Uniplan Investment Counsel, Inc. (“UIC”) is an investment adviser registered as such with the SEC under the Investment Advisers Act of 19401. We provide sophisticated, specialized investment advisory management, sub-advisory and portfolio modeling services, on both a discretionary and nondiscretionary basis. We customize our services to the specific needs of each situation, utilizing both our own intellectual and proprietary resources and resources available through relationships with other specialized investment advisers. In this regard, we tailor our services primarily to the unique needs of clients, as more fully described below. We were founded in 2010 by Richard P. Imperiale, who is our sole shareholder, sole director, Chairman and Chief Investment Officer, although we have common roots, together with other affiliated registered investment advisers founded by Mr. Imperiale, dating back to 1984. Additionally, our wholly-owned subsidiary, Uniplan Institutional Advisors LLC (“UIA”) is structured and designed to offer and provide, specialized single- portfolio investment management services to institutional clients (as more fully described below) and high net worth individuals in such a way as to claim Global Investment Performance Standards (GIPS®) verification for purposes of reporting performance results. Mr. Imperiale is the Chairman and Chief Investment Officer of UIA, as more fully described below. Both we and UIA provide investment advisory services to numerous types of clients, including high net worth individuals, corporations and other business entities, other investment advisers, investment companies and other pooled investment vehicles, banks and other financial institutions, pension and profit-sharing plans subject to the Employee Retirement Income Security Act of 1974 as amended (“ERISA”) and their sponsors, trusts, estates, and charitable organizations. As of December 31, 2022, we managed assets on a discretionary basis totaling approximately $628,700,000 over 1,565 accounts. Discretionary accounts are those in which we have full investment authority given objectives and guidelines established in consultation with clients. Our investment advisory and portfolio management services are provided either on the basis of being the primary investment adviser to the client or being a subadvisor to another investment adviser or other institution. Additionally, we provided investment advisory services on a non-discretionary basis with respect to assets totaling $821,600,000 over 2,568 accounts as of December 31, 2022. The substantial majority of our business consists of our participation as a sub- adviser in various “wrap programs” or “unified managed account” programs sponsored by brokerage firms or other institutions that are unaffiliated with us. We ourselves do not sponsor any wrap program or UMA program. We also provide investment management services to private and institutional investor clients, including high net worth individuals, individual retirement accounts (“IRAs”), trusts, and employee benefit plans, pursuant to (a) “dual contract” arrangements, whereby the client has a contract with the broker-dealer or other institution by which the broker-dealer/institution provides advisory, brokerage and/or 1 Such registration does not imply a certain level of skill or training. custodial services, and, in addition, a separate investment management agreement directly with us (usually the broker-dealer/institution refers the client to us); or (b) “single contract” arrangements, whereby an investor simply enters into a discretionary investment management agreement with us and either we or the client selects a broker-dealer and/or custodian to use for the client’s account. Additionally, we will provide consulting services in specific circumstances, depending on the situation. These various types of arrangements pursuant to which we provide our services are more fully described in subsection I, below. We will from time to time utilize modeling and other information and data generated by Uniplan Consulting, LLC (“UC”), an affiliated entity as more fully described in Item 10, below, in performing various of our investment advisory services, including our portfolio modeling services more fully described below. UC provides proprietary qualitative and quantitative research and analytics. Clients do not incur any cost or charge on account of our use of such models, information or data. I. Types of Advisory Arrangements. A. Wrap Program Accounts (Discretionary Investment Management) As stated above, we provide discretionary investment management services to broker-dealer sponsors of wrap programs that retain us as an investment manager for such investment accounts in their wrap programs as the sponsor may designate. These broker- dealer wrap program sponsors typically enter into an investment advisory agreement with the owner of the investor account, and the broker-dealer sponsor then enters into a sub- advisory or similar type of agreement with us. The sponsor also remains responsible for client intake procedures (including anti-money laundering procedures and compliance), analyzing its client’s financial and investment needs, determining whether our advisory services are suitable for its client, monitoring and evaluating our performance on its client’s behalf, executing brokerage transactions within its client’s account, and providing custodial services for its client’s assets, as well as providing to its client periodic reporting of account performance, activity, etc. Our agreement with a wrap program sponsor typically provides that we will maintain investment discretion over the purchase and sale of securities and other investments within investor’s account, consistent with the particular investment strategy selected by the sponsor and account owner, and the capabilities of the custodian of the investor account. The owner of the investor account generally does not pay an investment advisory fee directly to us; instead, the wrap program sponsor pays our advisory fee out of the proceeds of the “wrap fee” that the owner of the investor account pays to the program sponsor. Otherwise, with some exceptions, wrap program accounts are managed by us in a manner that is generally similar to private/institutional client separately managed accounts with which we directly enter into investment management agreements (see Item 4.I.C., below). The wrap programs in which we participate are listed in our Form ADV Part 1A, and our investment management fee should be described in each sponsor’s respective Schedule H or wrap brochure (also known as an appendix) and also described in Item 5, below. Clients should receive a sponsor’s Schedule H or wrap brochure and direct any questions regarding the overall wrap fee, including our sub-advisory fee, to the sponsor. B. Unified Managed Account (“UMA”) Programs (Portfolio Modeling/Non- Discretionary Investment Management). We also offer non-discretionary investment management services consisting of building and maintaining model portfolios for broker-dealer and other institutional sponsors of “unified managed account” (“UMA”) programs on a subadvisory basis, which the sponsor then uses as one input in developing the sponsor’s own investment recommendations to its clients and in otherwise managing its own client accounts. When a UMA program sponsor engages us to provide our portfolio modeling services, we construct model investment portfolios that correspond to UIC’s investment strategy selected by the program sponsor. In this regard, we provide the UMA program sponsor with model portfolios and related data identifying our recommendations as to the securities to be purchased, sold and held from time to time in each UMA program account, as well as the percentage of the model portfolio that would be invested in each security. The UMA program sponsor retains sole authority and responsibility for managing its clients’ accounts, including executing trades and determining whether (or to what extent) to implement our recommendations. In the event that a UMA program sponsor determines to follow our recommendation regarding the purchase or sale

of any securities or other investments, the UMA program sponsor may purchase and sell those investments within its clients’ accounts at the same time, prior to, or after we might purchase and sell those investments within the corresponding UIC strategy for our other clients who utilize our discretionary investment management services. The resulting UMA program sponsor’s trading activity could have a positive or negative impact on the price at which we are able to execute trades for discretionary accounts. This is because the UMA program sponsor’s trading activity may affect the availability of securities in the marketplace. We mitigate the potential effect of this trading activity through established trade rotation procedures. Like wrap program accounts, the UMA sponsor remains responsible for client intake procedures (including anti-money laundering procedures and compliance), analyzing its client’s financial and investment needs, determining whether our advisory services are suitable for its client, monitoring and evaluating client account performance, and providing to its client periodic reporting of account performance, activity, etc. C. Private/Institutional Client Separately Managed Accounts (Discretionary Investment Management). We provide discretionary investment management services to private and institutional clients, typically managed in accordance with investment objectives, guidelines, and restrictions as either the broker-dealer/ institution or the client may determine as to investment types or strategies, securities trading and/or custodian arrangements. Unlike our arrangements with wrap fee program sponsors, when we provide services directly to private or other institutional clients (including investment companies and other pooled investment vehicles), whether on a primary advisory or subadvisory basis, we enter into a “dual contract” agreement. Under a “dual contract” arrangement, we enter into an investment advisory agreement with the client account owner and, in addition, the client has a separate contract with its broker-dealer or other institution that provides related services to the client, such as brokerage and/or custodial services. We also may from time to time provide discretionary investment management services to private individual and institutional clients (including investment companies and other pooled investment vehicles) under “single contract” arrangements, pursuant to which we enter into an investment advisory agreement directly with the client services described in Item 4, Section II, below, pursuant to which we may create and implement specialized investment strategies developed in consultation with the client. Under either type of arrangement, we may also agree to manage the account subject to certain reasonable restrictions that the account owner client or, in the case of dual contract arrangements, the broker-dealer or other institution, imposes on us regarding investment types or strategies, securities trading and/or custodian arrangements, etc. Even in situations where the account owner client or its broker-dealer/other institution directs us to use a particular broker-dealer to execute trades, we reserve the right to consult with the account owner client and/or the broker-dealer/institution and “step out” and execute trades elsewhere where we believe that it is in the best interests of the account or if we believe that circumstances otherwise warrant. Like wrap program and UMA program accounts, under dual contract arrangements where the broker-dealer/institution refers the client account owner to us, the broker- dealer/institution is responsible for client intake procedures (such as anti-money laundering procedures/compliance), and, where we are authorized to manage only a portion of the client’s investment portfolio, analyzing the client’s financial and investment needs, determining whether our advisory services are suitable for the client, monitoring and evaluating client account performance, and providing to the client periodic reporting of account performance, activity, and the like. II. Types of Investments and Investment Strategies. With respect to all of our investment management services, we focus on particular types of investments, including the following: The remainder of this page is intentionally left blank INVESTMENT TYPE FOCUS Real Estate Investment Trusts (REITs) and Real Estate Operating Companies (REOCs) Strategies U.S. domestic REIT opportunities Small Cap Strategies U.S. domestic equities with a market capitalization of approximately $500 Million to $4 Billion Micro Cap Strategies U.S. domestic equities with a market capitalization of approximately $100 Million to $500 Million Equity Income Strategies (High Income Total Return) Providing current income with a total return framework focusing on dividend paying common stocks, REITs, global infrastructure, and preferred securities. Fixed Income Strategies US domestic fixed income with a credit and duration profile consistent with the client’s investment policy Discretionary Investment Management Services to Investment Companies As directed by investment company client as set forth in investment advisory agreement. We do not necessarily limit our investment advice to these specialized categories and we will periodically utilize different investment strategies outside of those described above depending on the objectives of the client. In such cases, we will consult closely with the client in developing such investment strategy. In providing our services, as stated above, we offer, upon request, several specialized portfolio-building and enhancement tools which focus on a particular type of investment strategy and/or are designed to help the client attain its particular portfolio objective. We may provide these specific portfolio-building and enhancement tools in cooperation with other specialized investment advisers or other specialized service providers. These additional portfolio-building and enhancement tools include the following: Socially-Responsible Investment (SRI) Overlay Services: We offer, upon request, affirmative and negative screening of securities as to environmental, social, and corporate governance (“ESG”) issues that may affect the overall performance of the client’s investment portfolio across industries, sectors, regions, asset classes and through time. As part of this service, we also may develop an active ownership policy for the client consistent with the client’s ESG objectives. As to securities purchased for the client’s portfolio using this service, we may also do the following: -- Exercise proxy voting rights for the client consistent with its ESG objectives and monitor compliance with the client’s proxy voting policy if the client requests; -- Develop an engagement strategy and capability (either directly or through outsourcing); -- Submit shareholder resolutions consistent with the client’s ESG objectives; and -- Engage with company leadership on ESG issues; and -- Participate in collaborative engagement initiatives with companies the client is invested in. Strategic and Tactical Portfolio Overlay Services: Upon request, we develop and implement short term and intermediate term asset allocation strategies for client portfolios to enhance total return and reduce portfolio volatility. We do this through our development and use of quantitative timing models and portfolio hedging techniques that might include: -- Long-short matched pair trading; -- Option writing strategies; -- Position specific hedges; -- ETF based portfolio hedging strategies; -- Strategic and tactical valuation monitoring. “Bespoke” Services: Upon request, we create and implement, on both a primary advisory and a subadvisory basis, specialized investment strategies to other registered investment advisers, institutional clients (including investment companies and other pooled investment vehicles) and other counter parties requiring custom-designed strategies as to a portion of the client’s portfolio tailored to a particular need, objective or circumstance of the client. Our “Bespoke” services are typically provided under direct “single-contract” relationships between us and the client (see Item 4.I.C.).