Who we are PCA is a limited liability partnership incorporated in England and Wales in November 2010. We are an SEC registered investment adviser and are authorised and regulated by the FCA. We are one of several Pemberton companies that focus on advising private funds or compartments of same that make commercial loans to European mid- market corporates seeking to grow and expand their businesses. We are a MiFID regulated firm. We are an exempt CTA. As at 28 March 2024, we employ 100 partners and employees. We have the following equity owners, as disclosed in our Form ADV Part 1: Legal & General Capital Investments Ltd-37.6%; PCA staff and management- 30%; Symon Drake-Brockman (Managing Partner)-26.4%; and Pemberton Asset Management Services UK Limited (“PC Services”)-6%. PC Services is a wholly owned subsidiary of Pemberton Asset Management Holdings Limited (“Holdings”). We identify the owners of Holdings in our Form ADV Part 1 Schedule B. As of 31 December 2023, our assets under management were US$ 16,920,708,174.84. Our regulatory assets under management are stated in our Form ADV Part 1. Both AUM and RAUM figures reflect end of quarter or end of month calculations of net asset value (NAV). The disclosures in this Form ADV Part 2A relate solely to any activities that involve U.S. resident persons that would invest in a fund or a compartment for which we serve as non-discretionary investment adviser or to a feeder fund for certain of these, named herein. Activities We do not manage assets in separately managed accounts. We manage assets for Luxembourg funds and compartments of funds, and feeder funds, as a non-discretionary adviser. Certain of these funds and compartments are not incorporated in the United States, are not marketed in the United States and do not have U.S. person investors. We receive a fee for advising them and are reimbursed for expenses. Other funds and compartments, and the feeder funds, are marketed in the United States or have U.S. person investors These are named and discussed below. We provide advice to the feeder funds noted below for hedging (Spot FX and FX forwards). Pemberton Asset Management S.A., a Luxembourg CSSF authorised Alternative Investment Fund Manager, “AIFM” (“IM” or “PAMSA”) is the investment manager to these funds and compartments. PAMSA is a Private Fund Adviser and files a report on Form ADV Part 1 with the SEC as an Exempt Reporting Adviser (“ERA”). The general partners named below of each fund or compartment that is marketed in the United States or that has U.S. person investors are named as a Special Purpose Entity (“SPE”) in the IM’s Form ADV Part 1 Schedule D Miscellaneous Box. Strategies, funds, and compartments Mid-Market Debt Strategy Pemberton Debt Fund SCS, SICAV-FIS (“Debt Fund”) is a Luxembourg investment company with variable capital. The Debt Fund’s general partner is Pemberton Debt GP S.à.r.l. (“Debt Fund GP”), a private limited company (société à responsabilité limitée) incorporated in Luxembourg and a wholly owned subsidiary of Holdings. Debt Fund GP is an ERA. We are the non-discretionary adviser for the following Debt Fund compartments that are marketed to or that have U.S. person investors.  Pemberton Debt Fund Compartment 1 (“Compartment 1”) of the Debt Fund: this is closed to new investors. Compartment 1 invests in a portfolio of senior secured loans to established mid-market European companies to generate an expected quarterly income stream and attractive returns for Investors. Compartment 1 uses leverage as explained in Item 8 below.  We are the non-discretionary adviser to Pemberton European Mid-Market Debt Fund II (A) (“Fund II”), Compartment 5 of the Debt Fund, which is closed to new investors. Pemberton Debt Fund II SCS, SICAV-RAIF (“Debt Fund II”): this is a Luxembourg investment company with variable capital – reserved alternative investment fund under the form of a common limited partnership structured as an umbrella fund. The Debt Fund II’s general partner Pemberton Debt GP II S.à.r.l. (“Debt Fund II GP”) a private limited liability company (société à responsabilité limitée) incorporated in Luxembourg and a wholly owned subsidiary of Holdings.  We are non-discretionary adviser to Pemberton European Mid-Market Debt Fund II (B) (“Compartment II (B)”), a compartment of Pemberton Debt Fund II SCS, SICAV-RAIF (“Debt Fund II”). U.S. persons invest in this through Pemberton Debt Fund Delaware II LP (Fund II Feeder Fund”), and all or substantially all of the assets in this feeder fund are invested in this compartment. This fund is now closed to new investors. Pemberton Mid-Market Debt Fund III SCS, SICAV-RAIF (“Debt Fund III”) is a Luxembourg investment company with variable capital. Its general partner is Pemberton Debt GP III S.à.r.l. (“Debt Fund III GP”), a private limited company (société à responsabilité limitée) incorporated in Luxembourg and a wholly owned subsidiary of Holdings. U.S. investors participate in Debt Fund III by investing in Pemberton Mid-Market Debt Fund III SCSp SICAV-RAIF (USD Co-investment) (“Debt Fund III (Co-Invest)”), which is now closed to new investors. We are the non-discretionary adviser to Pemberton Mid-Market Debt Fund IV (EUR) (“Debt Fund IV EUR”) and Pemberton Mid-Market Debt Fund IV (Levered) (“Debt Fund IV Levered”), compartments of Pemberton Mid- Market Debt Fund IV SCSp SICAV-RAIF is open to new investors. Debt Fund IV is a Luxembourg investment company with variable capital. Debt Fund IV’s general partner is Pemberton Debt Fund IV GP S.à r.l (“Debt Fund IV GP”), a private limited liability company (société à responsabilité limitée) incorporated in Luxembourg. Senior Loan Strategy We are non-discretionary adviser to Pemberton Senior Loan Fund II SCSp SICAV-RAIF; the compartment that is marketed to or that has U.S. person investors is the Pemberton Senior Loan Fund II (EUR) (“SLF II (EUR)”). Risk Sharing Strategy We are the non-discretionary adviser to Pemberton Risk Sharing Fund SCSp SICAV-RAIF (“RSS”). The compartments that are marketed to or that have U.S. person investors are Pemberton Risk Sharing Fund SCSp SICAV-RAIF - EUR (Unlevered) (“RSS EUR (Unlevered)”) and Pemberton Risk Sharing Fund SCSp SICAV-RAIF USD (Levered) compartment (“RSS USD (Levered)”). NAV Strategy We are non-discretionary adviser to Pemberton NAV Financing SCSp SICAV-RAIF; the compartments

that are marketed to or that have U.S. person investors are Pemberton NAV Financing SCSp SICAV-RAIF – Strategic Fund (“NAV Strategic”) and Pemberton NAV Financing SCSp SICAV-RAIF – Core Fund (“NAV Core”). NAV Core has a feeder fund for U.S. persons to invest; Pemberton NAV Financing Core USD Feeder SCSp. Strategic Credit Strategy We are the non-discretionary adviser to Compartment 4 of the Debt Fund, which is now closed to new investors. This compartment has a feeder fund for U.S. persons to invest; in turn, substantially all of the assets in each feeder fund are invested in a compartment (the remainder is used for hedging).  U.S. investors invested in Compartment 4 through a Delaware feeder fund, Pemberton Strategic Credit Fund Delaware I LP (“SCOF Feeder Fund”).  U.S. investors that are ERISA pension funds invested in SCOF through Pemberton Strategic Credit Fund Cayman I LP (“ERISA SCOF Feeder Fund”). We are the non-discretionary adviser to Pemberton Strategic Credit Fund II SCSp, SICAV-RAIF (“SCF II”). SCF II is a Luxembourg investment company with variable capital. SCF II’s general partner is Pemberton Strategic Credit Fund GP II S.à.r.l. (“SCF II GP”), a private limited company (société à responsabilité limitée) incorporated in Luxembourg and a wholly owned subsidiary of Holdings. The SCF II is an umbrella fund structure with separate compartments. Each compartment has its own assets, processes, objectives and restrictions. U.S. person investors participate in the USD compartment of the Pemberton Strategic Credit Fund II (B) compartment (“SCF II (B)”). SCF II (B) is now closed to new investors. We are the non-discretionary adviser to Pemberton Strategic Credit Fund III SCSp, SICAV-RAIF (“SCF III”); the compartments that are marketed to or that have U.S. person investors are the Pemberton Strategic Credit Fund III (A) (“SCF III (A)”) and Pemberton Strategic Credit Fund III (B) (“SCF III (B)”), closed to new investors. Working Capital Finance Strategy We are the non-discretionary investment adviser to Pemberton Payables & Receivables Opportunity Fund S.A. SICAV-FIAR (“PROF”); Global Trade Solutions 1 (“GTS 1”) is a compartment into which U.S. persons invests. PROF is a Luxembourg umbrella fund. PROF will, through one or more compartments, invest (either directly or through one or more investment holding companies) in a portfolio of one or more investment programmes sourced through approved servicers. ERISA Compliant Strategy We are the investment advisor and QPAM to the Pemberton Evergreen Alternative Credit Fund LP (“ERISA 1”) the fund into which U.S. persons invest. ERISA 1’s general partner is Pemberton Evergreen Alternative Credit Fund GP Limited (“ERISA 1 GP”), a private limited company incorporated in Cayman and a wholly owned subsidiary of Holdings. Co-investments, capital structure, parallel investments and transfers Co-investment: From time to time, a loan will be considered that would be suitable for one or more compartments, such as a compartment of Debt Fund IV, Debt Fund III, Debt Fund II, Debt Fund, SCF III, SCF II, SCF, SLF II, RSS, NAV or PROF. This allocation issue is a conflict of interest. To address this, loans are considered based on objective criteria that does not consider fees and that is assessed and documented in the credit due diligence process on the basis of each compartment’s specific investment objectives and restrictions and the allocation requirements applicable to a fund or a compartment. The final allocation, based on these criteria and in accordance with the Group Portfolio Management Allocation Policy, is made by the IM’s Portfolio Management Conducting Officer (“PMCO”) and presented to the IM’s Investment Committee (“IC”) for consideration and approval. Fee methodology and calculations are subject to a separate external independent, annual review by our auditors. Co-investment: From time to time, a loan will be considered that would be suitable for ERISA 1 (where PCA acts as the QPAM) alongside the other SLF, Debt Fund, SCF, NAV and RSS funds managed by the IM. This allocation issue is a conflict of interest. To address this, the final allocation is prepared in accordance with the Group Portfolio Management Allocation Policy and is made by the PCA Credit Review Committee with transparency provided on the allocation to the other funds: SLF, Debt Fund, SCF, NAV and RSS managed by the IM. Full transparency on the ERISA 1 allocation by PCA is also provided to the IM’s Portfolio Management Conducting Officer and presented to the IM’s IC. Fee methodology and calculations are subject to a separate external independent, annual review by our auditors. Capital structure: A conflict of interest arises when making investments at different levels of an issuer’s capital structure for different funds or compartments or between different vintages of the same strategy as the different funds will have conflicting motivations should the borrower enter a restructuring. To address this conflict, we have a process that involves a three-tier oversight approach undertaken by an initial and final Credit Review Committee with any conflict of interest present and being raised to the Conflicts Committee for review and clearance and then oversight by the IM’s IC which review and approve the investment. There is an eleven-step process approved by the Conflicts Committee that would oversee a restructuring workout. Transfers: Certain assets held by one fund or compartment can be transferred between funds or compartments causing a conflict of interest and an issue in valuing the asset to be transferred. Proposals to sell-down or transfer assets from a compartment to another vehicle or 3rd party will be executed in accordance with the respective General Partner’s contractual obligations. Where the GP believes the matter will have a material effect on the fund, this must be approved by the Investment Advisory Committee (“IAC”) (members of the IAC are limited partners who are large sophisticated institutions). For any asset transfer consideration will be given to (1) transfer price of the asset, (2) suitability of the transfer between a selling and buying entity and (3) commercial rationale as to why this is attractive for both sets of investors. The assets will be valued prior to any transaction according to the Valuation Policy and will be approved by the IM’s IC.