Background Polen Capital CLO Management, LLC (“Polen CLO Management”) was formed in 2024 as a Delaware series limited liability company. Since 2024, Polen CLO Management has been registered as an investment adviser with the Securities and Exchange Commission (“SEC”). Polen CLO Management has established separate segregated series (each a “Series”, and together, the “Series”) for (1) CLO collateral management activities (the “Management Series”), (2) EU/UK risk retention activities (the “Origination Series”), in the event that the applicable CLO is required to comply with risk retention requirements imposed by certain jurisdictions on sponsors of securitization transactions, and (3) holding investments in CLO Securities (the “Investment Series”). One or more funds advised by Polen Capital Credit, LLC, a Massachusetts limited liability company (“Polen Credit”) invest their assets primarily in the Investment Series and Origination Series of Polen CLO Management.
The members of Polen CLO Management are (i) Polen Capital CLO Equity Fund LP (“Polen CLO Equity Fund”), a Cayman Islands limited partnership, with respect to the Origination Series and the Investment Series, and (ii) Polen Credit with respect to the Management Series. Polen Credit is an investment adviser registered with the SEC with its principal office and place of business located at 1075 Main Street, Suite 320, Waltham, Massachusetts 02451. The general partner of the Polen CLO Equity Fund is Polen Capital CLO Equity GP LLC, a Delaware limited liability company, which, in turn, is owned by Polen Credit. Polen Credit is a wholly-owned subsidiary of Polen Capital Management, LLC (“Polen Capital”, and together with Polen Credit and Polen CLO Management, “Polen”), which is also an investment adviser registered with the SEC with its principal office and place of business located at 1825 NW Corporate Blvd., Suite 300, Boca Raton, Florida 33431. By virtue of Polen Capital owning 100% of the outstanding equity units of Polen Credit, and Polen Credit owning 100% of the outstanding units of the Management Series of Polen CLO Management, Polen Capital controls Polen CLO Management. Please refer to the Form ADV for each of Polen Credit and Polen Capital for additional information about their respective ownership and operations. Polen Capital, which is employee controlled, has established a management committee. This management committee is controlled by Stanley C. Moss, the chief executive officer of Polen Capital, Polen Credit, and Polen CLO Management, and Daniel Davidowitz, a portfolio manager and analyst at Polen Capital. By virtue of their control over the management committee of Polen Capital, which itself controls Polen CLO Management, Messrs. Moss and Davidowitz may be deemed controlling persons of Polen CLO Management. The business and affairs of Polen CLO Management will be managed exclusively by Polen Credit, as the sole owner of the Management Series of equity units issued by Polen CLO Management. Polen Capital has entered into an affiliate employee agreement to act as a shared service provider to Polen CLO Management as well as Polen Credit. This arrangement is described in Item10– OtherFinancial IndustryActivitiesandAffiliations. Polen CLO Management will act as collateral manager (whether on an advisory or sub-advisory basis) to issuers of collateralized loan obligation securities and to special purpose vehicles entering into short-term and long-term warehouse, repurchase, or other credit facilities to finance the preliminary accumulation and “ramp-up” of loans comprising all or a portion of the initial pool of collateral for any such issuer (each a “CLO”). Polen CLO Management may in the future advise one or more private funds (each a “Fund” and, together with the CLOs, “Clients”)

that invests directly or indirectly in the CLOs. Portfolio Management by Polen CLO Management Each CLO invests substantially all of its assets in loans, notes, and other securities, as permitted by the CLO governing documents. CLO liabilities are backed by the specific loans and other assets held within the special purpose vehicle (“SPV”) structure (collectively, “Assets”). In general, after its warehouse phase, a CLO is a pooled investment vehicle that has a tiered capital structure, issuing senior and mezzanine notes that are rated by one or more rating agencies (the “Rated Notes”) and unrated subordinated notes or other economic equity interests (the “Equity” and, together with the Rated Notes, the “CLO Securities”).
Each CLO is described in, governed by, and/or otherwise subject to a variety of documents (collectively, the “CLO Documents”), including: (i) the CLO’s organizational documents; (ii) during the warehouse phase, the relevant warehouse collateral management agreement, credit and security agreement, securities account control agreement, and other warehouse transaction documents; and (iii) upon the issuance of its CLO Securities, an offering circular, indenture, collateral management agreement, collateral administration agreement, conditional sale agreement, purchase agreement, subscription agreements, and other transaction documents. The CLO Documents describe the roles of various persons involved in the CLO, establish Polen CLO Management’s authority to perform certain investment management functions, including, without limitation, supervise and direct the investment and reinvestment of the collateral obligations and eligible investments and perform administrative and advisory functions as the collateral manager on behalf of the CLO in accordance with the applicable provisions under the collateral management agreement, collateral administration agreement and indenture and set forth detailed eligibility criteria, specifications and requirements regarding the types of investments and describe the overall composition of the CLO’s portfolio (including by imposing, as applicable, diversification, ratings, and concentration tests). In general, the primary investment objective of each CLO is to (i) provide consistently attractive risk- adjusted returns, and (ii) preserve capital in all market conditions. Each CLO will primarily focus on liquid investment opportunities, though it may also make investments from time to time that Polen CLO Management determines are illiquid. Investment assets of each CLO primarily include corporate senior secured bank loans and bonds, but other assets may be included depending on the terms of the applicable CLO indenture and the investment environment. While, in many cases, certain prospective investors in a CLO will influence the investment criteria, guidelines, and other terms set forth in the relevant Client’s final governing documents, it is generally the case that Polen CLO Management’s investment advice to each Client will primarily be limited to selecting and managing that Client’s assets. Polen CLO Management could hold interests in its CLOs, including in risk retention, if required, other Equity or first loss positions, or in any tranche of a CLO’s Rated Notes. Polen Capital CLO Equity GP LLC (“Polen GP”), a Delaware limited liability company wholly-owned by Polen Credit, is an affiliate of Polen CLO Management and serves as the general partner of the Polen CLO Equity Fund, which invests in the CLOs managed by Polen CLO Management.
Assets Under Management Because Polen CLO Management is a newly formed adviser, as of March 14, 2024 it did not yet manage any assets (discretionary or otherwise). Polen CLO Management does not participate in a wrap fee program.