TORTOISE CAPITAL ADVISORS, L.L.C.

The advisory business does not receive economic benefits from non-clients for providing advice to clients. It may engage unaffiliated independent contractors for client referrals, compensating them with a percentage of fees based on services performed, pursuant to written agreements. Clients are required to provide investment guidelines and restrictions in writing. The firm obtains research services, which can influence its selection of broker-dealers, potentially leading to the selection of a broker-dealer based on research benefits rather than the lowest transaction price. These brokerage products and services may be used across various client accounts, and a specific client may not always directly benefit from the research generated by their own commissions. The firm manages private funds where an affiliated general partner holds an interest and/or receives a carried interest in distributions, creating financial incentives. It acknowledges having financial incentives to favor certain clients over others. Client accounts may invest in different securities (e.g., equity, debt, preferred) of the same company and may compete for specific trades. The advice given, securities recommended, or transactions executed for certain accounts may differ from those for other client accounts, even if they share similar investment objectives.

The primary investment strategy is fundamentals-based and long-only, with an emphasis on managing risk, defined as the potential for a permanent loss of capital. Securities are purchased when fundamental-based risk, financial, and valuation models indicate they meet investment thresholds, sometimes with the idea of holding them for the long-term. There is a significant focus on companies in the energy industry, including energy and power infrastructure and the transition to cleaner energy. Investment strategies may also include short-term purchases and trading, leveraging and hedging, or writing (selling) covered call and put options on selected equity securities. For investment company clients, strategies may involve currency hedging transactions and interest rate transactions such as swaps, caps, and floors. Portfolio construction utilizes a three-prong approach: qualitative analysis (assessing asset quality, management, cash flows, and ESG factors), quantitative analysis (employing financial models for growth prospects, liquidity, and sensitivities), and relative value (using proprietary valuation models). These services are provided to individual and institutional investors, pooled investment vehicles, and clients in wrap fee programs.

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