Gladstone Management Corporation

Gladstone Management Corporation, established in 2002, is a Delaware corporation specializing in providing investment advisory services to publicly-traded management investment companies acting as business development companies (BDCs) and real estate investment trusts (REITs). The firm manages approximately $4.2 billion in assets on a discretionary basis as of July 31, 2024. Gladstone Management's fee structure includes base management fees ranging from 0.425% to 2.0% for different types of Fund Clients. Incentive fees are based on net investment income or realized capital gains. The firm may provide significant managerial assistance to BDC Fund Client portfolio companies and earn fees from REIT Fund Clients' borrowers or tenants. Investment discretion is fully delegated to Gladstone Management, which makes investment decisions based on the Fund Clients' objectives and guidelines. The firm has adopted a Code of Business Conduct and Ethics, including personal trading policies, to ensure compliance with fiduciary duties. Gladstone Management does not have custody of client assets but may be deemed to have custody in certain cases. The firm does not regularly vote proxies on behalf of clients. There are no financial conditions impairing the firm's ability to meet contractual commitments, and prepayment of fees is not required or solicited.