Blackstone Infrastructure Advisors L.L.C. (the “Advisor”) is a Delaware limited liability company. The Advisor provides investment advisory services to an open‐ended private investment fund that has as its primary investment objective the making of control and control‐oriented infrastructure investments, as well as in public‐private partnership infrastructure projects, in each case within the “Core+” and “Core” space and its parallel funds (“BIP”), its related parallel account (“BIP‐P” or the “Parallel Account”) and other managed accounts (the “Other Parallel Accounts”) and certain closed‐ended private funds and other single investor and pooled vehicles that have or may make separate investments in the infrastructure space or co‐invest alongside BIP (the “Other Infrastructure Vehicles” and, together with BIP and BIP‐P, the “Funds”). Affiliates of the Advisor serve as the general partner (the “General Partner,” and, collectively, the “General Partners”) of each of the Funds. The Advisor was established in 2017. The ultimate parent of the Advisor is The Blackstone Group Inc., which is a publicly held corporation listed on the New York Stock Exchange that trades under the ticker symbol “BX”. Please see the structure chart below. The Blackstone Group Inc. (together with its affiliates, “Blackstone”) is a leading global alternative investment manager with investment vehicles focused on the private equity, real estate, hedge fund solutions, non‐investment grade credit, secondary private equity funds of funds and multi‐asset class strategies. Effective as of July 1, 2019, The Blackstone Group Inc. converted from a Delaware limited partnership named The Blackstone Group L.P. to a Delaware corporation. Please see Item 10 – Other Financial Industry Activities & Affiliations for more information.

As of March 31, 2019 the Advisor has regulatory assets under management of $23,543,091,583.

Description of Advisory Services:

The Advisor serves as investment advisor to the Funds pursuant to the terms of the investment advisory agreements (the “Advisory Agreements”) between the Advisor and each of the Funds, and makes investment decisions for the Funds including by evaluating the Funds’ investments. The individual needs of the investors in the Funds are not the basis of investment decisions by the Advisor. Investment advice is provided directly to the Funds by the Advisor and not individually to the Funds’ investors. Through a series of delegation agreements, the Advisor also provides specific portfolio management services to certain private investment funds managed by an affiliated alternative investment fund manager for the purposes of the European Union Alternative Investment Fund Managers Directive (“AIFMD”). Blackstone Intermediary Holdco L.L.C. Ultimate Parent Sole Member Blackstone Infrastructure Advisors L.L.C. The Blackstone Group Inc. (NYSE : BX) please register to get more info

Management Fees and Performance Fees Pursuant to the Advisory Agreements with each of the Funds, the Advisor is entitled to compensation from each Fund for its services in the form of an annual management fee (the “Management Fee”), payable quarterly in arrears consisting of the sum of (i) up to 1.00% per annum (which varies among the Funds) of the applicable Fund’s (i) total invested capital, in the case of certain Funds that are structured as “closed‐ended funds”, or (ii) net asset value, in the case of a Fund that is structured as a “open‐ended fund” (and certain Funds that are structured as “closed‐ended funds”) plus (ii) up to 0.50% per annum (which varies among the Funds) of undrawn capital commitments with respect to certain limited partners of certain Funds. The Management Fee is prorated for any partial periods. In certain cases, the Management Fee payable by an investor in a Fund may be waived or reduced for certain investors that have certain characteristics, such as if a Fund investor participates in an early closing of a Fund or makes a commitment to a Fund above a certain threshold. As set forth in Item 6 below, each of the General Partners receives performance‐based compensation in respect of either realized or unrealized (dependent upon the Fund) appreciation, subject to certain conditions, and, in addition, certain Funds distribute current income from investments. The offering materials (including the private placement memorandum as amended, restated or supplemented from time to time) (the “Offering Materials”), the organizational documents (including any applicable limited partnership agreements, limited liability company agreements and other formation documents, as amended or restated from time to time) (the “Organizational Documents”) and Advisory Agreement of each Fund include further details on fees, compensation and related matters. Management Fees and performance‐based compensation are either called from investors in the form of cash or units of the relevant Fund, if applicable, or drawn down from the relevant Fund’s subscription credit facility. Certain investors in the Funds, including current and/or former senior advisors, employees, officers and retired partners of Blackstone, chief executive officers of Blackstone Portfolio Entities (as defined herein), investment funds advised by Blackstone Multi‐Asset Advisors L.L.C. (“BTAS Funds”), employees of PJT Partners Inc. (“PJT”), BREP Funds, BREDS Funds, PE Funds, GSO Funds Strategic Partners, Life Sciences, BIS Funds, BAAM Funds (including BSOF), BSCH, Blackstone Life Sciences Funds, BTO Funds, BXMT Funds (each as defined herein) and certain other investment funds, managed accounts and/or other similar arrangements otherwise advised, managed or operated by Blackstone (and including such future investment funds, managed accounts and/or other similar arrangements) and any successors thereto (collectively, “Other Blackstone Clients”) and/or charitable programs, endowment funds and related entities established by or associated with any of the foregoing (including any trusts, family members, family investment vehicles, estate planning vehicles, descendant, trusts and other related persons or entities) (“Blackstone Investors”), will not pay Management Fees and/or performance‐based allocations in connection with their investment in the Funds or Blackstone‐ sponsored funds that make investments in or alongside one or more of the Funds. Notwithstanding the foregoing, such investors will either directly pay for their pro rata share of certain Fund expenses (as described below), or the pro rata amount of such expenses will be allocated to the applicable General Partners or their affiliates. In addition, to the extent current and/or former partners, employees, advisors and other persons referred to above, including their charitable programs, endowment funds and related entities established by or associated with any of the foregoing (including any trusts, family members, family investment vehicles, estate planning vehicles, descendants, trusts and other related persons or entities) and related entities, make capital commitments and/or otherwise invest in or alongside the Funds, any such amounts may, in each General Partners sole discretion, be treated as satisfying the applicable portion of any required capital commitment of such General Partner and/or its affiliates to the applicable Fund (even in circumstances where any such commitments or investments are made following a separation from Blackstone). For more information with respect to the allocation of Fund expenses, please see “Expenses” in Item 5 below. In addition, from time to time, Blackstone may enter into economic and/or fee sharing arrangements with respect to one or more Funds and/or certain limited partners thereof, which rights will not generally be made available to other limited partners. Blackstone Strategic Relationships In addition, Blackstone has entered, and it can be expected that Blackstone in the future will enter, into strategic relationships (“Strategic Relationships”) with investors that incorporate one or more investment strategies in addition to that of any particular Blackstone fund. A Strategic Relationship often involves an investor agreeing to make a capital commitment to multiple Blackstone funds, one or more of which may include a Fund. Investors will not receive a copy of any agreement memorializing a Strategic Relationship program (even if in the form of a side letter) and will be unable to elect any such rights or benefits afforded through a Strategic Relationship. Specific examples of such additional rights and benefits include, among others, specialized reporting, discounts on and/or reimbursement of management fees and/or carried interest or preferential or favorable rights applied to some or all of the relevant investment program and/or investment vehicles (including, as applicable, any of the Funds), secondment of personnel from the investor to Blackstone (or vice versa), as well as priority rights or targeted amounts for co‐investments alongside Blackstone funds (including, without limitation, preferential allocation of co‐investment, and preferential terms and conditions related to co‐ investment or other participation in Blackstone vehicles (including any carried interest and/or management fees to be charged with respect thereto)). The co‐investment that is part of a Strategic Relationship may include co‐investment in investments made by a Fund. Strategic Relationships may therefore result in fewer co‐investment opportunities (or reduced allocations) being made available to other investors in the Funds. Other Fees Payable to the Advisor and its Affiliates In addition, pursuant to the Advisory Agreements with certain Funds, the Advisor may charge investors with capital commitments below a certain threshold a servicing fee (the “Servicing Fee”), subject to the right of the applicable General Partner, in its sole discretion, to reduce or waive such fee. The Servicing Fee is generally equal to a percentage based on the investor’s share of net asset value (“NAV”) and payable quarterly in arrears. In addition to the Advisor’s Management Fee, any Servicing Fee and performance‐based allocations (see Item 6 below), the Advisor and its affiliates may also receive syndication and financial advisory fees (including underwriting fees), monitoring fees, property/asset management fees, acquisition fees, fees for asset management and/or property management services, mortgage servicing and due‐diligence, loan servicing, organization and financing fees and similar fees for arranging acquisitions and other major financial restructurings, commitment, transaction, break‐up and topping fees, operational fees, divestment fees and directors’ fees, fees for services related to group purchasing, healthcare consulting/brokerage, investment banking, capital markets, credit origination, loan servicing and/or other types of insurance, management consulting and other similar operational and finance matters, and/or other fees and annual retainers from (or, with respect to) the Funds’ portfolio companies. The Management Fee paid by Fund investors generally will not be offset by break‐up, topping, commitment (including fees received in respect of guarantees as contemplated by the applicable partnership agreement), monitoring, transaction, directors’ and organizational fees or any other fees received by the Advisor and its affiliates. Certain of the Funds bear the cost of fund administration services provided by Blackstone employees (including the allocation of their compensation), and except in certain limited circumstances or with respect to certain Funds, such amounts will not offset management fees. Fund investors should carefully consult the applicable Fund’s offering documents and Organizational Documents to determine the offsettable fees, if any, and the management fee offset percentage, if any, applicable to the Funds in which they are invested (See “Other Fees Received by the Advisor and its Affiliates” in Item 10 below). In addition, the Advisor will also engage and retain on behalf of the Funds and/or their portfolio companies senior advisors, industry experts, executive advisors, consultants, and other similar professionals who are not employees or affiliates of the Advisor and who may, from time to time, receive payments from, or allocations with respect to, portfolio companies or the Funds, and such amounts will not offset the Management Fee paid by the Funds (See “Advisors, Consultants and Partners” in Item 10 below). The precise amount of, and the manner and calculation of, the fees and compensation described above, including the Management Fee, any Servicing Fee and performance‐based compensation, are established by the Advisor through negotiations with investors in each Fund, and the offering documents, the Organizational Documents and the Advisory Agreement of each Fund include further details on such fees, compensation and related matters. Expenses The following is a list of expenses that are typically borne by the Funds (and indirectly by the Fund investors). This list is not intended to be exhaustive; prospective and existing investors in the Funds are advised to review the applicable Fund offering materials and Organizational Documents for a more extensive description of the expenses associated with an investment in the Funds. Subject to the limitations set forth in the Organizational Documents, costs, expenses and charges specifically attributed or allocated by the Advisor and its affiliates to the Funds may exceed what would be paid to an unaffiliated third party for substantially similar services.  Legal fees (including costs for in‐house transactional legal advice and/or services allocated by the Advisor to the Funds or their portfolio entities on matters related to potential or actual investments or transactions and other legal matters of the Funds).  Placement fees.  Regulatory filing fees of the Funds, including but not limited to compliance with U.S. federal and state securities laws and international laws, such as the AIFMD.  Expenses related to the Advisor’s compliance matters and regulatory filings to the extent they relate to its Funds’ activities (e.g., Form PF, U.S. Commodity Futures Trading Commission (“CFTC”) filings, AIFMD filings (including any costs associated with the AIFMD marketing passport)) and any related regulations, including costs and expenses of collecting and calculating data and preparation of regular reports to be filed with EEA member states.  Administrative fees, expenses and/or charges (See “Other Fees Received by the Advisor and their Affiliates” in Item 10 below).  Organizational expenses associated with operating the Funds.  Operating expenses.  Consultant and senior advisor expenses (See “Advisors, Consultants and Partners” in Item 10 below).  Technology expenses (which may include internally allocated charges for certain Funds).  Accounting fees.  Taxes, tax‐related interest and expenses related to the preparation and delivery of any entity‐level taxes.  Tax advisor fees including all expenses in connection with any tax audit, examination or investigation.  Audit fees.  Brokerage commissions.  Transaction fees.  Fees and expenses associated with borrowing, guarantees and other financing, including interest charges.  Expenses of loan servicers and other service providers (including, for the avoidance of doubt, the costs and charges allocable with respect to the provision of fund administration or other services and professionals related thereto (including secondees and temporary personnel or consultants) as deemed appropriate by the General Partner).  Expenses associated with the development, negotiation, acquisition, holding, monitoring and disposition of investments.  Fees, costs and expenses related to the organization or maintenance of any intermediate entity used to acquire, hold or dispose of any one or more investments or otherwise facilitating a Fund’s investment activities.  Custodial fees.  Depository fees.  Research‐related expenses, including news and quotation equipment and services and data collection and including costs allocated by Blackstone’s internal research and third party groups (which are generally based on time spent), internal and third‐party printing (including a flat service fee) and publishing (including time spent performing such internal printing and publishing services).  Broken‐deal expenses (See “Other Fees Received by the Advisor and its Affiliates” in Item 10 below).  Expenses associated with the preparation, printing and delivery of the Funds’ periodic reports and related financial and other statements and investor notices and communications (including preparation and delivery of tax returns, K‐1s and other communications or notices relating to the Funds).  Expenses of the L.P. Advisory Committees or any independent client representative.  Expenses of investor meetings.  Expenses associated with a Fund’s compliance with applicable laws and regulations.  Expenses of litigation involving the Funds or entities in which the Funds have investments and the amount of any judgments, fines, remediation or settlements paid in connection therewith.  Expenses incurred in connection with complying with provisions in investor side letter agreements, including “most favored nations” provisions.  In‐house fund administration costs and related overhead (See “Other Fees Received by the Advisor and its Affiliates” in Item 10 below).  Travel and entertainment expenses in connection with the Funds’ fundraising and investment activities (including first class and/or business class airfare (and/or private charter, where appropriate), first class lodging, ground transportation, travel and premium meals (including closing dinners and mementos, cars and meals (outside normal business hours), social and entertainment events with Portfolio Entity management, customers, clients, borrowers, brokers and service providers)). Travel and entertainment expenses in connection with a trip taken by employees of the Advisor and/or the General Partner for purposes of multiple matters will generally be allocated to each such matter based on the time spent for each matter and then the resulting expenses will be allocated among the Funds, Other Blackstone Clients and/or the Advisor as otherwise set forth herein.  Expenses associated with the acquisition, settling, holding, monitoring, and disposition of investments (including without limitation, any brokerage, custody, or hedging costs and travel and related expenses in connection with the Funds’ investment activities).  Insurance (including cost of title insurance).  Indemnification expenses (including advancement of any fees, costs or expenses to persons entitled to such indemnification).  Expenses of liquidating the Funds.  Marketing, advertising, printing, wholesaling and other capital raising expenses associated with investor admission/subscription and investor‐related services and other similar costs.  Arbitration expenses.  Valuation costs.  Expenses of third‐party advisory committees of the Funds as well as of other goods and services provided by third parties and other third party professionals.  Expenses associated with redemptions and admissions/subscriptions. Certain personnel of Blackstone and its affiliates, including consultants, may be seconded to one or more Portfolio Entities, service providers and vendors or limited partners of a Fund and Other Blackstone Clients to provide services, including the sourcing of investments for the Funds or other Parties. The salaries, benefits, overhead and other similar expenses for such personnel during the secondment could be borne (in whole or in part) by Blackstone and its affiliates or the organization for which the personnel are working or both. In addition, personnel of portfolio entities, vendors, service providers (including law firms and accounting firms) and limited partners of the Funds and Other Blackstone Clients may be seconded, or serve internships at, Blackstone and Portfolio Entities of the Funds. While the Funds, Other Blackstone Clients and their Portfolio Entities are often the beneficiaries of these types of arrangements, Blackstone is from time to time a beneficiary of these arrangements as well, including in circumstances where the vendor or service provider also provides services to the Funds in the ordinary course. Blackstone or the portfolio entity may or may not pay salary or cover expenses associated with such secondees and interns, and if a portfolio entity pays the cost it will be borne directly or indirectly by the Funds. The Management Fee will not be offset or reduced as a result of these secondments or internships or any fees, expense reimbursements or other costs related thereto. The personnel described above may provide services in respect of multiple matters, including in respect of matters related to Blackstone, its affiliates and related parties, and any costs of such personnel may be allocated accordingly. Investors in a Fund are allocated their pro rata share of such additional fees and expenses and the Funds generally bear their share of fees and expenses as part of their participation in investments. Pursuant to the Organizational Documents of certain Funds, all expenses (including organizational, legal, reporting and compliance‐related expenses and other expenses described in Item 5 above) are generally allocated between such Funds (including any parallel funds formed in the future in Luxembourg and any related AIFMD and other marketing and compliance‐related expenses that are not directly connected to such Funds and their activities) on a pro rata basis; provided, that the General Partners may in good faith allocate any expenses of the applicable Funds and their respective alternative investment vehicles between or among the Funds and their respective alternative investment vehicles on another basis if they determine such allocation is more equitable or appropriate under the circumstances. From time to time, each General Partner will be required to decide whether costs and expenses are to be borne by a Fund, on the one hand, or the relevant General Partner and the Advisor, on the other, and/or whether certain costs and expenses should be allocated between or among the Funds, on the one hand, and other funds, investment vehicles, separate managed account arrangements and special purpose vehicles managed by affiliates of Blackstone (“Other Blackstone Accounts”), on the other. Certain expenses may be suitable for only a particular Fund participating in specific investments and may be allocated to and borne only by such Fund, or, as is more often the case, expenses may be allocated pro rata among the Funds participating in the relevant investment(s) (or in such other allocation as the applicable General Partners decide in good faith is more equitable or appropriate) even if the expenses relate only to particular vehicle(s) and/or investor(s) therein (or some of all Funds in the case of expenses applicable to such Funds generally). With respect to broken deal expenses, the Funds will generally be required to bear their pro rata portion of broken deal expenses in accordance with the amount they were expected to invest in the unconsummated deal. Certain co‐investment vehicles however, or certain potential co‐investors who might have invested in a transaction had it been consummated will not be allocated any share of such break‐up or topping fees or broken deal expenses, such as potential investors in co‐investment structures relating to a specific investment where the legally binding agreements relating to such co‐investment are not executed until the time of the deal closing, unless the applicable General Partner determines otherwise in its discretion or as may be set forth in the relevant operative agreements. Each General Partner will make such judgments in a manner that it determines to be fair and reasonable in good faith, notwithstanding its interest in the outcome, and may make corrective allocations should it determine that such corrections are necessary or advisable. However, such determination is inherently subjective and may give rise to conflicts of interest in light of the inherent biases in the process. There can be no assurance that a different manner of allocation would not result in a Fund bearing less (or more) expenses. please register to get more info

In addition to the Management Fees and other fees described in Item 5 that are received by the Advisor, the General Partners of BIP and BIP‐P each receive performance‐based compensation equal to 12.5% and 10%, respectively, of any appreciation (including unrealized appreciation) of the Fund’s investment portfolio, taking into account any distributions made to investors over the applicable period, following BIP or BIP‐P, as applicable, achieving a certain hurdle amount during such period (as set forth in the applicable Fund’s organizational documents). The General Partners of Other Infrastructure Vehicles generally receive a percentage of the profits of current disposition proceeds from each such Other Infrastructure Vehicle with respect to each investor (other than those that are affiliates of the Advisor), typically analogous to the performance‐based compensation received with respect to BIP and BIP‐P. BIP distributes cash available for distribution, as determined by the applicable General Partner in its sole discretion, on a periodic basis. Investors in BIP will have all of such distributions reinvested by the applicable General Partner of BIP unless they elect otherwise. In addition, BIP generally expects to reinvest proceeds received by it in connection with a disposition or use such proceeds for any other purpose permitted under the Organizational Documents (including satisfying redemption requests). The fact that the Advisor’s affiliates are in part compensated based on the performance of the Funds may create an incentive for the Advisor to make investments on behalf of investors that are riskier or more speculative than would be the case in the absence of the performance‐ based compensation arrangement, or time the sale of investments in a manner motivated by the personal interests of Blackstone personnel. However, the commitment by Blackstone to invest in the Funds, loss carryforward provisions or clawback provisions (which are provisions in certain of the Organizational Documents that require a General Partner to make up any depreciation over a certain period of time prior to taking incentive compensation or return excess amounts of performance based allocations that have been received, respectively), and the fact that the preferred return is calculated on an aggregate basis, in each case, where applicable, should tend to reduce the incentive to make more speculative investments or otherwise time the sale of investments in a manner motivated by personal interests of Blackstone personnel. In connection therewith, the General Partner’s clawback obligation in certain Funds may create an incentive for such General Partner to defer the disposition of one or more investments in such Funds if such disposition would result in a realized loss, a return on investment that was less than the preferred return and/or the finalization of dissolution and liquidation of such a Fund where a clawback obligation would be owed. As described in Item 5, Blackstone Investors are not subject to Management Fees or performance‐based compensation allocations. please register to get more info

The Advisor manages the Funds. The Funds’ investors may consist of some or all of the following:  Banks and other financial institutions  Insurance companies  Investment companies  Public and private retirement and pension plans  Public and private profit sharing plans  Trusts and estates  Charitable organizations and foundations, including endowment funds thereof  State and municipal government agencies  Sovereign wealth funds  Private investment funds  Corporations  Business entities other than those listed above  High net worth individuals  Family offices Investors may also include other funds, vehicles and/or accounts managed by affiliates of Blackstone (including investors in Funds established for the BTAS program, Blackstone Harrington Partners L.P., Fidelity and Guaranty Life and Strategic Partners funds). All investors are subject to applicable suitability requirements. The Advisor and the General Partners require that each investor in the Funds be (i) an “accredited investor” as defined in Regulation D under the U.S. Securities Act of 1933, as amended (the “Securities Act”), and (ii) a “qualified purchaser” as defined in Section 2(a)(51) of the U.S. Investment Company Act of 1940, as amended, and meet other suitability requirements (including, in some circumstances, a person that is not a U.S. Person as defined in Regulation S under the Securities Act). Generally, investors must invest a minimum dollar amount as determined in the applicable General Partner’s sole discretion. Each General Partner reserves the right, in its sole discretion, to waive the minimum dollar amount. please register to get more info

Investment Strategies:
The Advisor offers advice to the Funds generally to invest in control and control oriented infrastructure investments, as well as in public‐private partnership infrastructure projects, in each case within the “Core+” and “Core” space (including (i) preferred stock, debt and other securities relating to common equity investments and (ii) preferred stock, debt and other securities that are expected to produce equity‐like returns) in conjunction with privately negotiated transactions. These investments are generally made in connection with acquisitions, dispositions, restructurings, workouts, management acquisitions and other similar situations and utilize some degree of leverage. The Advisor’s investment analysis methods include fundamental, technical and cyclical research. The Advisor’s investment team is responsible for evaluating securities (and other products) for investment. The Advisor’s investment professionals also review all portfolios for adherence to the investment objectives of each portfolio and the Fund’s stated investment strategies. The Advisor personnel generally meet each Monday to discuss potential and pending transactions. At that meeting such transactions are discussed (unless there are no new developments or activities to report). If the Advisor’s consideration of a transaction has advanced beyond the preliminary evaluation stage, a brief memorandum to a review committee (the “Review Committee”) is prepared and the transaction is discussed at the regular weekly meetings of the Review Committee. If at such meeting the Review Committee authorizes the transaction team to continue to pursue the transaction, the transaction team will conduct further work. If the transaction reaches the stage where the transaction team proposes to make a definitive bid to acquire or invest in the target company or business (usually this is the “second round” of bidding, following an initial round in which preliminary, non‐binding indications of interest are submitted by interested bidders), it will prepare a detailed memorandum on the transaction for the investment committee (“Investment Committee”) and convene a meeting of the Investment Committee to discuss the transaction in depth with the transaction team and decide whether to authorize such a definitive bid and what the bid should be. In addition to an in‐depth discussion of the target company or business and the investment thesis, deal tactics and potential exit strategies will usually be discussed by the Investment Committee and the transaction team. The Investment Committee will often conduct multiple meetings on a particular deal. Both the Review Committee and Investment Committee processes involve a consensus approach to decision making. The sole limited partner of BIP‐P will be entitled to a non‐voting observer seat on the Investment Committee. Blackstone believes that a key component of being a responsible investor is an active evaluation of the environmental, social and governance (“ESG”) components of each investment we make. Review of ESG risks is integrated into Blackstone’s investment analysis and decision‐making process from pre‐acquisition diligence through post‐acquisition monitoring. Blackstone’s approach to ESG is designed to identify risks and enhance long‐term performance across our various investments.
Risk of Loss:
An investment in the Funds entails a significant degree of risk and therefore should be undertaken only by investors capable of evaluating the risks of the Funds and bearing the risks such investments represent. Set forth below is a non‐exhaustive list of such risks: 1. No assurance of investment return 2. Limited operating history 3. Reliance on the Sponsor 4. Role of private equity professionals 5. Highly competitive market for investment opportunities; operators and other partners 6. General economic and market conditions 7. Financial market fluctuations; availability of financing 8. Inflation 9. Investment outside the United States generally 10. Economic, political and social risks 11. Regional risk; independence of markets 12. Trade policy 13. Terrorist activities 14. Natural disasters 15. Corruption risk; FCPA 16. Privatization 17. Foreign investments controls 18. Foreign capital controls 19. Legal framework and corporate governance 20. Accounting, disclosure and regulatory standards 21. Investments in emerging markets and the Asia Pacific region 22. Potential collapse of the Euro 23. United Kingdom exit from the European Union 24. Chinese growth slowdown; Chinese economy 25. Investments in open market purchases; publicly traded securities 26. Nature of debt securities 27. Convertible securities 28. Illiquid and long‐term investments 29. Non‐controlling investments; investments with third parties 30. Investment in restructuring 31. Investment in less established companies 32. Investments in regulated industries 33. Future investment techniques and instruments 34. Technological innovations 35. Environmental matters 36. Government action risk 37. Force majeure risk 38. Availability of insurance against certain catastrophic losses 39. Volatility of commodity prices 40. Catastrophe risk 41. Energy and natural resources regulatory risk 42. Risks related to hydraulic fracturing 43. Regulatory approvals 44. Additional capital requirements 45. Adequacy of reserves 46. Deployment of capital 47. Distributions in‐kind 48. Failure to make payments 49. Risks relating to due diligence of investments 50. Political activities 51. Reliance on portfolio entity management and third parties 52. Risks in effecting operating improvements 53. Expedited transactions 54. Portfolio entity liabilities 55. Risks from operations of other portfolio entities 56. Volatility of credit markets may affect ability to finance and consummate investments 57. Bridge financings 58. Leverage; subscription line of credit 59. Foreign currency and exchange rate risks 60. Hedging risks/derivatives 61. Risk of limited number of investments; lack of diversification 62. Liabilities on disposition of investments 63. Documentation and legal risks 64. Legal, tax and regulatory risks 65. OFAC and sanctions considerations 66. Absence of oversight under the Investment Company Act 67. Derivatives; Registration under the U.S. Commodity Exchange Act 68. Pay‐to‐Play laws, regulations and policies 69. Financial industry regulation 70. Change of law risk 71. FATCA 72. Possible legislative or other developments 73. Proposed legislation adversely affecting Blackstone employees and other service providers 74. Limitations on deductions of business interest 75. Partnership audit legislation 76. Phantom income 77. Taxation in certain jurisdictions 78. UBTI & ECI; tax treatment of non‐U.S. feeder vehicles and corporations 79. Provision of managerial assistance 80. ERISA considerations 81. Risk arising from potential control group liability 82. Cyber security breaches 83. Acquisition of sub performing infrastructure loans and participation 84. Investments in the Energy Sector 85. General Infrastructure Investment Characteristic Risks 86. Operational risk 87. No market for limited partnership interests; restrictions on transfers 88. Restrictions on redemptions and withdrawals with respect to open ended Investment Vehicles 89. Dilution from Subsequent closings 90. Recycling, reinvestments 91. Possible exclusion 92. Amendments 93. Sponsor voting 94. Annual informational meetings 95. Handling of mail 96. Valuation matters 97. Uncertainty of projections
Investors are advised to review the applicable Fund offering materials for a more extensive
description of the risks of investing in the Funds.
Stock markets and bond markets fluctuate substantially over time and performance of any investment is not guaranteed. As a result, there is a risk of loss of value in the assets which the Advisor manages that is out of the Advisor’s control. The Advisor cannot guarantee any level of performance or that investors in the Funds will not experience a substantial or complete investment loss. There is no assurance that the Funds will be able to generate returns or that the returns will be commensurate with the risks inherent in their investment strategies. The marketability and value of any such investment will depend upon many factors beyond the control of the Funds. The expenses of the Funds may exceed their income, and an investor in a Fund could lose the entire amount of its contributed capital. Therefore, an investor should only invest in a Fund if the investor can withstand a total loss of its investment. The past investment performance of the Funds cannot be taken to guarantee future results of the Funds or any investment in the Funds. please register to get more info

The Advisor does not have any legal, financial or other “disciplinary” event to report. As a registered investment adviser, the Advisor is obligated to disclose any legal disciplinary event that would be material to a client when evaluating the adviser’s advisory business or integrity of its management. On occasion, in the ordinary course of its business, Blackstone is named as a defendant in a legal action. Although there can be no assurance of the outcome of such legal actions, the Advisor does not believe that any current legal proceeding or claim to which Blackstone is a party would individually or in the aggregate materially affect the Advisor and/or the Funds’ results of operations, financial position or cash flows. Certain regulatory, litigation and other similar matters are disclosed in (i) Blackstone’s public filings (including, without limitation, its current, periodic and annual reports on Forms 8‐K, 10‐Q and 10‐K), which may be accessed through the web site of the SEC (www.sec.gov) or Blackstone (http://ir.blackstone.com/investors/annual‐reports‐and‐sec‐filings/default.aspx), and (ii) materials made available through Blackstone’s BXAccess online portal, which is accessible to each Fund’s limited partners with respect to such Fund. please register to get more info

Other Financial Industry Activities and Affiliations Blackstone has conflicts of interest, or conflicting loyalties, as a result of the numerous activities and relationships of Blackstone, the Advisor, the Funds, the Other Blackstone Clients, the Portfolio Entities of the Funds and Other Blackstone Clients and affiliates, partners, members, shareholders, officers, directors and employees of the foregoing, some of which are described herein. However, not all potential, apparent and actual conflicts of interest are included below, and additional conflicts of interest could arise as a result of new activities, transactions or relationships commenced in the future. In addition, certain terms described herein may only be applicable to certain of the Funds but not others. Fund investors should review this section and the applicable Fund’s Organizational Documents carefully for additional risks and conflicts disclosure before making an investment decision. Any references to Blackstone and/or the Advisor in this section will be deemed to include their respective affiliates (including the General Partners), partners, members, shareholders, officers, directors and employees. References herein to “Portfolio Entity” describes, individually and collectively, any entity owned, directly or indirectly through subsidiaries, by the Funds or Other Blackstone Clients, including, as the context requires, Portfolio Entities, holding companies, special purpose vehicles and other entities through which Investments are held. If any matter arises that the Advisor determines in its good faith judgment constitutes an actual and material conflict of interest, the Advisor will take the actions it determines appropriate to mitigate the conflict, which will be deemed to fully satisfy any fiduciary duties it may have to the Funds or the Fund investors. Thereafter, the Advisor will be relieved of any liability related to the conflict to the fullest extent permitted by law. Actions that could be taken by the Advisor or its affiliates to mitigate a conflict include, by way of example and without limitation, (i) if applicable, handling the conflict as described in the Organizational Documents; (ii) presenting a material conflict of interest to the L.P. Advisory Committee and/or the limited partners (or L.P. representatives) of the Funds and as expressly provided for in the Organizational Documents; (iii) disposing of the investment or security giving rise to the conflict of interest; (iv) appointing an independent representative (an “Independent Client Representative”) to act or provide consent with respect to the matter giving rise to the conflict of interest; (v) in connection with a matter giving rise to a conflict of interest with respect to an investment, consulting with the L.P. Advisory Committee and/or the limited partners (or L.P. representatives) of the Funds or Independent Client Representatives (if any) regarding the conflict of interest and either obtaining a waiver or consent from the L.P. Advisory Committee and/or the limited partners (or L.P. representatives) or such Independent Client Representative of the conflict of interest or acting in a manner, or pursuant to standards or procedures, approved by the L.P. Advisory Committee and/or the limited partners (or L.P. representatives) or such Independent Client Representative with respect to such conflict of interest; (vi) disclosing the conflict to the limited partners (including, without limitation, in drawdown notices, distribution notices, quarterly letters or other communications); (vii) in the case of conflicts among clients, creating groups of personnel within Blackstone separated by information barriers (which may be temporary and limited purpose in nature), each of which would advise or represent one of the clients that has a conflicting position with other clients; (viii) implementing policies and procedures reasonably designed to mitigate the conflict of interest; or (ix) otherwise handling the conflict as determined appropriate by the Advisor in their good faith reasonable discretion. There can be no assurance that the Advisor will identify or resolve all conflicts of interest in a manner that is favorable to the Funds. Blackstone Policies and Procedures. For purposes of this Brochure, (a) “BTO Funds” shall be deemed to include any account, client, fund, vehicle or any other similar arrangement managed by Blackstone Tactical Opportunities Advisors L.L.C.; (b) “BREP Funds” shall be deemed to include any account, client, fund, vehicle or any other similar arrangement managed by Blackstone Real Estate Advisors L.P.; (c) “BREDS Funds” shall be deemed to include any account, client, fund, vehicle or any other similar arrangement managed by Blackstone Real Estate Special Situations Advisors L.L.C.; (d) “BTAS Funds” shall be deemed to include any account, client, fund, vehicle or any other similar arrangement managed by Blackstone Multi‐Asset Advisors L.L.C.; (e) “BAAM Funds” shall be deemed to include any account, client, fund, vehicle or any other similar arrangement managed by Blackstone Alternative Asset Management LP; (f) “BIP Funds” shall be deemed to include any account, client, fund, vehicle or any other similar arrangement managed by Blackstone Infrastructure Advisors L.L.C.; (g) “BIS Funds” shall be deemed to include any account, client, fund, vehicle or any other similar arrangement managed by Blackstone ISG‐II Advisors L.L.C.; (h) “GSO Funds” shall be deemed to include any account, client, fund, vehicle or any other similar arrangement managed by GSO Capital Partners LP; (i) “Strategic Partners” shall mean Strategic Partners Fund Solutions Advisors L.P.; (j) “Life Sciences” shall mean Blackstone Life Sciences Advisors L.L.C.; (k) “Clarus” shall mean Clarus Ventures, LLC; (l) “BSOF” shall mean Blackstone Strategic Opportunities Fund; (m) “BXMT” Funds” shall mean accounts, clients, funds, vehicles or any other similar arrangement managed by BXMT Advisors L.L.C. and (n) “BSCH” shall mean Blackstone Strategic Capital Holdings and its related vehicles/entities and successor funds. Performance‐Based Compensation. The Advisor’s performance‐based compensation creates a greater incentive for the Advisor to make more speculative investments on behalf of a Fund or time the purchase or sale of investments in a manner motivated by the personal interest of Blackstone personnel than if such performance‐based compensation did not exist, as the Advisor receives a disproportionate share of profits above the preferred return hurdle. In addition, recently enacted tax reform legislation provides for a lower capital gains tax rate on performance‐based compensation from investments held for at least three years, which may incentivize the Advisor to hold investments longer to ensure long‐term capital gains treatment or dispose of investments prior to any change in law that would result in a higher effective income tax rate on performance‐based compensation. The amount of the performance‐based compensation will be dependent on valuations conducted by the Advisor in the case of certain Funds, which could incentivize the Advisor to value the securities higher than if there were no performance‐based compensation. The Advisor can engage third parties to determine the value of securities distributed in‐kind or non‐marketable securities and rely upon the third‐party opinion of value, but there can be no assurance such an opinion will reflect value accurately. Allocation of Personnel. The Advisor will devote such time to the relevant Funds as it determines to be necessary to conduct its business affairs in an appropriate manner. However, Blackstone personnel, including members of the Investment Committee, will work on other projects, serve on other committees and source potential investments for and otherwise assist the investment programs of Other Blackstone Clients and their Portfolio Entities, including other investment programs to be developed in the future. Time spent on these other initiatives diverts attention from the activities of the Funds, which could negatively impact the Funds and their investors. Furthermore, Blackstone and Blackstone personnel derive financial benefit from these other activities, including fees and performance‐based compensation. Blackstone personnel outside the Blackstone Infrastructure group share in the fees and performance‐based compensation from the Funds; similarly, the Blackstone Infrastructure group personnel share in the fees and performance‐based compensation generated by Other Blackstone Clients. These and other factors create conflicts of interest in the allocation of time by Blackstone personnel. A General Partner’s determination of the amount of time necessary to conduct a Fund’s activities will be conclusive, and a Fund’s investors rely on such General Partner’s judgment in this regard. Outside Activities of Principals and Other Personnel and their Related Parties. Certain personnel of Blackstone may be subject to a variety of conflicts of interest relating to their responsibilities to the Funds, Other Blackstone Clients and their respective Portfolio Entities, and their outside business activities as members of investment or advisory committees or boards of directors of or advisors to investment funds, corporations, foundations or other organizations. Such positions create a conflict if such other entities have interests that are adverse to those of the Funds, including if such other entities compete with the Funds for investment opportunities or other resources. The Blackstone personnel in question may have a greater financial interest in the performance of the other entities than the performance of the Funds. This involvement may create conflicts of interest in making investments on behalf of the Funds and such other funds, accounts and other entities. Although the Advisor will generally seek to minimize the impact of any such conflicts, there can be no assurance they will be resolved favorably for the Funds. Also, Blackstone personnel are generally permitted to invest in alternative investment funds, private equity funds, real estate funds, hedge funds and other investment vehicles, as well as securities of other companies, some of which will be competitors of the Funds. Fund investors will not receive any benefit from any such investments, and the financial incentives of Blackstone personnel in such other investments could be greater than their financial incentives in relation to the Funds. Additionally, certain personnel and other professionals of Blackstone have family members or relatives that are actively involved in industries and sectors in which the Funds invest or have business, personal, financial or other relationships with companies in such industries and sectors (including the advisors and service providers described above) or other industries, which gives rise to potential or actual conflicts of interest. For example, such family members or relatives might be officers, directors, personnel or owners of companies or assets which are actual or potential investments of the Funds or other counterparties of the Funds and their Portfolio Entities and/or assets. Moreover, in certain instances, the Funds or their Portfolio Entities may purchase or sell companies or assets from or to, or otherwise transact with, companies that are owned by such family members or relatives or in respect of which such family members or relatives have other involvement. In most such circumstances, the Organizational Documents will not preclude the Funds from undertaking any of these investment activities or transactions. To the extent Blackstone determines appropriate, conflict mitigation strategies may be put in place with respect to a particular circumstance, such as internal information barriers or recusal, disclosure or other steps determined appropriate by the applicable General Partner. The Fund investors rely on the applicable General Partner to manage these conflicts in its sole discretion. Secondments and Internships. Certain personnel of Blackstone and its affiliates, including Consultants (as defined herein), may be seconded to one or more Portfolio Entities of the Funds and Other Blackstone Clients to provide finance, accounting and other similar services with respect to such Portfolio Entities. The salaries, benefits, overhead and other similar expenses for such personnel during the secondment could be borne (in whole or in part) by Blackstone and its affiliates or the organization for which the personnel are working or both. In addition, personnel of Portfolio Entities, vendors, service providers (including law firms and accounting firms) may be seconded, or serve internships at, Blackstone and Portfolio Entities of the Funds. While the Funds, Other Blackstone Clients and their Portfolio Entities are often the beneficiaries of these types of arrangements, Blackstone is from time to time a beneficiary of these arrangements as well, including in circumstances where the vendor or service provider also provides services to the Funds in the ordinary course. Blackstone or the Portfolio Entity may or may not pay salary or cover expenses associated with such secondees and interns, and if a Portfolio Entity pays the cost it will be borne directly or indirectly by the Funds. The management fee will not be offset or reduced as a result of these secondments or internships or any fees, expense reimbursements or other costs related thereto. The personnel described above may provide services in respect of multiple matters, including in respect of matters related to Blackstone, its affiliates and related parties, and any costs of such personnel may be allocated accordingly. Other Benefits. The Advisor and their respective personnel and related parties will receive intangible and other benefits, discounts and perquisites arising or resulting from their activities on behalf of the Funds, which will not offset or reduce management fees or otherwise be shared with the Funds, their Portfolio Entities or the Fund investors. For example, airline travel or hotel stays will result in “miles” or “points” or credit in loyalty or status programs, and such benefits will, whether or not de minimis or difficult to value, inure exclusively to the benefit of the Advisor or its respective personnel or related parties receiving it, even though the cost of the underlying service is borne by the Funds and/or Portfolio Entities. Similarly, the Advisor and its respective personnel and related parties, and third parties designated by the foregoing, also receive discounts on products and services provided by Portfolio Entities and customers or suppliers of such Portfolio Entities. The Fund investors consent to the existence of these arrangements and benefits. Advisors, Consultants and Partners. The Advisor, its affiliates and their respective personnel and related parties engage and retain strategic advisors, consultants, senior advisors, industry experts, joint venture and other partners and professionals, any of whom might be current or former executives or other personnel of the Advisor or Portfolio Entities of the Funds or Other Blackstone Clients (collectively, “Consultants”), to provide a variety of services. Similarly, the Funds, Other Blackstone Clients and their Portfolio Entities retain and pay compensation to Consultants to provide services, or to undertake a build‐up strategy to acquire and develop assets and businesses in a particular sector or involving a particular strategy. Any amounts paid by the Funds or a Portfolio Entity to Consultants in connection with the above, including performance‐based compensation (e.g., promote), retainers and expense reimbursements, will be treated as partnership expenses or expenses of a Portfolio Entity, as the case may be, and will not, even if they have the effect of reducing any retainers or minimum amounts otherwise payable by the Advisor, be chargeable to the Advisor or deemed paid to or received by the Advisor, or offset or reduce any management fees to the Advisor or be subordinated to return of the Fund investor’s capital. Amounts charged by Consultants will not necessarily be confirmed as being comparable to market rates for such services. Also, Consultants often co‐ invest alongside the Funds in Portfolio Entities and investments of the Funds, participate in long‐term incentive plans of a Portfolio Entity, and invest directly in the Funds or in vehicles controlled by the Funds, with reduced or waived management fees and/or performance‐based compensation, including after the termination of their engagement by or other status with Blackstone, and such co‐investment or participation (which generally will result in the Funds being allocated a smaller share of an investment and less co‐investment being available to Fund investors) may or may not be considered part of Blackstone’s side‐by‐side co‐investment rights, as determined by the Advisor in its sole discretion. Consultants’ benefits described in this paragraph may continue after termination of status as a Consultant. The time dedication and scope of work of a Consultant varies considerably. In some cases, Consultants provide the Advisor with industry‐specific insights and feedback on investment themes, assists in transaction due diligence, and makes introductions to, and provides reference checks on, management teams. In other cases, Consultants take on more extensive roles, including serving as executives or directors on the boards of Portfolio Entities and contributing to the identification and origination of new investment opportunities. The Funds may rely on these Consultants to recommend the Advisor and the Funds as a preferred investment partner and carry out its investment program, but there is no assurance that any Consultant will continue to be involved with the Funds for any length of time. The Advisor and the Funds may have formal or informal arrangements with Consultants that may or may not have termination options and may include compensation, no compensation, or deferred compensation until occurrence of a future event, such as commencement of a formal engagement. In certain cases, Consultants have attributes of Blackstone “employees” (e.g., they may have dedicated offices at Blackstone, receive administrative support from Blackstone personnel, participate in general meetings and events for Blackstone personnel or work on Blackstone matters as their primary or sole business activity, have Blackstone‐related e‐mail addresses or business cards and participate in certain benefit arrangements typically reserved for Blackstone employees), even though they are not Blackstone employees, affiliates or personnel for purposes of the Organizational Documents, and their salary and related expenses are paid by the Funds as partnership expenses or by Portfolio Entities without any reduction or offset to management fees. Some Consultants work only for a Fund and its Portfolio Entities, while other Consultants may have other clients. Consultants could have conflicts of interest between their work for a Fund and its Portfolio Entities, on the one hand, and themselves or other clients, on the other hand, and the Advisor are limited in their ability to monitor and mitigate these conflicts. As an example of the foregoing, in certain investments by the Funds including involving a “platform company,” the Funds will from time to time enter into an arrangement with one or more individuals (who may be former personnel of Blackstone or current or former personnel of Portfolio Entities of the Funds or Other Blackstone Clients, may have experience or capability in sourcing or managing investments, and may form a management team) to undertake a build‐ up strategy to acquire and develop assets and businesses in a particular sector or involving a particular strategy. The services provided by such individuals or relevant Portfolio Entity, as the case may be, could include the following with respect to investments of the Funds: origination or sourcing, due diligence, evaluation, negotiation, servicing, development, management (including turnaround) and disposition. The individuals or relevant Portfolio Entity could be compensated with a salary and equity incentive plan, including a portion of profits derived from the Funds or a Portfolio Entity or asset of the Funds, or other long term incentive plans. Compensation could also be based on assets under management, a waterfall similar to a carried interest, respectively, or other similar metric. The Funds could initially bear the cost of overhead (including rent, utilities, benefits, salary or retainers for the individuals or their affiliated entities) and the sourcing, diligence and analysis of investments, as well as the compensation for the individuals and entity undertaking the build‐up strategy. Such expenses could be borne directly by the Funds as partnership expenses (or broken deal expenses, if applicable) or indirectly through expenditures by a Portfolio Entity. None of such Portfolio Entities or Consultants will be treated as affiliates of the Advisor for purposes of the Organizational Documents and none of the fees, costs or expenses described above will reduce or offset the management fee. Multiple Blackstone Business Lines. Blackstone has multiple business lines, including the Blackstone Capital Markets Group, which Blackstone, the Funds, Other Blackstone Clients, Portfolio Entities of the Funds and Other Blackstone Clients and third parties may engage for debt and equity financings and to provide other investment banking, brokerage, investment advisory or other services. As a result of these activities, Blackstone is subject to a number of actual and potential conflicts of interest, greater regulatory oversight and more legal and contractual restrictions than if it had one line of business. For example, Blackstone may come into possession of information that limits the Funds’ ability to engage in potential transactions. Similarly, other Blackstone businesses and their personnel may be prohibited by law or contract from sharing information with the Advisor that would be relevant to monitoring the Funds’ investments and other activities. Additionally, Blackstone or Other Blackstone Clients can be expected to enter into covenants that restrict or otherwise limit the ability of the Funds or their Portfolio Entities and their respective affiliates to make investments in, or otherwise engage in, certain businesses or activities. For example, Other Blackstone Clients could have granted exclusivity to a joint venture partner that limits the Funds and Other Blackstone Clients from owning assets within a certain distance of any of the joint venture’s assets, or Blackstone or an Other Blackstone Client could have entered into a non‐compete in connection with a sale or other transaction. These types of restrictions may negatively impact the ability of the Funds to implement its investment program. (See also “—Other Blackstone Clients; Allocation of Investment Opportunities” herein) Finally, Blackstone personnel who are members of the investment team or investment committee may be excluded from participating in certain investment decisions due to conflicts involving other Blackstone businesses or for other reasons, in which case the Funds will not benefit from their experience. The Fund investors will not receive a benefit from any fees earned by Blackstone or its personnel from these other businesses. Blackstone is under no obligation to decline any engagements or investments in order to make an investment opportunity available to the Funds. Blackstone has long‐term relationships with a significant number of corporations and their senior management. The Advisor will consider those relationships when evaluating an investment opportunity, which may result in the Advisor choosing not to make such an investment due to such relationships (e.g., investments in a competitor of a client or other person with whom Blackstone has a relationship). The Funds may be forced to sell or hold existing investments as a result of investment banking relationships or other relationships that Blackstone and its affiliates may have or transactions or investments Blackstone and its affiliates may make or have made. Therefore, there can be no assurance that all potentially suitable investment opportunities that come to the attention of Blackstone will be made available to the Funds. (See “—Other Blackstone Clients; Allocation of Investment Opportunities” and “Portfolio Entity Relationships Generally” herein.) The Funds may also co‐invest with clients of Blackstone or other persons with whom Blackstone has a relationship in particular investment opportunities, and other aspects of these Blackstone relationships could influence the decisions made by the Advisor with respect to the Funds’ investments and otherwise result in a conflict (See also “—Other Blackstone Clients; Allocation of Investment Opportunities” herein.) Finally, Blackstone and Other Blackstone Clients could acquire limited partner interests in the Funds in the secondary market. Blackstone and Other Blackstone Clients would generally have greater information than counterparties in such transactions, and the existence of such business could produce conflicts, including in the valuation of the Funds’ investments. Minority Investments in Asset Management Firms. Blackstone and Other Blackstone Clients, including BSCH and its related parties, regularly make minority investments in alternative asset management firms that are not affiliated with Blackstone. The Funds, Other Blackstone Clients and their respective Portfolio Entities may from time to time engage in similar transactions, including with respect to purchase and sale of investments, with these asset management firms and their sponsored funds and Portfolio Entities. Typically, the Blackstone‐related party with an interest in the asset management firm would be entitled to receive a share of carried interest/performance based incentive compensation and net fee income or revenue share generated by the various products, vehicles, funds and accounts managed by that third party asset management firm that are included in the transaction or activities of the third party asset management firm, or a subset of such activities such as transactions with a Blackstone related party. In addition, while such minority investments are generally structured so that Blackstone does not “control” such third party asset management firms, Blackstone may nonetheless be afforded certain governance rights in relation to such investments (typically in the nature of “protective” rights, negative control rights or anti‐dilution arrangements, as well as certain reporting and consultation rights) that afford Blackstone the ability to influence the firm. Although BSCH does not intend to control such third party asset management firms, there can be no assurance that all third parties will similarly conclude that such investments are non‐ control investments or that, due to the provisions of the governing documents of such third party asset management firms or the interpretation of applicable law or regulations, investments by such Blackstone funds will not be deemed to have control elements for certain contractual, regulatory or other purposes. While such third party asset managers will not be deemed “affiliates” of Blackstone for any purpose, Blackstone may, under certain circumstances, be in a position to influence the management and operations of such asset managers and the existence of its economic/revenue sharing interest therein may give rise to conflicts of interest. Participation rights in a third party asset management firm (or other similar business), negotiated governance arrangements and/or the interpretation of applicable law or regulations could expose the investments of the Funds to claims by third parties in connection with such investments (as indirect owners of such asset management firms or similar businesses) that may have an adverse financial or reputational impact on the performance of the Funds. The Funds, their affiliates and their respective Portfolio Entities may from time to time engage in transactions with, and buy and sell investments from, any such third party asset managers and their sponsored funds and Portfolio Entities. There can be no assurance that the terms thereof will be at arm’s length or that Blackstone will not receive a benefit from such transactions, which may make it more likely that such transactions would be entered into. Blackstone Policies and Procedures; Information Walls. Blackstone has implemented policies and procedures to address conflicts that arise as a result of its various activities, as well as regulatory and other legal considerations. Some of these policies and procedures, such as Blackstone’s information wall policy, also have the effect of reducing firm‐wide synergies and collaboration that the Funds could otherwise expect to utilize for purposes of identifying and managing attractive investments. Personnel of Blackstone may be unable, for example, to assist with the activities of the Funds as a result of these walls. There can be no assurance that additional restrictions will not be imposed that would further limit the ability of Blackstone to share information internally. Data. Blackstone receives or obtains various kinds of data and information from the Funds, Other Blackstone Clients and their Portfolio Entities, including data and information relating to business operations, trends, budgets, customers and other metrics, some of which is sometimes referred to as “big data.” Blackstone may be better able to anticipate macroeconomic and other trends, and otherwise develop investment themes, as a result of its access to this data and information from the Funds, Other Blackstone Clients and their Portfolio Entities. Blackstone has entered and will continue to enter into information sharing and use arrangements, which may give Blackstone access to data that it would not otherwise obtain in the ordinary course, with the Funds, Other Blackstone Clients, and their Portfolio Entities, related parties and service providers. Although Blackstone believes that these activities improve Blackstone’s investment management activities on behalf of the Funds and Other Blackstone Clients, information obtained from the Funds and their Portfolio Entities also provides material benefits to Blackstone or Other Blackstone Clients without compensation or other benefit accruing to the Funds or their investors. For example, information from Portfolio Entities owned by the Funds may enable Blackstone to better understand a particular industry and execute trading and investment strategies in reliance on that understanding for Blackstone and Other Blackstone Clients that do not own an interest in the Portfolio Entity, without compensation or benefit to the Funds or their Portfolio Entities. Furthermore, except for contractual obligations to third parties to maintain confidentiality of certain information, and regulatory limitations on the use of material nonpublic information, Blackstone is generally free to use data and information from the Funds’ activities to assist in the pursuit of Blackstone’s various other activities, including to trade for the benefit of Blackstone or an Other Blackstone Client. Any confidentiality obligations in the Organizational Documents do not limit Blackstone’s ability to do so. For example, Blackstone’s ability to trade in securities of an issuer relating to a specific industry may, subject to applicable law, be enhanced by information of a Portfolio Entity in the same or related industry. Such trading may provide a material benefit to Blackstone without compensation or other benefit to the Funds or their investors. The sharing and use of “big data” and other information presents potential conflicts of interest and the Fund investors acknowledge and agree that any benefits received by Blackstone will not be subject to the management fee offset provisions or otherwise shared with the Funds or their investors. As a result, the Advisor have an incentive to pursue investments that have data and information that can be utilized in a manner that benefits Blackstone or Other Blackstone Clients. Blackstone Strategic Relationships. Blackstone has entered, and it can be expected that Blackstone in the future will enter, into strategic relationships with investors (and/or one or more of their affiliates) that involve an overall relationship with Blackstone that could incorporate one or more strategies in addition to the Funds’ strategy (“Strategic Relationships”). A Strategic Relationship often involves an investor agreeing to make a capital commitment to multiple Blackstone funds, one of which may be a Fund. Fund investors will not receive a copy of any agreement memorializing a Strategic Relationship program (even if in the form of a side letter) and will be unable to elect in the “most‐favored nations” election process any such rights or benefits afforded through a Strategic Relationship. Specific examples of such additional rights and benefits include, among others, specialized reporting, discounts on and/or reimbursement of management fees or carried interest, secondment of personnel from the investor to Blackstone (or vice versa), targeted amounts for co‐investments alongside Blackstone funds (including, without limitation, preferential or favorable allocation of co‐ investment, and preferential terms and conditions related to co‐investment or other participation in Blackstone funds (including any carried interest and/or management fees to be charged with respect thereto, as well as any additional discounts or rebates thereof or other penalties that may result if certain target co‐investment allocations or other conditions under such arrangements are not achieved)). The co‐investment that is part of a Strategic Relationship may include co‐investment in investments made by the Funds. Blackstone, including its personnel (including infrastructure personnel), may receive compensation from Strategic Relationships and be incentivized to allocate investment opportunities away from the Funds to or source investment opportunities for Strategic Relationships. Strategic Relationships may therefore result in fewer co‐investment opportunities (or reduced allocations) being made available to Fund investors. (See also “—Additional Potential Conflicts of Interest with respect to Co‐Investment; Strategic Relationships Involving Co‐Investment” herein.) Buying and Selling Investments or Assets from Certain Related Parties. The Funds and their Portfolio Entities may purchase investments or assets from or sell investments or assets of the Funds to Fund investors, Portfolio Entities of Other Blackstone Clients or their respective related parties. Purchases and sales of investments or assets of the Funds between the Funds or their Portfolio Entities, on the one hand, and Fund investors, Portfolio Entities of Other Blackstone Clients or their respective related parties, on the other hand, are not subject to the approval of any L.P. Advisory Committee or Fund investor or Independent Client Representative (if any). These transactions involve conflicts of interest, as Blackstone may receive fees and other benefits, directly or indirectly, from or otherwise have interests in both parties to the transaction. Blackstone’s Relationship with Pátria. Blackstone owns 40% of the equity interests in Pátria Investimentos Ltd. (“Pátria”), a leading Brazilian alternative asset manager and advisory firm. Pátria’s alternative asset management businesses include the management of private equity funds, real estate funds, infrastructure funds and hedge funds (e.g., a multi‐strategy fund and a long/short equity fund). Each of Blackstone’s and Pátria’s respective investment funds continues to pursue investment opportunities in accordance with their existing mandates. While it is not expected that there will be material overlap between the Funds’ investment programs and Pátria’s investment activities, there may be instances in which investment opportunities otherwise appropriate for the Funds will be shared with (or allocated to) Pátria. Therefore, there may be opportunities available to Pátria that are not shared with the Funds, and there may be opportunities available to the Funds that are shared with one or more Pátria funds. Blackstone generally expects, with respect to certain types of investments in Brazil otherwise suitable for the Funds, to permit such investments to be shared with and/or pursued by Pátria, which may be on a priority basis and may result in the Funds not participating in any such investments or participating therein to a lesser extent. In addition, the Funds may invest in companies or other entities in which Pátria sponsored investment funds make an investment in a different part of the capital structure (and vice versa). In such situations, the Funds and such other Pátria sponsored investment funds (and therefore Blackstone through its indirect minority interest in Pátria) may have conflicting interests (e.g., over the terms of their respective investments). Pátria is not considered an “affiliate” of Blackstone under the Organizational Documents, and therefore these transactions will not be subject to approval of any L.P. Advisory Committee, Independent Client Representative (if any) and/or the limited partners or Independent Client Representative (if any) of the Funds. Other Blackstone Clients; Allocation of Investment Opportunities. Blackstone invests its own capital and third‐party capital on behalf of Other Blackstone Clients and the Funds in a wide variety of investment opportunities throughout the world. In addition, certain exceptions exist that allow specified types of investment opportunities that fall within the Funds’ investment objectives or strategy to be allocated in whole or in part to Blackstone itself or Other Blackstone Clients, such as strategic investments made by Blackstone itself (whether in financial institutions or otherwise) and the exception for Other Blackstone Clients that have investment objectives or guidelines similar to or overlapping with those of the Funds. It is expected that some activities of Blackstone, the Other Blackstone Clients and their Portfolio Entities will compete with the Funds and their Portfolio Entities for one or more investment opportunities that are consistent with the Funds’ investment objectives, and as a result such investment opportunities may only be available on a limited basis, or not at all, to the Funds. The Advisor have conflicting loyalties in determining whether an investment opportunity should be allocated to the Funds, Blackstone or an Other Blackstone Client, and these conflicts may not necessarily be resolved in favor of the Funds. Although the BIP and BIP‐P Funds will generally serve as Blackstone’s primary commingled, diversified private “blind pool” investment vehicles for institutional investors having as their primary investment objective the making of control and control‐oriented infrastructure investments, as well as in public‐private partnership infrastructure projects, in each case within the “Core+” or “Core” space and in the United States, in certain circumstances, control‐oriented infrastructure investments will be required or permitted to be made by (to the potential exclusion of the Funds), or shared with, one or more Other Blackstone Accounts, including but not limited to funds and vehicles described above, other investment vehicles primarily designed to facilitate the investment of high net worth individuals and/or that have investment objectives similar to and/or overlapping with the Funds’ investment objectives. Blackstone has adopted guidelines and policies, which it may update from time to time, regarding allocation of investment opportunities. ● Overlapping Objectives and Strategies: In circumstances in which any Other Blackstone Clients have investment objectives or guidelines that overlap with those of the Funds, in whole or in part, Blackstone generally determines the relative allocation of investment opportunities among one or more of the Funds and/or Other Blackstone Clients on a fair and reasonable basis in good faith according to guidelines and factors determined by it. However, the application of those guidelines and factors may result in the Funds not participating, or not participating to the same extent, in investment opportunities in which they would have otherwise participated had the related allocations been determined without regard to such guidelines. The Advisor could also determine not to pursue opportunities as discussed below in “—Certain Investments inside the Funds’ Mandates that are not Pursued by the Funds.” Among the factors that the Advisor considers in making investment allocations among the Funds and Other Blackstone Clients are the following: (i) any applicable investment objectives, focus, parameters, guidelines, investor preferences, limitations and other contractual provisions and terms relating to the Funds and such Other Blackstone Clients and the duration of their investment period, (ii) available capital of the Funds and such Other Blackstone Clients, (iii) legal, tax, accounting, regulatory and other considerations deemed relevant by the Advisor, including, without limitation, (iv) primary and permitted investment strategies and objectives of the Funds and the Other Blackstone Clients, including, without limitation, with respect to Other Blackstone Clients that expect to invest in or alongside other funds or across asset classes based on expected return (such as BTAS Funds, BREP Funds, BREDS Funds, BCP Funds, GSO Funds, Strategic Partners, Life Sciences, BIS Funds, BAAM Funds (including BSOF), BSCH, Blackstone Life Sciences Funds, BTO Funds and certain managed accounts with similar investment strategies and objectives), (v) sourcing of the investment, (vi) the sector and geography/location of the investment, (vii) the specific nature (including size, type, amount, liquidity, holding period, anticipated maturity and minimum investment criteria) of the investment, (viii) expected investment return, (ix) risk/return profile of the investment, (x) expected leverage on the investment, (xi) expected cash characteristics (such as cash‐on‐cash yield, distribution rates or volatility of cash flows), (xii) capital expenditure required as part of the investment, (xiii) portfolio diversification concerns (including, but not limited to, whether a particular fund already has its desired exposure to the investment, sector, industry, geographic region or markets in question), (xiv) relation to existing investments in a fund, if applicable (e.g., “follow on” to existing investment, joint venture or other partner to existing investment, or same security as existing investment), (xv) avoiding allocation that could result in de minimis or odd lot investments, (xvi) co‐investment arrangements, (xvii) anticipated tax treatment of the investment, and (xviii) other considerations deemed relevant by the Advisor in good faith. Moreover, under certain circumstances investment opportunities sourced and/or identified by the Funds and that fall within the Funds’ investment strategy and objective may be allocated in whole or in part to Portfolio Entities, Other Blackstone Clients or portfolio entities of Other Blackstone Clients, or Blackstone. The allocation of investments to Other Blackstone Clients, including as described above, may result in fewer co‐investment opportunities (or reduced allocations) being made available to the Fund investors. ● Certain Investments inside the Funds’ Mandates that are not Pursued by the Funds: Under certain circumstances, Blackstone may determine not to pursue some or all of an investment opportunity within the Funds’ mandates, including without limitation, as a result of business, reputational or other reasons applicable to the Funds, Other Blackstone Clients, their respective Portfolio Entities or Blackstone. In addition, the Advisor may determine that the Funds should not pursue some or all of an investment opportunity, including, by way of example and without limitation, because the Funds have already invested sufficient capital in the investment, sector, industry, geographic region or markets in question, as determined by the Advisor in its good faith reasonable sole discretion, or the investment is not appropriate for the Funds for other reasons as determined by the Advisor in its good faith reasonable sole discretion. In any such case Blackstone could, thereafter, offer such opportunity to other parties, including Other Blackstone Clients or Portfolio Entities or Fund investors or Other Blackstone Clients, joint venture partners, related parties or third parties, and such parties may pursue the opportunity. Some examples of types of investments for which the General Partners will have discretion to allocate away from certain of the Funds include: (i) investments in companies with substantial real estate holdings, which may be allocated among the Funds, the Parallel Funds and Other Blackstone Clients on a basis that the General Partners believe in good faith to be fair and reasonable; (ii) investments in certain specific geographic areas outside the United States and Canada (to the extent Other Blackstone Clients are formed to invest therein), (iii) investments where the amount available for common or preferred equity investment by the Funds (and Other Blackstone Clients, if appropriate) would be less than a stated amount; (iv) transactions that would be precluded or materially limited by the investment limitations, or other requirements of the Organizational Documents or applicable law or regulation (including ERISA); (v) investments by Blackstone in asset management or financial advisory businesses, banking or other similar financial institutions, but only in the case of strategic acquisitions by Blackstone (and not any Other Blackstone Client); (vi) in respect of the BCP Funds, investment opportunities suitable for a lower risk, lower return fund, or, investment opportunities with respect to which the General Partners make a good faith determination that such opportunity is not expected to yield returns on investment within the range of returns expected to be provided by the Funds’ investments in which the Funds was organized to invest, based on the terms thereof and the information available relating to such opportunity at the time of its evaluation by the General Partners, whether as a result of a longer expected hold period or otherwise (i.e., “core” private equity or “core+” private equity investments); (vii) investment opportunities that are within the investment objectives of Blackstone’s infrastructure program, which consists of Blackstone Infrastructure Partners L.P. and one or more other open‐ended commingled private investment funds and separate accounts, including infrastructure investments (i.e., a longer‐life, stable asset) that, at the time of the initial investment therein, has a longer expected hold period and lower expected annual rate of return, in each case relative to those generally targeted by the Funds, as determined by the General Partners in good faith; (viii) debt investment opportunities, which may be allocated among the Funds and/or the GSO Funds; (ix) minority investments, which may be allocated to or shared with Blackstone Tactical Opportunities Fund L.P. and its related vehicles and successor funds; and (x) investment opportunities arising in instances where an affiliate of Blackstone acts as the general partner or investment manager (or any similar capacity) for another investment vehicle which is not a Similar Fund and such other investment vehicle (e.g., an investment fund the primary purpose of which is investing in assets or businesses related to the infrastructure sector) has investment objectives or guidelines in common with those of the Funds. In such instances, investment opportunities which are within such common objectives or guidelines will be allocated between the Funds and such other vehicle by the General Partners on a basis that the General Partners believe in good faith to be fair and reasonable (which may result in the Funds not participating and/or not participating to the same extent in such investment opportunity). In making its good faith determination as to what is “fair and reasonable” under the circumstances, the General Partners and their affiliates shall be permitted to consider a number of factors including, without limitation, the specific nature of the investment, size and type of the investment, relative investment strategies and primary investment mandates, portfolio diversification concerns, contractual obligations, applicable investment limitations or guidelines and other terms of such funds, relative amounts of available capital for each investment fund, duration of the investment period of each fund, source of the investment opportunity, the investment focus of each fund, anticipated holding period and remaining investment periods, co‐investment arrangements, withdrawal or repurchase requirement requests from a client, fund and/or vehicle and anticipated future contributions or subscriptions into an account, the nature and extent of involvement of the respective teams of investment professionals dedicated to the Funds when compared to the Other Blackstone Clients, legal, tax, regulatory, accounting and other similar considerations, and other considerations deemed relevant in good faith. In addition, as a general matter, it is expected that Blackstone’s Real Estate and GSO credit business will receive priority over most real estate opportunities and certain types of credit opportunities, respectively. The arrangements described herein may result in investments that fit within the primary investment mandates of the Funds being wholly or partially allocated to one or more Other Blackstone Clients. Any such Other Blackstone Clients may be advised by a different Blackstone business group with a different investment committee, which could determine an investment opportunity to be more attractive than the Advisor believes to be the case. In any event, there can be no assurance that the Advisors’ assessment will prove correct or that the performance of any investments actually pursued by the Funds will be comparable to any investment opportunities that are not pursued by the Funds. Blackstone, including its personnel, may receive compensation from any such party that makes the investment, including an allocation of carried interest or referral fees, and any such compensation could be greater than amounts paid by the Funds to the Advisor. In some cases, Blackstone earns greater fees when Other Blackstone Clients participate alongside or instead of the Funds in an investment. With respect to each General Partner’s ability to allocate investment opportunities, including where such opportunities are within the common objectives and guidelines of the Funds and Other Blackstone Client (which allocations are to be made on a basis that each General Partner believes in good faith to be fair and reasonable), Blackstone has established general guidelines for determining how such allocations are to be made, which, among other things, set forth priorities and presumptions regarding what constitutes “debt” investments, ranges of rates of returns for defining “core” or “core+” investments and “infrastructure investments,” presumptions regarding allocation for certain types of investments (e.g., distressed investments) and other matters. Moreover, the Parallel Account will participate in investments alongside the Fund, typically in an amount equal to the aggregate amount to be invested therein by the limited partners of the Fund and limited partners of any parallel fund (the “Parallel Account Investment Percentage”), subject to (i) legal, tax, regulatory, accounting, contractual and other similar considerations, (ii) any investment limitations of the Parallel Account or the Fund, (iii) the Parallel Account or the Partnership having available capital with respect thereto or (iv) the General Partner otherwise changing the Parallel Account Investment Percentage for a particular investment or prospective investments generally, each of which, in the case of (i) through (iv) above, could cause an increase or decrease in the size of the Parallel Account and/or the amount required to be invested by the Fund. In addition, if an investment would otherwise exceed 20% of the sum of the Fund’s NAV plus undrawn capital commitments at the time of acquisition, Blackstone may allocate such excess as it determines, including to Other Blackstone Accounts or other co‐ investors.

● Financial Compensation to Allocate Investment Opportunities to Other Blackstone Clients: When the Advisor determines not to pursue some or all of an investment opportunity for a Fund that would otherwise be within such Fund’s objectives and strategies, and Blackstone provides the opportunity or offers the opportunity to Other Blackstone Clients, Blackstone, including its personnel (including infrastructure personnel) may receive compensation from the Other Blackstone Clients, whether or not in respect of a particular investment, including an allocation of carried interest or referral fees, and any such compensation could be greater than amounts paid by such Fund to the Advisor. As a result, the Advisor (including infrastructure personnel who receive such compensation) could be incentivized to allocate investment opportunities away from the Funds to or source investment opportunities for Other Blackstone Clients. In addition, in some cases Blackstone may earn greater fees when Other Blackstone Clients participate alongside or instead of the Funds in an investment. ● BCEP Funds: The General Partner of the BCEP Funds reserves the right to organize, sponsor, raise and/or manage parallel vehicles, either directly or through an affiliate, for the benefit of certain investors, which may (a) employ investment strategies that are the same as or that overlap with those of the relevant BCEP Fund or the same or similar investment objectives as the relevant BCEP Fund and (b) have terms that differ from those of the relevant BCEP Fund. Parallel accounts may have terms that are more beneficial than those of the relevant BCEP Fund. For any investments that fall within the investment objectives of any of the BCEP Funds, the applicable BCEP Funds will generally invest and divest in each such investment at substantially the same time and on substantially the same terms pro rata based on the maximum aggregate capital commitments that each of the BCEP Funds may contribute to any single investment, unless the applicable General Partner determines in good faith that a different allocation or terms are reasonably necessary or appropriate due to legal, regulatory, tax, accounting or other considerations (which may include investment objective, investment limitations, investor preferences, available capital and/or other reasons). While the General Partner of the BCEP Funds will seek to allocate investments among the BCEP Funds, it is acknowledged and agreed that certain parallel vehicles of certain BCEP Funds may not necessarily participate in each investment made by the BCEP Funds as a result of the terms of the governing agreement of a relevant parallel vehicle, legal, tax, regulatory or other considerations, which will from time to time result in an increase in the BCEP Funds’ allocable share of such investment. In addition to different investor preferences, investors in the BCEP Funds should also note that the terms of the existing and future parallel vehicles (including the economic terms, investment limitations and veto rights with respect to investments, liquidity rights (including, but not limited to the ability to request or object to dispositions of investments, which may adversely affect investments in which the BCEP Funds or other investors have an interest, and contribution obligations of other investors with respect to such investments), investment period and suspension rights related thereto, diversification parameters, co‐investment and any board or governance rights afforded to investors of parallel vehicles) may materially differ, and may in some instances be more favorable to the investors of parallel vehicles than the terms of the applicable BCEP Fund. Such different terms will from time to time create potential conflicts of interests for the applicable General Partner or its affiliates, including with respect to the allocation of investment opportunities. The terms of the partnership agreements of parallel accounts will not be electable by investors in BCEP Funds under any “most‐ favored‐nations” clauses in such investors’ side letters.  Basis for Investment Allocation Determinations: The Advisor makes good faith determinations for allocation decisions based on expectations that may prove inaccurate. Information unavailable to the Advisor, or circumstances not foreseen by the Advisor at the time of allocation, may cause an investment opportunity to yield a different return than expected. For example, an investment opportunity that the Advisor determine to be consistent with the return objectives of a core+ fund rather than the Funds may not match the Advisors’ expectations and underwriting and generate an actual return that would have been appropriate for the Funds. Conversely, an investment that the Advisor expect to be consistent with the Funds’ return objectives may fail to achieve them. ● Investment alongside Other Blackstone Clients: The Funds will also invest alongside Other Blackstone Clients (including other vehicles in which Blackstone or its personnel invest) in investments that are suitable for one or more of the Funds and such Other Blackstone Clients. To the extent the Funds jointly holds securities with any Other Blackstone Client that has a different expected duration or liquidity terms, conflicts of interest will arise between the Funds and such Other Blackstone Client with respect to the timing and manner of disposition of opportunities. In order to mitigate any such conflicts of interest, the Funds may recuse themselves from participating in any decisions relating or with respect to the investment by the Funds or the Other Blackstone Client. If the Other Blackstone Client maintains voting rights with respect to the securities it holds, or if the Funds do not recuse themselves, Blackstone may be required to take action where it will have conflicting loyalties between its duties to the Funds and such Other Blackstone Clients, which may adversely impact the Funds. (See also “—Other Blackstone Clients; Allocation of Investment Opportunities” herein.) Even if the Funds (or any such Other Blackstone Clients and/or co‐investment or other vehicles) invest in the same securities, conflicts of interest may still arise. For example, it is possible that as a result of legal, tax, regulatory, accounting please register to get more info

The Advisor recognizes and believes that (i) high ethical standards are essential for its success and to maintain the confidence of its investors; (ii) its long‐term business interests are best served by adherence to the principle that the interests of investors come first; and (iii) it has a fiduciary duty to its investors to act in the best interests of the Funds. All Advisor personnel are required to act in accordance with the implied contractual covenants of good faith and fair dealing in respect of their dealings with investors and are required to comply with all applicable laws. The Advisor is governed by the Blackstone Code of Ethics (the “Code”). The Code governs a number of potential conflicts of interest which exist in connection with the Funds it manages. The Code is designed to ensure that the Advisor meets its fiduciary obligation to the Advisor’s investors (or prospective investors) and to instill a culture of compliance within the Advisor. An additional benefit of the Code is to detect and prevent violations of securities laws. The Code is distributed to each employee at the time of hire and annually thereafter, and it is available on Blackstone’s intranet website. The Advisor also supplements the Code with ongoing monitoring of employee activity. The Code includes, among other items, the following:  Requirements related to confidentiality;  Limitations on, and reporting of, gifts and entertainment;  Pre‐clearance of political contributions;  Pre‐clearance and reporting of employee personal securities transactions;  Pre‐clearance of outside business activities; and  Protection of persons who engage in “whistle blowing” activities from retaliation. On an annual basis, Blackstone requires all employees to certify that they are in compliance with the Code. Blackstone offers many different products and services across its many businesses and there are several potential conflicts of interest which will from time to time arise. Please see Item 10 – Other Financial Industry Activities & Affiliations for a list of investment related potential conflicts, including, in particular, “Other Blackstone Accounts; Allocation of Investment Opportunities” describing conflicts related to allocation of investment opportunities among investment funds sponsored by Blackstone and co‐investors. The Advisor has adopted policies and procedures to address such potential conflicts of interest. The Advisor’s related persons from time to time have bought or sold, or may in the future buy or sell, for their personal accounts, securities which are also purchased or sold for the account of our clients. The Advisor and its related personnel are subject to guidelines governing the ability to trade in personal accounts. The guidelines generally require that such trading be conducted for investment rather than speculative purposes (including by having minimum holding periods) and that all such personal securities transactions receive pre‐clearance from the Blackstone Legal and Compliance Department. As a policy matter, Blackstone personnel are generally prohibited from purchasing single‐name public securities in their self‐directed personal securities brokerage accounts. These guidelines are designed to comply with SEC requirements that registered investment advisors have a Code. In addition, Blackstone has implemented certain policies and procedures (e.g., information walls) to restrict access to material non‐public information. The Code is available for review upon request. You may request a copy of the Code by contacting Tia Breakley – Chief Compliance Officer; 212‐ 583‐5185; Breakley@blackstone.com.. please register to get more info

The Advisor does not generally trade in public securities; however, in the event the Advisor executes a brokerage transaction for the Funds (e.g. trades in public securities or enters into hedging transactions), the Advisor will generally consider qualitative factors including, but not limited to, the broker’s reliability and execution capabilities for the transaction, the commissions charged by the broker, and the broker’s reputation and responsiveness to requests for trade data and other financial information. please register to get more info

REVIEW OF ACCOUNTS Currently, the only accounts under the supervision of the Advisor are the Funds’ accounts. The Funds’ accounts and investment positions are monitored by the its personnel on a regular and current basis. The Advisor’s Investment Committee meets as necessary to review general portfolio composition, investment opportunities, market conditions, potential conflicts, and recent trading activities. The Investment Committee consists of a minimum of 4 persons and additional members depending on the particular investment, all of whom are Senior Managing Directors. The Advisor might periodically review on an expedited basis the assets of a Fund following a unique occurrence in the financial industry or market generally. The Investment Committee may also draw on regional and/or sector experts within Blackstone as appropriate given the specific profile of each investment opportunity. The sole limited partner of BIP‐P will be entitled to a non‐voting observer seat on the Investment Committee. REPORTS TO INVESTORS Investors in the Funds generally will receive written quarterly reports which will include capital balance and Fund performance statistics. Investors also will receive written annual audited financial statements for the Fund in which they are invested. The Advisor makes use of a website, BX Access, available at www.bxaccess.com for the distribution of reports and other information to investors in the Funds. Certain investors in the Funds may request additional information relating to the Funds and, to the extent such information is readily available or may be obtained without unreasonable effort or expense, the Advisor generally will provide such investors with the information requested. In addition, the sole limited partner of BIP‐P will be entitled to a non‐voting observer seat on the Investment Committee and therefore can be expected to receive additional information about the Funds not received by other Fund investors. Investors that request and receive such information will consequently possess information regarding the business and affairs of the Funds that may not be known to other investors. As a result, certain investors may be able to take actions on the basis of such information which, in the absence of such information, other investors do not take. please register to get more info

The Advisor has distribution and/or placement agent arrangements with a number of unaffiliated third parties. In a typical distribution or placement agent arrangement, the Advisor agrees to pay a third party solicitor for referring investors into an Advisor fund. Typically, third‐ party solicitors will be compensated based upon a percentage of the commitment size of the investors they refer (although other payment arrangements could exist). If third‐party solicitors are engaged, a prospective investor solicited by a third party will be informed of (and may be asked to acknowledge in writing its understanding of) any such arrangement. All fees for such solicitation services will be ultimately paid/borne by a corresponding reduction in the Management Fee by the Advisor and none of the investors in the Funds will be subject to any increased or additional fees or charges. Third‐party solicitors in the U.S. will be registered as broker‐dealers with the SEC. Third‐party solicitors outside the U.S. will be registered with a non‐U.S. regulatory body to the extent such registration is required in the applicable non‐U.S. jurisdiction. BAP, an affiliate of the Advisor, serves as a placement agent to the Funds in the U.S. but is not compensated for such services. please register to get more info

Rule 206(4)‐2, as amended (the “Custody Rule”), of the Advisers Act defines custody as holding client securities or funds or having any authority to obtain possession of them. The Funds generally have an Advisor affiliate acting as general partner and, as such, the Advisor is deemed to have custody of the Funds’ funds. The Advisor complies with the Advisers Act custody rule by, among other things, providing all investors in the Funds with audited financial statements. please register to get more info

The Advisor maintains the authority to manage the Funds on a discretionary basis, subject to the overall supervision of the applicable General Partner, in accordance with the investment guidelines, objectives, limitations, other provisions and terms set forth in the Funds’ Organizational Documents. please register to get more info

Proxy Policy Rule 206(4)‐6 under the Advisers Act (the “Proxy Rule”) requires registered investment advisers that exercise voting authority over client securities to implement proxy voting policies. Because the Advisor will generally be deemed to have authority to vote proxies relating to the companies in which its clients invest the Advisor has adopted a set of policies and procedures (together, the “Policy”) in compliance with the Proxy Rule. To the extent that the Advisor exercises or is deemed to be exercising voting authority over its clients’ securities, the Policy is designed and implemented in a manner reasonably expected to ensure that voting with respect to proxy proposals, amendments, consents or resolutions (collectively, “proxies”) is exercised in a manner that serves the best interest of the Funds, as determined by the Advisor in its discretion. Notwithstanding the foregoing, because proxy proposals and individual company facts and circumstances may vary, the Advisor may not always vote proxies in accordance with the Policy. In addition, many possible proxy matters are not covered in the Policy. Generally, the Advisor will vote proxies in favor of management’s recommendation, including, but not limited to, the following matters: (i) the election of the board of directors; (ii) the approval of financial statements as presented by management; and (iii) will generally vote in favor of the selection of independent auditors even if the proposed auditor is currently the auditor of The Blackstone Group Inc. In certain cases where an investment is made with Blackstone‐affiliated or unaffiliated sponsors, proxy voting may be delegated to such other sponsors (each such sponsor a “Voting Sponsor”) provided that Blackstone reasonably believes that such Voting Sponsor’s policies regarding proxy voting are consistent with the Policy. From time to time, conflicts may arise between the interests of the investor, on the one hand, and the interests of the Advisor or its affiliates, on the other hand. If the Advisor determines that it has, or may be perceived to have, a conflict of interest when voting a proxy, the Advisor will address matters involving such conflicts of interest on a case‐by‐case basis by consulting with the Chief Compliance Officer to determine how to vote in the best interests of the investors, subject to legal, regulatory, contractual or other applicable considerations. The analysis will be documented. The Advisor, in its sole discretion, may elect not to vote certain routine proxies if unduly burdensome. Investors may request a copy of the Policy and the voting records relating to proxies as provided by the Rule by contacting Tia Breakley – Chief Compliance Officer; 212‐583‐5185; Breakley@blackstone.com. please register to get more info

The Advisor has never been the subject of a bankruptcy petition and is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to its clients.
Item 19 – Requirements for State Registered Advisers
This item is not applicable as the Advisor is not registered in any state. please register to get more info