Rand Capital Management, LLC is organized as a Delaware limited liability company and was formed in 2019. RCM is owned by Callodine Credit, LLC which is owned by Callodine Group, LLC (“Callodine Group”). The principal owner of Callodine Group is James Morrow. Advisory Services RCM provides discretionary advisory services to its clients. RCM’s current clients consist of (i) Rand Capital Corporation (RAND), a publicly traded, closed-end management company that has elected to be regulated as a business development company (“BDC”) under the Investment Company Act of 1940, as amended (“1940 Act”) and (ii) two privately offered investment funds (“Private Funds”) which are closed to new investors. The BDC and the Private Funds are each referred to herein as a “Client” and collectively as “Clients.” RCM may, in the future, organize and sub-advise, additional investment vehicles that follow an investment program similar to or different from the investment program of RCM’s existing Clients. Private Funds RCM manages the following privately offered pooled investment vehicles exempt from registration under the Investment Company Act of 1940, as amended:
• BlueArc Mezzanine Partners I, LP (“BAMP”) (closed to new investors)
• Callodine Strategic Credit Fund II, LP (“CSCF”) (closed to new investors) The Private Funds were formerly advised by Callodine Strategic Credit, LLC, an Exempt Reporting Adviser. Callodine Strategic Credit merged with RCM effective June 1, 2023. The Private Funds pursue an investment strategy of investing in mezzanine debt and

structured capital solutions to lower middle market companies in the U.S. RCM manages the Private Funds in a manner consistent with the investment strategy described in the Funds’ offering documents. In addition to day- to-day portfolio management responsibilities, RCM bears primary responsibility for making investment decisions for the Funds. RCM does not provide specifically tailored advice to investors in the Private Funds. Any investment restrictions applicable to the Funds are set forth in the organizational or offering documents. The BDC The BDC’s investment focus is to seek current income and capital appreciation by focusing its debt and related equity investments in privately held, lower middle market companies with committed and experienced management in a broad variety of industries. Client assets are managed in accordance with the particular investment objectives, strategies, restrictions and guidelines set forth in the regulatory documents filed with the SEC and any other applicable governing documents (“Governing Documents”). RCM does not tailor its advisory services to the needs of individual investors in the BDC. Any investment restrictions applicable to the BDC are set forth in the registration statement and other applicable governing documents. As of December 31, 2023, the regulatory assets under management for the BDC were $81,021,982. The regulatory assets under management for the Private Funds were $76,690,561. RCM’s total regulatory assets under management was $157,712,543, all of which are managed on a discretionary basis.