Accessibility Statement

1. Our Commitment

AARO Real Estate LLC (“AARO Real Estate,” “we,” “us,” or “our”) is committed to making https://aarorealestate.com (the “Site”) usable by as many people as possible, including people with disabilities and people who use assistive technologies such as screen readers, screen magnifiers, speech recognition software, and keyboard-only navigation. We want every visitor, whether here to learn about our business, to register interest as an accredited investor, to apply for a role, or to contact us, to be able to do so with equal access and equal opportunity.

We treat accessibility as an ongoing operating responsibility, not a one-time project. We maintain a standing accessibility program (Section 5), we test the Site on a recurring basis, we fix barriers as we identify them, and we provide direct assistance and alternative formats to anyone who asks (Section 9). This Statement describes that program, tells you exactly how to reach us, and explains what you can expect when you do.

2. What This Site Is, What It Is Not, and the Scope of This Statement

Nature of the Site. The Site is the corporate and informational website of a privately held hospitality investment and management company. It describes who we are, our investment approach, properties we own or manage, and current openings, and it allows accredited investors to register interest in being contacted. All content on the Site is available free of charge, without an account, and without purchase.

What the Site does not do.

• The Site is not a point of sale. No securities, investment interests, goods, or services are offered, sold, or purchased on or through the Site. Any offering is made only through definitive offering documents delivered directly to identified, verified accredited investors outside the Site, as our Terms and Conditions and Disclaimer explain.

• The Site does not take transactions. The Apply to Invest form registers interest only. It creates no account, no investment, no commitment, and no entitlement, and a member of our team follows up personally by telephone or email with every submission.

• The Site is not the investor portal. Verified investors are separately invited to a portal hosted and operated by a third-party platform provider, reached through its own login and governed by the Investor Portal Terms of Use and Investor Portal Privacy Notice. See Section 13.

• The Site is not a hotel reservation or guest-services platform. Reservations and guest services at any hotel we own or manage are provided through the applicable hotel brand’s reservation systems and the property itself, not through this Site.

• Our office is not open to walk-in visitors. Our Houston office is a private business office; meetings are by appointment. The Site does not provide access to, or substitute for, any physical place that is open to the general public.

Scope. This Statement applies to the public pages of the Site at https://aarorealestate.com that we author, control, and publish: the home page, informational pages, portfolio pages, careers pages, contact and inquiry forms, and the legal policy pages linked in the Site footer. It does not apply to, and we do not control the accessibility of:

• Third-party websites we link to for convenience, including hotel brand and franchisor websites, individual hotel property websites, and job boards. Those sites are governed by their own accessibility policies and we are not responsible for them.

• Content, documents, or communications we provide to you outside the Site, including by email, in person, by telephone, or on paper, except that Section 9 of this Statement applies to alternative formats we provide on request.

• Social media platforms and other third-party channels on which we or our personnel may publish content.

• The AARO investor portal, which is hosted and operated on a third-party platform provider’s systems and reached by a separate login. Accessibility of the portal is addressed in Section 13 and in the Investor Portal Privacy Notice.

• Third-party identity, accreditation, electronic signature, and payment providers used in investor onboarding, which collect information directly under their own terms.

3. Who This Site Serves

The investment opportunities referenced on the Site are available only to persons who qualify as “accredited investors” under Rule 501(a) of Regulation D under the Securities Act of 1933, and only after separate, offline verification of eligibility. Nothing on the Site is directed to, or is an offer or solicitation to, any person who does not so qualify. The Site’s informational content is open to anyone, and we make it, and the assistance described in Section 9, available to anyone who asks, whether or not they are eligible to invest.

The Site also serves prospective employees, hotel brand and franchise partners, lenders, professional advisors, and members of the press and public seeking information about our company. Each of those audiences can obtain any Site content, and can accomplish anything the Site allows, through the direct-assistance channels in Section 9.

4. Accessibility Standard and How We Describe Our Progress

The Web Content Accessibility Guidelines (WCAG), published by the World Wide Web Consortium (W3C), are the most widely referenced technical guidelines for making web content accessible. We use WCAG 2.2 Level AA as the benchmark against which we design, build, test, and measure the Site, and we work toward conformance with it on a continuing basis. We also look to Section 508 of the Rehabilitation Act of 1973, the U.S. Department of Justice’s published guidance on web accessibility for businesses open to the public, and the general accessibility principles of the Americans with Disabilities Act (ADA) as reference points. We are aware that the Department of Justice has not adopted a binding technical standard for private business websites, and that the standards and guidance in this area continue to develop. We monitor those developments and update our practices and this Statement accordingly.

How we describe our progress. We describe our accessibility work in terms of the benchmark we use, the measures we take, the testing we perform, and the specific limitations we know about (Section 7). We do not represent that the Site, or any page, document, or feature on it, meets every success criterion of WCAG 2.2 Level AA at all times, because web content changes and testing, by its nature, identifies issues after they appear. Any page that we have not yet tested or remediated to our benchmark is addressed through the assistance and alternative-format commitments in Section 9, which are available for every page of the Site.

No overlay widgets. We do not rely on automated accessibility “overlay” or “widget” products as a substitute for accessible design and testing. Where we make any assistive feature available on the Site, it supplements, and does not replace, the measures described in Sections 5 and 6.

5. Our Accessibility Program

We maintain the following standing program, and we keep records of each element so that our practices can be demonstrated:

• Accessibility Coordinator. A designated member of our team is responsible for the accessibility of the Site, for receiving and responding to accessibility requests and feedback, for maintaining the accessibility request log, and for coordinating remediation. The Coordinator can be reached at the contact points in Section 10.

• Recurring testing. We test the Site using automated accessibility testing tools and manual testing, including keyboard-only navigation, screen reader review, color contrast measurement, text resizing to 200 percent, and review on mobile devices. We test at least once every twelve (12) months, before and after we publish any new page, form, or significant feature, and whenever a visitor reports a barrier.

• Independent review. We periodically obtain an accessibility evaluation of the Site from a qualified independent accessibility professional or firm, and we use the resulting findings to prioritize remediation.

• Remediation log. We maintain a dated log of accessibility issues identified through testing or feedback, the action taken, and the date resolved. When a visitor reports a barrier, we test the specific page and function reported using the assistive technology, browser, and device the visitor identified, where we are able to do so, and we record the result.

• Vendor requirements. When we select a website platform, form tool, scheduling tool, or other third-party technology that visitors interact with on or through the Site, we consider accessibility in the selection, request the vendor’s accessibility conformance documentation where available, and raise accessibility issues with the vendor when we become aware of them.

• Content practices. Our personnel who publish Site content follow written practices for headings, alternative text, link text, color contrast, and document formatting, and receive guidance on those practices.

• Statement review. We review this Statement at least once every twelve (12) months and whenever we make a material change to the Site, the program, or our practices.

6. Measures We Take on the Site

• Semantic structure. Each page has a single descriptive title, a logical heading hierarchy, landmarks for navigation, main content, and footer, and lists for grouped items, so that assistive technologies can present page structure accurately.

• Text alternatives. Meaningful images, including property photographs and team portraits, carry descriptive alternative text. Decorative images are marked so assistive technologies can skip them. Longer descriptions of any image are available on request.

• Keyboard operability and focus. Navigation, links, buttons, form controls, and the cookie consent banner are designed to be reachable and operable by keyboard alone, in a logical tab order, with a visible focus indicator, and without keyboard traps.

• Color and contrast. Text and interactive elements are designed to meet WCAG minimum contrast ratios, and color is never the only means of conveying information.

• Resizable, responsive content. The Site reflows across screen sizes and remains usable when text is enlarged to 200 percent or when browser zoom or large-text settings are used, without horizontal scrolling or loss of content.

• Accessible forms. The Site’s Apply to Invest form collects a name, email address, telephone number, investment interest range, and an acknowledgment checkbox. Each field has a visible, programmatically associated label; required fields and errors are identified in text, not only by color; and instructions appear before the form rather than only on submission.

• Link purpose. Link text describes the destination. Links to external sites are presented so that the visitor is not surprised by a change of context.

• Motion. We avoid content that flashes, and we respect the operating system or browser “reduce motion” preference where animation is used.

• Consistent navigation. Navigation and footer elements appear in the same order on every page, and the cookie consent banner can be operated and dismissed without blocking access to content.

• Plain language and navigable policies. We write in plain, direct English. Our legal policies are long documents; each is organized with numbered headings so that assistive technologies can navigate them, and each is available in an alternative format on request.

• Accessibility of this Statement. This Statement is linked from the footer of every page of the Site, is reachable by keyboard and screen reader, and is available in an alternative format on request.

7. Known Limitations and the Alternative for Each

Some areas of the Site may not yet meet our benchmark. The limitations we currently know about are listed below, each with its reason and the alternative we provide. If you encounter a barrier that is not listed, please tell us (Section 10); we will add it to our remediation log and provide an alternative.

• Platform-generated components. Certain interface elements, including the cookie consent banner and form controls, are generated by our website platform. We configure them for accessibility but do not control their underlying code. Alternative: every function of every form is available by telephone and email (Section 9).

• JavaScript-dependent forms. Site forms require JavaScript to submit. Alternative: send the same information to us by email or telephone and we will record and process it exactly as if it had been submitted through the form.

• Documents provided by email or download. Documents we send or make available for download, including PDFs, may not all be fully tagged for screen readers. Alternative: on request we will provide any such document as accessible electronic text, a tagged PDF, a Word document, or in large print.

• Photographic content. Alternative text is necessarily brief and cannot convey every visual detail of a property or portrait. Alternative: a longer description of any image is available on request.

• Investor portal and verification tools. The investor portal and the identity, accreditation, signature, and payment tools used with it are operated by third parties, and we do not control their code. Alternative: see Section 13 for the alternative onboarding and document-delivery methods we provide to verified investors.

8. Technical Specifications and Compatibility

Accessibility of the Site relies on HTML5, CSS3, JavaScript, and WAI-ARIA, where applicable, working together with your web browser and any assistive technology or plug-ins installed on your device. The Site is designed for the current and immediately prior versions of Google Chrome, Apple Safari, Mozilla Firefox, and Microsoft Edge on desktop, and the default browsers on current iOS and Android devices, and for compatibility with commonly used assistive technologies including NVDA, JAWS, VoiceOver, and TalkBack screen readers, screen magnification, speech recognition software, and keyboard-only navigation. Older browsers and assistive technologies that do not support these technologies may provide a degraded experience; the assistance in Section 9 is available in every case.

9. Direct Assistance, Alternative Formats, and Auxiliary Aids

Everything on the Site, and every action that can be taken through it, is also available directly from our team. If any part of the Site is not accessible to you, or if you simply prefer another method, contact our Accessibility Coordinator at admin@aarorealestate.com, by telephone at (832) 500-3098 (staffed Monday through Thursday, 9:00 a.m. to 12:00 p.m. Central Time, excluding federal holidays, company closures, and days when our team is traveling or out of the office), or by mail at the address in Section 17. Because staffed telephone hours are limited and vary with travel, email is the most reliable channel; email and voicemail received outside staffed hours are reviewed and returned on the next staffed business day. The telephone line is a channel for reaching us and reporting barriers; it is not offered as a substitute for the Site or for the alternative formats described below. These channels are offered in addition to, not in place of, our work to make the Site itself accessible.

Through these channels we will, at no cost to you and without requiring you to disclose the nature of any disability:

• Read Site content to you, answer questions about it, and provide it in accessible electronic text, tagged PDF, Word, plain text, or large print, by email or by mail.

• Register your interest as an accredited investor on your behalf, based on the same information the Apply to Invest form collects, provided by you by telephone or email, with exactly the same effect and the same follow-up as a form submission.

• Provide a longer description of any image, and describe the structure and content of any page.

• Provide any Site policy, including this Statement, in an alternative format.

• For verified investors, provide the alternative portal, onboarding, and document-delivery methods described in Section 13.

We provide these auxiliary aids and services in a timely manner and in a way that protects your privacy and independence. Where more than one method would be effective, we will give primary consideration to the method you request and will consult with you about it; the final selection of a method rests with us, provided that it results in effective communication for you. If a requested method would fundamentally alter the nature of the information or service, or would impose an undue burden, we will provide an alternative method that is effective to the maximum extent possible.

Response times. We will acknowledge a request for assistance or an alternative format within ten (10) business days of receipt. We will provide the requested information, format, or service within ten (10) business days of acknowledgment for standard Site content, and within a reasonable time thereafter for lengthy documents or requests that require production of a new format, keeping you informed of progress. If you tell us a request is time-sensitive, we will prioritize it.

10. How to Report an Accessibility Barrier, and What We Will Do

We welcome reports of any barrier and any suggestion for improvement. To report a barrier:

Email: admin@aarorealestate.com (subject line “Website Accessibility”)

Telephone: (832) 500-3098 (staffed Monday through Thursday, 9:00 a.m. to 12:00 p.m. Central Time, excluding federal holidays, company closures, and days when our team is traveling or out of the office)

Mail: AARO Real Estate LLC, Attn: Accessibility Coordinator, 10050 Northwest Freeway, Suite 105, Houston, TX 77092

To help us act quickly, please include, if you can: the web address (URL) of the page; what you were trying to do; what happened; the browser, device, and operating system you were using; any assistive technology you were using; and the best way to reach you. You do not need to disclose a disability to make a report.

What we will do. We will (a) acknowledge your report within ten (10) business days; (b) record it in our remediation log; (c) test the page and function you identified, using the assistive technology, browser, and device you identified where we are able; (d) provide you the information or service you were seeking through an alternative method within ten (10) business days of acknowledgment, so that you are not left waiting on a technical fix; (e) correct the barrier, or implement an equivalent alternative on the Site, within a reasonable time, and in any event within sixty (60) business days of your report, or any shorter period required by applicable law, for barriers within our control, unless the correction requires a change by a third-party platform or vendor, in which case we will tell you that, raise the issue with the vendor, and keep the alternative in place; and (f) tell you when the barrier has been corrected.

Escalation. If you are not satisfied with our response, reply to our acknowledgment and ask that the matter be escalated. A principal of the company will personally review it and respond within ten (10) business days.

11. Notice and Opportunity to Resolve

Our Accessibility Coordinator is the fastest way to resolve any accessibility concern, and we ask that anyone who encounters a barrier on the Site tell us about it through the channels in Section 10 before pursuing any other course. We cannot correct a barrier that we do not know about, and we will act on every report we receive as described above.

If you or your representative intends to assert that the Site does not comply with an accessibility standard or law, we ask that you provide us written notice, directed to the Accessibility Coordinator at the email or mailing address in Section 10, that identifies each page and barrier at issue and the date it was encountered, so that we can investigate and correct it. We will acknowledge such a notice within ten (10) business days, investigate it, and respond in writing within thirty (30) business days with the results of our investigation and the corrective action taken or planned. We will complete corrections within our control within sixty (60) business days of the notice, or any shorter period required by applicable law, wherever reasonably feasible. For claims under the Texas Human Resources Code, Chapter 121, this process is consistent with the pre-suit notice and opportunity to correct that Section 121.0041 of that Code provides for claims alleging noncompliance with technical standards, including Internet website accessibility guidelines.

Nothing in this Section conditions, limits, or waives any right you have under applicable law, and nothing in it is an admission that any page or feature of the Site is noncompliant with any standard or law.

12. Third-Party Platforms, Vendors, and Content

The Site is hosted on a third-party website platform and uses third-party services for analytics, email, and form handling. Verified investors are separately invited to an investor portal hosted on a third-party platform provider’s systems, and investor onboarding uses third-party identity and accreditation verification, electronic signature, and payment providers, each of which collects information directly under its own terms and privacy notice. The Site also links to hotel brand and franchisor websites and job boards.

We select these services with accessibility in mind, request their accessibility conformance documentation where available, raise accessibility issues with them when we learn of them, and keep records of the information we supply to them. We do not control their code, design, or accessibility practices, and this Statement does not extend to them. If you encounter a barrier in a third-party service reached from or used in connection with the Site, tell us; we will provide the same information or outcome through an alternative method, and we will raise the issue with the vendor.

13. Investor Portal and Investor Communications

Verified accredited investors may be invited to use the AARO investor portal for onboarding, document delivery, electronic signature, reporting, and tax documents. The portal is hosted on a third-party platform provider’s systems, and its interface, forms, and documents are generated in substantial part by that provider and by other third-party verification, signature, and payment providers. We consider accessibility in selecting these providers, request their accessibility conformance documentation, and raise accessibility concerns with them on your behalf, but we do not control their code and do not represent that they conform to any standard.

If you are an investor or prospective investor and cannot access or complete any step in the portal or in onboarding because of a disability, contact the Accessibility Coordinator (Section 10). We will provide a reasonable alternative within the response times in Section 9, which may include: delivering offering documents, subscription documents, statements, reports, and tax documents in accessible electronic text, tagged PDF, or paper form; completing identity and accreditation verification through an alternative method the applicable provider supports, or through a licensed third-party verifier; manual, wet-ink execution of documents; and assistance by telephone. Alternative methods remain subject to the identity, accreditation, anti-money-laundering, and other verification requirements described in the Investor Portal Terms of Use and the applicable Investment Documents, which we apply equally to every investor.

This Section describes accommodations for using the portal. It does not modify the Investor Portal Terms of Use, the Investor Portal Privacy Notice, or any Investment Document, and nothing in this Statement constitutes an offer to sell or a solicitation of an offer to buy any security.

14. Job Applicants and Candidates

AARO Real Estate is an equal opportunity employer and provides reasonable accommodations to qualified individuals with disabilities throughout the application and hiring process. If you need an accommodation to search for a position, complete an application, submit materials, or participate in an interview or assessment, contact us at admin@aarorealestate.com with “Application Accommodation” in the subject line, by telephone at (832) 500-3098, or by mail at the address in Section 17. We will acknowledge the request within ten (10) business days and work with you on an effective accommodation. Requests are handled confidentially, are not considered in hiring decisions, and are kept separate from your application. Nothing in this Statement alters our Privacy Policy regarding applicant information or creates an employment relationship.

15. Continuous Improvement, Review, and Records

We review this Statement and the accessibility of the Site at least once every twelve (12) months and whenever we make material changes to the Site. The “Last Updated” date above reflects the most recent revision. We retain prior versions of this Statement, our testing results, our remediation log, and our accessibility request log, and we will make the current Statement available in an alternative format on request. We may update this Statement at any time to reflect changes in the Site, our practices, applicable standards, or applicable law.

16. Relationship to Our Other Policies; No Admission; Reservation of Rights

This Statement supplements, and should be read together with, our Privacy Policy, Terms and Conditions, Disclaimer, and Cookie Policy, each of which is linked in the Site footer. On matters of accessibility, this Statement controls; on other matters, those documents control.

This Statement describes our good-faith commitment, our program, and our current practices. It is not a representation or warranty that every page, feature, or document on the Site conforms to any technical standard at all times, and no statement in it is, or shall be construed as, an admission that the Site or any part of it fails to comply with any law. Our investigation of, response to, or correction of any reported barrier, and any alternative format or assistance we provide, are undertaken in good faith and are not an admission of fault or liability.

Nothing in this Statement, and nothing in our Terms and Conditions, Disclaimer, or other policies, waives, limits, or conditions any right you have under the Americans with Disabilities Act, Section 508 of the Rehabilitation Act, the Texas Human Resources Code, or any other applicable federal, state, or local accessibility or anti-discrimination law, and no provision of any of our policies shall be construed to require you to arbitrate, waive, or limit any such right to the extent that law does not permit it.

17. Contact Us

Accessibility Coordinator

AARO Real Estate LLC

10050 Northwest Freeway, Suite 105, Houston, TX 77092

Email: admin@aarorealestate.com

Telephone: (832) 500-3098 (staffed Monday through Thursday, 9:00 a.m. to 12:00 p.m. Central Time, excluding federal holidays, company closures, and days when our team is traveling or out of the office)