Identify your principal owner(s). Hale Capital Management, LP (“Hale Capital”) is a Delaware limited partnership that was formed on January 7, 2008. Hale Capital is owned by Martin de Mora Hale, Jr. specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. Hale Capital provides discretionary investment advice to (i) Hale Capital Partners, L.P., a U.S. organized private investment partnership (the “Partnership”) and (ii) certain vehicles established with certain of the Partnership’s limited partners that may co-invest with the Partnership (“Co- Investment Vehicles”). As of the date of this Brochure, Hale Capital does not manage any Co-Investment Vehicles, but has managed Co-Investment Vehicles in the past and may do so in the future. As such, Hale Capital includes references to Co-Investment Vehicles throughout this Brochure. Hale Capital generally invests and trades on behalf of clients primarily in equity securities, debt instruments and other obligations of companies (i) with market capitalizations typically less than $500 million, (ii) in the process of recovering from or experiencing operating downturns, financial difficulties

and/or adverse market conditions, and/or (iii) in other extraordinary situations including, but not limited to, debt restructurings, management reorganizations and product transitions. (See Item 8 “Methods of Analysis, Investment Strategies and Risk of Loss”) individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. Hale Capital does not tailor advisory services to investors in the Partnership or the Co-Investment Vehicles. (See Item 16 “Investment Discretion.”). Hale Capital, in its sole discretion, has in the past and may again in the future, (through the use of side letters or other agreements), modify certain of the offering terms for investors that are principals, employees or affiliates of Hale Capital and for certain large, strategic or other investors. services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Hale Capital does not participate in wrap fee programs. discretionary basis and the amount of client assets you manage on a non- discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2023, Hale Capital managed approximately $191,361,810 in regulatory assets on a discretionary basis. Hale Capital does not manage any assets on a non-discretionary basis.