Alcentra Limited is a private company limited by shares and incorporated in England and Wales. We are a subsidiary of Alcentra Asset Management Limited which, in turn, is an indirect, wholly owned subsidiary of Franklin Resources Inc. The Firm has been providing investment advisory services since July 2002. On November 1, 2022, Franklin Resources Inc. acquired Alcentra and became the sole owner of the Adviser. The acquisition has resulted in certain organizational and operational changes impacting the Adviser. The acquisition raises certain conflicts of interest between the Adviser and certain other advisory affiliates. Please see Item 11 and Item 12 below for information regarding how such conflicts of interest are generally addressed by the Adviser through implementation of related policies and procedures. We provide discretionary and non-discretionary investment advisory services to institutional clients in the form of separate accounts, pooled investment vehicles (private funds) that are exempt from registration in the United States, and to other investment advisers through sub-advisory agreements. Our US clients are subject to Securities and Exchange Commission (“SEC”) regulation. Our business is not limited to US clients and US operations but is also subject to foreign registration and regulation by the United Kingdom Financial Conduct Authority (“FCA”).
• We focus on the sub-investment grade debt capital markets. Our employees are primarily organized in the following teams: Credit Analysts, Finance, Risk and Compliance, Global Operations and Business Development. These teams support the European Liquid Loan, , Private Credit, Special Situations, Structured Credit and Multi Strategies of the Firm. See Item 8 below.
• Our clients are typically private funds but also include some separately managed accounts, whose investors include a variety of institutions (“Professional Clients”).

These funds include collateralized loan obligations (“CLOs”), private loan funds, and private credit. Alcentra also provides discretionary investment services to private funds with multi-credit strategies. These private funds will generally be divided into sleeves for each of the underlying strategies. Portfolio management for specific sleeves may be delegated from our affiliate, Alcentra NY, under a sub- advisory agreement. See Item 7 below.
• For our separately managed accounts, we offer investment advisory services tailored to meet clients’ individual investment goals. We work with clients to create investment guidelines mutually acceptable to the client and the Firm. When creating investment guidelines, clients may impose investment restrictions in certain individual securities or types of securities. Clients who impose investment restrictions might limit our ability to employ the strategy resulting in investment performance that differs from that of other client accounts.
• We also offer investment advisory services to private funds. Each private fund has an investment objective and a set of investment policies and/or guidelines that we must follow. For this reason, we cannot tailor the investment advisory services we provide to pooled investment vehicles to meet individual investor needs. In addition, we cannot impose individual investment restrictions on our investment strategies for underlying investors in the private funds.
• The Firm also shares internal research and other services with our affiliate Alcentra NY (“Alcentra NY”) through a service agreement. In addition, we serve as sub-adviser to several private funds which are advised by Alcentra NY through a separate sub-advisory agreement. See Item 10 below. Assets Under Management As of December 31, 2023, we manage approximately $20.4 billion on a discretionary basis and $206 million on a non-discretionary basis.