Newstone Capital Partners, LLC (“Newstone”) is a Delaware limited liability company that commenced providing advisory services in May of 2006. The principal owners of Newstone are John C. Rocchio and Timothy P. Costello. Newstone provides the services described below to its advisory clients, which are private investment funds (collectively, the “Newstone Funds” or “Funds”). A related person of Newstone generally acts as general partner or manager of each Newstone Fund, and Newstone acts as investment advisor to each Newstone Fund. References to Newstone in this brochure include, as the context requires, affiliates through which Newstone provides investment advisory services or that act in any capacity referenced in the previous sentence. Newstone’s investment advisory business is principally focused on privately placed mezzanine investments, generally consisting of subordinated debt with some form of equity participation, and also includes senior notes, second-lien debt, preferred stock or high-yield bonds of principally larger middle-market companies in a variety of industries, locations, stages and styles. The combined debt and equity investments may, from time to time, result in a Newstone Fund having representation on the boards of directors of the companies in which it invests and providing significant input into major financial and business decisions of such companies. The Newstone Funds generally invest in privately-held portfolio companies, but may also make investments from time to time in companies whose securities are publicly traded. Newstone tailors its advisory services to the specific investment objectives and restrictions of each Newstone Fund set forth in such Newstone Fund’s limited partnership agreement, confidential private placement memorandum, investment management agreement and/or other governing documents (collectively, the “Governing Documents”). Investors and prospective investors of each Newstone Fund should refer to the Governing Documents of the applicable Newstone Fund for complete information on the investment objectives and investment restrictions with respect to such Newstone Fund. There is no assurance that any of the Newstone Funds’ investment objectives will be achieved. In accordance with common industry practice, one or more of the Newstone Funds or their general partners reserve the right to enter into “side letters” or similar agreements with certain investors pursuant to which the general partner grants the investor specific rights, benefits,

or privileges that are not made available to investors generally. The terms of such agreements will be made available to other actual investors in such Newstone Fund. Additionally, from time to time and as permitted by the relevant Governing Documents, Newstone expects to provide (or agree to provide) co-investment opportunities (including the opportunity to participate in co-invest vehicles) to certain current or prospective investors or other persons, including other sponsors, market participants, finders, consultants and other service providers, Newstone’s personnel and/or certain other persons associated with Newstone and/or its affiliates. Such co-investments typically involve investment and disposal of interests in the applicable portfolio company at the same time and on the same terms as the Newstone Fund making the investment. However, from time to time, for strategic and other reasons, a co-investor or co-invest vehicle may purchase a portion of an investment from one or more Newstone Funds after such Newstone Funds have consummated their investment in the portfolio company (also known as a post- closing sell-down or transfer), which generally will have been funded through Newstone Fund investor capital contributions and/or use of a Newstone Fund credit facility. Any such purchase from a Newstone Fund by a co-investor or co-invest vehicle generally occurs shortly after the Newstone Fund’s completion of the investment to avoid any changes in valuation of the investment. Where appropriate, and in Newstone’s sole discretion, Newstone reserves the right to charge interest on the purchase to the co-investor or co-invest vehicle and to seek reimbursement to the relevant Newstone Fund for related costs. However, to the extent any such amounts are not so charged or reimbursed, they generally will be borne by the relevant Newstone Fund. Newstone does not participate in any wrap fee programs. Newstone manages all assets of the Newstone Funds on a discretionary basis in accordance with the terms and conditions of each Newstone Fund’s Governing Documents. As of December 31, 2023, the amount of assets under management (“AUM”) that Newstone manages on a discretionary basis was approximately $1,085,950,000. The amount of AUM reported herein is based upon the net assets and unfunded commitments of each Newstone Fund and thus differs in amount from, and method of computation used for, the amount of regulatory assets under management reported in Item 5.F. in the ADV Part 1A.