Tremont Realty Capital LLC: investment adviser

The investment guidelines for each Client will be defined in such Client’s organizational documents, management agreement with the Firm or other records and will be tailored to the specific goals, objectives and operating guidelines of such Client. Each Client has, or will have prior to becoming a Client, established a policy prohibiting investments in publicly traded securities and generally limiting permissible investments to commercial real estate debt, mortgages, mezzanine financing and preferred equity investments. The Firm is headquartered in Newton, Massachusetts and is a wholly owned subsidiary of The RMR Group LLC (“RMR LLC”), an alternative asset management company. RMR LLC is a majority owned subsidiary of The RMR Group Inc., a public holding company that conducts substantially all of its business through RMR LLC. Mr. Adam Portnoy controls The RMR Group Inc. through his voting ownership, and position as sole trustee, of the controlling shareholder of The RMR Group Inc. As of September 30, 2025, the Firm managed $763,324,546 of Client assets on a discretionary basis.

Fees and compensation for each Client will be described in the management agreement related to a Client. Management fees are generally assessed monthly or quarterly in arrears and are either billed to Clients or deducted from Client assets depending on the specific terms of the Firm’s agreement with such Client. The Firm, in addition to the management fee, will be paid or reimbursed for certain costs in consideration of Page | 4

business management services the Firm provides, including, among others as agreed with a Client, providing executive and administrative personnel, office space and office services, regulatory, tax and legal compliance services, auditing, investor relations services, administering the Client’s day to day operations and liaising with the Client’s board of directors/trustees on a variety of operational and compliance matters. Other Fees and Expenses Clients will bear administrative, operating and other expenses to the extent set forth in their respective agreements with the Firm.

It is expected that all Clients will be charged an incentive performance fee or allocation which may be partially, primarily or wholly based on metrics involving net income rather than capital gain or appreciation; however, the amount of such fee may vary among Clients, which could create an incentive for the Firm to allocate more attractive investment opportunities to Clients with higher fees. This risk may be mitigated to the extent any applicable Clients have different investment objectives and guidelines such that they would generally not be expected to compete with one another for the same investments. The Firm will monitor Clients’ accounts for compliance with their respective investment guidelines and follow certain allocation policies. Under the allocation policies, if a particular investment is appropriate for two or more applicable Clients, the Firm will allocate the investment in a manner determined in good faith to be fair and equitable and consistent with the Firm’s allocation policies, as applicable. The allocation will depend on the determination of all relevant factors, such as the Clients’ respective investment objectives, desired allocations and cash availability, including certain arrangements where the Firm is only providing investment advice with respect to specific investments. Please also refer to Item 10 regarding the Firm’s allocation policies. Incentive performance fees or allocations create a risk that the Firm will cause a Client to make investments that are more speculative than it would if the Client did not pay incentive performance fees or allocations.

Investments in commercial real estate debt, mortgages, and mezzanine financings generally expose Clients to the risks of owning real estate and the risks of leveraged investing. General Risks of Owning Real Estate-Related Investments Risks associated with real estate related investments, such as commercial real estate debt, mortgages and mezzanine financings, and the potential ownership of real estate as a result of owning such investments, may result from downturns in the U.S. or global economy, local conditions, possible adverse changes in zoning laws, changes in market demand for leasing or owning commercial real estate, limitations on rents, the quality and philosophy of property managers and leasing agents, competition based on rental rates, attractiveness and location of the properties, environmental liability, the financial condition of tenants, availability of buyers and sellers of properties, quality of maintenance, the risk of casualty or condemnation losses and terrorist attacks, war or other acts that destroy real property, changes in operating costs, government regulations, interest rate levels, tax rates, and availability of financing. The commercial real estate markets continue to be adversely affected by economic conditions in the United States and global financial markets generally, including current inflationary pressures, interest rate fluctuations, supply chain issues, geopolitical risks, and prolonged economic slowdown or recession. Investments in commercial real estate debt, mortgages, and mezzanine financings may also be affected with risks arising from the use of real estate; for example, environmental cleanup risks for properties used to store hazardous materials or compliance costs arising from American with Disabilities Act for real estate which is open to public access. Risks of Leveraged Investing Leverage strategies are generally designed to enhance returns to investors but also increase the risk associated with the investment. Use of borrowed funds to leverage investments involves a significant degree of financial risk and can rapidly multiply the effect of any increase or decrease in the value of any investment. For example, a leverage strategy may increase the exposure of the leveraged investments to adverse economic factors, such as interest rate fluctuations, economic downturns and other circumstances that could cause deterioration in the value of the investments.

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Where the Firm or its affiliates are representing a borrower, the Firm or its affiliates may be paid a commission or origination fee as a result of any such transaction. The Firm’s and its affiliates’ activities in representing borrowers may, in some cases, create a conflict of interest when the financing sought by such borrowers falls within a Client’s investment objective. The Firm seeks to manage this conflict by generally limiting its borrower-side activities to financing opportunities that do not overlap with Clients’ investment objectives and by actively monitoring involved employees to ensure that their activities are conducted fairly and reasonably and without resulting in material disadvantages to Clients. While the Firm or its affiliates expect to act as loan originator for certain transactions presented to Clients, the Firm also sources investment opportunities for its Clients from third party intermediaries or brokers and makes recommendations to, or discretionary investment decisions for, Clients based on its evaluation of what investment opportunities are in a particular Client’s best interests. The Firm or an affiliate of the Firm serves, and may in the future serve, as general partner, managing member, or external business manager of a Client and has, and may in the future further have, limited partnership or other economic interests in a Client. In particular, as of the date of this brochure, the Firm has an approximately 11.3% ownership interest in Seven Hills Realty Trust, a Client that is a REIT. These arrangements create conflicts of interest, particularly because personnel of the Firm, its affiliates and their managed entities serve as trustees, directors or officers of Clients, and engage in other activities or lines of business similar to those in which such Clients engage. The Firm or its affiliates provide or may provide management or investment advisory services to other clients, including clients or accounts in which the Firm, its affiliates or their personnel have a controlling, substantial or sole economic interest; therefore, conflicts of interest exist with regard to the allocation of investment opportunities and for the time and attention of the Firm’s personnel. The Firm and its affiliates seek to resolve such conflicts in good faith and in their fair and reasonable discretion. In the case of such a conflict, the Firm and its affiliates will endeavor to allocate such investment opportunities in a fair and equitable manner, consistent with the Firm’s allocation policies, taking into account such factors as they deem appropriate. With Page | 7

respect to mortgage loan investments, which are the only types of investment opportunity that may be appropriate for more than one Client, the Firm has established an investment committee (the “Investment Committee”) that is responsible for evaluating mortgage loan origination opportunities and making determinations as to whether to move forward with funding a loan, taking into account Clients’ investment considerations. The Investment Committee may consider, without limitation, any or all of the following factors with respect to such opportunity and each Client (listed below without regard to any order of importance):

investment objectives, strategy and criteria; any known investment policies and restrictions, guideline limitations or investment objectives that are relevant to the transaction, including the need for distributions; effect of the investment on the diversification of the Client’s portfolio, including by geography, size of investment, type of investment and risk of investment; ability of a Client to commit to an investment opportunity within the required timeframe for a particular transaction; leverage policy, the availability of financing for the investment by each client and cash requirements; anticipated cash flow of the asset to be acquired; tax profile of the Client and the tax characteristics of the investment; the size of the investment; whether the Client has any existing positions in the opportunity; the extent to which a Client has been provided a greater or lesser volume or quality of investment opportunities relative to others; availability and cost of capital; risk return profiles; targeted distribution rates; anticipated future pipeline of suitable investments; the expected holding period of the investment and the Client's investment period, if applicable; and such other factors as the Firm deems relevant and believes to be appropriate under the circumstances.

The Investment Committee has broad discretion in making these determinations and is not required to take any of these factors into account or to assign greater, lesser or equal importance to any of these factors. The Investment Committee is also not limited in the factors that it may consider in making these determinations to those set forth above, and may take into account such other matters as it may, in its discretion, consider appropriate from time to time. Differences among accounts will impact the investment decision for each account, and the Investment Committee is under no obligation to make similar investments in accounts with similar investment objectives. If the Investment Committee determines mortgage loan investment opportunities are equally appropriate for more than one client, it will generally allocate such opportunities on a rotational basis. Additionally, current and future business activities by and investments of the Firm, its affiliates, and entities to which they provide management or investment advisory services or their affiliates Page | 8

create conflicts of interest. For example, the Firm may determine to offer a Client and one or more other entities also managed by it or its affiliates opportunities to co-invest in commercial real estate loans. Similarly, an affiliate of the Firm manages equity real estate investment trusts and real estate related operating businesses that have in the past assumed or placed mortgage financing on some of the real estate they own and may consider doing so in the future, and a Client may be offered opportunities to provide commercial real estate loan financing to entities the Firm or its affiliates manage. These activities would give rise to conflicts of interest. Whenever a co-investment opportunity or other potential transaction between a Client and any other entity to which the Firm or its affiliates provides management or investment advisory services arises, such investment or transaction will not be made unless it is approved by the Client in the manner contemplated by its governing documents or account agreements.

In addition to requiring compliance with the applicable securities laws, the Code establishes policies and procedures designed to prevent the misuse of material, non-public information, and identifies activities that are either expressly prohibited or that require approval. The Code is based upon the principle that the Firm and its employees owe a duty to the Firm’s Clients to conduct Client affairs, including personal securities transactions, in such a manner as to avoid serving employees’ own personal interests ahead of those of the Clients, taking inappropriate advantage of employees’ positions with the Firm, and any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading, and other forms of prohibited or unethical business conduct. Additional conflicts of interest present in connection with the Firm’s management of Client accounts, and how the Firm addresses those conflicts, are described under Item 5, Item 6, and Item 10. The Firm or an affiliate of the Firm serves, and may in the future also serve as general partner, managing member or external business manager of a Client and further has, and may in the future further have, limited partnership or other economic interests in a Client. The Firm or an affiliate of the Firm also seeks to invest for its own account in the same types of securities recommended to Clients.

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In no case will such payments be made if in violation of any state or federal law, rule or regulation, including without limitation Rule 206(4)-1 under the Advisers Act or similar state rules regarding solicitation and/or state rules requiring registration of investment adviser representatives. Page | 10

In addition, unaffiliated REIT investors are expected to receive annual financial statements within 120 days of the REIT’s fiscal year end that are prepared in accordance with U.S. generally accepted accounting principles and audited by third party auditors that are regulated by the Public Company Accounting Oversight Board.