ACON EQUITY MANAGEMENT, L.L.C. (“ACON,” or the “Adviser”) is a Washington, DC-based investment advisory firm affiliated with ACON Investments, L.L.C. (“ACON Investments” or the “Firm”). ACON Investments is an international private equity fund management company originally founded in 1996 by Bernard Aronson, Kenneth Brotman and Jonathan Ginns. The Adviser was formed in 2011. For purposes of this brochure, “we,” “us” and “our” refer to the Adviser and its investment advisory business. We provide investment advisory services to a line of private equity funds (each, an “ACON Fund” or “Fund” and collectively, the “ACON Funds” or “Funds”) that target making investments in middle-market companies, principally in the United States, with the objective of achieving long- term appreciation for our investors. Our pooled investment vehicles (each, an “ACON Investment Vehicle” or an “Investment Vehicle”) seek to make investments in a range of industries, including without limitation, consumer retail, industrials and business services. Our investment strategy focuses on revenue growth and operational improvements as one of the primary tools to achieve value creation. Our investment mandate permits us to make equity and equity-linked debt investments and other opportunistic investments. We aim to invest primarily in companies in which we will have the right to control or exert significant influence over the portfolio company’s strategic planning, operations and development. Our advisory services include identifying, evaluating, structuring, recommending and negotiating investment acquisition and disposition opportunities; identifying sources of financing for proposed investments; supervising the negotiation, preparation and review of agreements and other documents in connection with investments, dispositions and financings; and ongoing monitoring and management of portfolio company investments. We provide these services directly or through affiliated special purpose general partner or manager entities established to manage ACON Investment Vehicles (collectively, “GPs/Managers”). ACON’s advisory services are not tailored to individual investors in our Investment Vehicles, but are provided in accordance with the investment strategies of such vehicles. One or more of our representatives typically serves as a member of the board of directors of the portfolio companies our Investment Vehicles acquire. In addition to the private equity fund platform we offer our investors, ACON and its affiliates (including other registered affiliated investment advisers of ACON) also offer investors in their Funds, prospective investors and third parties that are not Fund investors, opportunities to co- invest alongside the relevant Fund in ACON-identified investment opportunities, whether through an ACON-sponsored investment vehicle (a “Co-Invest Vehicle”) or directly into the underlying portfolio company. There is no guarantee that co-investment opportunities will always be available. These co-investments may be made on a discretionary basis or on a non-discretionary basis subject to certain defined parameters. In addition to the ACON Funds and Co-Invest Vehicles, ACON and its affiliates have, and may in the future, provide investment advisory services to various pooled investment vehicles that target making investments in a single asset or company, or a more limited number of assets or companies compared to our Funds, with the objective of achieving long-term appreciation for our investors (each, an “ACON Standalone Investment Vehicle” or “Standalone Investment Vehicle”). Such Standalone Investment Vehicle investments may be made on a discretion or non-discretionary basis subject to certain defined parameters. The Adviser is a limited liability company organized under the laws of the State of Delaware. The Adviser is owned by Bernard Aronson, Kenneth Brotman, Jonathan Ginns and Daniel Jinich.1 The Adviser is party to an arrangement with ACON Investments pursuant to which the Firm and/or its affiliates provide the services of various private equity fund investment, finance, accounting, tax, investor relations, legal, compliance and support professionals to the Adviser. Since the Firm’s inception, ACON Investments has managed, or has had under management, approximately $7.0 billion in capital.2 In addition to its U.S.-focused business, the Firm operates two other businesses, one that is focused on middle-market investing in Latin America and the other focused on middle- market investing in Southern Europe.3 In connection with the sponsorship and operation of the Funds (and under certain circumstances the Co-Invest

Vehicles and Standalone Investment Vehicles) and to the extent the circumstances require, the Adviser organizes various domestic and foreign feeder funds, parallel funds and alternative investment vehicles (and related blockers) (collectively, “Feeders, Parallel Funds and AIVs”). We organize these vehicles to accommodate particular tax, regulatory, or other needs as the circumstances may require. For avoidance of doubt, the term “Investment Vehicles” includes the ACON Funds, Co-Invest Vehicles, Feeders, Parallel Funds, AIVs and Standalone Investment Vehicles for which the Adviser provides advisory services. The relationship between ACON and each Investment Vehicle is governed by the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”), as well as the governing documents of each Investment Vehicle (each, an “Investment Agreement”; and, when specifically referring to a Fund, the “Fund Agreement”) and the terms of any investment advisory agreements concluded between ACON and each Investment Vehicle. Investments in the ACON Investment Vehicles are privately offered only to qualified investors that satisfy applicable eligibility and suitability requirements. ACON Investment Vehicles are not registered under the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”) and the limited partnership or other interests offered by such vehicles are not registered under the U.S. Securities Act of 1933, as amended (the “Securities Act”). Various ACON personnel (including without limitation employees of ACON affiliates and the named “Principals” of each Fund (hereinafter referred to as “Principals”) often invest (and often are required by investors to invest) in ACON Investment Vehicles (including Co-Invest Vehicles) and, as a result, their economic interests may be better aligned with those of the investors. In connection with the provision of advisory services to the Investment Vehicles, ACON or its GPs/Managers often enter into side letters or other writings (“side letters”) with investors, which have the effect of establishing rights under, or altering or supplementing the terms of, a vehicle’s Investment Agreement in respect of the investor to whom a side letter is addressed. Side letters 1 Please refer to Schedules A and B to ACON’s Part 1 of Form ADV for information regarding ACON’s beneficial owners and control persons. 2 Represents cumulative capital commitments in the Firm’s private equity platforms since ACON Investments’ inception in 1996 through March 31, 2024 and capital raised in listed vehicles sponsored by ACON. Excludes co-investment capital invited by ACON Investments to invest alongside, but not managed by, affiliates of ACON Investments. 3 See Item 10 (Other Financial Industry Activities and Affiliations) for a list of the other ACON affiliated registered investment advisers. provide the investor with economic, regulatory, and other terms that are more favorable than the terms offered to other investors. Side letter provisions cover a broad variety of topics. Examples of certain side letter provisions for the benefit of an investor include, without limitation: a waiver or reduction of management and/or other fees/allocations (including differences in application of fee offset provisions with respect to such investor); payment of reduced carried interest or carried interest that may be cross-collateralized across more than one ACON Investment Vehicle; economic or other incentives tied to the making of commitments to one or more other ACON Investment Vehicles, including future Funds; the provision of additional information, reports or access rights; rights related to specific regulatory requests of certain investors; more favorable transfer rights; the ability to opt-out of certain investments; withdrawal rights due to adverse tax, investor policy, regulatory or other events; consent rights to certain Investment Vehicle actions or Investment Agreement amendments; priority and/or other rights with respect to the review of co- investment opportunities (and the terms thereof); and rights to participate on a particular ACON Investment Vehicle’s advisory committee (also known as the limited partner committee). The foregoing list is not exhaustive. In addition, certain side letters with investors contain provisions that economically incentivize ACON to offer co-investment opportunities to such investors.4 We expect to enter into side letters with investors in future Funds and other Investment Vehicles, the terms of which may be similar or different than those described above. As of December 31, 2023, ACON had approximately $5.2805 billion of client assets under management, all of which is managed on a discretionary basis.5