Great Elm Capital Management, Inc.

Great Elm Capital Management, LLC is a registered investment adviser established in May 2016, specializing in managing portfolios invested in debt instruments, equity securities, and derivatives. The firm offers investment advice on international and domestic securities to clients such as a business development company and a private investment fund. Great Elm operates under discretionary management, with $350,862,168 in regulatory assets under management as of December 31, 2024. Clients are charged a combination of performance-based fees and asset-based management fees, with specific fee structures outlined for different investment vehicles. The firm does not participate in wrap fee programs and does not accept compensation for the sale of securities. Great Elm's investment strategies focus on generating current interest and capital appreciation through investments in middle-market companies' capital structures. The firm emphasizes risk protection by investing in assets exceeding debt values and employs various investment instruments, including debt, equity, and equity-related securities. Clients are advised to carefully review the risks associated with investments, such as credit risk, interest rate risk, and cybersecurity risks. Great Elm has no disciplinary events to report and has implemented a Code of Ethics to ensure high ethical standards among employees. The firm exercises investment discretion over client portfolios and has adopted a proxy voting policy to vote in the best interests of clients when applicable. Great Elm maintains custody of assets for Private Funds and has no financial conditions impairing its ability to meet client commitments.