receive a prorated portion of the management fee (based generally on the number of days during the period) through the effective date of the withdrawal or redemption, as applicable. For a more detailed description of fees for each Client, please refer to the applicable Governing Documents. Investment terms for joint ventures and separately managed accounts are negotiated on a case-by-case basis with those parties. Affiliate Fees Affiliates of the Investment Advisers perform various additional services for Clients for which they receive fees. The potential for affiliates of the Investment Advisers to receive additional economic benefits creates conflicts of interest and creates an incentive for Bridge or an applicable affiliate to select an affiliated service provider, or to otherwise select service providers based on the potential benefit to Bridge or affiliates (including service providers in which Bridge or Apollo holds an interest, even if not affiliated service providers), rather than to Clients or their existing or potential portfolio investments. The affiliates of the Investment Advisers receive fees for the following services, including fund administration fees, property management fees and expenses, leasing commissions (including commissions or bonuses paid for resident referrals), construction management fees, development fees, advertising management fees and reimbursements, architectural and space planning fees, software fees, including property management and other software, fees for pricing advisory services, fees or overhead allocation for procurement,

Page 10 of 75

Item 5 – Fees and Compensation

accounting and other services, fees and expenses related to engagement of professionals engaged through Apollo Portfolio Performance Solutions (“APPS”), debt placement/sourcing fees, interest (in cases where the lender is an affiliate of the Investment Advisers), recruiting fees, marketing fees, fees for public-relation services, loan underwriting fees, insurance fees and premiums, reimbursement for reasonable fees and expenses of in-house legal personnel, reimbursement of reasonable fees and expenses of in-house tax professionals, due diligence fees, and acquisition fees. In some cases, such fees are received solely by an affiliate of the Investment Advisers and in other cases, such fees are shared with a third party. For example, with real estate development projects that involve a joint venture development partner, construction management fees or development fees may either be paid in full to the respective affiliate of the Investment Adviser or a portion may be shared with the third-party joint venture development partner. Additionally, affiliated broker-dealers may be compensated based on the size and/or successful closing of a transaction. This gives Bridge an incentive to use such affiliated broker-dealer in addition to, or in lieu of, unaffiliated service providers. The receipt of transaction-based compensation may also cause persons associated with the affiliated broker-dealer to focus on the successful completion of a transaction rather than on other factors. In addition, the Investment Advisers or their affiliates have, or have caused the Funds to contract with, pay fees to, or engage in transactions with businesses in which the Investment Advisers or their affiliates or personnel of the Investment Advisers or their affiliates hold an interest. To the extent the Investment Advisers or their affiliates have invested in such businesses or invest additional amounts in such businesses, they would receive direct or indirect compensation (including in some cases the right to receive or acquire additional ownership interests), in connection with the utilization of such services or products by the Funds or investments held by the Funds which results in a conflict of interest or the perception thereof in engaging the relevant entity as a service provider in light of the personal benefits that accrue through the investment(s) they hold in the business. For example, a portfolio investment of a Client or an Apollo Client may lease space from Bridge, an affiliated service provider, or a portfolio investment of another Client or an Apollo Client. Furthermore, the Investment Advisers or their affiliates have established related or affiliated entities, including other Clients or Apollo Clients, to, (a) lease solar equipment to be used at properties owned by certain other Clients, or (b) lease rooftop space at properties owned by certain Clients to generate and sell solar power to tenants of such properties, the Clients or its affiliates or utility providers. Although the terms of any lease or other contract between the Investment Advisers or their affiliates and other Clients related to solar power, solar equipment or similar renewable energy initiatives are expected to be substantially similar to those negotiated with third-party owners of properties, including payment of market rents and other market lease terms, there will be no third-party verification of such market terms and there is no assurance that such terms will be substantially similar to those provided by unaffiliated parties in all material respects. The Investment Advisers or their affiliates collect fees (including financing fees) and tax benefits in connection with such leasing business and solar equipment transactions, which fees or benefits will not accrue to the benefit of the Funds or the Clients in any manner. Owners of such

Page 11 of 75

Item 5 – Fees and Compensation

solar equipment are generally entitled to certain tax credits, which tax credits are not expected to flow through to the Clients owning the real estate properties that utilize such solar equipment. Master Insurance Program. Certain Clients and Apollo Clients (including their investments and tenants) participate in a master insurance program sponsored by an affiliate of the Investment Advisers, which in exchange for fees and premiums paid to an affiliate of the Investment Advisers, bears the risk of certain insurable losses. Depending on losses for a particular year, these fees and premiums result in a net gain for affiliates of the Investment Advisers. The master insurance program facilitates the consolidation of property and general liability insurance risk among multiple U.S. properties owned by Clients, increasing coverage limits and controlling cost. The allocation of fees and premiums related to coverage under the master insurance program among Clients and affiliates of the Investment Advisers is based on customary factors such as risk exposure and prior loss experience related to the assets owned by each Client. While an increase in losses at investments owned by a particular Client will generally result in an increased allocation of fees and premiums to such Client for future coverage, other Clients may indirectly bear an increase in their fees and premiums due to the consolidated structure of the master insurance program. Further, certain Clients may have an opportunity to receive a return premium at the end of a term of an insurance policy based on lower-than-expected claims and losses within investments owned by such Client. In the event that any such return of a premium or refund is paid after the end of the term of a Client according to its governing documents, any such return or premium would be allocated to other participating Clients or retained by the Investment Advisers for its own account. Affiliate Fee Rates; No Offset. Such fees and expenses paid to affiliates of the Investment Advisers accrue to the benefit of the Investment Advisers or their affiliates, and not the Clients. Such fees are generally not offset against any management fees earned by the Investment Advisers. The fees paid to affiliates of the Investment Advisers are generally either (a) paid at a rate set forth in the Governing Documents, or (b) paid at a rate that is equal to or below market rates, as determined by the respective General Partner in its sole discretion. However, in circumstances in which an Investment Adviser commits or has committed to seek “market” or “arms-length” rates or terms, the Investment Advisers undertake no minimum account of benchmarking and do not represent that any such benchmarking ultimately will be accurate, comparable or related specifically to the assets, services, geographies or comparable markets to which such rates or terms relate. The Investment Advisers reserve the right to deem third-party investment in a transaction to be verification that the transaction was entered into at a value that is “arms-length” or at market rates. In addition, where such rates or terms include hourly components, the Investment Advisers reserve the right to rely on estimates of time spent for the purpose of allocating or charging for such services. There can be no assurance under such arrangements that the amount of compensation paid in a particular year or other applicable period will be proportional to the number of hours worked or the amount of written work product generated. With respect to the portion of any such portfolios or assets owned by other investors that are not Fund Investors, the General Partner or its affiliates receive separate compensation at agreed upon

Page 12 of 75

Item 5 – Fees and Compensation

rates. The General Partner, Investment Advisers and affiliates are not obligated, and do not expect, to share any such earned fees with a Client or the Fund Investors. Additional Benefits to the Investment Advisers or Affiliates. The Investment Advisers, their affiliates, and personnel can also be expected to receive certain intangible and/or other benefits or perquisites arising or resulting from their activities on behalf of the Funds, which will not be subject to management fee, performance allocation or promote interest offsets or otherwise shared with Clients, the Funds, Fund Investors and/or investments or assets held by Clients or the Funds. For example, consistent with market practice for residential property management, certain property management employees receive rent discounts in exchange for living on-site, and any such discounted amounts are not subject to any management fee offset or otherwise shared with the relevant Clients. Further, airline travel, hotel stays, rental cars and other operating expenses incurred on credit cards, rewards cards, or through rewards programs as a Client expense result in “miles,” “points,” cash rebates or credit in loyalty or status programs, and such benefits and/or amounts will, whether or not de minimis or difficult to value, inure exclusively to the Investment Advisers, their affiliates and their personnel (and not to the Clients, the Funds, the Fund Investors and/or investments or assets held by Clients or the Funds) even though the cost of the underlying expense is borne directly or indirectly by the Clients or their investments and indirectly by the investors in such Fund. Expenses The following is a list of expenses that are typically borne by the Clients directly or indirectly through investments. This list is not intended to be exhaustive, and the expenses borne by various Clients differ from one Client to another. Fund Investors should carefully review the applicable Governing Documents for additional information about the expenses associated with an investment in a particular Client. The amount of expenses is substantial and will reduce the actual investment returns realized by Clients (and indirectly by Fund Investors). Organizational Expenses. In general, each Client bears its own organizational fees and expenses (as defined in the applicable Governing Documents), including generally all legal, accounting, filing and other organizational and offering expenses incurred in connection with the formation of such Client (including as applicable, feeder vehicles that invest in such Client), the applicable General Partner and related vehicles, and the marketing and offering of interests in such Client and related vehicles. Marketing and offering costs generally include but are not limited to placement fees, commissions, travel and travel-related expenses (e.g., accommodations, meals, entertainment), conference fees, events, conference sponsorship, publications and subscriptions. Organizational expenses may be subject to a cap set forth in a Client’s Partnership Agreement, which cap generally provides for an offset against management fees for any organizational expenses in excess of the cap. Subject to the relevant Governing Documents, while Clients do not generally pay discrete fees to Bridge’s affiliated broker-dealer, Apollo Global Securities, LLC (“AGS”), for raising capital in connection with the formation or organization of such Clients, AGS is entitled to expense reimbursement and charges fees, for example, to Clients in connection with coinvestment opportunities and certain other investment opportunities, or to feeder funds that are

Page 13 of 75

Item 5 – Fees and Compensation

managed by persons unaffiliated with Bridge in order for such unaffiliated feeder fund to be provided the opportunity to invest in the applicable Client, among other costs. AGS may also receive fees from investors in certain Clients. Partnership Expenses. In general, each Client bears all expenses related to its own and its related entities ongoing existence and operations, to the extent not paid by or reimbursed by an entity in which a Client invests or a third party, regardless of whether a transaction is consummated (including for transactions that would have been syndicated if consummated), as set forth in further detail in the applicable Governing Documents. Such Partnership Expenses include but are not limited to (i) all costs of management, conduct and operation of the Client and its business or otherwise attributable to the existence of the Client and its related entities (including parallel vehicles, feeder vehicles, alternative investment vehicles and special purpose entities), including fees, costs and expenses relating to the maintenance of registered offices, corporate licensing and similar expenses, (ii) the management fee, organizational expenses, and any acquisition, debt sourcing, development, construction management, fund administration, and other affiliated fees, (iii) all costs and expenses incurred in conducting research and due diligence investigations into, purchasing, acquiring, bidding on, developing, holding, monitoring, negotiating, structuring, hedging, financing and disposing of investments, including costs for financial, legal (whether inhouse or outside counsel), accounting, consulting (including fees, expenses, and applicable overhead related to professionals engaged through APPS) or other advisers or any lenders, brokers, investment banks and other financing sources and other costs and to fees, costs and expenses relating to the maintenance of registered offices, corporate licensing fees in connection with transactions which are not consummated, duplicating, postage, delivery, lodging, travel (including airfare consistent with the Investment Advisers travel policies, which may include business or first class airfare and the use of non-commercial planes), communications charges, and appraisal fees (including obtaining an independent valuation of investments or other assets, where applicable), software licenses and other software fees or costs (including allocations of software licenses and other software fees or costs shared with affiliates of the Investment Advisers, as reasonably determined by the respective General Partner and Investment Adviser), engineering and environmental services, and property and asset management fees and expenses incurred in connection therewith (to the extent not subject to any reimbursement of such costs and expenses by entities in which the Client invests or other third parties), and all costs of any investment-related vehicles including any subsidiary of the Client which elects to be taxed as a REIT, (iv) fees and expenses for accountants, auditors, appraisers, attorneys (whether in-house or outside counsel), tax professionals (whether in-house or outside tax professionals), consultants and other advisors which may include affiliates of Apollo, (v) (A) all out-of-pocket costs and expenses, if any, incurred in researching, developing, conducting due diligence investigations into, negotiating and structuring prospective or potential investments which are not ultimately made, including any legal (whether in-house or outside counsel), accounting, due diligence, advisory, financing and consulting costs and expenses in connection therewith, (B) costs of any proposed co-investment transaction that is not consummated, and including broken deal expenses, diligence and pursuit expenses, and other third-party out-of-pocket expenses, and (C) any deposits or down payments of cash or other property that are forfeited in connection with a proposed investment that is not ultimately made, (vi) sales, leasing and brokerage commissions (including Page 14 of 75

Item 5 – Fees and Compensation

to brokers, dealers, or investment bankers), development fees, loan servicing fees, property management fees and expenses (including marketing expenses and community initiatives or charitable contributions intended to raise the community profile of one or more real estate investments), custodial expenses and other investment costs incurred in connection with investments (including, without limitation, costs related to field inspection, rehabilitation, title and closing), (vii) principal, interest on and fees and expenses arising out of all borrowings made by the Client or its subsidiaries, including the arranging thereof, (viii) the costs of any fidelity bond or similar insurance and the costs of any litigation, D&O liability or other insurance and indemnification or extraordinary expense or liability relating to the affairs of the Client, including the amount of any judgments, settlements or fines paid in connection with any litigation, governmental inquiry, investigation or proceeding involving the Client, the respective General Partner, Investment Adviser or their respective affiliates or other indemnitees, except to the extent such expenses or amounts have been determined to be excluded from the indemnification provided for in the Governing Documents, (ix) any taxes, fees or other governmental charges levied against the Client (including out-of-pocket expenses with respect to the Client’s legal and regulatory compliance (whether in-house or outside counsel)) and all expenses incurred in connection with any tax audit, investigation, settlement or review of the Client or associated with its administrative, reporting, monitoring, research or research-related costs, including its annual meeting expenses and costs associated with its financial statements and tax returns (whether inhouse or outside tax professionals), including the expenses of the Client’s fund administrator (which is generally an affiliate of the Investment Adviser), and including costs of the representation of the Client or the applicable Fund Investors by the partnership representative or designated individual (but any taxes, fees or charges levied in respect of or otherwise in connection with any specific Fund Investor(s) or allocated to Fund Investors pursuant to the Governing Documents will be charged solely against the interest of, or reimbursed by, such Fund Investor), (x) other governmental or regulatory charges, and regulatory and legal fees and expenses (and damages) of the Client and its affiliates in connection with ongoing compliance, filings and reporting obligations under the Advisers Act (including the cost of preparing any notices or reports the Investment Adviser is required to prepare as a result of its relation to the Clients and intended or actual operations), the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”), “blue sky,” or any other applicable laws, including filing fees and expenses and expenses related to the preparation of regulatory filings, or incurred in connection with any litigation or governmental inquiry, investigation or proceeding involving or in relation to the Client or its affiliates, (xi) legal, compliance, regulatory, custodial, depositary, Swiss representative and paying agent and other fees and expenses attributable to or associated with the requirements of the Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers and any national private placement regimes; (xii) costs in connection with the Client’s financial statements, reports, notices, tax returns, Schedule K-1s (or similar schedules), other costs of reporting to or otherwise communicating with Fund Investors (whether in-house or outside tax professionals), including expenses incurred in connection with providing the Fund Investors access to a database or other forum hosted on a website designated by the respective General Partner, (xiii) the expenses of any Limited Partner Advisory Committee (“LPAC”) (including expenses of voting and non-voting members) and meetings of one or more Fund Investors, (xiv) costs associated with the winding up, termination, dissolution or liquidation Page 15 of 75

Item 5. Fees and compensation

of the Client, the General Partner or any of their related vehicles (including any parallel vehicle, feeder vehicle, alternative investment vehicle or special purpose entity), (xv) costs of enforcement related to defaults by Fund Investors in the payment of any capital contributions, (xvi) any restructuring, modifications, revisions or amendments to the constituent documents of the Client and related entities, including the respective General Partner, Investment Adviser, any parallel vehicles, feeder vehicles, alternative investment vehicles and special purpose entities, (xvii) hedging transactions for the Client, (xix) expenses incurred in

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connection with compliance with side letters, (xx) fees, costs and expenses incurred in connection with retaining, meeting or otherwise engaging with property brokers and other third parties in connection with sourcing, acquiring, financing, disposing of or otherwise managing investments for Clients, including out-ofpocket costs in respect of the foregoing (including travel consistent with the Investment Advisers travel policies), meals, gifts and entertainment expenses, (xxi) other extraordinary, nonrecurring matters, and (xxii) any other costs and expenses of the Client and related entities, including the respective General Partner, Investment Adviser, any parallel vehicles, feeder vehicles, alternative investment vehicles and special purpose entities, and such other fees (to the extent not otherwise addressed in the Governing Documents) as may be approved by the LPAC or otherwise pursuant to the Governing Documents. Out-of-pocket expenses associated with completed transactions are generally capitalized as part of the acquisition price thereof. Expense Allocation. Expenses are generally borne pro rata by Fund Investors in the applicable Client. From time to time, there are certain fees, costs and expenses incurred for the account or benefit of more than one Client. Under these circumstances, each Client will typically bear an allocable portion of any such fees, costs or expenses in proportion to the relative size of the Client, commitment to the activity or entity to which such expense relates, or in such other manner as the Investment Adviser or Bridge considers fair and equitable under the circumstances in its discretion, in each case, subject to the terms of the respective Governing Documents. Such allocations take into account a variety of considerations and will vary depending on the type of expense, including, without limitation, allocations based on assets under management, net asset value, holdings percentages, number of positions held by different funds and accounts, number of funds and accounts in a particular strategy, number of users of such resource within a strategy and estimates on time spent relating to a particular Client. Despite the good faith judgment of the Investment Advisers and their respective affiliates to arrive at a fair and reasonable expense allocation methodology, the use of any particular methodology may lead one Client to bear relatively more expense in certain instances and relatively less in other instances compared to what such Client would have borne if a different methodology had been used to allocate such expenses. From time to time, the Investment Advisers may revise or change previously determined allocation methodologies in an effort to ensure that such expenses remain fairly and equitably allocated among the Clients. The Clients are generally not responsible for the Investment Advisers’ normal and recurring routine operating expenses of managing the Client, including compensation of employees, rent, utilities and other expenses of management (but not including any “partnership expenses” or “organizational expenses,” as such terms are defined in the applicable Governing Documents).

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Item 6 – Performance-Based Fees and Side-by-Side Management

Multiple Layers of Fees and Expenses for Certain Clients Fund Investors in Clients that make secondary investments in private fund interests bear their share of multiple distinct layers of management fees, carried interest, performance fees or performance allocations, and expenses. Because such Clients invest in fund of fund interests, Fund Investors would bear their share of three distinct layers of fees and expenses with respect to those fund of fund investments. This includes one layer of fees and expenses associated directly with the management of such Client by the applicable Investment Adviser, a second layer of fees and expenses associated with the underlying fund of fund managers and sponsors, and a third layer of fees and expenses associated with the underlying fund managers and sponsors selected by the underlying fund of funds managers and sponsors. In the event that an Apollo Client invests in a Client, subject to the Governing Documents of the investing Apollo Client, to the extent the Governing Documents of the Client require the investing Apollo Client to bear Management Fees but provide for an offset thereto in respect of all or a percentage of the “transaction fees,” or other substantially similar offsetable amounts in accordance with such Governing Documents and receivable by Bridge, such offsetable amounts will, with respect to the investing Apollo Client, be treated in a manner in accordance with the Governing Documents of the Client. No such offset will apply with respect to any “transaction fees,” or substantially similar amounts if the applicable Governing Documents do not require such an offset or the investing fund is not bearing Management Fees with respect to such investment and fees paid to affiliates will not constitute offsetable amounts and will be retained by Bridge. Furthermore, to the extent any fee offsets at the level of a Client would exceed the amount of Management Fees otherwise payable by the investing Apollo Client with respect to such Client, the investing Apollo Client will not, and no investor of such investing Apollo Client will be given the opportunity to elect to, receive any such excess offset amounts. Clients should refer to the applicable Governing Documents for more details regarding fees and expenses that apply to a particular Client. Item 6 – Performance-Based Fees and Side-by-Side Management Performance-Based Fees Our General Partner entities are generally entitled to receive performance-based fees from Clients in the form of incentive fees, carried interest, performance fees or performance allocations, which are generally calculated as a percentage of the profits earned during a defined performance period, subject to performance thresholds set forth in the applicable Governing Documents. These performance-based fees are structured to comply with Rule 205-3 under the Advisers Act. Any performance-based fees are separate and distinct from any management fees charged to Clients for advisory or investment management services or any transaction-based or other affiliate fees charged to Clients. Performance-based fees can create incentives for the General Partner entities to recommend investments to Clients that could be riskier or more speculative than those that would be Page 17 of 75

Item 6. Performance-based fees and side-by-side management

recommended under different fee arrangements. Performance-based fees that include a “catchup” provision creates a conflict of interest that could impact the timing of dispositions of investments. For example, if investments held by a Client were performing at or near the preferred return, the General Partner would be incentivized to continue to hold the investments because a significant portion (or all) of the additional return would be paid to the General Partner as carried interest pursuant to the “catch-up” provisions.

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The applicable Investment Adviser or General Partner may waive or reduce all or any portion of any fee, including the incentive fee, carried interest, performance fee or performance allocation in its sole discretion with respect to certain investors, including Fund Investors affiliated with the Investment Adviser or its affiliates (including employees, owners, business associates, and certain family and other relationships). Side-by-Side Management The Investment Advisers provide concurrent management services on both a discretionary and non-discretionary basis to Clients, which in some cases have similar or overlapping investment mandates but differing compensation and fee arrangements. Affiliates of the Investment Advisers also provide concurrent management services to Apollo Clients which could have similar overlapping investment mandates and/or compete with Clients. Capital deployments into investments of similar asset classes are generally subject to limitations in the applicable Governing Documents. However, the Investment Advisers are not necessarily prohibited from pursuing the investment by multiple Funds into the same investment. Please refer to the Governing Documents of each Fund for further details. There are diverse groups of Fund Investors within each Fund and there is potential for a conflict of interest to arise in connection with different fee structures applicable to investments of the Clients of the Investment Advisers. The potential for the Investment Advisers and their affiliates to receive greater fees from certain Clients creates a conflict of interest with respect to the allocation of investment opportunities. The Investment Advisers seek to address this allocation conflict of interest by maintaining an investment allocation policy designed to assist the Investment Advisers in allocating investment opportunities between and/or among Clients in a fair and equitable manner over time in accordance with the allocation policy, each Investment Adviser’s fiduciary obligations to Clients, and consistent with the corresponding investment mandates of each Client set forth in the Governing Documents. Where Apollo Clients have similar or overlapping investment mandates, Apollo’s affiliated investment advisers have adopted an allocation policy designed to assist in allocating investment opportunities between or among Apollo Clients and Clients in a fair and equitable manner over time. The classification of an investment opportunity as appropriate or inappropriate for a particular Client will be made by the applicable General Partner or the Investment Advisers and their respective affiliates, in good faith, at the time of purchase. This determination frequently will be subjective in nature and may ultimately prove to have been more appropriate for another Client. There can be no assurance that the application of these policies and procedures will result in fair or equitable allocation of, or participation in, investment opportunities, or comparable performance of investments allocated to one Client as compared to another.

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Item 7 – Types of Clients

Item 7. Types of clients

The Investment Advisers generally provide investment advice to various commingled investment funds and other vehicles, joint venture projects, separately managed accounts, and alternative investment vehicles, including any parallel and feeder investment vehicles (each, a “Fund” and collectively, the “Funds”). The Investment Advisers also serves as manager of various vehicles on a non-discretionary basis or co-investment vehicles structured to facilitate participation by thirdparty co-investors in certain investments, including investments alongside its Clients (“CoInvestors” and with the Funds, each a “Client”). Investment advice is provided directly to the Clients, subject to the discretion of the applicable General Partner, and not individually to Fund Investors.

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Fund Investors include high-net-worth individuals, banks or thrift institutions, other investment entities, endowments, foundations, sovereign wealth funds, family offices, government or private pension and profit-sharing plans, trusts, estates or charitable organizations or other corporations or business entities and include, directly or indirectly, principals or other employees of the Investment Advisers and their affiliates. Fund Investor Qualifications and Minimum Investments Fund interests are generally offered and sold only to investors that are (i) “accredited investors” as defined in Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), (ii) “qualified clients” as defined under the Advisers Act, and (iii) “qualified purchasers” as defined in Section 2(a)(51)(A) of the Investment Company Act of 1940, as amended (the “Investment Company Act”), or “knowledgeable employees” of Bridge as defined in Rule 3c-5 under the Investment Company Act. Minimum initial investment requirements vary by Client but generally range from $250,000 to $5 million. Please see each Client’s Governing Documents for the minimum initial investment requirement applicable to such Client. The applicable General Partner, in its sole discretion, has waived, and is expected in the future to waive on occasion, the minimum initial investment requirements for a particular Client, Fund or Fund Investor. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies The Investment Advisers perform extensive due diligence, analysis and evaluation of each investment opportunity when formulating investment advice for, or managing assets of, Clients. Each Investment Adviser has a specialized and operationally driven investment team responsible for deal sourcing, acquisitions and asset management across our strategies. The investment process employs collaboration across Investment Advisers, enabling each Investment Adviser to leverage local market knowledge and provide a holistic underwriting of each investment. Each Investment Adviser’s investment process generally utilizes rigorous and data-driven analytics to focus investment activity in markets that it believes exhibit strong growth potential. The Investment Advisers strategies generally focus on real estate equity and debt investments and renewable energy infrastructure investments in select sectors of the United States real estate market, particularly in submarkets that the Investment Advisers believe support attractive, riskPage 19 of 75

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

adjusted investments in residential housing, multifamily communities, workforce and affordable housing communities, logistics properties, commercial office buildings and seniors housing communities. Certain Investment Advisers also focus on secondary investments in private fund interests. The Investment Advisers tailor their advisory services to the strategy of each Client as set forth in the applicable Governing Documents. Real Estate Equity Strategies The Investment Advisers have deep experience in all parts of the real estate investment process and the key states of the investment process for real estate related equity strategies are as follows:

Sourcing: The Investment Advisers have extensive experience and have built reputations for property acquisition, investment management, property management, development, and financing. Because of the reputation and the success of past projects, the Investment Advisers have developed strong relationships with all of the types of transaction sources across the market. Key sourcing relationships for real estate equity strategies include institutional property owners, REITs, broker networks, banks and non-bank financial institutions, and investment managers. The Investment Managers vertically integrated structure also is a strong driver of unique and off-market investment opportunities, by virtue of local market connectivity and operating presence, providing access to investment opportunities that are in many cases proprietary. The Investment Advisers believe that these relationships and vertically integrated structure provide compelling access to attractive deal flow.

Analyzing and Acquiring: The Investment Advisers implement longstanding and consistent investment policies and procedures across real estate equity strategies and the Investment Committee for each strategy reviews each investment at numerous points in the analyzing and acquiring process. Once a property has been initially screened and the preliminary due diligence and underwriting have been completed, a transaction is submitted to the Investment Committee for consideration. Upon receipt of approval from the Investment Committee, the Investment Adviser or an affiliate will negotiate a letter of intent with the seller and will work with legal counsel to negotiate the applicable legal agreements. Upon completion of this negotiation, the Investment Advisers will complete the due diligence procedures, which include negotiation of the legal agreements, physical analysis reports, competitive market analysis, market and demographic trends, and design the business plan for the investment.

Managing and Leasing: The Investment Advisers believe that one of the most important success factors in real estate investment is the proper execution of the business plan at the property level. Having a fully integrated platform provides access to asset and portfolio managers, accounting, information technology and support staff. Frequent communication and detailed reporting as a standard practice allows for standards to be consistent across assets and markets.

Improving: The Investment Advisers seek to improve and add value to properties. In most cases, the bulk of value created for Funds is driven by unique value creation strategies and Page 20 of 75

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

superior execution. For example, the Investment Advisers seek to implement improvements that create value through increased tenant satisfaction, occupancy, rent growth and collections, as well as reduced downtime.

Selling: The Investment Advisers seek to identify potential exit strategies prior to the initial acquisition of an investment and seek to obtain the highest value when exiting its investments by (a) establishing a disposition team that will select the best method for marketing the property; (b) oversee preparation of the sales package, and (c) work with a selected broker to design and implement the most effective market and advertising strategy.

Real Estate Debt Strategies The Investment Advisers have a team of highly experienced and qualified personnel who belong to cross-disciplinary teams responsible for all stages of the investment process for our real estate debt strategies, the key stages of which are as follows:

Sourcing: Investment sourcing for our real estate debt strategies is driven by our long-term partnerships with Fannie Mae and Freddie Mac, which creates opportunities for us for direct investment in Fannie Mae mortgage-backed securities and Freddie Mac K-Series investments, often bypassing auction processes. The Investment Advisers extensive relationships with capital markets desks enable sourcing of credit market opportunities across real estate debt investments, and broad broker connectivity enables identifying financing opportunities and/or purchases of mezzanine / preferred equity positions. The local market presence of the Investment Advisers affiliates and vertically integrated structure generates incremental investment opportunities for direct lending.

Due Diligence / Closing: For loan and securities investments, the Investment Advisers employ detail-oriented, rigorous review processes to analyze all potential investments, including review of all available loan-level information, analysis of property performance and competitive set, evaluation of the strength of the borrower and review of the borrower’s background and experience, and review of appraisal, environmental and engineering reports, if/as available.

Asset Management: The Investment Advisers’ investment teams continuously monitor all debt portfolio investments, including review of servicer reports and watchlists, market research, asset review and periodic asset management meetings, and in addition, the property management affiliates will assist in the event of foreclosure or restructure.

Exit Strategy: The Investment Advisers implement and review a range of exit strategies for each debt investment, including sale, hold to maturity or structured exit. The Investment Advisers benefit from in-house securitization and capital markets expertise and undertake a regular review of exit strategies as part of the asset management process.

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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

Renewable Energy Infrastructure Investments The Investment Advisers have a team of highly experienced and qualified personnel who belong to cross-disciplinary teams responsible for all stages of the investment process for our renewable energy infrastructure strategy, the key stages of which are as follows:

Sourcing: Investment sourcing for our renewable energy infrastructure investments is driven by relationships within the commercial real estate and solar sectors that are expected to serve as sources of potential solar development opportunities. The Investment Advisers expect to seek and source deal opportunities in commercial real estate owned by other Clients, properties owned by large real estate owners and other strategic business relationships.

Analyzing, Underwriting and Managing Bid Process: The Investment Advisers employ a diversified mix of both bottom-up and top-down analytical methodologies covering solar productivity, local incentive/regulatory environments, real estate markets and macroeconomic trends to evaluate renewable energy investments. The Investment Advisers utilize certain software and construction management experience to manage the contractor bid and construction process for the applicable projects.

Asset Management: The Investment Advisers’ investment teams manage and operate renewable energy arrays or selectively pursue sale-leaseback transactions where appropriate to monetize certain additional tax incentives. The Investment Advisers maintain continuous monitoring of all investments, including retaining and monetizing solar credits, operations and maintenance plans and completing repairs as needed.

Exit Strategy: The Investment Advisers implement and review a range of exit strategies for each investment, including asset sales either as a portfolio to renewable energy investors, as individual assets to building owners or as another structured exit.

Secondary Investments in Private Fund Interests The Investment Advisers have a team of highly experienced and qualified personnel responsible for pursuing negotiated small and mid-sized secondary transactions in private fund interests. This team employs a value- focused approach to pricing transactions through fundamental portfolio analysis and reviews the underlying investments in the portfolios it evaluates, leveraging its database of information and network of industry contacts to perform due diligence. The key stages of the investment process are as follows:

Sourcing: Investment sourcing for secondaries investments focuses on identifying high quality investment opportunities in non-competitive situations. Deal sourcing generally occurs in a number of ways, including but not limited to, on-going contact with existing networks, participating in annual meetings of its private equity funds, responding to inbound inquiries from potential sellers, and the occasional use of and payment to thirdparty finders.

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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

Negotiation: The investment team engages with sellers throughout the transaction process, from initial contact to final pricing and execution. The engagement enables insight into the key issues and motivations facing sellers, establishes personal relationships with the important decision makers and secures valuable information about the underlying assets.

Portfolio Due Diligence: The investment team conducts a review of the underlying investment positions in the private equity funds it evaluates, leveraging its database of information and network of industry contacts to perform due diligence.

Disciplined Valuation and Approval Process: The investment team constructs cash flow models for the private equity funds and transactions it evaluates (including direct investments (co- investments) in operating entities and companies). This analysis provides assessments of a private equity fund’s current value and projected returns (value and timing) by investment, while factoring in underlying fees, expenses and carried interest to scrutinize potential returns against the risks and overall concentrations.

Focus on Transaction Execution: The investment team focuses senior level resources on completing transactions as efficiently as possible.

Risk of Loss Investing in securities involves a risk of loss that the Client and Fund Investors should be prepared to bear. There are numerous risks involved for each investment made by each Client and any applicable Fund Investors, and such risks are identified and described in detail within the applicable Governing Documents. There can be no assurance that any Client will be able to achieve its investment objectives or generate returns, or that any such returns will be commensurate with the risks of investing in the types of transactions described in the applicable Governing Documents. Accordingly, the following is not an exhaustive list or description of the risks involved, but rather is a summary of such risks intended to be supplemented by reference to the applicable Governing Documents. Investments by and in the Clients of the Investment Advisers entail a high degree of risk and such investments are suitable only for sophisticated individuals and institutions for whom an investment with the Investment Advisers does not represent a complete investment program and who fully understand and can bear the risks of such an investment, including a loss of some or all capital invested. Clients and Fund Investors should carefully consider, among other factors, the risk factors found in the applicable Governing Documents and in this Brochure when determining whether an investment is suitable. Prior to making any investment decision, a Fund Investor should consult with its attorney and its investment, accounting, regulatory and tax advisors to determine the consequences of an investment and arrive at an independent evaluation of such investment, including the applicability of any legal investment restrictions. There can be no assurance that the particular Fund or investment will be able to achieve its investment objectives, and investment results vary substantially on an annual basis. Past performance is not indicative of future results. While the discussion below often refers to a “Fund” or the “Funds,” it enumerates certain risk factors that apply generally to an investment in a Fund as well as to the Clients generally. Page 23 of 75

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

Restrictions on Transfer and Withdrawal. Interests in the Clients have not been registered under the Securities Act, the securities laws of any United States state, or the securities laws of any other jurisdiction, and therefore, cannot be sold unless they are subsequently registered under the Securities Act and other applicable securities laws or an exemption from registration is available. It is not expected that registration under the Securities Act or other securities laws will ever be affected. Interests may only be offered, sold or transferred to individuals or entities that are qualified investors under applicable securities laws. Furthermore, there is no public market for the interests in the Clients, and none is expected to develop. Each Fund Investor will be required to represent that it is a qualified investor under applicable securities laws and that it is acquiring its interest for investment purposes and not with a view to resale or distribution. Each Fund Investor must be prepared to bear the economic risk of an investment for an indefinite period of time. Generally, a Fund Investor will not be permitted to assign, sell, exchange or transfer any of its interest, rights or obligations with respect to its interest, except by operation of law, without the prior written consent of the General Partner, which consent may be withheld in the sole and absolute discretion of the General Partner. Except in extremely limited circumstances or openended funds, voluntary withdrawals from a Client will not be permitted. Secondary Transfers of Partnership Interests. To the extent that a General Partner has discretion over a secondary transfer of interests in a Client pursuant to the Governing Documents and subject to any restrictions therein, the General Partner could identify a limited number of persons to potentially acquire the interest being transferred, including (i) investors in one or more Clients; (ii) individuals and entities that are not investors in any Clients (but could in the future become investors in Clients); (iii) one or more affiliates of the Investment Advisers, including Apollo; and/or (iv) Apollo Clients (including funds that primarily engage in the purchase of fund-related interests in the secondary market), and could take into consideration a variety of factors as it deems necessary in exercising its discretion with respect to a secondary transfer of interests in a Client. To the extent one or more affiliates acquires an interest in a Client via a secondary transfer, conflicts of interest could arise such as: (i) an additional layer of fees and incentive compensation in the case of an acquisition by another Client; (ii) the acquiror of such interests would have additional information about the interests being purchased (including the fact that a Fund Investor is seeking to sell or dispose of its interests) compared to third parties interested in such acquisition, which could allow such affiliate to offer a more competitive or informed offer to acquire such interests; (iii) an increased indirect economic investment for the affiliates of the Investment Advisers that could impact the portfolio management of the Client; and (iv) an incentive to adjust the portfolio management of the Client in a manner that is primarily for the benefit of the purchaser in the secondary transfer. Moreover, there is an ongoing trend in the private equity industry of fund sponsors offering liquidity to investors in existing funds through a structured or stapled secondary process where purchasing investors would, as a condition to participating in such purchase from existing investors, also make a commitment to a new fund being raised. The Investment Advisers could be incentivized to engage in such a process for one or more of its existing Clients (or any investments therein) to the extent doing so could be expected to improve the Investment Adviser’s ability to raise a successor fund to such fund and to form and attract capital to existing or future other Clients (e.g., by securing an agreement from the purchasing investors participating in the process to make commitments to such funds or, more generally, by Page 24 of 75

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

positively impacting the performance information for the relevant fund that is presented to prospective investors). No Assurance of Investment Return. A Client’s General Partner and Investment Adviser cannot provide assurance that they will be able to choose, make, and realize investments in any particular type of investment. There can be no assurance that any Client will be able to generate returns for the applicable Fund Investors or that the returns will be commensurate with the risks of investing in the type of assets, securities, or transactions applicable to the Client’s strategy. There can be no assurance that any Fund Investor will receive any distribution from the Client. There is no assurance that any benefits or advantages to Fund Investors suggested or implied in the applicable Governing Documents will be available or accomplished. There can be no assurance that projected or targeted returns for any Client will be achieved. Accordingly, an investment in a Client should only be considered by persons who can afford a loss of their entire investment. Substantial Fees and Expenses. Clients typically pay Management Fees, organizational expenses, and Operating Expenses as set forth in their governing documents and/or fee agreements, whether or not they make any profits, as well as performance-based compensation if they make profits. While it is difficult to predict the future fees and expenses of the Clients, such fees and expenses could be substantial. See Item 5 for additional information on fees and expenses. Enhanced Regulatory Scrutiny and Regulation. The Investment Advisers are subject to extensive regulation, including periodic examinations by governmental agencies and self-regulatory organizations or exchanges in the U.S. and foreign jurisdictions where they operate. Each of these regulatory bodies with jurisdiction over the Investment Advisers or their affiliates has significant regulatory powers over the business of the Investment Advisers, including the authority to grant, cancel, delay or prohibit the Investment Advisers ability to carry on certain activities. Possible disciplinary actions include the suspension of individual employees, limitations on engaging in certain lines of business for specified periods of time, revocation of investment adviser or other registrations, censures and fines. These regulatory requirements are evolving. Any failure of the Investment Advisers to comply with these rules and regulations could expose the Investment Advisers and the Clients to liability or other risks. Additionally, due to the fact that Apollo is a publicly traded company with many different asset management and advisory businesses that operate on a global basis, the Investment Advisers may be subject to increased scrutiny and greater regulatory oversight than would be the case absent the Apollo relationship. Furthermore, increased regulatory oversight of Bridge and its affiliates (including Apollo) may impose additional requirements and administrative burdens on Bridge, including, without limitation, implementing new policies and procedures and complying with reporting obligations. Bank Deposit Risks. Clients make deposits in regulated financial institutions, which include national, regional and community banks. The solvency of national, regional and community banks are affected by many factors including changes in interest rates, economic and political conditions, broad trends in business and finance, bank regulation and legislation, monetary and fiscal policies, inflation, market conditions, and confidence in the safety and soundness of the banking system or a specific institution. National, regional and community banks are affected by many risks,

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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

including: (i) liquidity risk where a bank’s management fails to ensure that sufficient funds are available to meet demands of capital providers, depositors, as well as borrowers; (ii) asset quality and credit risk attributable to a bank’s assets based on the creditworthiness of borrowers as well as the value of the assets securing such loans; (iii) capital risk if a bank fails to maintain appropriate capital reserves to serve as a cushion against losses; (iv) earnings risk if a bank fails to generate sufficient earnings to support asset growth, provide for loan losses, and/or support its ability to pay dividends to stockholders; (v) management risks if a bank’s management incorrectly identifies, measures, monitors and/or controls the risks of a bank’s activities to ensure safe, sound, and efficient operation in compliance with applicable laws and regulations; (vi) litigation risks due to the volume of claims and amount of damages and penalties sought in any litigation and regulatory proceedings against financial institutions; (vii) market risks directly and indirectly attributable to changes in market conditions including fluctuations in interest rates, equity and futures prices, changes in the implied volatility of interest rates, and price deterioration or changes in value of long-term assets due to changes in market perception or actual credit quality; (viii) market competition resulting in a bank’s rapid loss of customers and deposits to larger banks or financial institutions which are perceived to offer more competitive interest rates and/or greater safety and stability; (ix) monetary policy risks attributable to net interest margin requirements in a volatile interest rate environment; and (x) regulatory risks attributable to violations of or changes in various state and federal banking regulations which have a negative adverse impact on such institutions. Any deposits made to a depository institution are subject to risks that losses may occur if the depository institution fails and the amounts on deposit are not adequately insured. In light of interest rate volatility, certain banks may be subject to greater than average risk of failure. In the event of any bank failure there are risks that the Clients may experience losses, including a loss of certain funds in excess of applicable FDIC insurance limits which have been deposited with any insured bank. Moreover, in periods of economic stress, the bank default rate may increase, which may have an adverse effect on deposits available to the Clients from any bank. Pay-to-Play Laws, Regulations and Policies. The SEC, as well as certain U.S. state and local governments or agencies, have adopted ‘‘pay-to-play’’ laws and regulations which restrict the political activities of investment managers that seek investment from, or manage funds on behalf of, state and local government entities. Such restrictions can include limits on the ability of the investment managers to make political contributions to, fundraise for, or provide gifts or entertainment to, certain state and local candidates, officials and political organizations, as well as obligations to make regular disclosures about such political activities to federal, state or local regulators and to use only parties that are subject to equivalent political activity restrictions in soliciting investment from state and local government entities. The SEC’s pay-to-play rule for the Investment Advisers imputes the personal political activities of certain executives and employees, and in some instances their spouses and other immediate family members, to the Investment Advisers for purposes of potential pay-to-play liability. Violation of pay-to-play laws can lead to the loss of management fees, rescission of current commitments and a loss of future investment opportunities. Issues involving pay-to-play violations and alleged pay-to-play violations often receive substantial media coverage and can result in regulatory inquiries from federal, state or local regulators. A failure to comply with the applicable

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pay-to-play laws, regulations or policies by the Investment Advisers or a party acting on their behalf could have an adverse effect on the Clients. AIFMD. The European Union (“EU”) Alternative Investment Fund Managers Directive (“AIFMD”) imposes requirements on alternative investment fund managers (each, an “AIFM”) that market alternative investment funds (“AIFs”) to professional investors within the European Economic Area (“EEA”). Countries within the EEA also have specific local requirements for marketing AIFs into their jurisdiction through national private placement regimes or other regulations. The General Partner of certain Clients has formed parallel AIFs in Luxembourg primarily to facilitate the participation of investors in the EEA under the AIFMD. A third-party AIFM has been engaged to act as an EEA AIFM with respect to certain Clients. Control over portfolio management and certain other functions are retained by the Investment Advisers. These Clients are in scope of the AIFMD requirements to varying degrees, including rules relating to restrictions on the use of leverage, requirements in relation to liquidity, risk management, and valuation of investments. These regulations could create a conflicting regulatory regime with the Clients based in the United States, and such conflict could make it more difficult for the Investment Advisers to achieve their investment objectives. Compliance with these AIFMD and other EU regulations could materially increase the costs to the Clients, and failure to comply with such regulations could expose the Investment Advisers and the Clients to liability or other risks. Illiquid Investments. Certain Clients intend to invest in real estate properties, real estate businesses, and preferred equity and debt obligations secured by real estate properties for which the number of potential purchasers and sellers, if any, is often very limited. Further, there is no established market for secondary investments in private funds. This factor may have the effect of limiting the availability of these investments for purchase by the Client and may also limit the ability of a Client to adjust its investing strategy in response to adverse changes in the performance of investments or changes in economic or market trends. As a result of these Clients’ illiquid investments, there may be little or no near-term cash flow available to the investors. Consequently, dispositions of such investments may require a lengthy time period or may result in distributions in kind to the Investors. Additionally, the realizable value of a highly illiquid investment may be less than its intrinsic value. The liquidity of certain portfolio investments will depend on the liquidity of the applicable market which, in some cases, could be adversely impacted by the secondary market trading activities of Bridge’s affiliates. Dilution from Additional Closings. Fund Investors that are admitted or increase their capital commitment at subsequent closings will generally participate in existing investments of a Client, diluting the interest of existing Fund Investors that do not determine to increase their capital commitment. Although Fund Investors will contribute their pro-rata share of previously funded contributions (plus an additional amount thereon), there can be no assurance that this payment will reflect the fair value of a Client’s existing investments at the time such additional Fund Investors subscribe for interests in the Client. Recycling; Reinvestment. During a Client’s commitment period, proceeds distributable (or previously distributed) to the Fund Investors that constitute a return of capital contributions may

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be retained and reinvested (or recalled for reinvestment) or recalled for use for any purpose permitted under the applicable Governing Documents. Accordingly, a Fund Investor may be required to fund an aggregate amount in excess of its capital commitment during the term of the Client, and to the extent such recalled or retained amounts are reinvested in investments, a Fund Investor will remain subject to investment and other risks associated with such investments. Mandatory Withdrawal. Under certain circumstances, a Client’s General Partner may require a Fund Investor to withdraw from the Client. A Fund Investor required to withdraw from the Client could suffer a material loss on its investment, and the other Investors may be required to make additional pro rata contributions of capital in respect of investments made after such withdrawal, subject to certain limitations in the Governing Documents. Early Termination. It is possible that a Client may be dissolved and terminated prematurely, and as a result, may not be able to accomplish its objectives and may be required to dispose of its investments at a disadvantageous time or make an in-kind distribution (resulting in Fund Investors not having their capital invested and/or deployed in the manner originally contemplated). General Economic and Market Conditions. The real estate industry generally and the success of a Client’s investment activities will both be affected by general economic and market conditions, as well as by changes in laws, currency exchange controls, and national and international political and socioeconomic circumstances. These factors may affect the level and volatility of investment prices and the liquidity of a Client’s investments, which could impair the Client’s profitability or result in losses. In addition, general fluctuations in interest rates may affect a Client’s investment opportunities and the value of the Client’s investments. A sustained downturn in the United States or global economy (or any particular segment thereof) could adversely affect a Client’s profitability, impede the ability of a Client’s portfolio entities to perform under or refinance their existing obligations and impair a Client’s ability to effectively exit its investments on favorable terms. In particular, volatility in global markets related to movement in interest rates in the United States and global trade tensions (including any trade tensions between the United States and its major global trading partners, such as China, Mexico, Canada and the EU) may have a material adverse effect on the volatility of investment prices and the liquidity of a Client’s investments, as well as global economic conditions generally. General Real Estate Risks with Respect to Equity Investments. Certain Client’s investments will be subject to the risks incident to the acquisition, development, ownership and operation of real estate and risks incident to the making of recourse and nonrecourse loans secured by real estate. Deterioration of United States real estate fundamentals will negatively impact the performance of a Client. Real property investments are subject to varying degrees of risk, including changes in general or local economic conditions, interest rates, availability of mortgage funds, real estate taxes and other operating expenses, environmental changes, acts of God (which may result in uninsured losses), local employment conditions, domestic and foreign competition, and other factors, which are beyond the control of a Client, its General Partner and its Investment Adviser. Real estate values are affected by a number of factors, including (i) changes in the general economic climate, (ii) local conditions (such as an oversupply of space or a reduction in demand

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for space), (iii) the quality and philosophy of management, (iv) competition based on rental rates, (v) attractiveness and location of the properties, (vi) financial condition of tenants, buyers and sellers of properties, (vii) quality of maintenance, insurance and management services and (viii) changes in operating costs. Real estate values are also impacted by government regulations (including those governing usage, improvements zoning and taxes), interest rate levels, the availability of financing, and potential liability under changing environmental and other laws. General Real Estate Risks with Respect to Debt Investments. Certain Client’s investments consist of debt and equity securities in entities that derive their cash flow and value from the performance of underlying real estate properties. The cash flow, value and marketability of real estate is subject to a number of factors, including, among others, changes in the general economic climate, local conditions (such as an oversupply of space or a reduction in demand for space), the quality and philosophy of the managers of the properties, competition based on rental rates, attractiveness and location of the properties, financial condition of tenants, buyers and sellers of properties, quality of maintenance, insurance costs, changes in operating costs, changes in government regulations (including those governing usage, improvements zoning and taxes), interest rate levels, the availability of financing and potential liability under changing environmental and other laws. In certain circumstances, those Clients may be required to foreclose upon collateral and become the direct owner of real estate and subject to additional real estate related risks. Uninsured Losses with Respect to Equity Investments. Certain Clients maintain insurance coverage against liability to third parties and property damage as is customary for similarly situated businesses. However, there can be no assurance that insurance will be available or sufficient to cover any such risks. There are certain types of losses (generally of a catastrophic nature such as those caused by fire, flood, freeze, hail, hurricanes, drought, severe frost, disease, pests, riots and wars) that are uninsurable, not fully insurable or not insurable on economically feasible terms. If such losses occurred to the investment assets, a Client could lose both its invested capital and profits anticipated therefrom, and the respective Fund Investors could lose their investment, except for the residual value, if any, of the underlying real estate remaining after such event. Even if such catastrophic events do not directly impact equity investments owned by Clients, insurance premiums could increase in all markets, indirectly impacting insurance costs or coverage levels with respect to investments owned by Clients. For example, while the catastrophic wildfires in California during January 2025 did not directly impact equity investments owned by Clients, we anticipate nationwide impacts to insurance premiums and coverage from insurance companies due to the significant losses related to the California fires. Uninsured Losses with Respect to Debt Investments. For Clients that make debt investments, including direct lending, it is anticipated that such Client’s borrowers will maintain insurance coverage against liability for personal injury and property damage. However, there can be no assurance that such insurance will be sufficient to cover any such liabilities. Insurance against certain risks, such as earthquakes or floods, may be unavailable, or available only in amounts that are less than the full market value or replacement cost of the applicable collateral. In addition, there can be no assurance that particular risks, which are currently insurable, will continue to be insurable on an economical basis or that current levels of coverage will continue to be available

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on an economical basis. Should an insured or underinsured loss occur, such Client could lose its investment as well as anticipated income from such investment. Maintenance Costs. The cost of maintaining investment assets is substantial. A Client generally plans for adequate working capital to maintain the assets it holds as investments; however, if circumstances change or if the Client’s projections prove inaccurate, the Client may not have sufficient working capital to maintain the investments properly and the investments could lose value. Maintenance costs can vary substantially based on market and other factors, and any changes in these market factors could have a materially negative impact on the maintenance of these investments, and in some cases, on the value of such investments. Ability to Resell Real Estate Assets; No Assurance of Appreciation or Profits. The resale potential of real estate investments will be affected by those conditions that affect the value of real estate and markets in general, including the possibility of increased interest rates, declining real estate values, low demand for various types of real estate, changes in demographics, changes in tax laws affecting real estate owners, competition from other properties located in the area, zoning changes, or unfavorable general or local economic conditions. Although a Client in some cases will be seeking real estate that it anticipates will be in the path of development or other resale potential, there can be no assurance that any of the real estate properties acquired by any Client will be developed for residential, commercial or any other purpose or increase in value during the time period anticipated by the Client or at any time. Further, no assurance can be given that there will be a ready market for these properties at the time a Client elects, or is forced, to sell. All investments in real property are illiquid. Investments in Land/New Development. Certain Clients acquire direct or indirect interests in undeveloped land or underdeveloped real property, which is generally non-income producing. To the extent that a Client invests in such assets, it will be subject to the risks normally associated with such assets and development activities. Such risks include, without limitation, risks relating to (i) the availability and timely receipt of zoning and other regulatory approvals, (ii) the cost and timely completion of construction (including risks beyond the control of the Client, such as the weather, cost and availability of labor and materials) and (iii) the availability of both construction and permanent financing on favorable terms, or at all. These risks could result in substantial unanticipated delays or expenses and, under certain circumstances, could prevent completion of development activities once undertaken, any of which could have an adverse effect on a Client. Real Estate Community Initiatives. A Client and/or real estate properties owned by a Client expect to make charitable contributions or donations, or otherwise sponsor various events and organizations, in furtherance of the Client’s or a real estate property’s business, as determined by the General Partner in its sole discretion, which also may provide a benefit to the Investment Advisers and/or its affiliates, including other Clients and/or projects managed by the Investment Advisers or its affiliates. Such contributions, donations and sponsorships (collectively, “Sponsorships”) are expected to support, among other things, development of community facilities and infrastructure (e.g., playgrounds or bicycle paths), community events (e.g., festivals or art installations), local organizations (e.g., recreational sports activities or seasonal camps) and

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other causes as determined by the General Partner in its sole discretion to be generally beneficial to long-term community development (e.g., scholarships for higher education). Any such Sponsorships made by, or allocated to, a Client will generally be funded by capital contributions from the limited partners, which will reduce the aggregate amount of capital that would otherwise be available to a Client to consummate investments. Any such Sponsorships made by a property owned by a Client will generally be funded by cash flows generated by the operation of such property, which will reduce the aggregate amount of capital that would otherwise be available to the property to allocate to capital expenditures and ongoing cash needs. There can be no assurance that any Sponsorships will ultimately benefit a Client or any property owned by a Client Fund, and the Investment Advisers and their affiliates may indirectly benefit from any name recognition or goodwill generated by such Sponsorships. Non-Control Investments. A Client may hold non-controlling interests in certain investments and, therefore, may have a limited ability to protect its position in such investments. As a condition of making non-controlling investments, a Client may seek to obtain appropriate shareholder rights to protect such investments, but such Client may not necessarily pursue or obtain such rights in all cases. If a Client does not have a controlling position or other shareholder rights to protect its interests, it is possible that a portfolio investment could take actions that negatively impact the value of such investment or that prevent such Client from disposing of such investment. The mere fact that the General Partner of a Client disagrees with decisions made by other investors in such an investment likely will not trigger any particular ability of such Client to dispose of such investment, with the result that the value of a Client’s interest in such investment may be materially affected by the decisions of other investors. In addition, in certain situations, including where the businesses are in bankruptcy or undergoing a reorganization, minority investors may be subject to the decisions taken by majority investors, and the outcome of a Client’s investment may depend on such majority-controlled decisions, which decisions may not be consistent with such Client’s objectives. Investments with Third Parties in Joint Ventures and Other Entities. A Client may hold noncontrolling interests in certain investments or may co-invest with third parties or affiliates of Bridge (including employees) through partnerships, joint ventures or other entities. Such noncontrolling interests in investments may involve risks not present in investments where a thirdparty is not involved, including the possibility that a third-party partner or co-venturer may have financial difficulties resulting in a negative impact on such investment, may have economic or business interests or goals which are inconsistent with those of the Client, may be in a position to take action contrary to the Client’s investment objectives, may prohibit the Client from making operational changes intended to improve cash flow from the investment or may limit the Client’s flexibility to dispose of the investment. In addition, a Client may in certain circumstances be liable for the actions of its third-party partners or co-venturers. A Client’s ability to seek redress against a partner or manager that acts in a manner contrary to the interests of the Client may also be limited. Investments made with third parties or affiliates of Bridge (including employees) in joint ventures or other entities may involve carried interest and other fees payable to such third-party partners or co-venturers. Any such arrangements will result in lower returns to the Client than if such arrangements had not existed. In addition, if a Client and a third party or co-venturer cannot

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agree on decisions affecting the joint venture, it may adversely impact the investment results of the Client. In such event, the Client could have a diminished capacity to obtain investment opportunities, to capitalize upon relationships with co-venturers and to structure and execute its potential investments and dispositions. Investment Programs. Bridge may recruit an existing or newly formed management team to pursue a new “investment program” opportunity that is expected to lead to additional investment opportunities or new Clients. For example, certain Investment Advisers intend to commence a program to issue and sell beneficial interests in specific Delaware statutory trusts holding real estate properties (each, a “DST” and collectively, the “DST Program”). These DSTs may include properties previously owned by Clients, sold to the DST at fair market value as determined by Bridge in accordance with its valuation policies. The DST Program is expected to include a fair market value purchase mechanic that allows a Client (in some cases, the same Client that initially owned the real property sold to the DST) to acquire the DST after a number of years have passed and certain conditions have been met, in exchange for shares or units in the Client. Any fees, costs and expenses arising from or in connection with such investment program will generally be borne by Clients participating in such investment program; however, it is possible that Clients or affiliates participating in an investment program at the time it is launched may bear more than their proportionate share of certain fees, costs and expenses of such investment program, especially any start-up costs. In general, investment programs are expected to give rise to additional investment opportunities for the Investment Advisers, Clients or affiliates, and are expected to generate additional fees to Bridge or its affiliates, including additional management, transaction, or performance fees. Any such fees or benefits will accrue to the benefit of Bridge or its affiliates and will not be allocated to (or offset any management or other fees payable by) the Client, even where such Client sold a real property to the DST. Portfolio Investment Relationships. Bridge pursues investments in real estate related companies, including early- and growth-stage property technology companies. Such companies could be counterparties or participants in agreements, transactions, or other arrangements with other investments of Bridge that, although Bridge determines to be consistent with the requirements of such Clients’ Governing Documents, may not have otherwise been entered into but for the affiliation with Bridge, and which involve fees and/or servicing payments to Bridge-affiliated entities that are not subject to management fee offsets. For example, Bridge, like other firms, causes portfolio investments to enter into agreements regarding group procurement, utility administration, benefits management, data management and/or mining, technology development, purchase of title and/or other insurance policies (which may be pooled across portfolio investments and discounted due to scale), and other similar operational initiatives that result in fees, commissions or similar payments and/or discounts being paid to Bridge or its affiliates, or a portfolio investment, including related to a portion of the savings achieved by the portfolio investment. Moreover, Bridge and its affiliates are often eligible to receive favorable terms for procurement due in part to the involvement of portfolio investments of Clients in such arrangements, and any discounted amounts will not be subject to the management fee offsets or otherwise shared with the relevant Clients. In addition, portfolio investments of certain Clients may do business with, support, or have other relationships with competitors of a Client’s

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investments, and in that regard prospective investors should not assume that a company related to or otherwise affiliated with Bridge will only take actions that are beneficial to or not opposed to the interests of a Client and its portfolio investments. Exclusive Arrangements. It is possible that, from time to time, Bridge, Clients, Apollo Clients or any of their respective affiliates or portfolio investments, could enter into exclusivity, non-competition or other arrangements with one or more joint venture partners, operating partners or other third parties with respect to potential investments in a particular geographic region or with respect to a specific industry or asset type pursuant to which Clients, Bridge, Apollo Clients or any of their respective affiliates, could agree, among other things, not to make investments in such region or with respect to such industry or asset type outside of its arrangement with such person. Similar issues could arise in connection with the disposition of an investment. Accordingly, there could be circumstances in which Bridge or a Client could source a potential investment opportunity or be presented with an opportunity by a third party, and as a result of such arrangements with such person, a Client or its portfolio investments could be precluded from pursuing such investment opportunities. A Client’s investment strategies in certain investments could, but are not expected to, depend on its ability to enter into satisfactory relationships with joint venture or operating partners. There can be no assurance that Bridge or an affiliate’s future relationship with any such partner or operator would continue (whether on currently applicable terms or otherwise) with respect to a Client or that any relationship with other such persons would be able to be established in the future as desired with respect to any sector or geographic market and on terms favorable to a Client. Holding Entities and Tracking Interests. An Investment Adviser could determine that for legal, tax, regulatory, accounting, administrative or other reasons that a Client should hold an investment through a single holding entity through which one or more other Clients or Apollo Clients hold different investments (including where a portfolio or pool of assets has been divided and allocated among a Client, other Clients or Apollo Clients) in respect of which such Client does not have the same economic rights, obligations or liabilities. In such circumstances, it is expected that the economic rights, liabilities and obligations in respect of the investment that is indirectly held by a Client would be specifically attributed to such Client through tracking interests in such holding entity or back-to-back or other similar contribution or reimbursement agreements or other similar arrangements entered into with other Clients or Apollo Clients, and that such Client would be deemed for purposes of its Governing Documents to hold its investment separately from, and not jointly with, such other Clients or Apollo Clients (and vice versa in respect of the investments held indirectly through such holding entity by such other Clients or Apollo Clients). The use of such investment structures in connection with a Client’s investment activities could have an adverse impact on such Client. For example, liabilities could arise in relation to a specific investment held indirectly through such holding entity by another Client or Apollo Client and a counterparty could seek recourse against the holding entity from a different investment that is held indirectly through such holding entity by a different Client or Apollo Client, but not the original Client. A Client’s investment made through such a holding entity will therefore be subject to risks by virtue of other investments owned by the holding entity in which such Client does not have a tracking interest, and such risks would not be present if separate holding entities were used for the separate

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investments made by a Client and other Clients or Apollo Clients. Furthermore, certain holding structures may require a newly established manager, advisor, service provider or other entity intended to address certain legal, tax, regulatory, accounting, administrative or other considerations applicable to participating Clients. For example, due to rules, regulations and/or requirements in a particular jurisdiction (e.g., licensing requirements), it may be the case that in order to comply with the foregoing, one Apollo entity serves a particular role for a Bridge entity (e.g., as an administrator or other role requiring a license) that it otherwise would not but for the rules, regulations and/or requirements in such jurisdiction. It is possible that a Client will be responsible for the costs and expenses of establishing such holding structure (including any such newly established entities) prior to, and/or in anticipation of, other Clients or Apollo Clients participating through such structure for their investments and it is expected that such other Clients or Apollo Clients reimburse a Client for any such costs and expenses on a pro rata basis. Investments in Clients. To the extent set forth in a Client’s Governing Documents, an Apollo Client could also invest in Clients, including: (i) asset-backed securities issued by or related to Clients; (ii) joint ventures; (iii) newly formed Clients established for a particular investment, asset type, investment strategy, or sector; (iv) via secondary transfers of interests of a Client; and (v) in circumstances where such Apollo Clients could serve as the initial or “anchor” investor in a new Client. Such activity will subject a Client to additional risks, including additional exposure to the same investments made by the Client. For example, a Client could bear an additional layer of fees and incentive compensation (which will not reduce Management Fees paid by such Client and will be retained by, and be for the benefit of, Bridge or its affiliates or employees) as a result of investing into an additional Client, as well as its pro-rata share of the expenses of such Clients. Additionally, a Client could bear, directly or indirectly, the organizational expenses and operational expenses that arise at the other Client or Apollo Clients. An Apollo Client will generally not have an active role in the day-to-day management of another Client, platform investment or joint venture or have the opportunity to evaluate the specific investments made thereby before they are made. Similarly, an Apollo Client could invest on the basis of certain short-term market considerations. As a result, the turnover rate with the Apollo Client could be significant, potentially involving substantial brokerage commissions, fees, and other transaction costs. Inability to Refinance Investment. If a Client makes an investment in a transaction with the intent of refinancing a portion of the equity investment, there is a risk that the Client will be unable to complete successfully the refinancing. There is also a risk that certain investments acquired using indebtedness may be difficult or impossible to refinance when the loan matures. The inability to complete a refinancing or to complete one as quickly as originally planned would lead to increased risk due to a longer-than-expected investment period, which limits the Client’s ability to redeploy the capital from a disposition and may also jeopardize the return expectations that the General Partner had originally estimated for the investment. In addition, if a loan matured before refinancing could be procured, the lender could foreclose on the collateral, and the Client might suffer losses as a result of that foreclosure. Length of Loan Terms. Certain Clients enter into or assume loan agreements to finance the acquisition of certain investments where the associated loan has a prepayment penalty and a

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maturity date that is after the term of the Client. If interest rates decline or the terms of the loan agreements are viewed as unfavorable to potential buyers of the Client’s assets, the Client may be unsuccessful in disposing of investments on terms that are favorable to the Client. The result of such financing may negatively affect the Client’s investment returns. Bankruptcy Considerations. Investments made in assets operating in workout modes or under bankruptcy, insolvency or other debtor-protection codes could, if a Client inappropriately exercises control over the management and policies of the debtors, be subordinated or disallowed, and the Client could be liable to third parties in such circumstances. Furthermore, distributions made to the Client in respect of such investments, and distributions by the Client to the Fund Investors, could be recovered if such distributions are found to be a fraudulent conveyance or preferential payment or the equivalent under the laws of certain jurisdictions. Bankruptcy laws may delay the ability of a Client to realize on collateral for loan positions held by it or may adversely affect the priority of such loans through doctrines such as equitable subordination or may result in a restructure of the debt through principles such as the “cramdown” provisions of the bankruptcy laws. Client Borrowing. Clients may borrow on a secured or unsecured basis for any purpose, including to make any investment or to increase investment capacity, pay fees and expenses or to make distributions. Although a Client may not intend to employ significant leverage at the Client level, the Client may achieve leverage in certain transactions at entities below the Client level, and such leverage may fluctuate depending on market conditions. The interest expense and other costs incurred in connection with such borrowing may not be recovered by appreciation in the investments purchased or carried. Gains realized with borrowed funds may cause the Client’s returns to be higher than would be the case without borrowings. If, however, investment results fail to cover the cost of borrowing, the Client’s returns could also decrease faster than if there had been no borrowings. Further, such leverage will increase the exposure of an investment to adverse economic factors such as rising interest rates, downturns in the economy or deteriorations in the condition of the investment. If the Client defaults on secured indebtedness, the lender may foreclose and the Client could lose its entire investment in the security for such loan. The Client may also seek to issue preferred equity to third-party co-investors in connection with certain investments. While such preferred equity would not be viewed as debt for general purposes, it would have certain features in common with debt, including a priority in rights of repayment and distributions that would be senior to the Client’s equity investment. In addition, borrowings by the Clients are generally secured by the Fund Investors’ capital commitments and/or the Client’s assets (including in connection with a net-asset-value or NAV facilities). Such collateralized borrowings may be cross collateralized with the assets of any parallel vehicle, subsidiary, financing vehicle or alternative investment vehicle of such Client and such entities may be held jointly and severally liable for the full amount of the obligations arising out of such borrowings. In addition, a provider of the foregoing financing could include Apollo Clients, Apollo, its affiliates, and its employees. It is often preferred (or commercially required) for a counterparty to view the various entities as one single “Bridge” party and therefore appropriate for these obligations to be addressed among Clients by way of a back-to-back or reimbursement type arrangement. As part of financing transactions and other arrangements for the benefit of portfolio investments,

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including hedging arrangements and other transactions that arise in the ordinary course or support the day-to-day operations of such portfolio investments, counterparties could require or otherwise request credit support or other risk enhancements. In such cases, Bridge sometimes determines to engage an Apollo-controlled vehicle which can result in fees not subject to any offset. Further, to the extent the income received from investments is used to make interest and principal payments on such borrowings, Investors may be allocated income, and therefore tax liability, in excess of cash received by them in distributions. The presence of leverage substantially increases the risk profile of the Client and its investments. There can also be no assurance that a Client will have sufficient cash flow to meet its debt service obligations. As a result, a Client’s exposure to losses may be increased due to the illiquidity of its investments generally. Risks Related to Debt Investments. The leveraged capital structure of the entities and properties underlying the investments in which a Client may invest will increase their exposure to adverse economic factors (such as rising interest rates, competitive pressures, downturns in the economy or deterioration in the condition of the entity or property) and to the risk of unforeseen events. This leverage may result in more serious adverse consequences to such underlying entities or properties (including to overall profitability or solvency) in the event these factors or events occur than the consequences for less leveraged entities or properties. For example, rising interest rates may significantly increase interest expense for floating rate debt, or a significant market downturn may affect ability to generate positive cash flow, in either case causing an inability to service outstanding debt, which may include the debt investments held by a Client. If any underlying entity or property cannot generate adequate cash flow to meet debt obligations, it may default on its loan agreements or be forced into bankruptcy. As a result, a Client may suffer a partial or total loss of invested capital, particularly in the case of any mezzanine or second-lien debt investments of the Client, in light of the subordinated position of such investments. Conflicts Related to Multiple Investments in Capital Structure or Investments in Which Multiple Clients or Affiliates Participate. Increasingly, given changes in the regulatory environment for banks, as well as structural developments in the capital markets, affiliates of Bridge have opportunities to provide holistic financing solutions, which could in certain instances involve the participation of affiliates of Bridge or Apollo Clients in either a single investment or a related series of investments. Subject to applicable allocation policies, certain Clients may invest in a portfolio investment in which another Client, affiliate of Bridge or Apollo Client holds an investment, including in a different class of the capital structure. For example, multiple Clients, affiliates or Apollo Clients focused on debt investments may (i) acquire securities from the same issuer that are pari passu with securities owned by other Clients, affiliate of Bridge or Apollo Clients, or (ii) acquire securities that are senior or junior to securities of the same issuer that are held by other Clients, affiliate of Bridge or Apollo Clients. These investment opportunities could be beneficial for Bridge and/or Clients, to the extent that affiliates of Bridge are able to provide “one-stop shopping” financing solutions and, consequently, drive terms and increase the economics that are captured by Bridge and/or Clients. Conflicts of interest are expected to arise under such circumstances. For example, if an issuer of securities is in bankruptcy proceedings and multiple

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Clients, affiliates of Bridge or Apollo Clients own securities in different parts of the capital structure, the Client, affiliate or Apollo Client holding the senior securities would generally be expected to aggressively pursue the issuer’s full assets to satisfy the indebtedness held by such Client, affiliate or Apollo Client, even if the other Clients, affiliates or Apollo Clients holding the junior securities would not have access or the ability to take similar action. In such circumstances, the Investment Advisers would seek to treat each Client fair and equitably and would take steps to reduce the potential for conflicts between the interests of each of the Clients. However, in some cases, to reduce the potential for conflicts between the interests of each of the Clients, the Investment Advisers may choose to take certain actions that, in the absence of such conflict of interest, it would not take (e.g., the Investment Advisers might cause a Client to divest itself of an asset that it might otherwise have retained or may try to ensure that Clients own the same securities to preserve the alignment of interest between Clients). Any such actions could have the effect of benefitting one Client at the expense of another Client. In order to be viewed as a credible counterparty that is capable of delivering comprehensive financing solutions without recourse to traditional third-party financial intermediaries, it is possible affiliates of Bridge will need to “speak for” the full amount of a financing in situations where such affiliates and/or Clients or Apollo Clients could not have sufficient capacity (or demand) for the investment opportunity. In these situations, including when it is unclear at the outset of negotiating a transaction whether there is sufficient internal demand, Clients and not for the avoidance of doubt affiliates of Bridge, could have to incur the expense of engaging either a third party or an affiliated service provider or a platform investment that is engaged in sourcing investment opportunities, in order to provide services such as identifying potential third-party investors (including potential co-investors), structuring the transaction so that it will be more marketable to third-party investors, preparing marketing materials, performing outreach, and executing on a syndication and sell-down strategy. In connection with any investment opportunity where affiliates of Bridge and/or two or more Clients or Apollo Clients are expected to participate (including in connection with co-investments), to the extent a deposit, commitment (financial or otherwise) or other contingency is required or otherwise viewed at the time as appropriate for the investment opportunity or transaction process, affiliates of Bridge have the discretion to cause such affiliates and/or one of the participating Clients or Apollo Clients, to make the deposit, provide the commitment or make such arrangements to support and be liable for the contingency on behalf of itself and/or other Clients, and will take such additional steps to ensure such arrangements are ultimately shared equitably among such affiliate and/or the participating Clients or Apollo Clients as the affiliate determines to be reasonable. A Client is not restricted in its ability to engage in such actions as part of structuring, negotiating, consummating, hedging (and/or entering into other derivative transactions with respect to), financing (including post-closing financing and leverage transactions) and disposing of investment opportunities. Clients will, from time to time, subject to their Governing Documents, as applicable, acquire and dispose of assets, securities, or other financial instruments at different times and upon different terms. The interests of Clients or Apollo Clients in such investments will not be aligned in all or any circumstances, and there will be actual or potential conflicts of interests or the appearance thereof. In this regard, actions could, from time to time, be taken by Bridge that are adverse to

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one or more Clients. Bridge will also have ongoing relationships with issuers whose securities have been acquired by or are being considered for investment by Clients. Subject to the limitations included in a Client’s Governing Documents, situations could arise where another Client or Apollo Client acquires or otherwise engages in transactions with respect to securities of an entity in which such Client or Apollo Clients have a financial interest (whether in the same or a different class of securities) or otherwise engages in selling, divesting or making further acquisitions or otherwise engages in transactions with respect to securities of such entity, including in connection with and following a co-investment. For example, a Client and its portfolio investments can engage assets or portfolio investments of other Clients, affiliates of Bridge or Apollo Clients to provide additional services with respect to, or in connection with financial transactions with, a Client’s portfolio investments or vice versa. To the extent that any transactions involve the sale of securities between Clients or Apollo Clients, such transactions will be conducted in accordance with, and subject to, the terms of the applicable Governing Documents for each Client. The Investment Advisers recognize that conflicts arise under such circumstances and will endeavor to treat all Clients fairly and equitably. To that end, the Investment Advisers have adopted policies and procedures which are designed to address such potential conflicts of interest. The application of such policies and procedures are expected to vary based on the particular facts and circumstances surrounding each investment by two or more Clients or affiliates or Apollo Clients in different classes, series or tranches of an issuer’s capital structure (as well as across multiple issuers or borrowers within the same overall capital structure), and as such, investors should expect some degree of variation, and potentially inconsistency, in the manner in which potential or actual conflicts are addressed. The Investment Advisers intend to resolve such situations in an impartial manner, but there can be no assurance that their own interests will not influence their conduct. Short-Term Loans. From time to time, a Client may make loans on a short-term, unsecured basis in anticipation of a future equity or long-term debt take-out refinancing. There can be no assurance that such take-out refinancing will occur on time, on desirable terms or at all, and such bridge loans may remain outstanding. In such event, the interest rate on such loans may not adequately reflect the risk associated with the unsecured position taken by such Client. Expedited Transactions. Investment analyses and decisions by a General Partner and Investment Adviser may frequently be required to be undertaken on an expedited basis to take advantage of investment opportunities. In these circumstances, the General Partner may not have performed thorough due diligence, resulting in making an investment that the General Partner would not otherwise have made. A General Partner and Investment Adviser often expect to rely upon independent consultants and available resources, including market research (which may include reliance on artificial intelligence or machine learning), information provided by the target, and certain assumptions. No assurance can be given as to the accuracy or completeness of the information provided by such independent consultants or the assumptions used during the diligence process, and a Client may incur liability as a result of such inaccuracy or incompleteness of such information. Further, indemnification or other remedies may not be available to the Client

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due to contractual provisions with such independent consultants limiting such indemnification or other remedies. Environmental Liabilities. A Client may be exposed to substantial risk of loss arising from investments involving undisclosed or unknown environmental, health or occupational safety matters, or inadequate reserves, insurance or insurance proceeds for such matters that have been previously identified. 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 on or in such property. Such laws may impose joint and several liability, which can result in a party being obligated to pay for greater than its share, or even all, of the liability involved. Such liability may also be imposed without regard to whether the owner knew of, or was responsible for, the presence of such hazardous or toxic substances. The cost of any required remediation and the owner’s liability therefore as to any property are generally not limited under such laws and could exceed the value of the property and the aggregate assets of the owner. The presence of such substances, or the failure to properly remediate contamination from such substances, may adversely affect the cash flow and operations of the property, the owner’s ability to sell the real estate or to borrow funds using such property as collateral, which could have an adverse effect on the Client’s return from such investment. Environmental claims with respect to a specific investment may exceed the value of such investment, and under certain circumstances, subject the other assets of the Client to such liabilities. In addition, some environmental laws create a lien on contaminated property in favor of governments or government agencies for costs they may incur in connection with the contamination. Climate Change May Impact the Assets Owned by our Clients. The Investment Advisers face both physical climate change risks, such as increasing temperatures, rising sea levels, changing weather patterns and more frequent or intense droughts, floods and storms, and transition climate change risks, such as new or changing land use policies, carbon emissions regulations, water conservation regulations, reporting requirements, technology standards and market trends. We cannot predict with certainty the extent, rate, or impact of climate change or the measures that government authorities or others may implement to address climate change. The potential impacts of climate change on our operations are highly uncertain and will vary across the geographies in which we operate and where our Clients own properties. Such impacts may result in stranded assets and volatile or decreased demand at certain of the properties owned by our Clients. The Investment Advisers or the Clients may become subject to new or changing laws or regulations related to climate change, which could adversely impact the investment returns of our Clients. The federal government and certain state and local governments have enacted or proposed climate change laws and regulations, including in jurisdictions in which our Clients own properties. These laws and regulations could result in increased litigation risk and substantial costs, including compliance costs, energy costs, retrofit costs, construction costs, monitoring and reporting costs, capital expenditures for environmental control facilities and other additional costs for the properties owned by our Clients. These increased costs could negatively impact the investment returns of our Clients.

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Failure to Acquire Identified Properties or Investments. There can be no assurance that any Client will complete the acquisition of any of the investments that have been identified as potential investments or acquisition targets, or that the General Partner and Investment Adviser will be able to identify other investments or acquisition targets that meet the Client’s investment criteria. A Client’s acquisition of the properties that have been identified as potential acquisition targets, or of any other investments, will depend on, among other things, the willingness of the parties to proceed with the contemplated transaction and the General Partner’s and the Investment Adviser’s ability to negotiate mutually satisfactory terms with the sellers and to enter into binding agreements with respect to such investments or properties. Even if a Client does enter into binding agreements with respect to such investments or properties, there can be no assurance that the closing conditions under those agreements will be satisfied and that the Client will close on the investments or acquisition properties. A Client’s inability to acquire investments in the future that satisfy its investment criteria would have an adverse effect on the Client’s operating results and ability to make distributions to its partners. Diversification. To the extent the applicable Investment Adviser concentrates a Client’s investments in a particular market, the Client’s portfolio may become more susceptible to fluctuations in value resulting from adverse economic or business conditions affecting that particular market. Although the General Partner will attempt to minimize risk, the Client’s actual returns will be subject to numerous factors beyond the General Partner’s control. Because the Client’s investments are expected to be concentrated within targeted markets or strategies, portfolio diversification will be less than would be possible if the Client were to invest in a range of real estate opportunities across several markets and strategies. Such reduced diversification may increase the volatility of the Client’s returns and could reduce the Client’s returns relative to more diversified funds. In addition, during the early stages of a Client’s term, the Client may hold more concentrated positions than it otherwise would. Changes in Investment Focus. It is possible that Clients are not restricted in terms of the percentage of their capital that can be invested in a particular industry, geographical region, or type of investment. While a Client’s governing documents generally contain a description of the types of investments that other Clients have historically made and/or information about Apollo’s expectations with respect to such Client, many factors could contribute to changes in emphasis in the construction of such Client’s portfolio, including changes in market or economic conditions or regulation as they affect various industries and changes in the political or social situations in particular countries. There can be no assurance that the investment portfolio of any Client will resemble the portfolio of any other Client. Need for Follow-on Investments. Following its initial investment in a given asset, a Client may decide to provide additional funds or increase its investment in such asset. There is no assurance that a Client will make follow on investments or that a Client will have sufficient funds to make all or any of such investments. Any decision by a Client not to make follow on investments or its inability to make such investments may have a substantial negative effect on an asset in need of such an investment or may result in a lost opportunity for the Client to increase its participation in a successful operation.

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Contingent Liabilities Associated with Secondary Investment Transactions. In cases where a Client acquires a private fund interest in a secondary transaction, such Client may acquire contingent liabilities of the seller of the interest, including unfunded capital commitments. For example, where the seller has received distributions from the relevant underlying fund and, subsequently, such underlying fund recalls one or more of these distributions, the Client (as the purchaser of the private fund interest to which such distributions are attributable and not the seller) may be obligated to return monies equivalent to such distributions to the underlying fund. Multiple Layers of Expense for Secondary Investments. Clients that invest in private fund interests in the secondary market include multiple layers of expenses and management costs that will be borne, directly and indirectly, by each such Client. Impact of Leverage by Underlying Funds on Secondary Investments. For Clients that invest in private fund interests in the secondary markets, certain underlying funds or portfolio investments often have highly leveraged capital structures. The use of leverage magnifies the unfavorable effects on equity values. The highly leveraged capital structures of such underlying funds and/or underlying portfolio investments will magnify the exposure to adverse economic factors such as rising interest rates, reduced cash flows, fluctuations in exchange rates, inflation, downturns in the economy or deterioration in the condition of the underlying company or its industry. In particular, in the event an underlying portfolio investment cannot generate sufficient cash flow to meet its principal and interest payments on its debt obligations, the value of such underlying portfolio investment, and indirectly the underlying fund which owns an interest in such portfolio investment, could be significantly reduced or even eliminated. Moreover, an underlying fund may itself employ leverage and its inability to meet its principal and interest payments on indebtedness will similarly have a material adverse effect on the underlying fund and, indirectly, the Client that invested in the private fund interests of such underlying fund. Secondary Investments in Private Fund Interests. Certain Clients invest in private fund interests in the secondary markets across a range of alternative private equity strategies. When making a secondary investment by acquiring an interest from an existing limited partner, the Client generally will not have the opportunity to negotiate the terms or other special rights and privileges of the private fund interests being acquired, other than the purchase price. Further, the underlying funds are managed by professional investment advisers unrelated to the Investment Advisers and the performance of such investments will depend primarily on such unrelated managers. In addition, Clients may receive in-kind distributions of securities from portfolio funds. There can be no assurance that securities distributed in kind by portfolio funds to Clients will be readily marketable or saleable, and such Clients may be required to hold such securities for an indefinite period and/or may incur additional expense in connection with any disposition of such securities. Uncertainty of Financial Projections. A Client’s General Partner will generally establish the capital structure of portfolio entities on the basis of financial projections for such portfolio entities. Projected operating results will often be based on management judgments. In all cases, projections are only estimates of future results that are based upon assumptions made at the time that the projections are developed. There can be no assurance that the projections will be

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obtained; actual results may vary significantly. General economic conditions, which are not predictable, can have a material adverse impact on the reliability of such projections. Calculation Methodology. Apollo, in its discretion, selects and applies the calculation methodology for determining the cost basis of a Client’s investments for purposes of calculating Management Fees, including in connection with determining the types and amounts of expenses associated with an investment that will be included in the calculation of adjusted cost (which includes expenses capitalized into the acquisition cost of an investment and certain Operating Expenses associated with such investment, including any expenses that constitute fees or other amounts paid to Affiliated Service Providers) and whether and to what extent a disposition or write-down has occurred with respect to an investment, including for purposes of determining whether adjusted cost should be reduced or distributions should be made. Broken Deals. Investments in the real estate industry often require extensive due diligence activities and regulatory permits or approvals. Due diligence may include, without limitation, feasibility and technical studies, preliminary marketing studies, business plan development, and legal and environmental review, any or all of which entail significant third-party expenses. In the event that an investment is not consummated, a Client may bear some or all of such third-party expenses and any termination fees. With respect to investments in which third parties have agreed to co-invest with the Client, any investment expenses or indemnification obligations related to such investments are expected to be borne by the Client and such co-investors (whether directly or through a co-investment vehicle) in an equitable manner as determined by the Client’s General Partner (which may be in proportion to the capital committed by each to such investment). If a proposed co-investment opportunity and/or co-investment vehicle is not consummated, the Client will generally bear some or all of the costs of such proposed co-investment (including broken deal expenses, diligence and pursuit expenses, and other third-party out-of-pocket expenses). Cybersecurity Risks. With the increased use of technologies and the dependence on computer systems, complex information technology, artificial intelligence, and communication systems to perform necessary business functions, investment vehicles such as the Clients and their service providers may be prone to operational and information security risks resulting from cyber‐attacks. In general, cyber‐attacks result from deliberate attacks, but unintentional events may have effects similar to those caused by cyber‐attacks. Cyber‐attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial‐of‐service attacks on websites, the unauthorized release of confidential information and causing operational disruption. Successful cyber-attacks against, or security breakdowns of, a Client, a General Partner, and/or third-party service providers may adversely impact a Client or Fund Investors. For instance, cyber‐attacks may interfere with the processing of Fund Investor transactions, impact a Client’s ability to value its assets, cause the release of private Fund Investor information or confidential information of a Client, impede trading, cause reputational damage, and subject a Client to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, ongoing prevention costs and/or additional compliance costs. A Client incurs substantial costs for cyber-security risk management in order to prevent any cyber incidents in the future. A Client and Fund Investors could be negatively impacted as a result. Data taken in such breaches may be used by criminals in

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identity theft, obtaining loans or payments under false identities, and other crimes that could affect Fund Investors directly as well as affect the value of assets in which the Client invests. These risks can disrupt the ability to engage in transactional business, cause direct financial loss and reputational damage, lead to violations of applicable laws related to data and privacy protection and consumer protection, or incur regulatory penalties, all or part of which may not be covered by insurance. Similar types of operational and technology risks are also present for the portfolio investments in which certain Clients invest, which could have material adverse consequences for such investments, and may cause a Client’s investments to lose value and negatively affect returns to investors. Data Privacy. The adoption, interpretation and application of consumer protection, data protection and/or privacy laws and regulations in the United States, Europe and other jurisdictions (collectively, “Privacy Laws”) could significantly impact current and planned privacy and information security related practices, the collection, use, sharing, retention and safeguarding of personal data and current and planned business activities of the Investment Advisers, the Clients Funds and/or their investments, and increase compliance costs and require the dedication of additional time and resources to compliance for such entities. A failure to comply with such Privacy Laws by any such entity or their service providers could result in fines, sanctions or other penalties, which could materially and adversely affect the results of operations and overall business, as well as having a negative impact on reputation and Fund performance. As Privacy Laws are implemented, interpreted and applied, compliance costs for the Investment Advisers, the Funds and/or their investments are likely to increase, particularly in the context of ensuring that adequate data protection and data transfer mechanisms are in place. Certain jurisdictions, including U.S. states, have proposed, adopted or are considering similar Privacy Laws, which if enacted could impose significant costs, potential liabilities and operational and legal obligations. Such Privacy Laws and regulations are expected to vary from jurisdiction to jurisdiction, thus increasing costs, operational and legal burdens, and the potential for significant liability for regulated entities, which could include the Investment Advisers, the Funds and/or their investments. Artificial Intelligence and Machine Learning Developments. Recent technological advances in artificial intelligence and machine learning technology (collectively, “Machine Learning Technology”), including OpenAI’s release of its ChatGPT application, pose risks to Bridge, the Investment Advisers and Clients of the Investment Advisers. Bridge employs a risk-based framework for overseeing the use of Machine Learning Technology in connection with its business activities, including investment activities, and has implemented an internal policy governing use of Machine Learning Technology (the “AI Policy”). Bridge, in its discretion, may modify or amend the AI Policy at any time. Notwithstanding the AI Policy, Bridge personnel, other associated persons or any of its affiliates could, unbeknownst to Bridge, utilize Machine Learning Technology in contravention of the AI Policy. Bridge, the Investment Advisers and Clients of the Investment Advisers could be further exposed to the risks of Machine Learning Technology if third-party service providers or any counterparties, whether or not known to Bridge, also use Machine Learning Technology in their business activities. Bridge will not be in the position to control the

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manner in which third-party products are developed or maintained or the manner in which thirdparty services are provided. Use of Machine Learning Technology by any of the parties described in the previous paragraph could include the input of confidential information (including MNPI) — either by third parties in contravention of non-disclosure agreements, or by Bridge personnel and affiliates in contravention of the AI Policy into Machine Learning Technology applications, resulting in such confidential information becoming part of a dataset that is accessible by other third-party Machine Learning Technology applications and users. Independent of its context of use, Machine Learning Technology is generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that Machine Learning Technology utilizes to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error – potentially materially so – and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of Machine Learning Technology. To the extent that Bridge, the Investment Advisers and Clients of the Investment Advisers are exposed to the risks of Machine Learning Technology use, any such inaccuracies or errors could have adverse impacts on Bridge, the Investment Advisers and Clients of the Investment Advisers. Machine Learning Technology and its applications, including in the private investment and financial sectors, continue to develop rapidly, and it is impossible to predict all future risks that may arise from such developments. Risks Associated with Certain Computer and Algorithmic Research Tools. Research and creative tools that harness generative artificial intelligence (collectively, “Computer and Algorithmic Research Tools”), as well as other machine learning techniques, will continue to become more accessible to Bridge. Prospective investors should anticipate that Bridge will utilize Computer and Algorithmic Research Tools in connection with its business activities, including acquisition activities. The use of Computer and Algorithmic Research Tools brings with it known, anticipated, and as-yet-unknown risks and conflicts, including the risk that Bridge’s compliance and operational policies and procedures will not anticipate every potential issue and conflict, and that Bridge’s surveillance and control systems might not be sufficient to identify every instance of noncompliance. Among other things, this means that Bridge’s policies and procedures relating to Computer and Algorithmic Research Tools will continue to evolve rapidly, and without notice to investors. As is the case with all third-party services and products, Bridge intends to exercise levels of review and testing before deployment that Apollo deems appropriate, but the relative novelty of Computer and Algorithmic Research Tools likely will result in some degree of incorrect or unclear inputs into Bridge’s acquisition and operations process. This could lead to an increase in interpretative issues, errors of judgement and systems errors, notwithstanding the benefits that deploying new services and products is expected to create. Where appropriate, Bridge will work with providers and vendors to improve or fix licensed services and products, but that will not always be feasible. To the extent that Bridge develops proprietary Computer and Algorithmic Research Tools, similar risks will exist. Any fees, costs and expenses arising from or in connection with Computer and Algorithmic Research Tools charged by third-party providers or vendors and/or incurred in-house by Bridge and its personnel could be borne by Clients and allocated among Clients in accordance with Bridge expense allocation procedures.

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Bridge’s use of Computer and Algorithmic Research Tools will be subject to its policies and procedures on cybersecurity, privacy, and confidentiality. However, the effectiveness of those policies when using Computer and Algorithmic Research Tools is dependent on the licensor adhering to its contractual commitments and to applicable law, as well as the effectiveness of the licensor’s (and Bridge’s) cybersecurity, systems and other structural safeguards being effective in design and operation. To the extent that there is a breach or failure in any of these safeguards, investors could be harmed by the theft, misappropriation, or release of their confidential information, or by an impairment in the value of assets directly or indirectly caused by such breach or failure. Independent of its context of use, certain varieties of Computer and Algorithmic Research Tools are generally highly reliant on the collection and analysis of large amounts of data, and it is not practicable to incorporate all relevant data into the models that Computer and Algorithmic Research Tools utilize to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error – potentially materially so – and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of Computer and Algorithmic Research Tools. Such models also are subject to inherent bias (owing to the structure of their initial programming) as well as acquired biases (reflecting the data upon which they were trained). To the extent that Bridge is exposed to the risks of using Computer and Algorithmic Research Tools, any such inaccuracies or errors could have adverse impacts on Bridge, Bridge, the Investment Advisers and Clients of the Investment Advisers. Natural Disasters. Upon the occurrence of a natural disaster such as flood, hurricane, fire, or earthquake, the impacted region may not efficiently and quickly recover from such events, which could have a material adverse effect on a Client’s investments. As impacts of weather events and climatological risks increase, the impacts of these events may be more widely felt, impacting more investments, and increasing regional market volatility. Weather events in particular are difficult to accurately predict between the origin of an investment and its maturity. Such disasters may cause damage that exceeds insurance coverage and may elevate costs even if a Client investment is not directly impacted by disaster. Terrorist Acts, War, and Similar Dislocations. Incidents of war, riots, or civil unrest may create instability in a region or globally, even if a Client does not hold investments in the region impacted by war, riots or civil unrest. For example, the invasion of Ukraine by Russian troops and ongoing armed conflict have resulted in a broad array of new and expanded sanctions, export controls and other measures against Russia and certain banks, companies, officials and individuals affiliated with Russia or certain Russian entities. The severity and duration of the conflict and its impact on the global economic and market conditions are impossible to predict. Such uncertainty and conflict could materially and adversely impact the Client’s and their investments, even if not located within the impacted regions. Additionally, terrorist attacks and related events can result in increased global economic volatility. We cannot predict the effects of terrorist acts (or threats thereof), military action or similar events. Such disruptions of the world financial markets could affect interest rates, ratings, credit risk, inflation, availability of borrowing and other factors relating to and impacting a Client’s investments.

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Political Elections. The outcome of future global political elections in any jurisdiction where a Client, as well as Bridge and its affiliates operate or invest could create significant uncertainty with respect to legal, tax and regulatory regimes that affect them. Changes in the composition or policies of the various governments following such elections could result in a number of changes to fiscal, trade, monetary, environmental, social and other policies, as well as the global financial markets generally. Any significant changes in, among other things, economic policy (including with respect to interest rates, foreign trade and regulatory changes leading to greater availability of bank debt), the regulation of the asset management industry, tax law, climate policy, immigration policy and/or government entitlement programs could have a material adverse impact on a Client and its investments. Political Risks in General. Any significant changes in, among other things, economic policy (including with respect to interest rates and foreign trade), the regulation of the asset management industry, insurance law, tax law, immigration policy, environmental protection and/or climate-related policies or regulations and/or government entitlement programs could have a material adverse impact on Clients and their investments. More generally, legislative acts, rulemaking, adjudicatory or other activities by U.S. or non-U.S. governmental, quasi-governmental or self-regulatory bodies, agencies and regulatory organizations could make it more difficult (or less attractive) for certain Clients to achieve their investment objectives, or for relevant portfolio companies to engage in their respective businesses. Populist, protectionist and anti-globalization movements, particularly in Western Europe and the US, could result in material changes in economic, trade and immigration policies, all of which could lead to significant disruption of global markets and could have materially adverse consequences for Clients with investments whose operations are directly or indirectly dependent on international trade. Uncertainty Regarding Ongoing Trade Negotiations between the US and Other Countries. Recently, tariffs have been imposed on imports from certain other countries outside of the US. Further trade restrictions and/or tariffs may be forthcoming and may be dependent on evolving domestic and international political developments. Certain international trade agreements may also be at risk. Tariffs and similar trade restrictions may lead to global economic stagnation or increased inflation and therefore materially and adversely affect Clients. These and future tariffs, as well as any other global trade or supply chain developments, bring with them uncertainty. Bridge cannot predict future changes to imports covered by tariffs, or which countries will be included or excluded from such tariffs. Recent trade tensions between the US and other countries, including China, have led to concerns about economic stability and could have an adverse impact on global economic conditions. The US and other countries have each been implementing increased tariffs on imports from the other, and the US has also adopted certain targeted measures such as export controls or sanctions on certain countries. While certain trade agreements have been agreed between the US and other countries, there remains much uncertainty as to whether the trade negotiations between the US and other countries will be successful and how global tariffs will progress. If trade wars between the US and other countries continue or escalate, or if additional tariffs or trade restrictions are implemented by the US or

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other countries in connection with global trade wars, there could be material adverse effects on the global economy, and Clients and its portfolio investments could be materially and adversely affected. CFIUS and National Security/Investment Clearance Considerations. Certain investments by Clients, including those that involve businesses or real estate connected with, related to or that implicate national security, critical technology or critical infrastructure or the collection and storage of sensitive data, could be subject to review and approval by the Committee on Foreign Investment in the US (“CFIUS”), non-US national security/investment clearance regulators or other regulators (each, an “FDI Regulator”), depending on the beneficial ownership and control of interests in the Client that is making the investment. Further, beginning on January 2, 2025, the U.S. Department of the Treasury’s Outbound Investment Security Program (the “OISP”) went into effect, which prohibits or requires notification of certain types of outbound investments by U.S. persons into certain entities located in or subject to the jurisdiction of China, Hong Kong, and Macau (as well as certain entities subject to Chinese ownership or control) that are engaged in the development of certain technologies or products (presently, certain semiconductors and microelectronics, quantum information technologies, and artificial intelligence technologies), as well as any other countries that are or may be designated under the program’s regulations. In the event that an FDI Regulator reviews one or more of the Client’s proposed or existing investments, there can be no assurance that the Client will be able to maintain, or proceed with, such investments on terms acceptable to the Client. FDI Regulators could seek to impose limitations or restrictions that prevent the Client from maintaining or pursuing investments, which could adversely affect the Client’s performance with respect to such investments (if consummated) and thus the Client’s performance as a whole. In the event that one or more of a Client’s proposed or existing investments may be prohibited or notifiable under the OISP, there can be no assurances that such Client will be able to maintain, or proceed with, such investments on terms acceptable thereto. In addition, certain limited partners of Clients will be non-US investors, and in the aggregate, could comprise a substantial portion of a Client’s commitments, which increases both the risk that investments could be subject to review by an FDI Regulator, and the risk that limitations or restrictions will be imposed by an FDI Regulator on such Client’s investments. In the event that restrictions are imposed on any portfolio investment by the Client due to the non-US status of a limited partner or group of limited partners or other related CFIUS, national security or other regulatory considerations, the general partner could choose to restrict such limited partner, or such group of limited partners, from investing in any such investment, or implement a structure for such investment that results in different instruments being held by or for the benefit of such investors, which could result in such investors receiving all or a portion of any distributions relating to such investment in a different manner, or on different timing, than other investors or the general partner (including in respect of its carried interest). In the event that restrictions are imposed on any existing investment by the Client due to the non-US status of a limited partner or group of limited partners or other related CFIUS, national security or other regulatory considerations, subject to the Governing Documents of a Client, the general partner could require such limited partner(s) to withdraw from the Client. The general partner will also have authority to restrict information otherwise required to be provided to limited partners or the

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advisory board to the extent necessary or desirable to address CFIUS, national security or other regulatory considerations, and could in certain circumstances (and to the extent applicable to a Client) substitute a vote of the advisory board for a vote of a majority-in-interest of limited partners (or vice-versa) to address such considerations. A limited partner could not be permitted to transfer all or any part of its interest to a person that gives rise to CFIUS, national security or other regulatory considerations with respect to the Client or actual or potential investments. If the Client is investing in portfolio investments for which approval by an FDI Regulator is being sought, the Client and a governmental entity could address perceived threats to national security or other relevant concerns through mitigation measures such as including contractual undertakings with such governmental entity, board resolutions and proxy agreements. Such measures could include the disclosure of certain identifying information relating to some or all of the limited partners to the applicable regulator, and/or, in certain circumstances, filing requirements being imposed on one or more limited partners and/or Co-Investors. The time it takes to negotiate any such measures or the length of the review process of an FDI Regulator could place the Client at a competitive disadvantage to purchasers not subject to review by an FDI Regulator. Such mitigation measures could also effectively impose significant operational restrictions on the Client, portfolio investments, the general partner, the Apollo Manager or their affiliates, partners, or employees. Should approval by an FDI Regulator be a closing condition to a prospective transaction, there is a risk that such approval might not be granted, and the Client will have to bear the costs and expenses relating to such unconsummated investment, in addition to the risk that disadvantageous conditions could be imposed. Moreover, it is possible that, when evaluating a potential portfolio investment, the general partner or the Investment Adviser could choose not to pursue or consummate such portfolio investment, if any of the foregoing risks could create liabilities or other obligations for any of the Client, the general partner, the Investment Adviser or any of their respective portfolio investments, affiliates, partners, or employees. Open-Ended Funds. Within open-ended Fund structures such as Bridge Agency MBS, there are distinct and additional risk factors than those that apply to close-end vehicles generally. These differences in risks include are described more fully in the applicable Governing Documents for the open-ended funds and include, among others, that the management fee is determined by the value of the portfolio instead of the amount of called capital or invested capital, that subject to the limitations and conditions set forth in the Governing Documents, the Investment Advisers can be entitled to performance related fees before the disposition and sale of all assets within the Fund, and in the case of Bridge Agency MBS, that (i) that the portfolio may be made up of highly liquid securities that can be traded in and out of on a daily basis, unlike a direct real estate investment (ii) that the strategy seeks to use of various derivative instruments to hedge interest rate and other risks, and such hedging is not guaranteed and may not be effective, and (iii) the use of higher leverage to achieve targeted returns. Generally, while the other Clients are all currently closed-end vehicles, the General Partner may have the option (subject to the applicable Governing Documents) to convert such fund to an open-ended structure, which may open such Client up to certain additional risks identified herein and in the other Governing Documents. Use of Subscription Lines. The Clients regularly incur indebtedness and guarantee obligations with respect to investments and partnership expenses and enter into one or more credit facilities or

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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

guarantees which may be secured by the Fund Investors’ unfunded commitments as well as the Client’s assets in order to enable the Clients to make investments or pay expenses without making a capital call on the Fund Investors. The interest expense and other costs of any such borrowing will be borne by the relevant Client and, accordingly, may decrease net returns of such Client. Subscription lines may obligate limited partners to contribute capital on an accelerated basis if a Client fails to repay the amounts borrowed under a subscription line. Moreover, any limited partner claim against a Client would likely be subordinate to the respective Client’s obligations to a subscription line’s creditors. Interest will accrue on any such outstanding borrowings and interest is expected to accrue at a different rate than the preferred return, which will begin accruing when capital contributions to fund such investments, or repay borrowings used to fund such investments, are actually made to the relevant Client. Drawing down on a subscription line allows a General Partner to fund investments and pay partnership expenses without calling capital, potentially for an extended period of time, subject to the applicable Governing Documents. Drawing down on a subscription line to fund an investment could result in a Client applying disposition proceeds from such investment to repay the borrowing and its related interest and expenses on the subscription line without a preferred return accrual on the amount invested for the Client. Accordingly, subscription line borrowings have the potential to support the distribution of proceeds to limited partners and increase the potential carried interest for the relevant General Partner. In light of the foregoing, an Investment Adviser and General Partner has an incentive and conflict of interest to cause such vehicle to borrow in this manner in lieu of drawing down capital commitments, subject to the applicable Governing Documents. Service Providers. A General Partner, Investment Adviser and its personnel maintain relationships with service providers (including lenders, brokers, insurance companies, accountants, attorneys, investment banking firms and other professional service providers), and such service providers may be investors in a Client or may be sources of opportunities for or counterparties in other transactions with the Client or such Investment Adviser. Service providers are generally entitled to indemnification under the terms of the service contracts or other arrangements entered into with the Clients or the respective General Partner, which costs and expenses of such indemnification would be borne by the respective Clients. The Investment Adviser and its affiliates and personnel may receive other benefits from these relationships that are not made available to the Client. For example, the Investment Advisers or their affiliates may, or may cause the Funds to contract with, pay fees to, or engage in transactions with businesses in which the Investment Advisers or their affiliates or personnel of the Investment Advisers or affiliates hold an interest. To the extent the Investment Advisers or their affiliates or personnel of the Investment Advisers or affiliates have invested in such businesses or invest additional amounts in such businesses, they would receive direct or indirect compensation (including in some cases the right to receive or acquire additional ownership interests), in connection with the utilization of such services or products by the Funds or investments held by the Funds. This presents a conflict of interest, as it may influence the Client or such Investment Adviser in deciding whether to select such a service provider or have other relationships with that service provider. Service providers to a Client or the Investment Adviser may charge different rates for their services or may have different arrangements for specific types of services, which may be more beneficial to certain of such persons than others or may benefit the service provider or its affiliates to a greater degree than Page 49 of 75

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

the benefit accorded to the Client. These benefits may include more favorable rates or arrangements available to the service provider than those payable by the Client, and the Client will not be entitled to share in any such benefits. Additionally, certain third-party advisors and other service providers and vendors to a Client and its portfolio investments (including accountants, administrators, lenders, bankers, brokers, attorneys, consultants, title agents, property managers and investment or commercial banking firms) are owned by Bridge, its Clients, Apollo, Apollo Clients or its affiliates or provide goods or services to, or have other business, personal, financial or other relationships with, Bridge, Apollo and their personnel. Although Bridge seeks to select service providers and vendors it believes are most appropriate in the circumstances based on its knowledge of such service providers and vendors (which knowledge is generally greater in the case of service providers and vendors that have other relationships with Bridge), the relationship of service providers and vendors to Bridge as described above will, in certain circumstances, influence Bridge in deciding whether to select, recommend or form such an advisor or service provider to perform services for a Client or a portfolio investment, the cost of which will generally be borne directly or indirectly by the Client, and can be expected to incentivize Bridge to engage such service provider over a third party, utilize the services of such service providers and vendors more frequently than would be the case absent the conflict, or to pay such service providers and vendors higher fees or commissions than would be the case absent the conflict. Bridge can be expected to also have an incentive to invest in or create service providers and vendors to realize these opportunities. Furthermore, Bridge will, from time to time, encourage third-party service providers to a Client and its portfolio investments to use other Bridge-affiliated service providers and vendors in connection with the business of a Client, portfolio investments, and unaffiliated entities, and Bridge has an incentive to use thirdparty services providers who do so as a result of the indirect benefit to Bridge or Apollo and additional business for the related service providers and vendors. Fees paid to or value created in these service providers and vendors do not offset or reduce the management fee payable by the investors of a Client and are not otherwise shared with a Client unless required by applicable Governing Documents. In some cases, it is possible that an affiliated service provider could earn fees in connection with the structuring, placement or syndication of any margin loan that is directly or indirectly for the benefit of a Client or could earn fees in connection with providing services in respect of certain borrowings (including back leverage) (even if the sole lenders are other Clients or Apollo Clients, members of Apollo and/or their respective portfolio investments) which could include the structuring, placement or syndication of any such credit facility or financing to support such back leverage or other financing efforts, and such fees would not offset Management Fees. In the event service providers are affiliates of Bridge (as opposed to third parties), the engagement of such providers must typically comply with the conditions applicable to affiliate transactions, if any, set forth in the Clients’ Governing Documents. Real Estate Marketing Campaigns. Consistent with market practice for residential real estate investments, certain Clients that own residential real estate may choose to engage in marketing campaigns designed to enhance occupancy through lease renewals or new leases at a specific real estate property owned by a Client. The cost of these marketing campaigns is borne directly by the respective property and indirectly by Fund Investors. These marketing campaigns can differ by

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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

property, region, or Client. In some cases, these marketing campaigns include bonus payments to property management employees affiliated with the Investment Advisers for achieving leasing targets. These bonus payments can create a conflict of interest. In the event that a property owned by one Client was offering a bonus payment for a new lease, a property management employee working at a property for another Client would be incentivized to make referrals to the property with bonus payments as part of their marketing budget, even if such properties are owned by a separate Client. The costs of these marketing campaigns, including any bonus payments paid to property management employees, do not offset any management or any other fees paid to any affiliates of the Investment Advisers. Hedging Transactions. In connection with certain investments, Clients could employ hedging strategies (by means of derivatives, in support of financing techniques, or otherwise) that are designed to reduce the risks to Clients of fluctuations in interest rates and other asset prices, as well as other identifiable risks. While the transactions implementing such hedging strategies are designed to reduce certain risks, such transactions themselves could entail certain other risks such as the risk that counterparties to such transactions could default on their obligations and the risk that the rates, prices and/or cash flows being hedged behave differently than expected. Unanticipated changes in interest rates, securities, commodities and other asset prices or other events related to hedging activities could result in a poorer overall performance for Clients than if they or their investments had not implemented such hedging strategies. Foreign Corrupt Practices Act Considerations. The Investment Advisers are subject to a number of laws and regulations governing payments and contributions to public officials or other parties, including restrictions imposed by the U.S. Foreign Corrupt Practices Act (“FCPA”) and other applicable anti-corruption laws, anti-bribery laws and regulations, as well as anti-boycott regulations, to which they are subject. In recent years, the U.S. government has devoted greater resources to enforcement of the FCPA and sanctions and export control laws. Any determination that an Investment Adviser has violated these laws could subject it to, among other things, civil and criminal penalties, material fines, profit disgorgement, injunctions on future conduct, securities litigation and a general loss of Fund Investor, any one of which could adversely affect the Investment Advisers’ business prospects and financial position, as well as a Client’s ability to achieve its investment objective and conduct its operations. Monetary Policy and Governmental Intervention. The U.S. Federal Reserve (the “Federal Reserve”) and global central banks take actions in response to inflation metrics, such as through benchmark interest rates, asset purchase programs and lending facilities. Further, the executive branch of the U.S. government is issuing a number of tariffs and other trade protection measures through executive orders and taking actions to reduce or eliminate staffing and budgets at various federal agencies and programs. These changes could materially and negatively impact interest rates, supply chains, inflation, availability of financing, and world economies generally, which in turn could affect the performance of the investments of Clients. Inflation Risk. Inflation and rapid fluctuations in inflation rates have had in the past, and may in the future have, negative effects on the economies and financial markets, particularly in emerging

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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

economies, but also in more developed economies, including in the US economy which could be experiencing inflation in certain markets. For example, wages and prices of inputs increase during periods of inflation, which can negatively impact returns on investments. In an attempt to stabilize inflation, countries may impose wage and price controls or otherwise intervene in the economy. Governmental efforts to curb inflation often have negative effects on the level of economic activity. There can be no assurance that inflation will not become a serious problem in the future and have an adverse impact on a Client’s returns. If a portfolio company is unable to increase its revenue in times of higher inflation, its profitability might be adversely affected. A Client’s portfolio companies could in some cases have long-term rights to income linked to some extent to inflation, including, without limitation, by government regulations and contractual arrangements. Typically, as inflation rises, a portfolio company will earn more revenue but also will incur higher expenses; as inflation declines, a portfolio company might be unable to reduce expenses in line with any resulting reduction in revenue. A rise in real interest rates would likely result in higher financing costs for portfolio companies and Clients and could therefore result in a reduction in the amount of cash available for distribution to investors. Benchmark Rates. Interbank Offered Rates (“IBORs”), floating rate benchmark indices based on the cost of short-term, unsecured, interbank borrowing, have been the subject of national, international, and regulatory guidance and proposals for reform, which may cause such benchmarks to perform differently than in the past or have other consequences which cannot be predicted. The Secured Overnight Financing Rate (“SOFR”), an index calculated by reference to short-term repurchase agreements, backed by Treasury securities, was identified as the replacement rate for the US dollar London Interbank Offered Rate (“LIBOR”), which ceased publication in June 2023. SOFR is a relatively new reference rate with a limited history, and it remains difficult to predict its future performance. With respect to other IBORs, other alternative reference rates have been recommended in the relevant jurisdictions. The continued transition away from IBORs as a benchmark reference for interest rates may affect the cost of capital and may require amending or restructuring debt instruments and related hedging arrangements for Clients and their portfolio investments, and may impact the value of floating rate instruments based on IBORs that are held or may be held by Clients in the future, which may result in additional costs or adversely affect a Client’s liquidity, results of operations and financial condition. Further, it remains unclear to what extent these alternative reference rates will attain market acceptance as the transition away from the IBOR benchmarks progresses. As such, it is not possible to predict all potential effects of these changes on US and global credit markets. Investors should be aware that: (i) any changes to benchmark rates described in the previous paragraph could cause an interest or other reference rate to be lower and/or more volatile than it would otherwise be; (b) if the applicable rate of interest on any loan is calculated with reference to a tenor or currency which is discontinued, such rate of interest could then be determined by the provisions of the affected loan, which could include determination by the relevant calculation agent based on market convention that may or may not be developed at that time, or the loan

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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

could otherwise be subject to a certain degree of contractual uncertainty; (c) the administrators of benchmark rates will not have any involvement in the investments of Clients and could take any actions in respect of benchmark rates without regard to the effect of such actions on such investments; (d) any uncertainty in the value of a benchmark rate, or any uncertainty in the prominence of a benchmark rate as a benchmark interest rate due to the recent regulatory reform could adversely affect liquidity of Clients’ debt investments in the secondary market and their market value; and (e) an increase in alternative types of financing in place of benchmark ratebased loans (resulting from a decrease in the confidence of borrowers in such rates) could make it more difficult to source loans or reinvest proceeds in loans. If any benchmark rate is discontinued, including SOFR, it is uncertain whether broad and consistent replacement conventions and methodologies will be developed in the lending market and, if conventions develop, what those conventions will be and whether they will create adverse consequences for an issuer of debt obligations or the holders of any such debt obligations. If no such conventions develop, it is uncertain what effect broadly divergent interest rate calculation methodologies in the markets will have on the price and liquidity of the lending market and the ability of Bridge to effectively mitigate interest rate risks. Though most newly originated debt obligations in which a Client could seek to make investments are likely to provide mechanisms to amend the reference rate for their applicable interest rates, there can be no assurance that any such amendment (i) will be entered into, (ii) that is entered into will effectively mitigate interest rate risks or result in an equivalent methodology for determining such interest rates, (iii) will be entered into prior to any date on which the relevant debtholders, such as Clients in their capacity as debtholders, suffer adverse consequences from the elimination or modification or potential elimination or modification of SOFR or other benchmark rates or (iv) will not have a material adverse effect on a Client in its capacity as a debtholder and the liquidity of such floating rate investments. Any of the above or any other significant change to the setting of a benchmark rate could have a material adverse effect on the value of, and the amount payable under any loan or other debt instrument held by a Client which pays interest linked to a benchmark rate. Given the structural differences in alternative rates, Bridge has assessed impacted systems and processes to confirm operational readiness. Significant effort is required to transition to the use of new alternative reference rates, including to address the changes to impacted systems and processes, as well as to negotiate and implement necessary changes to existing contractual arrangements. Co-Investments. The Investment Advisers may offer co-investment opportunities in their sole discretion and may allocate such co-investments on the basis of the size of investor commitments to the Clients, the size or risk of an investment, strategic or other benefits, or the need for additional capital in order to complete an investment. In making such allocation decisions, the General Partner will be entitled to consider any interests and factors as it desires, including placing its own interests ahead of the interests of any other person. The allocation of co-investment opportunities will in many or all cases involve a benefit to the Investment Adviser, Bridge or their affiliates, including, without limitation, the receipt of fees or allocation of carried interest from the co-investment opportunity and Bridge is incentivized to offer such co-investments to certain co-

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Item 8. Methods of analysis, investment strategies and risk of loss

investors over others when the economic arrangement with such co-investors is more favorable to Bridge or Apollo and/or Clients they manage. Co-investment opportunities may also be offered to affiliates of the Investment Advisers or third parties to the exclusion of some or all of the investors in a Client in its General Partner’s sole discretion, and Bridge and Apollo may establish Clients for the sole purpose of investing in co-investment opportunities that arise and in which case result in more frequent co-investing opportunities offered to such Clients.

Read the rest of Item 8 (879 more words)

Additionally, given Apollo’s management of substantially all of certain insurance and financial businesses, Bridge is incentivized to allocate co-investment opportunities to such business which could create the appearance or existence of a conflict of interest insofar as Bridge being viewed as allocating coinvestment opportunities, including on a selective basis, to Apollo and/or certain insurance and financial businesses in which Apollo has a direct or indirect economic interest. The Investment Adviser may or may not charge management fees and/or carried interest in respect of coinvestments, as it determines in its sole discretion. While co-investment vehicles that invest alongside Clients are allocated their pro-rata portion of expenses related to investments, they generally will not be required to bear any portion of the organizational expenses or any other noninvestment related partnership expenses of such Clients (given that those other vehicles bear their own non-investment-related expenses). Co-investment vehicles do not generally share in broken deal expenses if such co-investment vehicles have not yet agreed to co-invest alongside the Client when the broken deal expenses are incurred. Investing in a Client does not give investors any rights, entitlements or priority to co-investment opportunities. Finally, some of the co-investors with whom Clients co-invest could have pre-existing investments with Apollo. The terms of those pre-existing investments could differ from the terms upon which such persons could invest with Clients. Side Letters. In accordance with common industry practice, each Fund, its General Partner, any of the Investment Advisers or Bridge routinely enters into “side letters” or similar writings, agreements or understandings with Fund Investors which have the effect of establishing favorable rights, benefits or privileges under, or altering or supplementing, the terms of the respective Governing Documents without any further act, approval or vote of any other Fund Investors. These rights include, but are not limited to, certain “most favored nations” processes, economic rights, liquidity, withdrawal or transfer rights, different performance hurdles, minimum investment amounts, co-investment allocation or participation rights, voting rights, management fee offsets for certain fees, information rights, additional or modified reporting obligations, excuse or exclusion rights, agreements to assist with the taking or defending of certain tax positions, obligations and restrictions on the applicable General Partner with respect to its discretion on certain matters and other rights or terms including those requested in light of particular investment, legal, regulatory or public policy characteristics of a Fund or a particular Fund Investor. As a result of certain side letters, limited partners investing in the same Fund could have different returns and receive different information. Any rights established, or any terms of the respective Governing Documents so altered, modified or supplemented in a side letter with a Fund Investor, will govern with respect to such Fund Investor notwithstanding any other provision of the respective Governing Documents. Additional benefits provided to a Fund Investor via a side letter will not necessarily be disclosed or available to other Fund Investors. By their nature, side letters will give preferential treatment to those who have entered into such arrangements. For example, Page 54 of 75

Item 9 – Disciplinary Information

if the Governing Documents of a Fund provide that expenses incurred in connection with the compliance of side letter provisions are borne as organizational or partnership expenses, all investors of such Fund would bear such expenses and not solely the Fund Investor that entered into that specific side letter. Further, side letters may have adverse effects, such as placing limitations on the allocation of certain investment opportunities to other Clients. Any coinvestment rights granted in a side letter or other similar agreement may result in fewer coinvestment opportunities (or reduced or no allocations) being made available to other investors. Except as otherwise agreed with a Fund Investor or required by law, a side letter with one Fund Investor is not required to be disclosed to other Fund Investors. Dependence on Key Professionals. The ability of a Client to achieve its investment objective will be dependent on the diligence, skill, judgment, business contacts and personal reputations of senior investment professionals or other key personnel. These individuals possess substantial experience and expertise in investing, are responsible for locating and executing on the Client’s investments and have significant relationships with the institutions that are the source of many of our investment opportunities. Therefore, the departure of one or more of these individuals could have a materially adverse effect on the ability of the Client to achieve its investment objectives. Bridge includes publicly traded equity as a portion of its compensation to certain personnel, including senior investment professionals. To the extent such personnel are unable to sell such equity, or the value of such equity decreases, such personnel may have a reduced incentive to devote the necessary time and attention to the investment activities of such Client or otherwise remain at Bridge. Further, if such an individual joins competitors or forms competing companies, it could result in the loss of significant investment opportunities. Other Risks. Please see each Client’s Governing Documents for a more detailed list and description of the risks involved for such Client and any investment in such Client. Item 9 – Disciplinary Information Certain management persons and employees of Apollo are management persons of the Investment Advisers. As such, the items noted below are required to be disclosed pursuant to this

Item 9. Disciplinary information

be disclosed pursuant to this Item 9. On August 23, 2016, without admitting or denying any wrongdoing, certain related persons, namely Apollo Management V, L.P., Apollo Management VI, L.P. Apollo Management VII, L.P. and Apollo Commodities Management, L.P., consented to the entry of an order to cease and desist from committing or causing any violations and future violations of Section 206(2) and 206(4) of the Advisers Act and Rules 206(4)-7 and 206(4)-8 thereunder.

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According to the SEC order, such related persons did not provide sufficient pre-commitment disclosure regarding the possibility of accelerating otherwise authorized fees upon termination of management consulting agreements with their portfolio investments, a related person did not adequately disclose that interest from a loan from a private equity fund to its general partner would be allocated to the general partner, such related persons did not adequately supervise a former senior partner’s expense

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Item 10 – Other Financial Industry Activities and Affiliations

reimbursement practices and such related persons failed to adopt and implement policies and procedures reasonably designed to prevent violations of the Advisers Act and its rules. As part of the settlement, such related persons agreed to pay $37,527,000 of disgorgement and $2,727,552 of prejudgment interest to limited partners of its fund and a civil monetary penalty of $12,500,000 to the SEC. On January 13, 2025, the SEC issued a settled administrative order finding that Apollo Capital Management willfully violated Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder. The order also found that Apollo Capital Management failed to reasonably supervise its employees within the meaning of Advisers Act Section 203(e)(6). Specifically, the order found that from at least December 2019 to January 13, 2025, certain personnel sent and received communications on platforms that were not approved for business purposes, many of which were not preserved on firm systems. In numerous instances, ACM managers themselves communicated using these unapproved communication platforms. In determining to accept ACM’s offer of settlement, the SEC considered steps undertaken by Apollo Capital Management prior to and after being approached by the SEC staff, as well as cooperation afforded the SEC staff. Apollo Capital Management also agreed to complete certain undertakings, including an internal review of its electronic communications policies and procedures. In connection with the order, Apollo Capital Management admitted the facts alleged in the order and acknowledged that its conduct violated the federal securities laws. Apollo Capital Management was (i) censured; (ii) ordered to cease and desist from committing or causing any violations and any future violations of Advisers Act Section 204 and Rule 204-2(a)(7) thereunder; and (iii) ordered to pay a penalty of $8.5 million. Item 10 – Other Financial Industry Activities and Affiliations The Investment Advisers are affiliated with Apollo and its affiliates, including Apollo’s affiliated investment advisers, sponsors, private funds, other investment vehicles, affiliated service providers and other entities. The following enumerates certain conflicts of interest arising from the financial industry activities and affiliations of the Investment Advisers and their affiliates, including those of Apollo and its affiliates that the Investment Advisers believe are material to the advisory business or Clients of the Investment Advisers. Additional Affiliated Registered Investment Advisers. The Investment Advisers are under common control with Bridge Net Lease Fund Manager LLC, a registered investment adviser. Additionally, the Investment Advisers are affiliated with the following AGM affiliates that are registered with the SEC as investment advisers under the Advisers Act and are associated with numerous Apollo affiliated relying advisers.

Apollo Capital Management, L.P. Apollo Investment Management, L.P. Apollo Credit Management, LLC Apollo Credit Capital Adviser, LLC Apollo Real Estate Fund Adviser, LLC ARIS Management, LLC

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Item 10 – Other Financial Industry Activities and Affiliations

Apollo Manager, LLC Apollo S3 RIC Management, L.P. Apollo MPS Management, LLC

Affiliated General Partners and Other Activities. The Investment Advisers have various affiliated entities, including entities that act as General Partner or managing member to the Clients of the Investment Advisers and affiliated entities that provide services to the Clients or to the assets held by the Clients. These affiliates earn fees from the Investments Advisers’ Clients, which will not be shared with or credited to Fund Investors. The fees earned by these affiliated companies are set forth in more detail herein under the heading “Item 5 – Fees and Compensation” and in the Governing Documents. Affiliated Insurance Company. Bridge Investment Group Risk Management, Inc. is an insurance company registered in the state of Utah (the “Bridge Insurance Captive”). Clients pay fees and premiums to the Bridge Insurance Captive and the Bridge Insurance Captive manages the master insurance program with third party insurance companies and bears the risk of certain insurable losses. Affiliated Broker-Dealers. Apollo Global Securities, LLC (“AGS”), is a securities broker and dealer registered with the SEC and admitted to membership in FINRA. FINRA authorizes AGS to engage in certain types of business, and in secondary market trades involving securities it is permitted to trade, AGS has the ability to execute trades on a principal, riskless principal or agency basis and could elect to hold inventory of securities as part of its secondary market activities in anticipation of demand for such securities (all of the foregoing activities, “Secondary Trading”). AGS also supports asset-backed securities sourced by Apollo affiliates, including providing secondary market trading services with respect to such securities. In the context of Clients and Apollo Clients, AGS seeks to provide secondary market liquidity where AGS served as a principal underwriter, selling or placement agent in connection with the primary offering. AGS earns fees (e.g., a spread, mark-up, or commission) for its role in connection with secondary market transactions, among others. Affiliated transactions through AGS and/or its affiliates are subject to Apollo’s best execution practices. AGS does not receive, hold/custody, or otherwise handle customer funds and/or securities. In addition to AGS, Griffin Capital Securities, LLC and Athene Securities, LLC, both of which are subsidiaries of Apollo, are broker-dealers registered with the SEC and admitted to membership in FINRA. Affiliated Loan Origination and/or Servicing Businesses. Affiliates of Apollo Clients, including their existing or potential portfolio investments (including certain platform investments) are engaged in the loan origination and/or servicing businesses. In connection with lending activities, such loan origination and/or servicing businesses could receive certain fees, including, arranger, brokerage, placement, syndication, solicitation, underwriting, agency, origination, sourcing, structuring, collateral management, or loan administration, advisory, servicing, commitment, facility, float or other fees, discounts, spreads, commissions and concessions and other fees received. A Client or the issuers of financial instruments held by a Client could acquire loans originated, structured, placed and/or arranged by such affiliated party loan origination and/or servicing businesses and in

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Item 10. Other financial industry activities and affiliations

respect of which such businesses receive fees. For example, loans, such as term loans and revolvers, originated by Bridge affiliates, Clients, Apollo Clients and/or their respective portfolio investments, including subscription lines, net asset value-based facilities, ABLs, and other similar facilities, could involve the engagement of related-party loan origination or servicing businesses as a service provider.

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In connection with such activities, conflicts of interest usually arise with respect to, among other things, the role of any service provider engaged in the loan origination or servicing businesses in such transaction, including the information available to such person with respect to such transaction and the fees and other terms (including as to whether such terms are at market rates) on which such person is participating in such transaction. Clients can acquire loans originated, structured, arranged and/or placed or arranged by related-party loan origination or servicing businesses, including Bridge affiliates, Clients, Apollo Clients and their respective portfolio investments and affiliated service providers. To the extent Bridge makes a determination that the long-term hold of an investment should be reduced from the original amount funded, an affiliate could be engaged to provide syndication or other services as part of the effort to selldown and receive a fee for the provision of such services; however, it is possible that the portfolio investment does not pay for its expenses of the applicable affiliated service provider, in which case such expenses will be borne by the Client and will not, for the avoidance of doubt, offset any Management Fees paid by such Client, and to the extent applicable, will be capitalized as part of the amount invested by such Client as part of the acquisition price, financing or otherwise for consummated investments and therefore included in the adjusted cost of the relevant investment for such Clients for purposes of calculating Management Fees. Any such fees or other compensation will be retained by and be for the benefit of such affiliated service provider. In connection with loan origination, structuring, placement or arrangement activities or other loan origination or servicing activities for which affiliated loan origination or servicing business could be retained, such Bridge affiliates or other applicable person will receive fees, compensation, and reimbursement for costs or expenses. Such fees can be charged on a cost reimbursement, costplus, market, or other basis (as determined by Apollo). Further, affiliated service providers can, from time to time, participate in underwriting syndicates and/or selling groups with respect to the equity and debt instruments issued or acquired by Clients or their existing or potential portfolio investments and other entities in or through which Clients or their existing or potential portfolio investments invest, or in connection with a Client’s disposition of all or a portion of a portfolio investment to a third party such that an affiliated service provider could facilitate or provide seller financing in connection with such disposition. Subject to the requirements in the Investment Company Act, to the extent applicable to any Client, any such affiliated service provider will receive fees, other compensation or reimbursements for costs or expenses in connection with providing services to Clients or their existing or potential portfolio investments or third parties. Subject to the Governing Documents of a Client, any such fees, compensation or reimbursements received by an affiliated service provider will not be applied to reduce Management Fees or other fees payable by a Client or any of its investments or otherwise directly or indirectly benefit such Client or any of its investors. Such fees will otherwise be borne by the Client or by the issuers of financial instruments held by the Client.

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Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Affiliated Title Agent. Nations Land Services (“NLS”) acts as a title agent in facilitating and issuing title insurance in connection with investments by Apollo Clients, affiliates, related parties, and third parties, and is expected to act as a title agent in facilitating and issuing title insurance in connection with investments by Clients of the Investment Advisers. In connection with such services to Clients and their portfolio investments, NLS earns fees, which would have otherwise been paid to third parties and are not otherwise offset against fees payable by a Client. An affiliate of Bridge receives distributions from NLS based on its equity interest in NLS. As a result, there is an inherent conflict of interest that incentivizes Bridge to engage NLS over a third party. Other Activities and Relationships. Employees of the Investment Advisers, Apollo and their affiliates serve on the boards of directors of companies, including companies in which the Clients, Apollo Clients, the Investment Advisers or their affiliates have a financial interest. Serving in such capacity may give rise to conflicts to the extent that such employee’s fiduciary duties as a director conflict with the interests of a Client. Additionally, in the event any such persons (i) obtain material non-public information with respect to any such company; or (ii) is subject to trading restriction pursuant to the internal policies of such company, the Investment Advisers could be prohibited from engaging in transaction with respect to the securities or instruments of such company. Such a prohibition could have an adverse effect on Clients. Such positions could also have the effect of impairing the ability of the Investment Advisers to sell the related securities when, and upon the terms, they could otherwise desire. In addition, because of conflicting fiduciary duties, Investment Advisers could be restricted in choosing investments for Clients, which could negatively impact returns received by the Client. For example, an Investment Adviser would be restricted in choosing investments for a Client if an employee of the Investment Advisers, Apollo and their affiliates obtained certain material non-public information. The Investment Advisers and certain affiliates are registered or have Clients subject to regulatory or reporting requirements with certain foreign financial regulatory authorities, including the UK Financial Conduct Authority in the United Kingdom, the Commission de Surveillance du Secteur Financier in Luxembourg, and the Cayman Islands Monetary Authority. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Investment Advisers have adopted a code of ethics as part of its compliance program (the “Compliance Program”) pursuant to Rule 204A-1 under the Advisers Act that establishes standards of conduct for its supervised persons. The Compliance Program includes general requirements that such supervised persons comply with their fiduciary obligations to Clients and applicable securities laws, and specific pre-clearance and reporting requirements relating to, among other things, personal trading, outside business affiliations, political contributions, conflicts of interest, certain investments, and confidentiality of Client information. The Compliance Program requires all supervised persons to make compliance certifications attesting to compliance with the compliance program on a quarterly and annual basis. It requires supervised persons to report any violations of the Compliance Program promptly to the Investment Advisers’ Chief Compliance

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Officer. Nothing contained in the Compliance Program prohibits or limits any supervised person from reporting possible violations of applicable laws or regulations to any governmental agency or entity or engaging in any other conduct that is protected under applicable whistleblower provisions. The Investment Advisers reserve the right to refine and modify its Compliance Program and other policies and procedures over time. No current or prospective Fund Investor should invest with any Client of the Investment Advisers on the basis of, or otherwise rely on, the provisions contained in the Compliance Program, and any such refinements or modifications have the potential materially to affect the investments available to the Clients or the expenses borne by the Clients. Current and prospective Fund Investors may obtain a copy of the Investment Advisers’ code of ethics by contacting the Chief Compliance Officer at 1-801-506-1463 or compliance@bridgeig.com. Conflicts of Interest Active employees of Bridge, including those employees who are on Investment Committees or have management positions of the General Partners of the Funds, have significant real estate and other investments outside of Bridge and its Clients. Further, Apollo advises various clients that have overlapping or competing investment objectives with Clients, which gives rise to inherent conflicts of interests. The Investment Advisers will endeavor to resolve such conflicts in a manner they deem fair and equitable to the extent possible under the prevailing facts and circumstances, including as noted below. Limited Partner Advisory Committee. To help mitigate certain conflicts of interest, each discretionary Fund may establish a LPAC that consists of unaffiliated limited partners. The Investment Advisers generally attempt to resolve conflicts of interest in a fair and equitable manner, but conflicts will not necessarily be resolved in favor of a Client’s interest. The LPAC for each respective Client is authorized to give certain consents on behalf of such Client, including consenting to certain conflicts of interest situations as well as certain approvals or consents required by U.S. federal securities laws. All limited partners of a particular Fund are bound by the determinations of the LPAC regardless of whether an individual limited partner is represented by a member of the LPAC. If the LPAC consents to a particular matter and the Investment Advisers act in a manner consistent with, or pursuant to the standards and procedures approved by, the LPAC, or as otherwise provided in the Governing Documents, then the Investment Adviser and its affiliates will not have any liability to a Fund or the Fund Investors for such actions taken in good faith. The LPAC will not necessarily represent the interests of all Fund Investors. Certain LPAC members are expected to have various business and other relationships with the Investment Advisers or their affiliates (including longstanding investment relationships with Bridge or Apollo). In certain circumstances, these factors will influence LPAC members to be more aligned with the Investment Advisers and the relevant General Partner and favor proposals brought to the LPAC. A Fund’s LPAC is expected to be comprised of representatives of limited partners with divergent interests, objectives, regulatory treatment, tax sensitivities, portfolio compositions, experience, and other factors. Each member of the LPAC generally act in the interests of the Fund Investor with which it is associated, and the members of the LPAC are themselves subject to potential

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conflicts of interest in approving or rejecting proposals based on factors that are applicable to the firms they individually represent, rather than considerations relevant to limited partners as a whole. For example, in a cross transaction situation where an Investment Adviser arranges for a Client to purchase an investment from or sell an investment to another Client, if an LPAC member has an interest in both Clients involved in the cross transaction, such member could favor one Client over the other if such member’s interests are more aligned with the Client it favors. In addition, if the member has an interest unrelated to the Investment Advisers, such as an interest in an Apollo Client involved in a transaction with a Client, it could not act in the best interests of the Client that it represents. A General Partner is authorized to appoint limited partners to the LPAC of its Fund in its sole discretion, and is permitted to consider various factors including the timing and amount of a limited partner’s commitment to a Fund or future Fund, their perception of a limited partner’s effectiveness on an LPAC, legal and regulatory considerations, the interests of the limited partner and the degree to which they are likely to align with the relevant Fund and the General Partner and other factors. Generally, Fund Investors will not be entitled to control the selection of members of the LPAC or to review the actions or deliberations of the LPAC. For additional details regarding the LPAC of each Fund, please refer to the applicable private placement memorandum under the headings “Risks and Potential Conflicts of Interest” and “Advisory Committee” or similar headings. Managing Conflicts Outside of the Limited Partner Advisory Committee. As further described in the Governing Documents, not all actual or apparent conflicts of interest will require LPAC review or consent. In particular, the Governing Documents generally provide that if an affiliate of any General Partner is aware of an investment opportunity that falls within an applicable Fund’s investment guidelines and parameters, such investment opportunity must be presented to the applicable Fund. If such investment opportunity fits within the parameters of the applicable Fund and would be pursued by such Fund, the applicable Investment Committee will review the opportunity at the next scheduled Investment Committee meeting and will either vote to (i) assume the affiliate’s bidding position with respect to the investment opportunity, or (ii) refuse to take further action with respect to the investment opportunity on behalf of the applicable Fund. The members of the Investment Committee may not elect to take further action with respect to the investment opportunity for any reason. Should the Fund refuse to take further action with respect to such investment opportunity, then the affiliate would generally be permitted to pursue and invest in such investment opportunity. Personal and Affiliate Conflicts. Certain employees of the Investment Advisers or their affiliates may, directly or indirectly, engage in other business ventures or outside affiliations in addition to providing services to the Funds. For example, certain employees of the Investment Advisers or their affiliates are licensed real estate agents/brokers and may engage in non-Client-related real estate sales and leasing transactions provided that such activities occur outside of regular business hours and do not compete with the business of the Investment Advisers and their affiliates. Further, employees of the Investment Advisers or their affiliates provide services to multiple Clients, including Clients with similar or overlapping investment mandates. Conflicts of interest arise due to the time, attention and resources devoted by such employees to other business ventures, outside affiliations or various Clients. For additional details please refer to the applicable

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Governing Documents under the headings labeled “Other Activities; Restrictions on Competing Funds” and “Restrictions on Investments Away from the Partnership” or similar headings. The Investment Committees of the Funds generally consist of Bridge’s active employees and affiliates and therefore have inherent conflicts of interest. Certain inherent conflicts of interest arise from the fact that: (i) the Investment Advisers provide investment management services to more than one Client; (ii) Clients have one or more overlapping, competing or related investment objectives or strategies; and (iii) Bridge and Apollo are affiliated and provide investment management services to Clients that also could have overlapping, competing, or related investment objectives or strategies; (iv) different Clients, including Apollo Clients, are expected to participate in different classes of the capital structure of the same portfolio investment; and (v) Apollo and Apollo Clients invest in a broad base of portfolio companies. Clients of the Investment Advisers will be incentivized, directly or indirectly, to do business with these portfolio companies. In addition, the investment strategies employed by Bridge for current and future Clients and/or by Apollo for Apollo Clients could conflict with the strategies employed by Bridge for current and future Clients and could affect the prices and availability of the securities and other assets in which such Clients invest. Certain Financing Transactions. Unless Clients’ Governing Documents provide otherwise, Clients are authorized to engage in cross investments with, and provide financing to or receive financing from Bridge, Apollo, Clients, Apollo Clients or any of their respective affiliates and can engage in financing transactions, including acting as a committed underwriter or guarantor in any such transaction, with any such person (including, in each case, in connection with a disposition of a portfolio investment). The proceeds of such financing transactions could be used to, among other things, repay, redeem, or otherwise benefit Bridge, Apollo, Clients, Apollo Clients or any of their respective affiliates. Bridge anticipates that transactions of this type would be entered into where they are expected to be beneficial to a Client or the applicable portfolio investment, such as where Bridge believes that participating in the underwriting of a portfolio investment’s debt issuances— including in connection with a Client’s acquisition and financing of a portfolio investment—can provide benefits to both the Client that holds an interest in the relevant portfolio investment and the Clients participating in the financing opportunity. Given the actual or potential conflicts of interest to which Bridge could be subject in transactions of this type, Bridge anticipates in any debt financing involving the acquisition of a controlling interest in a portfolio investment by another Client or an Apollo Client that, Bridge affiliates and Clients that commit to or invest in such debt financings will do so on terms not materially less favorable to other Clients or the applicable portfolio investment than the terms of the debt financing that would apply to unaffiliated third parties participating in the same tranche of such debt financing. In circumstances where the financing is asset-based or otherwise non-recourse financing, Bridge could undertake similar measures that could also involve, among other things, seeking to obtain market terms or benchmarks for comparable transactions from unaffiliated third parties or other indicia of fairness to the applicable Client. However, where Bridge or Clients do not control the relevant investment, the foregoing measures are not expected to be undertaken, in light of the involvement of other persons unaffiliated with Bridge in such investment. Any

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financing transactions of this type will be made in accordance with Bridge’s policies and procedures then in effect. Any cross investments or financing transactions of this type will be made in accordance with the Investment Advisers’ policies and procedures then in effect, and (x) neither Bridge, Apollo, Client, Apollo Client, or any of their affiliates (each, a “Bridge Person” and collectively, “Bridge Persons”), will be prohibited from acquiring, or otherwise engaging in transactions, including financings, with respect to securities or other financial instruments of any person (including a special purpose vehicle) in which another Client has a financial interest (whether in the same or a different class of securities or other financial instruments) or selling, divesting, making further acquisitions or otherwise engaging in transactions with respect to securities or other financial instruments of such person, including in connection with or following a co-investment and (y) a Client will not be prohibited from acquiring, or otherwise engaging in transactions, including financings, with respect to securities or other financial instruments of any person (including any special purpose vehicle) in which a Bridge Person has a financial interest (whether in the same or a different class of securities or other financial instruments) or selling, divesting, making further acquisitions or otherwise engaging in transactions with respect to securities or other financial instruments of such person, including in connection with or following a co-investment; provided, that any such transaction referred to in clause (x) is on market terms that are not materially less favorable to such entity than would have been the case if such entity were not an entity in which a Client had a financial interest, and any such transaction referred to in clause (y) is on market terms that are not materially less favorable to a Client than would have been the case if the Client were not an entity in which such an Bridge Person had a financial interest, in each case, as determined by Bridge. Related Financing of Counterparties to Acquire Investments or Assets from a Client and its Portfolio Investments. There could be situations in which an Apollo Client will offer and/or commit to provide financing to one or more third parties that are expected to bid for and/or purchase a portfolio investment (in whole or in part) from Clients. This type of financing could be provided through pre-arranged financing packages arranged and offered by an Apollo Client to potential bidders in the relevant sales process or otherwise pursuant to bilateral negotiations between one or more bidders and such client. Such financing arrangements, and the potential syndication thereof, could also include the engagement of affiliated service providers and the fees earned by such providers will not be subject to any offsets of Management Fees. For example, where a Client seeks to sell a portfolio investment (in whole or in part) to a third party in the normal course, an Apollo Client may offer the third-party debt financing to facilitate its bid and potential purchase of such portfolio investment. This type of arrangement would be expected to be offered in situations in which Bridge or its affiliates believe it provides benefits to a Client by supporting one or more third parties in its/their efforts to successfully bid for and/or acquire one or more portfolio investments. However, acquisition financing arranged and offered by Apollo Clients also creates potential conflicts of interest. In particular, an Apollo Client’s participation as a potential lender in the sales process could create an incentive to select a third-party bidder that uses financing arranged by such client

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to the potential detriment of the Client. Conversely, the participation of such clients as potential lenders could create an incentive for Bridge to agree to certain terms in an effort to facilitate the consummation of the sale by the Client. Affiliated service providers could also receive fees in connection with any such transaction, as described above, which would not necessarily have been the case if other Apollo Clients had not committed to the financing. Conflict Mitigation. In order to mitigate potential conflicts of interest in these situations, Bridge could seek to take one or more of the following actions (as it determines in its discretion) in satisfaction of its duties to Clients: (i) offer portfolio investments for sale in the normal course via competitive bidding processes designed to optimize the outcome for the Client owning such investment; (ii) engage one or more independent advisers, such as sell-side brokers or bankers, to administer and facilitate a commercially fair and equitable sales process; (iii) consult with investors and/or seek approval from the LPAC; and (iv) such other actions that Bridge deems necessary or appropriate taking into account the relevant facts-and-circumstances. However, there can be no assurance that any particular action will be feasible or effective in any particular situation, or that Bridge’s own interests will not influence its conduct, and it is possible that the outcome for Clients will be less favorable than otherwise would have been the case if Bridge did not face these conflicts of interest. In addition, the actions that Bridge pursues are expected to vary based on the particular facts and circumstances of each situation and, as such, there will be some degree of variation and potentially inconsistency in the manner in which these situations are addressed. In certain situations, Bridge could accept a bid for a portfolio investment from a bidder that received acquisition financing from an Apollo Client that is at a lower price than an offer that it received from a party that has independent financing sources. For example, although price is often the deciding factor in selecting to whom to sell a portfolio investment, other factors frequently influence the seller, including, among other things, closing conditions, lack of committed financing sources, regulatory or other consent requirements, and such other factors that increase the risk of the higher-priced bidder being able to complete or close the transaction under the circumstances. Bridge could therefore cause a Client to sell an asset to a third party that has received financing from another Apollo Client, even when such third party has not offered the most attractive price. In certain situations, affiliated service providers could receive fees, other compensation or reimbursements for costs or expenses in connection with providing such acquisition financing, and such fees, compensation or reimbursements received will not reduce Management Fees paid by Clients and will be retained by, and be for the benefit of, the affiliated service provider. Sharing of Services. In certain circumstances, in order to create efficiencies and optimize performance, one or more portfolio investments of a Client could determine to share the operational, legal, financial, back-office or other resources of another portfolio investment company of the Client, another Client, Apollo Clients or an affiliate of Bridge. In connection therewith, the costs and expenses related to such services will be allocated among the relevant entities on a basis that Bridge or its affiliate determines in good faith is fair and equitable (but which will be inherently subjective). Determining an allocable share of internal and other costs, or otherwise allocating costs, inherently requires the judgment of Bridge and there can be no

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assurance that the Client will not bear a disproportionate amount of any costs. In addition, it is possible that a portfolio investment could be in the business of providing goods or services that are, or could be, utilized by another portfolio investment, portfolio company or property, including a portfolio investment owned by an affiliate of Bridge, a different Client or a Apollo Client (and for this purpose, any such portfolio investment that is providing such services could be considered an affiliated service provider for purposes of the applicable Clients’ Governing Documents). The provision of such services by certain existing and potential portfolio investments could incentivize the Investment Advisers to facilitate arrangements with portfolio investments of other Clients, Apollo Clients or an affiliate of Bridge in order to create business opportunities for the portfolio investments providing such services. As a result of this conflict, services provided to a portfolio investment could not be the same in terms of quality and terms as they would be if they resulted from a negotiation with a third party. These types of arrangements will not require the consent of the applicable LPAC or Fund Investors. Procurement. There are situations in which an Investment Adviser or one of its affiliates, including affiliated service providers, is in a position of facilitating or otherwise making available portfolio investment goods, services, financing arrangements or other third-party group purchase arrangements (each such service or arrangement, a “Group Purchasing Opportunity”) and, as a result, certain portfolio investments of a Client could be counterparties or participants in agreements, transactions or other arrangements with third parties, the portfolio investments of other Clients, Apollo Clients or Apollo. Such Group Purchasing Opportunities could involve favorable procurement terms, including fees, servicing payments, rebates, discounts, or other financial benefits. An Investment Adviser could be eligible to receive favorable terms for its procurement due in part to the involvement of its portfolio investments or third parties in such Group Purchasing Opportunities, and any discounted amounts will not be subject to offset against the Management Fee or otherwise shared with Clients. As a result, an Investment Adviser could be incentivized to facilitate or seek to influence the participation of portfolio investments of Clients in Group Purchasing Opportunities with portfolio investments of other Clients, Apollo Clients, Apollo or third parties (and even if subject to fees and carried interest, will receive the applicable discount to which Clients are entitled), even though such Group Purchasing Opportunities could not be the most appropriate or offer the best terms. Portfolio Investment Relationships. A Client’s portfolio investments could be counterparties or participants in agreements, transactions, or other arrangements with other portfolio investments of such Client and portfolio investments of other Clients, Apollo Clients and/or Apollo or its affiliates that, although Bridge determines to be consistent with the requirements of such Clients’ governing agreements, may not have otherwise been entered into but for the affiliation with Bridge, and which may involve fees and/or servicing payments to Bridge-affiliated entities that are not subject to Management Fee offsets. For example, Bridge could, like other firms, in the future cause portfolio investments to enter into agreements regarding group procurement, benefits management, data management, technology development, purchase of title and/or other insurance policies (which may be pooled across portfolio investments and discounted due to scale), and other similar operational initiatives that may result in fees, commissions or similar payments and/or discounts being paid to Bridge or its affiliates, or a portfolio investment, including

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Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

related to a portion of the savings achieved by the portfolio investment. Moreover, Bridge and its affiliates are often eligible to receive favorable terms for procurement due in part to the involvement of portfolio investments of Clients in such arrangements, and any discounted amounts will not be subject to the Management Fee offsets or otherwise shared with the relevant Clients and one or more affiliated service providers could be engaged to facilitate such arrangements and receive fees, including from the participating portfolio investments, which could take the form of a percentage of the savings realized. In addition, portfolio investments of Clients may do business with, support, or have other relationships with competitors of a Client’s portfolio investments, and in that regard prospective investors should not assume that a company related to or otherwise affiliated with Bridge will only take actions that are beneficial to or not opposed to the interests of a Client and its portfolio investments. Bridge could also enter into or cause a Client or its portfolio investments to enter into, financing or similar transactions or arrangements in respect of balance sheet assets or accounts receivable held by such Client’s portfolio investments. For example, Bridge, its affiliates, Apollo Clients, or any of their respective portfolio investments, subsidiaries or special purpose vehicles could acquire one or a group of a Client’s portfolio investments’ interests in certain assets, accounts receivable or similar future cash flows. While any such transaction could provide liquidity, operating cash, or other benefits to the relevant portfolio investment, it could also result in such portfolio investment receiving a lesser return on the relevant assets than would have been the case had it retained them. Bridge will also be incentivized to cause portfolio investments to enter into such transactions both in its or its’ affiliates capacities as the counterparty or sponsor thereof, and in order to use the proceeds of such transactions to make distributions to Clients and investors, including carried interest distributions. Material Non-Public Information and Restricted Lists. Bridge has adopted the use of one or more restricted lists and related policies and procedures to provide for the proper handling of material non-public information to prevent violations of laws and regulations prohibiting the misuse of such information and to avoid situations that might create an appearance of misuse. The Bridge and Apollo compliance teams are responsible for monitoring the restricted lists, administering the related policies and procedures, overseeing potential and actual conflicts of interest, and escalating, as appropriate. There could be circumstances in which one or more individuals associated, including investment professionals and committee members otherwise involved in investment activities, will be precluded from providing services to Clients or from being involved in specific investment related activities or decisions because of certain confidential information available to those individuals or to other parts of Bridge or Apollo, or because of other applicable legal or regulatory restrictions resulting from their involvement. In such circumstances, applicable legal or regulatory restrictions could require such investment executives to recuse themselves from the relevant investment committees or otherwise from participating in investment activities or decisions relating to Clients’ investments. Conflicts Related to Possible Future Activities and Affiliate Activities. The Investment Advisers and their affiliates will expand the range of services they provide over time. Except as provided herein and in the applicable Governing Documents, the Investment Advisers and their affiliates will not

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be restricted in the scope of their business or in the performance of any such services (whether now offered or undertaken in the future) even if such activities could give rise to conflicts of interest, regardless of whether such conflicts are described herein. The Investment Advisers will endeavor to resolve such conflicts in a manner they deem fair and equitable to the extent possible under the prevailing facts and circumstances. Participation or Interest in Client Transactions Investment in Clients. Certain affiliates of the Investment Advisers invest in Clients alongside Fund Investors. Such affiliates generally receive a waiver or reduction of all or any portion of applicable management fee, incentive fee, carried interest, performance fee or performance allocation. Any personal investment in the same investment held by a Client or any personal investment transaction proposed with a Client requires pre-approval by the Investment Advisers’ Chief Compliance Officer. Co-Investment Transactions. Each General Partner may, in its sole and absolute discretion, provide co-investment opportunities alongside any of the Funds to certain persons, such as other Fund Investors, strategic investors or affiliates of the Investment Advisers. The terms of any such coinvestment, including the fees and carried interest applicable thereto, if any, will be negotiated by the applicable General Partner and the joint venture partner on a case-by-case basis in their sole and absolute discretion. The carried interest and management fees payable by the joint venture, if any, may be calculated solely with respect to such co-investment. The Investment Advisers may offer co-investment opportunities in their sole discretion and may allocate such co-investments on the basis of the size of investor commitments to the Clients, the size or risk of an investment, strategic or other benefits, or the need for additional capital in order to complete an investment. In making such allocation decisions, the General Partner will be entitled to consider any interests and factors as it desires, including placing its own interests ahead of the interests of any other person. Although co-investment opportunities are generally made on the same or similar terms as a Fund investment, conflicts may arise with respect to the allocation of investment opportunities. Warehoused Investments. Bridge or its affiliated entities may warehouse one or more investments (subject to applicable laws and regulations) for certain Clients, subject to the applicable Governing Documents. Bridge or the applicable general partner of the Client will determine, in its discretion, when to transfer such warehoused investments to the applicable Client, which will affect the amount of interest that will accrue to and be paid to Bridge or its affiliates. Because the value of the warehoused investments may decline prior to their transfer to the applicable Client, there can be no assurance that their value at the time of transfer will not be less than their cost to the applicable Client. Other Activities and Investment Allocation. Affiliates of the Investment Advisers manage, advise and/or provide other services to many of the real estate assets held by the Funds and their related vehicles. Investment opportunities are allocated in accordance with the Governing Documents (including the Investment Advisers’ allocation policies) and other applicable Client agreements. Affiliates also manage and advise certain real estate related investments qualified under United States Treasury Regulation Section 1031 or Section 721 which may have investment objectives Page 67 of 75

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that overlap with, and/or may co-invest alongside, the Funds. Where there is discretion, investment opportunities generally will be allocated among participating entities on a basis that the applicable General Partner determines in good faith to be fair and reasonable, including the deployment of the remaining available capital of each of the Funds, concentration limits, reserve requirements and investor suitability. By their nature, United States Treasury Regulation Section 1031 investments mature or are sold from time to time, and the proceeds must be redeployed within a given time frame and in certain structures (or may be contributed to certain Clients pursuant to Section 721 in accordance with the applicable Governing Documents), thus there are conflicts of interests as to the terms and timing among these entities and sources of funds. The applicable General Partner will generally maintain operational control of a particular investment in which any affiliate co-invests, except for instance in certain Funds where the General Partner (in its sole discretion) determines that operational control should be maintained by a joint venture partner. Cross Transactions, Agency Cross Transactions, Riskless Principal Transactions and Principal Transactions. The Investment Advisers reserve the right to cause a Client to enter into a transaction whereby the Client (i) purchases securities from, or sells securities to, other Clients managed by the Investment Advisers, Apollo Clients or co-investors or co-investment vehicles or (ii) co-invests alongside such other Clients, Apollo Clients or co-investors. Such transactions may arise in contexts where a portfolio investment owned by one Client is acquired by a portfolio investment owned by another Client or an Apollo Client. Any of these transactions raise potential conflicts of interest, including where the investment of one Client supports the value of portfolio investments owned by another Client or where the transaction allows the Investment Advisers or their affiliates to realize carried interest or receive future management fees or other compensation with respect to such investments. These conflicts are heightened to the extent the relevant securities are illiquid or do not have a readily ascertainable value, and there generally can be no assurance that the price at which such transactions are entered into represent what would ultimately be the underlying investment’s fair value. The Investment Advisers intend that any such transactions be conducted in a manner that they believe in good faith to be fair and equitable to each Client under the circumstances, including consideration of the potential present and future benefits with respect to each Client. Further, cross transactions are expected to arise in the context of allocations or other re-balancing of investments among parallel investing entities or Clients with similar or overlapping investment strategies. In such circumstances, the Investment Advisers generally will not seek a fairness opinion or LPAC consent given that such transactions typically are effected close in time to the initial Client’s investment or pursuant to authorizing provisions in the relevant Governing Documents. The Investment Advisers also reserve the right to cause Clients to enter into certain transactions for administrative purposes that may be deemed cross transactions. For example, one Client nearing the end of its term may hold an active license that is no longer required for such Client. For administrative convenience, we may cause such Client to transfer the license, or a special purpose entity created to hold the license, to another Client in lieu of terminating the license. Generally, the Investment Advisers will determine in their sole discretion there is no active market for such license prior to such transfer and will take such steps as they deem necessary or appropriate under the circumstances and the applicable Governing Documents to ensure the terms of such transactions are fair and reasonable. Page 68 of 75

Item 11. Code of ethics, participation in client transactions and personal trading

An adviser that arranges for a security to be purchased from or sold to a client from its own account is engaging in a “Principal Transaction.” A “Riskless Principal Transaction” is a kind of Principal Transaction that occurs when an adviser acting through an affiliated broker-dealer purchases or sells for an advisory client a security on a principal basis by locating the desired security in the marketplace and, when found, simultaneously buying or selling the security for the client through an offsetting transaction in the adviser’s own account (or the account of an affiliated broker-dealer).

Read the rest of Item 11 (417 more words)

In this way, the security briefly, or at least notionally, passes through the account of the adviser (or its affiliated broker-dealer), and the client is charged a markup or markdown rather than a commission. Although Riskless Principal Transactions economically resemble agency transactions (where a broker executes a client’s trade directly with a counterparty and charges a commission), such trades are treated as Principal Transactions fully subject to the requirements of Advisers Act Section 206(3). An “Agency Cross Trade” occurs when an adviser (or its affiliate) arranges for a trade to be executed between two clients and acts as a broker for both clients, usually by charging a fee for effecting the transaction. The Investment Advisers direct Clients to engage in cross transactions (discussed above), Agency Cross Trades, Riskless Principal Transactions, and Principal Transactions (collectively referred to as “affiliated transactions”), from time to time and subject to the applicable Client’s investment guidelines and restrictions. All these types of affiliated transactions give rise to conflicts of interest between Clients or Apollo Clients and/or between Clients and Bridge or affiliates. For example, one Client could be advantaged to the detriment of another Client where the investments being exchanged are not priced in a manner that reflects their fair value. To the extent that any affiliated transaction described above could be viewed as a Principal Transaction, the Investment Advisers will comply with the requirements of Section 206(3) of the Advisers Act and policies and procedures designed to ensure compliance. Personal Trading Employees subject to the Investment Advisers Compliance Program must comply with all applicable laws and regulations, and must obtain pre-approval for all securities transactions (including, but not limited to, investments in private placements and limited offerings) other than those involving: mutual funds, exchange traded funds, exchange traded notes, interval funds, open end funds and closed end funds; government and municipal securities; variable annuities; commodities; indices; currencies and cryptocurrencies; dividend reinvestments; transactions in third-party managed accounts; and grants of equity-based awards covering publicly traded stock to employees as part of an equity incentive plan. Approval will generally not be granted for securities transactions involving any companies on the Investment Adviser’s restricted list. The Investment Advisers Compliance program contains pre-clearance requirements, reporting requirements and other provisions that restrict trading by supervised persons. On a quarterly basis, supervised persons must certify all covered transactions and periodically certify that they have read and understand the compliance program, including the prohibitions and limitations on personal trading.

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Item 12 – Brokerage Practices

Item 12. Brokerage practices

The Investment Advisers generally do not require the selection of brokers/dealers on behalf of Clients. Certain Clients, including Bridge Agency MBS, use the services of certain brokers/dealers in connection with their investments, for which such Client will bear applicable fees of such brokers/dealers. The Investment Advisers do not receive fees, commissions or other compensation from any broker/dealer arrangements, including Fund Investor referrals or Client referrals. Although the Investment Advisers do not expect to regularly engage in public securities transactions, from time-to-time, certain Clients receive distributions in the form of publicly traded securities from the private equity funds and co-investment interests held by the applicable Client.

Read the rest of Item 12 (760 more words)

To the extent an Investment Adviser is engaging in a public securities transaction on behalf of such Clients, it intends to follow the brokerage practices described below. If an Investment Adviser sells publicly traded securities for a Client, it will seek to select brokers on the basis of best price and execution capability. In selecting a broker to execute Client transactions, an Investment Adviser may consider a variety of factors, including: (i) execution capabilities with respect to the relevant type of order or security; (ii) commissions charged and competitiveness of commissions, rates and spreads; (iii) the reputation and responsiveness of the firm being considered; (iv) the gross compensation paid to the broker; and (v) the financial strength of the broker and its ability to respond promptly to inquiries during volatile markets. The Investment Advisers have no duty or obligation to seek in advance competitive bidding for the most favorable commission rate applicable to any particular Client transaction or to select any broker on the basis of its purported or “posted” commission rate, but will endeavor to be aware of the current level of the charges of eligible brokers and to reduce the expenses incurred for effecting Client transactions to the extent consistent with the interests of such Clients. Although the Investment Advisers will generally seek competitive commission rates, it may not necessarily pay the lowest commission or commission equivalent. Transactions that involve specialized services or access on the part of the broker involved generally entail higher commissions or their equivalents than would be the case with other transactions requiring more routine services. For example, when a Client receives distributions in the form of publicly traded securities from its investment in an underlying fund, the applicable Investment Adviser generally utilizes the same broker to execute the sell transaction that received the distributed security from the underlying fund investment, and such disposition might not always be executed at the lowest available commission. Consistent with an Investment Adviser seeking to obtain best execution, brokerage commissions on Client transactions may be directed to brokers in recognition of research furnished by them, although the Investment Advisers generally do not make use of such services. As a general matter, research provided by these brokers would be used to service all of the Funds. However, each and every research service may not be used for the benefit of each and every Fund managed by the Investment Advisers, and brokerage commissions paid by one Fund may apply towards payment

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Item 13 – Review of Accounts

for research services that might not be used in the service of such Fund. To the extent that an Investment Adviser allocates brokerage business on the basis of research services, it may have an incentive to select or recommend broker/dealers based on the interest in receiving such research or other products or services, rather than based on its Funds’ interest in receiving the most favorable execution. The Investment Advisers do not anticipate engaging in significant public securities transactions; however, to the extent that an Investment Adviser engages in any such transactions, orders for purchase or sale of securities placed first will be executed first, and within a reasonable amount of time of order receipt. To the extent that orders for any Funds are completed independently, the Investment Adviser may also purchase or sell the same securities or instruments for several Funds simultaneously. From time to time, the Investment Advisers may, but are not obligated to, purchase or sell securities for several Client accounts at approximately the same time. Such orders may be combined or “batched” to facilitate obtaining best execution and/or to reduce brokerage commissions or other costs. Batched transactions are executed in a manner intended to ensure that no participating Fund is favored over any other Fund. When an aggregated order is filled in its entirety, each participating Fund generally will receive the average price obtained on all such purchases or sales made during such trading day. To the extent such orders are not batched, they may have the effect of increasing brokerage commissions or other costs. When an aggregate order is partially filled, the securities purchased or sold will normally be allocated on a pro rata basis to each Fund participating in such buy or sell order in accordance with the amount of securities originally requested for such Fund. Each Fund generally will receive the average price obtained on all such purchases or sales made during such trading day. Exceptions to pro rata allocations are permissible provided they are fair and equitable to the Funds over time.

Item 13. Review of accounts

The investments made by the Funds are generally private, illiquid and long-term in nature. Accordingly, the review process is not directed toward a short-term decision to dispose of securities. However, each Investment Adviser closely monitors the related investments in which the Funds invest, and the Investment Committee of each respective General Partner regularly monitors to confirm that each Fund is maintained in accordance with its stated objectives. The Chief Compliance Officer or a designee periodically monitors Investment Committee meetings and materials, reviews Governing Documents and Fund statements and communications to confirm that each Fund is maintained in accordance with its stated objectives.

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Several of Bridge’s principals serve on the Investment Committee of various General Partner entities for various Funds, serve as managers of the Investment Advisers, and work closely with other affiliated professionals to oversee and monitor the operations, financial performance and strategic direction of the Funds in which they are involved and such Fund’s investments.

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Item 14 – Client Referrals and Other Compensation

Periodic Reviews Fund Investors generally receive individual quarterly reports and annual audited financial reports, which they may review with the Investment Advisers on an as-needed basis. In the case of Bridge Agency MBS, Fund Investors receive individual monthly partner capital statements and annual audited financial reports, which they may review with the Investment Advisers on an as-needed basis. Accounts are reviewed quarterly, or more frequently when market conditions dictate. Other conditions that may trigger a review include changes in tax laws and/or material new investment information. Regular Reports Each Fund generally delivers an audited annual report and unaudited quarterly statements (or monthly partner capital statements in the case of certain Funds) to Fund Investors. One of Deloitte & Touche LLP and its affiliates, Ernst & Young LLP and its affiliates, and RSM US LLP have been appointed as auditors for the Funds that are also Clients of the Investment Advisers. Bridge Fund Financial Services LLC, an affiliate of the Investment Advisers, together with a third-party fund administrator for certain non-U.S. Clients, Langham Hall or its affiliates, perform fund administration services for the Funds. Financial reports and tax reporting documents are generally provided to the Fund Investors within 120 days of the fiscal year end for each applicable Fund, as set forth in the applicable Governing Documents. The Investment Advisers generally host Fund Investor meetings and calls and other quarterly meetings and calls as appropriate for certain Funds and Fund Investors. In addition to the information provided to all investors, the Investment Advisers may provide certain Fund Investors (including but not limited to those Fund Investors that are part of an LPAC) with additional information or more frequent reports that other Fund Investors will not receive.

Item 14. Client referrals and other compensation

Other Compensation In connection with investments made by certain Clients, affiliates of the Investment Advisers receive certain transaction or other fees and compensation in addition to the management fees and any applicable performance or incentive fees. The potential for affiliates of the Investment Advisers to receive such additional economic benefits creates conflicts of interest. Please see the Governing Documents and “Item 5 – Fees and Compensation – Affiliate Fees” for additional information about such fees and other compensation.

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Referrals From time to time, the Investment Advisers and/or the General Partners have entered into, and are expected in the future to enter into, placement arrangements pursuant to which the Investment Advisers, the General Partners or the Client compensate third parties for referrals that result in a potential investor becoming a Fund Investor. The Investment Advisers, the General Partners or the Client receive potential investor referrals which may come from current Fund Page 72 of 75

Item 15 – Custody

Investors, Clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The Investment Advisers do not compensate referring parties for these referrals unless they have the proper securities license to perform and receive compensation for such services. Third-party firms that are properly licensed to sell securities receive compensation for providing solicitation, placement or other related services. This may be a flat-fee or a percentage of management fees or capital committed by the applicable Fund Investor, for the sale of the interests of the Client, and such firms are generally reimbursed for expenses incurred in connection with solicitation efforts. In some cases, these third-party firms have certain levels of exclusivity negotiated with respect to marketing, distribution and related activities in certain territories for Clients. The applicable Client may also pay placement fees and commissions generally based on the size of the commitment, and to the extent that such Client pays any placement agent fees or commissions (or any interest thereon or any expense of any such agent), such amounts will generally be treated as “organizational expenses” and will be initially borne by the Fund. Generally, the management fee payable to the applicable Investment Adviser will be reduced or offset by 100% of any such placement agent fees and expenses, except for certain administrative expenses related to placement agent engagement and placement fees payable in connection with subsidiary REIT preferred stock offerings undertaken in order to comply with certain REIT qualification requirements, which are generally de minimis. In some cases, these third-party firms charge additional advisory or other fees to their clients, including those that invest in Funds, which fees do not offset or reduce any management fees paid to the Investment Advisers. Generally, these third-party firms are not acting as investment advisers to prospective investors, and each prospective investor must make their own decision regarding a potential investment in any of the Funds. As a result of these fees, these third-party firms and placement agents have financial and other incentives to recommend certain investments, including those in the Funds. Prospective investors should recognize that these third-party firms may be influenced by their financial or other interests in current or future fees and commissions in the Funds or future investment vehicles sponsored by the Investment Advisers. Referrals to Third Parties The Investment Advisers do not accept referral fees or any form of remuneration from other professionals when a potential investor is referred to such parties by the Investment Advisers or their affiliates.

Item 15. Custody

The Investment Advisers are generally deemed under Rule 206(4)-2 of the Advisers Act to have custody of the Funds’ cash and securities, and the Investment Advisers general policy is to ensure that any Client’s cash and securities, as applicable, are held by one or more qualified custodians that are not affiliated with the Investment Advisers. These custodians also provide other financial or other services to one or more Clients and in some cases, will provide more favorable rates or services in exchange for an agreement to maintain certain cash deposits at those custodians. The cash deposits of one Client can provide ancillary benefits to other Clients. Each custodian provides, among other things, regular periodic statements to the Clients. Each Investment Adviser regularly

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Item 16 – Investment Discretion

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reconciles its records to those of the qualified custodians. For fixed-income investments where securing mortgages notes, commercial or residential mortgage-backed securities and other documents are required, the applicable Client has associated custody relationships with BNY Mellon, US Bank and other qualified custodians for such investments. The Clients currently use Bridge Fund Financial Services LLC, an affiliate of the Investment Advisers, and Langham Hall (in the case of certain non-U.S. Clients) as fund administrators. The fund administrators generally provide quarterly account statements (or monthly account statements in the case of Bridge Agency MBS) to their respective Clients and the Clients in turn provide such statements to Fund Investors. These quarterly or monthly account statements are not audited. The Investment Advisers will cause each Fund to be audited annually by a nationally recognized independent accounting firm and will distribute such audited financial statements, prepared in accordance with U.S. generally accepted accounting principles, to investors generally within 120 days after the end of each fiscal year. Although not common practice for the Investment Advisers, the Investment Advisers may elect to retain an independent firm to perform a surprise audit and internal controls report as prescribed by Rule 206(4)-2 of the Advisers Act.

Item 16. Investment discretion

Investment advice is provided directly to each Client and not individually to the Fund Investors of any Client. The General Partners and the Investment Advisers have broad discretion and authority in controlling the investments and affairs of those Clients. The Investment Advisers assume this discretionary authority pursuant to the terms of the Governing Documents and powers of attorney executed by Fund Investors. These General Partners may only direct and approve such investment strategies within the guidelines included in the applicable Governing Documents for each such Client.

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Pursuant to the terms of the Governing Documents and in accordance with common industry practice, each Fund, its General Partner, any of the Investment Advisers or Bridge routinely enter into “side letters” or similar writings, agreements or understandings with Fund Investors which have the effect of establishing favorable rights, benefits or privileges under, or altering or supplementing, the terms of the respective Governing Documents without any further act, approval or vote of any other Fund Investors. These rights include, but are not limited to, certain “most favored nations” processes, economic rights, liquidity, withdrawal or transfer rights, different performance hurdles, minimum investment amounts, co-investment allocation or participation rights, voting rights, management fee offsets for certain fees, information rights, additional or modified reporting obligations, excuse or exclusion rights, agreements to assist with the taking or defending of certain tax positions, obligations and restrictions on the applicable General Partner with respect to its discretion on certain matters and other rights or terms including those requested in light of particular investment, legal, regulatory or public policy characteristics of a Fund or a particular Fund Investor. Any rights established, or any terms of the respective Governing Documents so altered, modified or supplemented in a side letter with a Fund Investor, will govern with respect to such Fund Investor notwithstanding any other provision of the respective Governing Documents. Additional benefits provided to a Fund Investor via a side letter will not necessarily be available to other Fund Investors. By their nature, side letters will give preferential treatment to those who have entered into such arrangements. The Investment

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Item 17 – Voting Client Securities

Advisers tailor their advisory services to the needs of Clients as set forth in the applicable Governing Documents. The Governing Documents generally set forth certain limitations on investments that can be made by the applicable Client, including but not limited to limitations on the type of securities, assets or geographical limitations that may be acquired by the applicable Client. With respect to certain Clients, the respective Investment Adviser does not have full discretion and is required to obtain investor consent for certain investment decisions and other actions. The Investment Adviser considers those accounts to be managed on a non-discretionary basis.

Item 17. Voting client securities

Although the Investment Advisers do not expect to engage in the types of transactions where proxy voting is applicable, the Investment Advisers have adopted Proxy Voting Policies and Procedures (the “Proxy Policy”) to address how they vote proxies for any Client for which they have proxy voting discretion, including the Clients. The Proxy Policy seeks to ensure that the Investment Advisers vote proxies in the best interest of their Clients, including where there are material conflicts of interest. The Investment Advisers believe their interests are aligned with those of the Fund Investors through the Investment Advisers’ and their principals’ substantial capital commitment to the Funds, and therefore generally do not seek investor approval or direction when voting proxies.

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In some cases, certain Investment Advisers delegate proxy voting authority to a third party, such as a co-investment lead manager, or may take into consideration recommendations made by third parties, such as lead managers for co-investments. The Proxy Policy sets forth certain specific proxy voting guidelines that apply when the Investment Advisers do vote proxies on behalf of a Client. In the event that there is a conflict of interest between an Investment Adviser and any Client in voting proxies, the Proxy Policy requires that the Investment Adviser address the conflict using specific procedures, which may include seeking the approval of the applicable LPAC on the proposed proxy vote or through other alternatives set forth in the Proxy Policy. A copy of the Investment Advisers’ Proxy Policy as well as information relating to how the Investment Advisers voted with respect to a particular proxy, as applicable, will be provided to any Client, or Fund Investor, upon request to the Investment Advisers’ Chief Compliance Officer at 1-801-506-1463 or at compliance@bridgeig.com.

Item 18. Financial information

The Investment Advisers do not have financial impairments that would preclude them from meeting contractual commitments to Clients. The Investment Advisers have not been the subject of a bankruptcy petition within the last 10 years.

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Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.