Inclusive Capital, a Delaware limited partnership and a registered investment adviser, and its affiliated investment advisers, including Inclusive Capital Partners Spring Fund Manager, L.L.C. and Inclusive Capital Partners Spring Fund II Manager, L.L.C., its relying advisers (each, a “Relying Adviser,” and together, the “Relying Advisers”), provide investment advisory services to (i) investment funds privately offered to qualified investors in the United States and elsewhere and/or (ii) separate accounts (each, a “Separate Account,” and collectively, the “Separate Accounts”). Inclusive Capital commenced operations in July 2020. References to “Inclusive Capital” herein should be read to include its Relying Advisers. As of March 29, 2024, Inclusive Capital’s clients include the following private investment funds to which Inclusive Capital or its affiliates provide investment advisory services (each, a “Fund,” and together with any future private investment fund to which Inclusive Capital or its affiliates provide investment advisory services, the “Funds”):
• Inclusive Capital Partners Spring Fund, L.P.
• Inclusive Capital Partners Spring International, L.P.
• Inclusive Capital Partners Spring Master Fund, L.P.
• Inclusive Capital Partners Spring Fund II, L.P.
• Inclusive Capital Partners Spring International Fund II, L.P.
• Inclusive Capital Partners Spring Fund II-B, L.P.
• Inclusive Capital Partners Spring Master Fund II, L.P.
• Inclusive Capital Partners Spring Master Fund B, L.P.
• In-Cap UL Holdings, LLC Spring GP I, L.P. and Spring GP II, L.P. are general partner entities that are affiliated with Inclusive Capital (each, a “General Partner,” together with any future general partner entities, the “General Partners,” and collectively with Inclusive Capital and their affiliated entities “In- Cap”). Each General Partner and Relying Adviser is subject to the Advisers Act pursuant to Inclusive Capital’s registration in accordance with SEC guidance. This Brochure also describes the business practices of the General Partners and the Relying Advisers, which operate as a single The Funds are private funds that constructively work with management and a company’s board of directors to implement strategies that seek to generate attractive returns for shareholders. Inclusive Capital’s investment advisory services to the Funds and the Separate Accounts include identifying and evaluating investment opportunities, negotiating the terms of investments (where applicable), managing and monitoring investments and achieving dispositions for such investments. Investments are made in public companies and/or in non-public companies. Inclusive Capital’s investment team has experience working with companies as shareholders, and oftentimes as members of the companies’ boards. In-Cap’s investment advisory services to the Funds are detailed in the relevant private placement memoranda or other offering documents (each, a “Memorandum”), limited partnership or other operating agreements of the Funds (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.” For Separate Accounts, the scope of Inclusive Capital’s investment advisory services may be provided on a discretionary basis or non-discretionary basis and any applicable investment guidelines and restrictions are set forth in separate account agreements (each, a “Separate Account Agreement”). Investors in the Funds (generally referred to herein as “investors” or “limited partners”) participate in the overall investment program for the applicable Fund, but in certain circumstances are excused from a particular investment due to legal, regulatory or other agreed-upon circumstances pursuant to the Governing Documents; for the avoidance of doubt, such arrangements generally do not and will not create an adviser-client relationship between Inclusive Capital and any investor. The Funds and/or the General Partners have entered into side letters or other similar agreements (“Side Letters”) with certain investors that have the effect of establishing rights under, or altering or supplementing the terms of, the Governing Documents with respect to such investors as further described herein. Additionally, from time to time and as permitted by the Governing Documents, Inclusive Capital reserves the right to provide (or agree to provide) co-investment opportunities (including the opportunity to participate in co-invest vehicles) to certain Fund and/or Separate Account investors or other persons, including other sponsors, market participants, finders, consultants and other service providers, Inclusive Capital’s personnel and/or certain other persons associated with Inclusive Capital and/or its affiliates. Such co-investments typically involve investment and disposal of interests in the applicable investment at the same time and on the same terms as the Fund and/or Separate Account making the investment, however, co-investments can vary in timing and terms. However, from time to time, for strategic and other reasons, a co-investor or co-invest vehicle (including a co-investing Fund and/or Separate Account) purchases a portion of an investment from one or more Funds and/or Separate Accounts after such Funds and/or Separate Accounts have consummated their investment in the company (also known as a post-closing sell- down or transfer), which generally will have been funded through investor capital contributions and/or use of a Fund credit facility. Where appropriate, and in Inclusive Capital’s sole discretion, Inclusive Capital 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 and/or Separate Account for related costs. However, to the extent such amounts are not so charged or reimbursed, they generally will be borne by the relevant Fund and/or Separate Account. As of December 31, 2023, Inclusive Capital had regulatory assets under management totaling approximately $1,728,092,053. Inclusive Capital Partners, L.L.C., a Delaware limited liability company, acts as the general partner of Inclusive Capital Partners, L.P.. Inclusive Capital is controlled by Jeffrey Ubben.