Bluestone Investment Manager, LLC (“BIM”), a Delaware limited liability company, is registering as a registered investment adviser. BIM maintains its principal office in McLean, Virginia. BIM along with the related persons disclosed in ADV Part 1A is the management company for Bluestone, a private equity firm targeting lower middle-market (“LMM”) businesses within the defense and government services sectors. Bluestone was formed in 2011. The principal owners of BIM are John Allen, and Bill Strang (collectively, the “Managing Partners”). BIM’s clients include the following (each, a “Fund,” and collectively, together with any future private investment fund to which BIM and/or its affiliates provide investment advisory services, the “Funds”):
• Bluestone Investment Partners II, LP;
• Bluestone Investment Partners III, LP
• Bluestone Investment Partners III-A, LP The following general partner entities are affiliated with BIM:
• Bluestone Investment GP II, LLC
• Bluestone Investment GP III, LP
• Bluestone Investment UGP III, LLC (each, a “General Partner,” and collectively, together with any future affiliated general partner entities, the “General Partners,” and together with BIM and their affiliated entities “Bluestone”). In certain cases, Bluestone has offered, and may in the future, offer to allow certain investors (including related persons of Bluestone) the ability to co-invest along with the Funds in certain Portfolio Companies. In certain cases Bluestone may form a co-investment vehicle to facilitate such investments (“Co-Investment Vehicle”). Such co-investments may or may not be subject to the fees described below in Item 5, or may be subject to different fee amounts and/or terms. Bluestone or the applicable general partner may offer co-investment opportunities to some investors and not others, at the discretion of the General Partner. In the future, Bluestone may provide investment advisory services to other Funds. The activities of each Fund are governed by a limited partnership agreement (each a “Fund Agreement”), that specifies the investment guidelines and investment restrictions applicable to each Fund. Typically, an affiliate of BIM serves as general partner of each of the Funds (each a “General Partner”). Each General Partner is a related person of BIM. Bluestone, together with the General Partners, provides investment management and/or

investment supervisory services. The General Partners and Funds retain Bluestone to provide investment management and advisory services. The General Partners retain management authority over the business and affairs of the Funds. Bluestone offers investment advice solely with respect to the investments made by the Funds in Portfolio Companies. Such services consist of sourcing, and evaluating investment opportunities; structuring, negotiating, and making investments on behalf of the Funds; managing and monitoring the performance of such Portfolio Companies; and exiting investments. Bluestone generally makes majority, control investments in lower middle-market (“LMM”) businesses within the defense and government services sectors. To date, all but one transaction in the Firm’s history has been a control investment. Bluestone generally has broad and flexible investment authority with respect to the Funds. Each Fund’s investment objective and strategy is set forth in the respective Fund’s governing documents (“Governing Documents”). All investors in the Funds (“Investors”) are provided with a Fund Agreement and a confidential private placement memorandum prior to making an investment. Investors are urged to carefully review those documents prior to making an investment in the Fund. Bluestone seeks investments for each Fund in accordance with the Fund’s investment objectives and strategy as set forth in the relevant Fund Agreement and confidential private placement memorandum. Certain investment limitations may be included in the Fund Agreements. Bluestone and/or the General Partners have and may in the future enter into side letter agreements with certain Investors. Side letters are negotiated prior to the General Partners’ acceptance of the Investor’s subscription, and may establish rights that supplement, or alter the terms of, the applicable Fund Agreement. Pursuant to such side letters, certain Investors have rights which are not available to all other Investors (including, without limitation, most favored nations rights, advisory board representation, transparency rights, reporting rights, and co-investment rights). Bluestone does not participate in wrap fee programs. As of December, 31 2023, Bluestone’s regulatory assets under management were approximately $307,567,007, all managed on a discretionary basis. Bluestone does not have any clients whose assets are managed on a non-discretionary basis.