The Adviser, a Delaware limited liability company and a registered investment adviser, and its affiliated investment advisers provide investment advisory services to investment funds privately offered to qualified investors in the United States and elsewhere. The Adviser commenced operations in December 2017. The Adviser is controlled by Jon Gimbel and Anthony Guagliano, who are its principal owners. The Adviser’s clients include the following (each, a “Fund,” and together with any future private investment fund to which the Adviser or its affiliates provide investment advisory services, the “Funds”):
• Gallant Capital Partners I, L.P. and Gallant Capital Partners I-A, L.P. (together, “Fund I”)
• Gallant Capital Partners II, L.P. and Gallant Capital Partners II-A, L.P. (together, “Fund II”) The Adviser’s clients also include the following (each, a “co-invest vehicle,” and together with any future co-investment vehicles to which the Adviser or its affiliates provide investment advisory services, “co-invest vehicles”):
• Gallant Capital Co-Invest I, LLC
• Gallant CMI Holdco, Inc.
• Gallant Screening Acquisition, LLC
• Gallant Screening Holdco, Inc.
• Gallant Sequoia Holdings, LLC
• Gallant Skygreen, LLC
• Gallant Optimized Marketing Parent, LLC
• Gallant Green Acquisition, LLC The following general partner entities are affiliated with the Adviser:
• Gallant Capital Partners GP I, L.P.
• Gallant Capital Partners GP II, L.P. (each a “General Partner” and collectively, together with any future affiliated general partner entities, the “General Partners,” and together with the Adviser and their affiliated entities, “Gallant”). Each General Partner is subject to the Advisers Act pursuant to the Adviser’s registration in accordance with SEC guidance. This Brochure also describes the business practices of the General Partners, which operates as a single advisory business together with the Adviser. The Funds are private equity funds and invest through negotiated transactions in operating entities, generally referred to herein as “portfolio companies.” Gallant’s investment advisory services to the Funds consist of identifying and evaluating investment opportunities, negotiating the terms of investments, managing and monitoring investments and achieving dispositions for such investments. Although investments are made predominantly in non-public companies, investments in public companies are permitted. Where such investments consist of portfolio companies, the senior principals (the “Partners”) or other principals or personnel of Gallant or its affiliates generally serve on such portfolio companies’ respective boards of directors or otherwise act to influence control over management of portfolio companies in which the Funds have invested. Gallant’s

advisory services to the Funds are detailed in the applicable private placement memoranda or other offering documents (each, a “Memorandum”), limited partnership or other operating agreements or governing documents (each, a “Partnership Agreement” and, together with any relevant Memorandum, the “Governing Documents”) and are further described below under “Methods of Analysis, Investment Strategies and Risk of Loss.” Investors in the Funds participate in the overall investment program for the applicable Fund, but may be excused from a particular investment due to legal, regulatory or other agreed-upon circumstances pursuant to the relevant Partnership Agreement. The Funds or the General Partners generally enter into side letters or other similar agreements (“Side Letters”) with certain investors that have the effect of establishing rights (including economic or other terms) under, or altering or supplementing the terms of, the relevant Partnership Agreement with respect to such investors. Additionally, as permitted by the relevant Governing Documents, Gallant expects to provide (or agree to provide) investment or co-investment opportunities (including the opportunity to participate in co-invest vehicles) to certain current or prospective investors or other persons, including other sponsors, market participants, finders, consultants and other service providers, portfolio company management or personnel, Gallant personnel and/or certain other persons associated with Gallant and/or its affiliates (e.g., a vehicle formed by Gallant’s principals to co- invest alongside a particular Fund’s transactions). Such co-investments typically involve investment and disposal of interests in the applicable portfolio company at the same time and on the same terms as the Fund making the investment. However, for strategic and other reasons, a co- investor or co-invest vehicle may purchase a portion of an investment from one or more Funds after such Funds have consummated their investment in the portfolio company (also known as a post-closing sell-down or transfer). Any such purchase from a Fund by a co-investor or co-invest vehicle generally occurs shortly after the Fund’s completion of the investment to avoid any changes in valuation of the investment. Where appropriate, and in Gallant’s sole discretion, Gallant reserves the right to charge interest on the purchase to the co-investor or co-invest vehicle (or otherwise equitably to adjust the purchase price under certain conditions), and to seek reimbursement to the relevant Fund for related costs. However, to the extent any such amounts are not so charged or reimbursed (including charges or reimbursements required pursuant to applicable law), they generally will be borne by the relevant Fund. As of December 31, 2023, Gallant manages $1,245,215,687 of client assets on a discretionary basis.