A. General Description of Advisory Firm Palladium Heritage Management, LLC (the “Registrant”), located in New York, New York, is an investment advisor to multiple pooled investment vehicles commonly known as private equity funds. For purposes of this Brochure, “Palladium” or the “Firm” includes the Registrant, along with its affiliated General Partner (as discussed below) and other affiliates such as Palladium Equity Partners Advisor, L.L.C. (the “Palladium Equity Partners Advisor”). Please see the Form ADV Part 2A for Palladium Equity Partners Advisor for information about the ownership of Palladium. The Registrant was organized in February 2022, registered as an investment adviser in 2022 and is controlled by its sole member, Palladium Heritage, LLC, which in turn is owned 51% by Katherine Lehman and 49% by Palladium Investment Partners, LLC. Palladium Investment Partners, LLC is controlled through wholly owned subsidiaries by the Management Committee of Palladium. The Palladium Equity Partners Advisor and the Registrant maintain a close relationship and share office space, systems, and personnel. Heritage (as defined below) personnel have access to the remainder of Palladium’s people and resources, including back-office support, fundraising and investor relations, finance, accounting and legal and compliance. Further, Heritage personnel have access to the intellectual capital, networks and experience of Palladium’s professionals by (1) participating in Palladium’s Weekly Meetings (as defined below), including portfolio reviews, (2) presenting potential deals at the Firm’s weekly deal review meeting to allow for idea and resource sharing, feedback and the highlighting of any areas of concern or further diligence and (3) cross-training and team sharing through a “secondment” process whereby an intermediate or junior professional from elsewhere in the Palladium organization is expected to be assigned to Heritage at any given time. In addition, two professionals from the Palladium organization have been appointed to the Heritage Investment Committee, including Palladium’s founder. The Heritage team also has direct access to databases and technologies within the Firm. In June 2021, affiliates of Palladium entered into a preferred equity financing transaction with certain private investment funds affiliated with Landmark Equity Advisors, LLC (collectively, “Landmark”) pursuant to which Landmark is entitled to receive, indirectly vis-à-vis their limited partnership interests in PEP Professionals Capital, L.P. (the “SPV”), a Delaware limited partnership controlled by an affiliate of Palladium, repayment proceeds representing a portion of the management fee income from the Registrant and 2% of the carried interest distributable with respect to certain potential future private equity funds that may be sponsored by Palladium, until such time as set forth in the governing documents of the SPV. B. Description of Advisory Services a. Advisory Services The Registrant is generally responsible for carrying out the day to day investment activities of Palladium Heritage Fund, L.P. (the “Partnership”) and its parallel funds, including Palladium Heritage (Parallel) Fund, L.P. (the “Parallel Fund” and together with the Partnership and its parallel funds, the “Heritage Fund” or “Fund”). The duties and obligations of the Registrant as advisor to the Fund are described more specifically in the advisory agreement that it entered into with the Fund. The Registrant may establish additional investment vehicles in the future, to which it may or may not provide investment advisory services. To the extent that another vehicle is established to which the Registrant provides investment advisory services, this Brochure and the Registrant’s Form ADV, Part 1A will be updated as appropriate to reflect such new vehicle. The Fund’s general partner is Palladium Heritage GP, LLC (“General Partner” and together with the Registrant, “Heritage”). The General Partner is generally responsible for the management, operation and policy of the Fund, which includes making investments on behalf of the Fund, entering into contracts on behalf of the Fund, acquiring, holding, and selling investments on behalf of the Fund, and serving as the agent designated to carry out the investment objectives of the Fund on behalf of all partners. The duties and obligations of the General Partner are more specifically described in the Limited Partnership Agreement (“Partnership Agreement”) that all partners in the relevant Fund enter into in connection with their investment in each such Fund. b. Private Funds Investments in the Fund are governed by the Partnership Agreement, which includes written investment guidelines that must be followed by the General

Partner in the course of investing on behalf of the Fund, as well as side letter agreements with particular Fund investors that require certain provisions relating to their investments in the Fund. We collectively refer to the Partnership Agreement, side letter agreements and advisory agreement of the Fund as the Fund’s “Governing Documents.” The Partnership relies on an exemption from registration as an “investment company” under Section 3(c)(7) of the Investment Company Act of 1940 (the “Company Act”). The Parallel Fund relies on an exemption from registration as an “investment company” under Section 3(c)(1) of the Company Act. Interests in the Fund are only being offered to qualified investors via private placements of securities that are exempt from registration with the SEC under the Securities Act of 1933 (the “Securities Act”). Investment advice is provided by the Registrant and General Partner directly to the Fund, and not individually to the investors in the Fund. Pursuant to the Governing Documents, investors are not permitted to impose restrictions on the Fund’s investments. The Heritage Fund targets investments in the lower end of the middle market. The Heritage Fund seeks to make control and control-oriented investments in business to business (“B2B”) and industrial companies (together, the “Target Sectors”) using a value-driven strategy with a focus on entrepreneur-backed companies, corporate carveouts, multi-seller transactions and other complex situations. The Heritage Fund team (including the senior investment professionals thereof, the “Senior Investment Team” and together with certain other professionals who provide services to the Fund, the “Heritage Fund Team”) intends to utilize a value-driven, active ownership investment approach, seeking to transform, professionalize and grow businesses through enhanced leadership and by implementing strategies for operational improvement and corporate growth. The Senior Investment Team sees significant opportunity for experienced investors and operating resources to professionalize business processes or capabilities typically lacking in smaller family-owned companies or corporate “orphans”. c. Co-Investment Vehicles From time to time, Heritage may offer equity co-investment opportunities to invest alongside the Fund in Fund investments. Such opportunities may arise from time to time where the General Partner determines that the aggregate amount to be invested would exceed the amount determined to be appropriate or applicable for the Fund, pursuant to the Governing Documents and in the General Partner’s good faith judgment. The Governing Documents contain provisions addressing allocation of co-investment opportunities, and Heritage maintains written allocation policies in its compliance manual. The considerations relating to the allocation of co-investments are described in greater detail at Item 11 (Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading) below. In certain instances, Heritage may consider establishing dedicated co-investment vehicles to invest alongside the Fund in the Fund investment. As of the date of this Brochure, the Registrant does not provide investment advisory services to any co-investment vehicle. The Registrant may establish co-invest vehicles in the future, to which it may or may not provide investment advisory services. To the extent that another co-investment vehicle is established to which the Registrant provides investment advisory services, this Brochure and the Registrant’s Form ADV, Part 1A will be updated as appropriate to reflect such new vehicle. From time to time, in connection with obtaining funding for portfolio investments, lenders may request equity co-investment opportunities as part of a lending agreement. When such circumstances arise, the General Partner will review the Fund’s opportunities to obtain funding in the market, and determine whether it is in the Fund’s best interest to agree to such request or to pursue alternative financing. d. Employee Investment Vehicles Certain Palladium employees are permitted to participate on a fee free basis in the Fund and/or Fund investments via specific investment vehicles established for such purpose. These employment investment vehicles are not expected to invest alongside the related Fund’s investment, but rather to participate as limited partners in the Fund and/or by investing in or alongside the related General Partner in the Fund. Heritage interests in Fund investments are discussed in greater detail at Item 11 (Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading) below. e. Assets Under Management Heritage’s Regulatory Assets Under Management as of December 31, 2023 total $43,271,557.