A. Introduction Lateral Investment Management, LLC (“LIM”) and Lateral SMA Agent, LLC (“LSMA”) (together “Lateral”) are growth equity investment advisers that are organized as Delaware limited liability companies. LIM was founded in 2014 and is minority owned. Mr. Richard de Silva is the majority owner of LIM (the “Managing Member” of LIM). LSMA was organized and formed in 2017. LIM, as the filing adviser, and LSMA, as the relying adviser, operate as a single advisory business and together file Form ADV. They (and where appropriate along with their affiliated general partner to each respective fund) are referred to throughout this Brochure as Lateral, unless otherwise appropriate. Lateral provides discretionary and non-discretionary investment advisory services to private pooled investment funds typically organized as Delaware limited partnerships and limited liability companies, and LIM also serves as a sub-adviser to one private fund (collectively, the “Funds”). The Funds are not registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”), and the securities of the Funds are not registered under the Securities Act of 1933, as amended (the “Securities Act”). Each Fund is governed by a limited partnership agreement or equivalent governing agreement (each, a “Fund Agreement”) that specifies the material terms and conditions of the Fund, including the applicable investment guidelines and investment restrictions, and in some cases confidential private placement memoranda are additionally prepared. The Sub-Advised fund is governed by an advisory agreement that specifies the sub-advisory services to be provided, in accordance with that fund’s investment management guidelines and that fund’s principal advisor. Some of the Funds act as master and feeder fund in a typical master-feeder structure, and some Funds act as co-investment vehicles, investing alongside the main fund in certain investments. Funds are more specifically described in Lateral’s Form ADV Part 1A, Schedule D. Throughout this Brochure, for simplicity, the Funds are categorized into four fund families, the “LUSCOF Funds,” the “Niagara Funds,” the “Niagara Plus Funds”, and the “Panther Plus Funds”. Additionally, where appropriate, the Sub-advised Fund and Non- Discretionary vehicles are separately referenced. For ease of clarity, the Sub-advised Fund’s assets are not included in part of the regulatory assets under management (“RAUM”) reported in this Brochure or the related Form ADV Part 1A. Moreover, the Non-Discretionary Funds include, exclusively, the feeder funds (which are

pooled vehicles) managed by Lateral. The LUSCOF Funds, Niagara Funds, Niagara Plus Funds, and Panther Plus Funds each have four distinct general partner entities (“Affiliated General Partners”) which are organized as Delaware limited liability companies and each further discussed in Item 10. The investors in the Funds (“Investors”) include, among others, family offices, certain financially sophisticated individuals, trusts, foundations, public pension plans, fund of funds, endowments and charitable organizations. B. Investments The Funds’ investments consist of private company securities. Lateral identifies investment opportunities and advises on the acquisition, management, monitoring and disposition of investments for each Fund. The investment strategy primarily consists of providing growth capital to non-sponsored lower middle market companies through the direct origination of short- term senior secured debt with minority equity stakes. Lateral focuses on lower middle market companies with limited borrowing availability such as owner-operated companies with no private equity sponsor. C. Advisory Services Lateral has broad and flexible investment authority per the Fund Agreement and additional governing documents with the exception of the Sub-advised private Fund and Non-Discretionary vehicles. Each Fund’s investment objectives and strategy is set forth in the relevant Fund Agreement and, in some instances, also in a confidential private placement memorandum, all of which Investors are urged to carefully review. The Investors are, to a certain extent, able to negotiate the terms of the applicable Fund Agreement in connection with, and prior to, their investments in a Fund. In certain cases, the Affiliated General Partners have entered into side letter agreements with certain Investors to modify certain rights and privileges which are not available to other Investors (including, without limitation, advisory and performance fee rates, information rights, reporting rights, capacity rights, approval rights and certain other protections and the right to receive certain special allocations) (the “Side Letters”). Once admitted to a Fund, an investor cannot seek additional investment guidelines or restrictions on such Fund, but in certain circumstances can invest in a non-discretionary or “fund of one” vehicle for additional investment opportunities. As of December 31, 2023, Lateral manages approximately $650,339,243.14 of assets on a discretionary basis and $131,909,851.23 on a non-discretionary basis. D. Wrap Fee Programs Lateral does not participate in wrap fee programs.