Needham Investment Management, LLC

Needham Investment Management, LLC, established in 1995, is a registered investment adviser providing discretionary portfolio management services to clients, including pooled investment vehicles and registered investment companies. The firm, a wholly-owned subsidiary of The Needham Group, Inc., manages regulatory assets totaling $1,406,166,639 as of December 31, 2024. NIM charges management fees based on assets under management, with registered investment companies paying 1.25% annually and pooled investment vehicles paying 1.00%, along with performance-based fees ranging from 15% to 20% of returns. Clients are billed monthly or quarterly, with fees not deducted directly from accounts. NIM's investment strategies focus on U.S. common stocks, utilizing fundamental analysis, industry focus, macroeconomic trends, and company visits. The firm also engages in short sales and hedging strategies to protect against market downturns. NIM operates under a fully discretionary model, making investment decisions based on individual client objectives and guidelines. The firm maintains a Code of Ethics, ensuring fair and honest dealings with clients and managing conflicts of interest related to personal trading and client transactions. NIM's proxy voting policies prioritize client interests, voting in favor of routine proposals and evaluating others based on client benefit. The firm complies with SEC regulations, including the Custody Rule, and maintains financial stability to meet client commitments.