A. General Description of Gabelli Funds, LLC Gabelli Funds, LLC (the “Gabelli Funds” or the “Adviser”) is a registered investment adviser that provides discretionary investment advisory services primarily to open and closed-end investment companies (the “Funds)”. The Adviser is a wholly owned subsidiary of GAMCO Investors, Inc. (“GAMCO Investors”), a Delaware corporation whose stock is traded on OTC Markets (OTCQX:GAMI). Mario J. Gabelli is deemed to be the controlling person of the Adviser on the basis of his ownership of a majority of the stock of GGCP, Inc., a privately held Wyoming corporation, which holds a controlling interest in GAMCO Investors. The Adviser provides investment advisory services to the following portfolios of active SEC registered open-end investment companies and closed-end investment companies: Open-End Funds (including ETFs): The Gabelli ABC Fund The Gabelli Asset Fund Gabelli Capital Asset Fund Comstock Capital Value Fund The Gabelli Dividend Growth Fund The Gabelli Enterprise Mergers and Acquisitions Fund The Gabelli Equity Income Fund The Gabelli Focus Growth and Income Fund The Gabelli Small Cap Growth Fund The Gabelli Global Financial Services Fund The Gabelli Global Growth Fund The Gabelli International Small Cap Fund The Gabelli Global Content & Connectivity Fund The Gabelli Rising Income and Dividend Fund The Gabelli Global Mini MitesTM Fund The Gabelli Gold Fund The Gabelli Growth Fund The Gabelli International Growth Fund The Gabelli SRI Fund The Gabelli Utilities Fund The Gabelli Value 25 Fund The Gabelli U.S. Treasury Money Market Fund Gabelli Media Mogul Fund Gabelli Pet Parents’TM Fund Gabelli Love Our Planet & People ETF Gabelli Growth Innovators ETF Gabelli Automation ETF Gabelli Financial Services Opportunities ETF Gabelli Global Commercial Aerospace & Defense ETF Gabelli Funds is sub-adviser to the Teton Westwood Mighty MitesSM Fund and Teton Convertible Securities Fund. Closed-end Funds: Bancroft Fund Ltd. Ellsworth Growth and Income Fund Ltd. The Gabelli Equity Trust Inc. The Gabelli Multimedia Trust Inc. The Gabelli Convertible and Income Securities Fund Inc. The Gabelli Utility Trust The Gabelli Dividend & Income Trust The Gabelli Global Utility & Income Trust GAMCO Global Gold, Natural Resources and Income Trust GAMCO Natural Resources, Gold and Income Trust The GDL Fund The Gabelli

Healthcare and Wellness Rx Trust The Gabelli Global Small and Mid Cap Value Trust The Adviser also provides investment management services to the GAMCO International SICAV, which is a Luxembourg SICAV qualified under the UCITS directive; and the Gabelli Merger Plus+ Trust, a closed-end fund organized under the laws of England and listed on the Specialist Fund Segment of the London Stock Exchange. In this brochure we may refer to SEC registered open-end and closed-end investment companies and non-U.S. Funds collectively as “Funds” or “Clients”. Investment management and administrative services fees charged to the Funds are based on average net assets, are computed either weekly or daily, and are payable monthly (at the beginning of the following month). Gabelli Funds may also earn performance based fees set forth in the particular fund’s prospectus. The advisory fees for the registered Funds are set forth in investment management contracts that are approved initially by shareholders and at least annually by the Directors/Trustees of the respective registered investment companies and are described in the prospectuses of such registered investment companies. The Adviser may periodically waive all or a portion of such fees or agree to reimburse expenses. B. Description of Advisory Services The Adviser manages various Funds under the “Value” investment orientation, primarily representing our absolute return, research-driven Private Market Value (PMV) with a CatalystTM. The Adviser also manages Funds that offer a “Growth” investment orientation, as well as other investment strategies including global and international equities, convertible securities, and sector specific investing. C. Availability of Tailored Services for Clients The primary clients of Gabelli Funds are the registered open and closed-end funds and are therefore managed in accordance with each individual fund’s prospectus and other fund governance documents. D. Client Assets Under Management At December 31, 2023, the adviser managed approximately $21 billion of client regulatory assets on a discretionary basis in eighteen (18) open-end and thirteen (13) closed-end registered management investment companies, a Luxemburg SICAV with three Sub-Funds, and one registered U.K. closed-end fund.