Aflac Asset Management LLC: investment adviser

Aflac GI provides comprehensive asset management services including credit portfolio management, asset allocation solutions, derivatives solutions and management, and other strategic and tactical portfolio management services. We utilize external managers for expertise in certain asset classes and, in certain cases, we employ derivatives to manage risks of our investment strategies and other Client activity. Portfolio Management – Fixed Income, Derivatives, and Alternative Solutions Aflac GI’s disciplined process uses a strategic asset allocation to seek long-term risk-adjusted investment returns and stable income within the regulatory and capital objectives of its Clients. To achieve this objective, Aflac GI typically invests in fixed income securities including investment-grade and below-investment-grade bonds, loans and structured securities, both publicly traded and privately originated. In using derivative instruments, Aflac GI seeks to mitigate various risks associated with its Clients’ investment portfolios and forecasted cash flows, including currency and interest rate risk. Aflac GI also manages a program of alternative assets, primarily private fund investments. Asset Allocation Services Aflac GI offers asset allocation services and multi-asset advisory services across asset classes and through its investments in portfolios and other investment vehicles that are managed by third-party managers. Externally-managed asset classes include but are not limited to commercial mortgages, transitional real estate loans, infrastructure debt, middle market loans, public equity and alternative investments such as private and real estate equity. Each third-party manager must meet certain requirements relating to the respective asset class at the time of manager selection. Third-party managers are responsible for determining the investments or securities that are purchased, sold or retained under their respective investment mandates for Aflac GI’s Clients. Other Aflac GI provides discretionary advisory services to sub-trusts of Global Alternatives Trust I, a Cayman Islands unit trust formed in 2019 (the “Fund”), the Global Alternatives Fund SPC and its related segregated portfolios. The only investors in the Fund are certain Insurance Company Clients, and Aflac GI does not customize its advisory services for each individual investor in the Fund.

The assets of the Fund are invested in accordance with its offering memorandum, deed of trust, and other governing documents (the “Governing Fund Documents”). The investment strategy of the Fund is described in greater detail under Alternative Assets in Item 8 below. Aflac GI also serves as a sub-advisor to Aflac Asset Management Japan Ltd. (“AAMJ”), an affiliated investment adviser licensed with the Japan Financial Services Agency. Aflac GI provides asset management services on behalf of AAMJ to Aflac Life Insurance Japan Ltd (“ALIJ”), an insurance company affiliated with Aflac GI. Subject to the sub-advisory investment guidelines and applicable law, Aflac GI advises AAMJ about the manner in which ALIJ invests in certain trust and other investment vehicles which, in some cases, are also Clients of Aflac GI. Aflac GI also provides portfolio management services to two Delaware statutory trusts that hold interests in a diversified pool of leveraged loans and in which ALIJ holds all the trust interests. Aflac GI managed approximately $118,596,150,569 of Client assets on a discretionary basis and $14,874,976,639 of Client assets on a non-discretionary basis, as of December 31, 2025.

Fees are individually determined based on the type of asset class for which management services are being provided, and will be calculated as a percentage of the assets under management within each asset class in a particular Client’s account. Fees are negotiable based on the individual Client. Fees will range within a given asset class, as described in the applicable fee schedule. Derivatives transactions, if any, are generally charged based on the quarter-end notional value, but may also be charged based on the absolute value of the quarter-end market value, as outlined in each Client’s agreement. Fees for public and private equity will be based on fair market value as determined in accordance with our valuation policies and procedures, and fees for all other assets will be based on book value. In addition to Aflac GI’s investment management fees, Clients are generally responsible for other trading costs and custodial fees related to their accounts, unless described otherwise in the applicable governing documents. Clients invested in the Fund are generally responsible for the portfolio’s expenses, including but not limited to management fees, fees and expenses of the directors, custodians, administrators, independent pricing vendors and other agents, transaction fees, taxes and fees for tax reporting. For more information on trading costs, please see Item 12 – Brokerage Practices below. To the extent that Clients’ accounts are invested in mutual funds, private funds or other collective investment vehicles, these funds charge a separate layer of management, performance, trading, and administrative expenses, which are borne indirectly by the investors in each such fund. Accordingly, where a Client invests in such funds, it will bear its share of such costs.

Aflac GI bills its Clients for its investment advisory services and does not deduct the fees from Clients’ assets. Aflac GI’s fees are exclusive of other fees and expenses that are incurred by, or on behalf of, the Client as documented in a written agreement with the Client. If any such expenses are paid by Aflac GI, Aflac GI will provide Client an invoice reflecting such expenses and the Client will reimburse Aflac GI or its affiliates for those expenses. In certain instances, our supervised persons will recommend that an Insurance Company Client invest in a private fund or other products that we or an affiliate sponsor, advise or otherwise provide services to. In such instances, the Client will generally pay two layers of fees, including underlying fees and expenses associated with the product, in addition to advisory fees charged by Aflac GI. Aflac GI has a conflict of interest to recommend that Clients invest in affiliated products, as Aflac GI and/or its affiliates will receive additional compensation in connection with such investments than if the Client invested in an unaffiliated product. Aflac GI addresses such conflicts of interests through disclosure and policies and procedures to ensure that any investment recommendation made to a Client is in accordance with its fiduciary duty. Further, in certain instances, Aflac GI will waive its advisory fee in connection with a Client’s investment in an affiliated product. Please see Item 10 of this Brochure for additional information.

Corporate Debt Aflac GI’s current investment strategy for corporate debt is to maximize net investment income in a manner consistent with the preservation of capital in accordance with client’s objectives and risk management practices and tolerances. The investment process begins with an independent approach to underwriting each issuer's fundamental credit quality. This underwriting process includes a thorough analysis of a variety of items including the issuer's country of domicile (including political, legal, and financial considerations); the industry in which the issuer competes (with an analysis of industry structure, end-market dynamics, and regulation); company specific issues (such as management, assets, earnings, cash generation, and capital needs); and contractual provisions of the instrument (such as financial covenants and position in the capital structure). Aflac GI has a team of dedicated credit analysts, each responsible for monitoring developments in their assigned industry sectors and reviewing the universe of issuers of publicly-traded bonds, privately placed debt, loans, structured finance products, infrastructure debt, or other appropriate fixed income investments which are either owned currently or have the potential to be purchased by Aflac GI for its Clients. The credit analysts closely monitor developments that may affect an instrument’s fundamental credit quality. They work closely with our team of credit portfolio managers to assess how these developments impact client objectives for income, taxes, gains/losses, and other portfolio considerations including asset liability management, diversification, and liquidity. Portfolio managers and analysts also collaborate closely with our team of corporate bond traders to stay current on technical market factors, such as new bond issuance, secondary market supply and demand, and other market issues which may impact the relative attractiveness of a current or prospective security. Aflac GI continuously seeks ways to improve the risk and/or return profile of the Client portfolios, while incorporating changing market conditions, client objectives, or both. These opportunities may be captured through new investment activity or a repositioning of existing holdings through bond sales, purchasing and trading. Derivatives Aflac GI uses derivative instruments and hedging strategies for purposes defined in IMAs and other policies associated with certain Clients and portfolios. The derivative activities are primarily used to hedge foreign exchange and interest rate risk in the Client investment portfolios as well as manage foreign exchange risk for certain forecasted cash flows of Clients. Derivatives instruments include foreign currency forward contracts, foreign currency options, foreign currency swaps, interest rate swaps, interest rate swaptions, and other instruments as determined by Aflac GI from time to time and as permitted by each Client. Alternative Assets Aflac GI invests Client assets in alternative asset classes via investment funds which are engaged in private equity and associated investment strategies, primarily through the Fund described in Item 4 above. The investment objective of the Fund is to invest in a fund-of-funds program consisting of investment funds that invest in one or more alternative asset classes, including, but not limited to private equity investments, real estate investments, leveraged loan investments, mezzanine credit investments, hedge fund investments, private asset-backed securities and infrastructure investments.

Other Asset Classes Aflac GI offers advisory services related to other asset classes to its Clients primarily through external managers (“External Manager Platform”). Under the External Manager Platform, Aflac GI manages Client assets through the selection of third-party external managers or management companies to advise separately managed accounts established for Clients that invest in asset classes that include commercial mortgage loans, collateralized loan obligations, asset-backed and mortgage-backed securities, transitional real estate, real estate equity, private and public equity, middle market loans, infrastructure debt and other instruments as determined by Aflac GI from time to time and as permitted by each Client. Aflac GI is responsible for the management and oversight of these accounts and provides evaluation, selection, integration, due diligence and reporting for the external managers of traditional and alternative asset classes. Aflac GI could potentially invest in other asset classes on behalf of its Clients that are directly managed as permitted by client IMA guidelines. Summary of Risks The description below is an overview of the material risks associated with Aflac GI’s significant investment strategies and is not intended to be complete. All investing involves the risk of loss and the investment strategies offered by Aflac GI could lose money over short or long periods, including loss of principal. Moreover, performance could be negatively impacted by a number of different market risks, some of which are described below. Clients should refer to the governing documents for their account and/or any investment products in which they are invested through for additional information regarding the risks specific to such accounts, strategies or vehicles. A. General Risks Artificial Intelligence--Artificial intelligence technologies, including machine learning and generative artificial intelligence (collectively, “AI Technology”), their potential future applications, and the laws, regulations, and standards governing their use continue to rapidly evolve. As of the date of this brochure, we do not use AI Technology to make investment decisions or provide investment advice, and AI Technology does not influence the investment advice we provide. While we utilize quantitative models and algorithms as part of our investment process, these tools do not rely on AI Technology. However, we utilize AI Technology to support certain non‐ investment operational functions, such as data processing, subject to human oversight. In addition, we rely on third-party service providers who utilize AI Technology. Although we conduct diligence on such service providers, we do not control how third parties develop, deploy, or maintain AI Technology, which may give rise to operational, legal, or regulatory risks. Use of AI Technology could exacerbate existing, or create new and unpredictable, risks to us and Client accounts, including competitive, operational, reputational, legal, and regulatory risks. For example, disruptions in the complex software and hardware systems used by AI Technology could impair our ability to use that AI Technology, process data, generate reports, or perform operational tasks. Further, the models used by AI Technology, and/or the data sets on which those models are trained, could be flawed, function in an unexpected manner, or otherwise reduce these tools’ effectiveness. Additionally, malicious use of AI Technology could also result in harm to us, including reputational harm, enablement of fraudulent activity, generation of misinformation, and increased cybersecurity threats, such as generation of deep-fakes and enablement of long-term and persistent phishing attacks. We maintain a robust governance framework to evaluate risks associated with AI Technology. Despite these precautions, the novelty

and rapid evolution of AI Technology increases the likelihood of associated risks materializing. Further, it is not possible to predict the full nature or extent of current or future risks related to the use and development of AI Technology. Allocation of Client Assets—Where there is limited availability for a certain asset, Aflac GI may not always be able to allocate such assets to all eligible Client accounts. In such instances, Aflac GI will allocate investment opportunities in accordance with its allocation procedures which are designed to be fair and equitable over time and under the particular circumstances. In addition, Aflac GI may not be able to allocate a particular asset to a Client due to conflicts of interest or other restrictions which may adversely affect the value of Client assets. Bankruptcy Risk—A company in which Client assets are invested may become involved in a bankruptcy or other reorganization or liquidation proceeding. Bankruptcy may result in, among other things, a substantial reduction in the interest rate and a substantial write down of the principal of the Client’s investment. Board Participation and/or Creditors’ Committees— Aflac GI may be restricted in its investment activities if employees have representation on the board of directors and/or creditors’ committees of companies, and the fiduciary duties owed to these companies and committees may conflict with the interests of Client assets. Cash Management Risk— From time to time Aflac GI will use money market funds, cash deposits and other cash equivalents to hold uninvested funds in Client accounts. Client assets may be held in cash and cash equivalents for an indefinite period of time when Aflac GI determines that the prevailing market environment, anticipated investment opportunities or other factors warrant doing so. As a result, the Client may receive lower returns than if the Client had been fully invested in the market and the cash and cash equivalents may generate minimal or no income which could negatively impact the Client’s return on assets and ability to achieve its investment objective. Counterparty Risk—Aflac GI may transact with a counterparty that is unable to perform their contractual and/or economic obligations. In addition, centralized clearing of certain OTC derivatives exposes Clients to the risk of a default by a clearing member or clearing house with respect to its cleared derivative transactions. As such, these events could have a material adverse effect on Clients’ assets and return on investments. Currency Risks—Client assets may be invested in investments denominated in currencies other than the currency in which the Client is domiciled. Fluctuations in exchange rates may adversely affect the currency in which the investment is denominated. Cybersecurity—The information and technology systems of Aflac GI and of third party service providers to Aflac GI and its Clients are vulnerable to cybersecurity and systems-related risk, including but not limited to potential damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors or phishing by or of their respective professionals, power outages, and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. Although Aflac GI and Aflac Incorporated have implemented various measures designed to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, it may be necessary for Aflac GI to make a significant investment to fix or replace them and to seek to remedy the effect of these issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the operations of Aflac

GI or its Client accounts and result in an inability to access investments or a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information. Furthermore, neither Aflac Incorporated nor Aflac GI can control the cybersecurity plans and systems put in place by third party service providers and issuers in which Clients invest. Data Sources Risks—Aflac GI utilizes external data sources in the investment process. As a result, if information that is received from the external data source is incorrect, we may not achieve the desired results. Aflac GI believes its external data sources to be generally reliable, however we typically receive these services “as is” and cannot guarantee that the data received from these sources is accurate. Environmental Risks and Natural Disasters—Client assets may be invested in investments in or relating to real estate assets that are subject to liability under environmental protection statutes, rules and regulations, and risks associated with natural disasters. Infrastructure Debt Risks—Infrastructure debt investments are generally linked to projects rather than a corporate entity. Infrastructure debt projects typically involve creation of a new entity, and income generated by the new entity directly services the debt, leaving debtholders with little or no recourse to the sponsor’s other assets. Infrastructure debt is subject to a variety of risks, not all of which can be foreseen or quantified, including: (i) local, national and international political and economic conditions; (ii) the supply and demand for services from, and access to, infrastructure; (iii) the financial condition of users and suppliers of infrastructure assets; (iv) changes in interest rates and the availability of funds which may render the purchase, sale, or refinancing of infrastructure debt difficult or impracticable; (v) changes in regulations, planning laws, and other governmental rules; (vi) changes in fiscal and monetary policies; and (vii) under-insured or uninsurable losses, such as force majeure acts and terrorist events. Many of the foregoing factors could cause fluctuations in usage, expenses and revenues, which could impact the ability to service infrastructure debt instruments. Interest Rate Risks—Interests rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by Clients. When interest rates increase, the value of a non-callable debt security tends to decline. A decline in interest rates may result in early prepayment of securities at time when equivalent securities bear a lower interest rate. In addition, the interest rate on floating rate investments is reduced when interest rates decline. Legal, Tax and Regulatory Risks—New and existing legal, tax, and regulatory regimes may adversely impact Aflac GI’s ability to conduct activities and transactions for Clients, or require material adjustments to the manner in which Aflac GI invests on behalf of its Clients. Liquidity Risks—Client assets may be invested in illiquid investments or in investments that are not publicly traded. As such, these assets may be difficult to purchase or sell. This can reduce a Client’s returns due to an inability to transact at advantageous times or prices. Moreover, investments that are illiquid or that trade in lower volumes may be more difficult to value than publicly traded or more liquid assets. Market and Macro Risks—The value of Clients’ investments will generally fluctuate in response to events affecting particular industry sectors or governments and/or general economic conditions. Non-U.S. Securities Risks—Investments in the securities of non-U.S. issuers are subject to the risks associated with non-U.S. markets in which those non-U.S. issuers are organized and operate, including but 10 | P a g e

not limited to, risks related to foreign currency limited liquidity, less government regulation, privatization, and the possibility of substantial volatility due to adverse political, economic, and geographic events or other developments, differences in accounting, auditing and financial reporting standards, the possibility of repatriation, expropriation or confiscatory taxation, adverse changes in investment or exchange controls or other regulations and potential restrictions on the flow of international capital. Public Health Risks (Including Acts of God and Geopolitical Risks)— The performance of Clients’ investments could be impacted by Acts of God or other unforeseen and/or uncontrollable events (collectively, “disruptions”), including, but not limited to, natural disasters, public health emergencies (including any outbreak or threat of existing or new pandemic or epidemic diseases), terrorism, social and political discord, geopolitical events, national and international political circumstances, and other unforeseen and/or uncontrollable events. These disruptions may impair an investment’s profitability. The extent of the impact of any such disruption on us, Clients, and any investments’ performance will depend on many factors, including the duration and scope of such disruption. A disruption may materially and adversely impact the value and performance of any investment, and our ability to achieve your investment objectives, ultimately resulting in significant losses. Valuation Risks—In valuing assets that lack a readily ascertainable market value, Aflac GI or its agent may utilize dealer-supplied quotations or pricing models. There is risk that the methodologies used in these third party quotations or pricing models are subject to error which could impact valuations. B. Risks that Apply Generally to Fixed-Income Investments Credit/Default Risk—Debt issuers and other counterparties of fixed income securities or instruments may default on their obligation to pay interest, repay principal or make a margin payment, or default on any other obligation. Additionally, the credit quality of securities or instruments held by Client accounts may deteriorate (e.g. be downgraded by ratings agencies), which could impair a security’s or instrument’s liquidity and decrease its value. Among other things, defaults, downgrades, and principal losses could result in the liquidation of the collateral and accelerate the payments of a Client’s investment, which may be at a loss. Credit Ratings—From time to time, Aflac GI uses credit ratings to evaluate securities even though such credit ratings might not fully reflect the true risks of an investment. High Yield Debt Securities Risks—High yield debt securities have historically experienced greater default rates than investment grade securities and are subject to additional liquidity and volatility risk. Issuer Risk—An issuer of a security may perform poorly and may not be able to meet principal and interest payments on their obligations. Changes to the financial condition or credit rating of an issuer of those securities may cause the value of the securities to decline or become worthless. Loan Risks—Risks associated with investing in loans include illiquidity due to extended trade settlement periods, default and foreclosure and decline in, or total loss of value of, any collateral securing the loan. Mortgage-Backed and/or Other Asset-Backed Securities Risks—Mortgage-related and other asset backed securities are subject to certain risks, such as “extension risk” (i.e. the risk that borrowers defer prepayment of loans due to market conditions), “prepayment risk,” (i.e. the risk of the premature return of principal) and, for 11 | P a g e

securities offered by non-governmental issuers, the failure of private insurers to meet their obligations and unexpectedly high rates of default on the mortgages backing the securities. Municipal Securities Risks—Municipal securities risks include credit/default risk, interest rate risk, potential changes in tax rates, the ability of the issuer to repay the obligation, the relative lack of information about certain issuers of municipal securities, and the possibility of future legislative changes which could affect the market for and value of municipal securities. Obligations Risks—Many loan obligations are subject to legal or contractual restrictions on purchase and sale or resale, and are relatively illiquid and may be difficult to value. Accordingly, where a Client invests in such loan obligations, there is risk that such assets could be difficult to sell, which could negatively impact the value of applicable Client accounts. Public/Private Side Risks— Borrowers of loans may provide lenders with confidential information about their business which could include material nonpublic information (“MNPI”). Under applicable law, Aflac GI and its related persons are prohibited from improperly disclosing or using MNPI for their personal benefit or for the benefit of any other person, including Clients. However, investors like Aflac GI can choose whether it will participate on the “private side” (i.e. receive borrower information that contains MNPI) or “public side” (i.e., whether to obtain only borrower information that does not contain MNPI). If Aflac GI chooses to receive “private side” information it will generally be restricted from purchasing or selling (but can continue to hold) the securities of the borrower (e.g., high-yield bonds) until such time as the information is no longer deemed MNPI in Aflac GI’s judgment. Aflac GI’s judgment with respect to whether it has MNPI could prove incorrect and, potentially, harm a Client. However, if Aflac GI participates on the “public side”, we will not be subject to trading restrictions, but, as a result, Aflac GI will not have access to borrower information that could be advantageous to a Client. Furthermore, other market participants could have possession of, and benefit from, such information. Structured Products Risk—Investment in structured finance arrangements, including collateralized mortgage obligations, collateralized debt obligations, collateralized bond obligations, collateralized loan obligations and private asset-backed securities, involve the risks associated with the underlying pool of securities or other assets, and also may involve risks different or greater than the risks affecting the underlying assets. In particular, these investments may be less liquid than the underlying debt obligations, making it difficult for an account to value its investment or sell the investment in a timely manner or at an acceptable price. C. Risks that Apply Generally to Derivatives Forward Contracts, Options and Swaps Risks—Investments in forward contracts, options and swaps, which are generally not regulated and are not subject to limitations on daily price moves, involve various types of risks, including, among others, market risk, liquidity risk, structuring risk, legal risk, tax risk, Counterparty Risk and Credit/Default Risk. Hedging Risks—Hedging techniques involve risks such as the possibility that losses on the hedge may be greater than gains in the value of the positions of our Clients.

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Requirement to Perform—When entering into forward, spot or option contracts, or swaps, a Client account will be required, and must be able, to perform its obligations under the contract. D. Risks that Apply Generally to the External Manager Platform Performance Dependent Upon Third-Party Management Companies—Returns of an investment in a thirdparty management company will depend upon the performance of such third-party management company. The past performance of a third-party manager may not be an indication of the future performance of such third-party manager. Reliance on Unaffiliated Advisers—Success of investments with a third-party manager depends upon, among other things, the ability of that manager to develop and successfully implement strategies that achieve their investment objectives. There is no guarantee that any third-party manager will be successful in achieving the investment objectives for Client accounts. E. Risks that Apply Generally to Alternative Investments Difficulty in Valuing Fund Investments—Valuation of interests in pooled investment vehicles and private funds may be difficult because there generally will be no established market for these interests or for securities of privately-held companies which such funds may own. Limited Ability to Negotiate Terms of Underlying Funds—Aflac GI may have limited or no opportunity to negotiate the terms of the interests in an Underlying Fund or other special rights or privileges, and, as a result, the terms, structure and other aspects of such investments may be disadvantageous for legal, tax, regulatory, and other reasons. Liquidity Risk—Private equity investments generally will be long-term and highly illiquid. Redemptions or withdrawals from external managers may be significantly delayed as a result of minimum holding periods, limitation of dates on which interests may be redeemed, significant redemption notice periods or redemption fees imposed by the external manager. F. Risks that Apply Generally to Real Estate Investments Commercial Mortgage Loans Risk—As with any interest rate sensitive investment, commercial mortgage loans are subject to interest rate movements which may lower investor returns when compared to current market rate returns. For example, during periods of declining interest rates, commercial mortgages can be expected to refinance at a lower interest rate, and the Client may lose future income streams from these investments. To the extent borrowers no longer make payments, it may become necessary to foreclose on, manage, and sell the property in order to recover all or a portion of unpaid loan balances. Real Estate Industry Risks—The real estate industry is sensitive to economic downturns, which may cause occasional or permanent reductions in property values and the values of securities of real estate companies may fluctuate between under-performance or outperformance of equity securities markets. Real Estate Equity Investing Risks— General investment risks related to the ownership of real property include, among others, declines in the value of real estate, negative changes in the climate for real estate, 13 | P a g e

risks related to general and local economic conditions, decreases in property revenues (including financial failure of tenants), increases in prevailing interest rates, property taxes and operating expenses, decreases in property revenue, changes in zoning laws and costs resulting from the cleanup of environmental problems. The value of real estate is typically dependent upon the ability or the potential for the applicable property to produce cash flow. However, a property’s net operating income and cash flow can be volatile. The net operating income, cash flow, and value of the properties can be adversely affected by any number of factors, including, without limitation: the age, design, and construction quality of the property; perceptions regarding the safety, convenience, and attractiveness of the property; the proximity and attractiveness of competing properties; the adequacy and effectiveness of the property’s operations, management, and maintenance; increases in operating expenses (including but not limited to real estate taxes and insurance premiums) at the property and in relation to competing properties; an increase in the capital expenditures needed to maintain the property or make improvements; costs associated with environmental liabilities or other legal liabilities; the dependence upon a single tenant, or a concentration of tenants in a particular business or industry; a decline in the financial condition of a major tenant; tenant bankruptcy; an increase in vacancy rates; and a decline in rental rates as leases are renewed or entered into with new tenants. Environmental Risk— The owner of real property can be exposed to substantial risk of loss from environmental claims arising with respect to real estate acquired with (or later subject to) environmental problems, and the loss could exceed the value of such investment. Environmental laws can often impose liability whether or not the owner or operator knew of, or was responsible for, the presence of such hazardous or toxic substances. Furthermore, changes in environmental laws or in the environmental condition of an asset can create liabilities that did not exist at the time of acquisition of investment and that could not have been foreseen. In addition, certain client real property assets could be located in earthquake zones or be subject to risks associated with other natural disasters, such as fire, windstorms, volcanic eruptions, flood or man-made disasters, including without limitation terrorist activities or acts of war. Uninsured Loss Risk— Generally, insurance coverage for a particular property is deemed adequate and appropriate given the property’s characteristics, relative risk of loss, the cost of such coverage, and industry practice. There are, however, certain types of losses that are generally excluded from coverage, such as losses due to riots or acts of war. Other losses are not economically feasible to insure fully, including without limitation losses due to floods or seismic activity, and therefore can be insured subject to certain limitations, including large deductibles or co- insurance payments. In the event an uninsured loss or a loss in excess of insured limits occurs, a client could lose its capital invested in such properties, as well as the anticipated future revenue from the properties. Portfolio Concentration Risk— Concentrations of a client’s portfolio in (or exposure to) real estate in certain geographic areas or certain types of real estate can increase the risk that adverse economic or other developments or natural or man‐made disasters affecting a particular region of the country or a particular segment of real estate, could adversely impact those properties.

In such instances, the Client will generally pay two layers of fees, including underlying fees and expenses associated with the product, in addition to advisory fees charged by Aflac GI. Aflac GI has a conflict of interest to recommend that Clients invest in affiliated products, as Aflac GI and/or its affiliates will receive additional compensation in connection with such investments than if the Client invested in an unaffiliated product. Aflac GI addresses such conflicts of interests through disclosure and by adopting policies and procedures to ensure that any investment recommendation made to a Client is in accordance with its fiduciary duty. Further, in certain instances, Aflac GI will waive its advisory fee in connection with a Client’s investment in an affiliated product. Aflac GI Holdings LLC owns a minority interest in Sound Point Commercial Real Estate Finance LLC (“SPCREF”), a registered investment adviser focused on commercial real estate investments, mortgage backed securities and other investments. SPCREF’s clients include certain affiliates and clients of Aflac GI. Aflac GI also has certain representatives that serve on SPCREF’s advisory board. Aflac GI has selected Sound Point Capital Management, L.P., the principal owner of SPCREF, to manage certain instruments on behalf of Clients and also recommends programs administered by Sound Point Capital Management, L.P. and SPCREF to Clients. As a result, Aflac GI Holdings LLC receives a financial benefit, including a share of the management fees Clients pay to SPCREF and any carried interest that may accrue. Additionally, certain Aflac GI clients holding real estate equity acquired through their mortgage programs enter into operating agreements for the special-purpose entities that hold real estate assets with SPCREF or a third party, which operating agreements set out that such SPCREF or third party will be responsible for the day-today management of the acquired real estate assets. Additionally, property managers can subcontract their obligations under the property management agreements to third party property managers or servicers. Subject to the terms of the specific written property management agreement and (in addition to the payment of assetrelated expenses of the portfolio property) the client will typically pay a property management fee payable monthly in advance, development fees, leasing fees, and construction management fees equal to a percentage of the cost of any interior and exterior construction, renovation, or repair of a portfolio property (other than ordinary maintenance and repairs). Aflac GI Holdings LLC owns a minority interest in Denham Sustainable Infra Management LP (“DSIM”), a registered investment adviser. DSIM’s clients include certain affiliates and clients of Aflac GI. Aflac GI also has certain representatives that serve on DSIM’s board. As a result, Aflac GI Holdings LLC receives a financial benefit, including a share of the management fees Clients of Aflac GI pay to DSIM and any carried interest that may accrue. 15 | P a g e

Aflac GI Holdings LLC owns a minority interest in Tree Line Capital Partners, LLC (“TLCP”), a registered investment adviser, and an indirect minority interest in Tree Line Capital Markets, LLC, a registered brokerdealer. TLCP’s clients include certain affiliates and clients of Aflac GI. Aflac GI also has certain representatives that serve on TLCP’s board. As a result, Aflac GI Holdings LLC receives a financial benefit, including a share of the management fees Clients of Aflac GI pay to TLCP and any carried interest that may accrue. From time-to-time Aflac GI Holdings LLC may acquire equity stakes in registered investment advisers which Aflac GI may select to manage investments on behalf of its Clients. In these circumstances, Aflac GI Holdings LLC may receive a financial benefit through its equity ownership. Aflac GI is not aware of all the relationships and dealings of SPCREF, DSIM, TLCP and/or their affiliates within the financial services sector or otherwise. As a result, Aflac GI is not aware of and therefore could not mitigate potential conflicts of interest that could arise in connection with the business of SPCREF, DSIM, TLCP or their affiliates. For example, clients of Aflac GI could be limited partners in the private funds of private equity sponsors to the portfolio companies of which DSIM, TLCP, or SPCREF provides financing. Similarly, affiliates of Aflac could provide insurance products to portfolio companies in which SPCREF, TLCP, or DSIM Clients invest. As described above, Aflac GI is affiliated with the following insurance companies that are admitted insurers in all 50 states, the District of Columbia, and several U.S. territories: Aflac Columbus, Aflac NY, CAIC and TOIC. Aflac GI is also affiliated with ALIJ, an insurance company incorporated in Japan, and Aflac Re Bermuda Ltd., a reinsurance company incorporated in Bermuda. Aflac GI has a sub-advisory agreement with AAMJ to assist AAMJ in providing asset management services to ALIJ. Aflac GI also has advisory agreements with sub-trusts of the Global Alternatives Trust I, i.e. the Fund, the Global Alternatives Fund SPC and its segregated portfolios. As part of its overall investment advisory arrangement with Aflac Columbus and AAMJ (as sub-adviser to ALIJ), Aflac GI provides advice with respect to investment in the Fund. Aflac GI has material business relationships with all of its Clients. Often personnel from Aflac GI and its Clients work together to manage Client portfolios and provide related services, including client liaison, investment monitoring, and account administration. Moreover, some of Aflac GI’s officers and all of its board members serve in a dual capacity as officers and/or board members of Aflac GI as well as officers and/or employees of Aflac Incorporated and/or one or more of its affiliates. These persons are shared with and provide services to Aflac GI under a service agreement with Aflac Incorporated (which has a services agreement with one or more affiliated companies). These persons are subject to the control of Aflac or its affiliates and might take actions that are different from the actions that individuals who are not employed by Aflac or its affiliates would take. Additionally, some Aflac GI employees serve on investment or other business committees of one or more of Aflac GI’s affiliates. Where Aflac GI employees have investment decision making authority for both Aflac GI and the Aflac GI affiliate, this creates actual and potential conflicts of interest, including but not limited to, a division of time and attention away from Aflac GI and its clients, as well as with regard to allocation of investment opportunities. Aflac GI has 16 | P a g e

implemented procedures to address actual and potential conflicts of interest that arise as a result of these situations. When Aflac GI’s investment professionals are performing work for more than one Aflac GI Client, the investment professional has an incentive to favor accounts that have larger assets under management than other accounts. Although this does not impact individual compensation, in such instances, the investment professional has an incentive to favor these accounts over others. However, all Aflac GI investment professionals are required to follow procedures for dealing with conflicts found in Aflac GI’s Code (see definition in Item 11 below) and the various policies that make up Aflac GI’s Compliance Manual (the “Compliance Manual”), which include Trade Allocation, Best Execution and Conflicts of Interest Policies. The Code and Compliance Manual require investment professionals to address all conflicts of interest.

The Code requires that our Employees adhere to the highest ethical standards and comply with applicable federal securities laws. Aflac GI distributes the Code to each employee and each employee is required to acknowledge receipt of the Code. The Compliance Team performs ongoing reviews of the Code, including monitoring of employee trading to ensure employees do not engage in improper transactions, and documents any violations. Aflac GI Employees may, from time to time, acquire or sell securities for their personal accounts that are also purchased, sold or held for the account of Clients. In addition, at times Employees may trade in a security at or around the same time as a Client. While this creates a conflict of interest, Aflac GI has policies and procedures in place to ensure that Employees always act in the Clients’ best interest, and Employees are not receiving better treatment with respect to their investments than Clients. The Code generally requires that all transactions in securities by Aflac GI Access Persons (as each term is defined in the Code) be cleared prior to execution through processes administered by the Compliance Team. Personal securities transactions also are subject to quarterly reporting requirements, annual certification requirements and related compliance obligations. Employees are also required to report to the Chief Compliance Officer (“CCO”) any violations of the Code that come to their attention. Among other things, the Code requires Aflac GI and its Employees to act in clients’ best interests, abide by all applicable regulations, avoid even the appearance of insider trading, and preclear and report on certain types of personal securities transactions. Employees are generally not permitted to trade alongside Client accounts. Aflac GI’s restrictions on personal securities trading apply to Employees, as well as Employees’ family members living in the same household. The Code of Ethics also covers matters such as outside business activities, gifts and entertainment, and political contributions.

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Aflac GI's Best Execution Policy describes the requirements for choosing a broker, and all new brokers must be approved by the Trade Practices Committee. Aflac GI's Compliance Team maintains an approved list of broker-dealers and all trades must be executed by these approved broker-dealers. The officer responsible for each asset class is responsible for the approved list of broker-dealers for the asset class and all additions to or deletions from this list are approved by the Trade Practices Committee, based upon a review of the brokerdealer’s ability to meet Aflac GI's requirements to seek to provide best execution for Client accounts. Directed Brokerage Occasionally, transactions are directed to a particular broker or dealer when market conditions indicate that this method is likely to produce better net prices. With regard to certain private fund clients, most investments made by such funds involve private securities that are not traded or sold through a broker-dealer. From time to time a portfolio company in such a fund later could seek to raise capital through a public offering of its common stock. If Aflac GI elects to liquidate a fund's interest in the portfolio company in the public offering, it could be required to do so through the underwriter of the offering or a broker-dealer specified by the underwriter or the equity sponsor. In that case, Aflac GI will be limited in its ability to select a broker-dealer to effect the transaction. In addition, Aflac GI might be unable to negotiate the commissions on such trades, and the fund could pay a higher commission than it would if Aflac GI was free to select the executing broker. Soft Dollars Aflac GI does not pay higher broker commissions in order to receive research or other products or services from brokers-dealers or other parties. In other words, Aflac GI does not make soft-dollar payments to brokerdealers. Nevertheless, Aflac GI has a Soft Dollar Policy in place in the event that it engages in soft dollars in the future. In the ordinary course of business, certain broker-dealers provide Aflac GI with research or analytical data, which they make available to a broad array of potential investors. Such data is not taken into consideration by Aflac GI in selecting broker-dealers. Aflac GI believes that any such data would be made available to Aflac GI regardless of whether or not trades are placed through a given broker-dealer. Aggregation and Allocation Aflac GI will aggregate the purchase or sale of securities for various client accounts if it is believed to be in the best interest of its Clients and consistent with Aflac GI’s duty to seek best execution. 18 | P a g e

The Trade Allocation Policy governs the allocation process and requires that the allocation process must treat everyone fairly over time, which is generally accomplished through pro rata allocation or a rotational basis, subject to factors such as IMA guidelines, client eligibility and other considerations. To the extent possible, orders are pre-allocated prior to execution. However, there may be instances where pre-allocating certain trades is not feasible or practicable given the unique nature of the respective market. In addition, in instances where there is limited capacity for a particular investment, it may not be possible or practical to allocate an investment pro-rata across all eligible client accounts. In these instances, not all clients that are eligible to participate in a particular investment will receive an allocation. Aflac GI will make such allocation determinations in accordance with its policies and procedures, which are designed to allocate in a fair and equitable manner over time and in light of the particular circumstances.

In the event a proxy is received, either physically or electronically, by Aflac GI for the benefit of its Clients, Aflac GI delegates the responsibility for voting such proxy (i.e., full discretion over the proxy voting execution function) to the respective external manager. If there is a proxy for an investment that is directly managed by Aflac GI, Aflac GI has adopted certain guidelines for voting proxies but may deviate from these guidelines when it determines that the particular facts and circumstances warrant such a deviation to protect the best interests of our Clients. If Aflac GI’s CCO identifies any potential conflict of interest with regard to a proxy vote between Aflac GI and one or more of our Clients, the CCO may convene an ad-hoc committee (“Conflicts Committee”) to debate the conflict and to give a ruling on a preferred course of action. If the Conflicts Committee determines that Aflac GI has a conflict of interest in any instance, the Conflicts Committee shall provide voting instructions. Aflac GI may cause the proxies to be voted in accordance with the recommendations of a third-party proxy advisory firm that Aflac GI may use to assist in voting proxies. For private equity investments managed by Aflac GI, consisting primarily of investments in private funds, Aflac GI exercises voting and consent rights relating to amendments to limited partnership agreements and other fund agreements. Aflac GI will evaluate the necessity to participate in shareholder class action litigation and similar matters. Aflac GI will not participate in class action litigation unless Aflac GI has the authority to act on behalf of Clients, determines it would be in the best interest of its Clients and uses a third party to assist in identifying and processing class action litigation. This third party is compensated on a contingency basis whereby they will receive a percent of any recovery obtained. The Clients/Fund will bear the cost, (i.e., receive a reduced amount of any class action proceeds), if any such third party is used for class action recovery services. Aflac GI credits any class action settlements received for a Client/Fund to that Client/Fund at time of receipt. All requests for proxy voting information and voting records, including Aflac GI’s Proxy Voting and Class Actions Policy, should be directed to, Jeffrey Haywood, CCO, at (212) 510-4600 or GIComplianceUS@aflac.com. Upon receiving a Client request, the CCO will forward a copy of the Client’s quarterly voting statement. The CCO maintains copies of all Client requests and of the information that was forwarded to the Client.

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