Advisory Firm ACON Investments Management, LLC (“AIM”) and its relying adviser, ACON Southern Europe Management, L.L.C. (“ASEM” and collectively with AIM, “ACON” or the “Adviser”)1 are Washington, DC-based investment advisory firms 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. AIM was formed in 2008 and ASEM was formed in 2019. For purposes of this brochure, “we,” “us” and “our” refer to the Adviser and its investment advisory business. We provide investment advisory services to various pooled investment vehicles (each, an “ACON Investment Vehicle” or an “Investment Vehicle”) that target making investments in middle- market companies with the objective of achieving long-term appreciation for our investors.2 AIM owns ASEM, which was formed to manage one or more Southern Europe-focused Investment Vehicles. 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”). In addition, under a participating affiliate arrangement, ASEM uses the services of appropriate personnel of ACON Southern Europe Advisory, SL (“ASEA”) for identifying suitable investment opportunities, structuring acquisitions and dispositions and monitoring the performance of portfolio companies. ASEA is a sociedad limitada incorporated under the laws of Spain and is not subject to regulation by the SEC. 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. AIM and ASEM are limited liability companies organized under the laws of the State of Delaware. AIM and ASEM are each owned by Bernard Aronson, Kenneth Brotman and Jonathan Ginns.3 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 1 AIM and ASEM satisfy the requirements of filing an umbrella registration as set forth in Form ADV’s General Instructions. For purposes of this Brochure, and unless otherwise noted, AIM is the filing adviser and ASEM is the relying adviser. 2 AIM also manages two Investment Vehicles that feed into respective U.S.-focused private equity funds managed by ACON EQUITY MANAGEMENT, L.L.C. (“AEM”) (SEC File No. 801-74406), an affiliate of ACON. Please refer to AEM’s Form ADV, including without limitation the Part 2A Brochure filed by AEM, for a discussion of AEM’s business, fees, expenses, risks and other disclosures made to the investors in such feeder vehicles. 3 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. inception, ACON Investments has managed, or has had under management, approximately $7.0 billion in capital.4 In addition to its Southern Europe-focused business, the Firm operates two other businesses, one

that is focused on middle-market investing in the United States and the other focused on middle-market investing in Latin America.5 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 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 often invest (and often are required by investors to invest) in ACON Investment Vehicles, and as a result, their economic interests may be better aligned with those of the investors. To the extent allowed by law, arrangements among all members of AIM, ASEM, ASEA and the Firm (collectively, the “ACON Group”) and its employees may take a variety of forms, including but not limited to dual employee, delegation, participating affiliate, sub-agency or other servicing arrangements. Certain directors, executive officers, investment professionals and employees of one entity within the ACON Group may also serve as directors, executive officers, portfolio managers and employees of one or more other entities within the ACON Group. In these circumstances, the member of the ACON Group with which the client has its participating affiliate agreement will remain ultimately responsible for the account from a legal and contractual perspective. No additional fees are charged for the affiliate’s services except as set forth in the applicable agreement. Please see Item 10 (Other Financial Industry Activities and Affiliations) for additional details regarding the nature of the relationship amongst the members of the ACON Group. 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 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 limitation on certain fees; payment of reduced carried interest; economic or other incentives tied to the making of commitments to one or more other ACON Investment Vehicles, including future 4 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. 5 See Item 10 (Other Financial Industry Activities and Affiliations) for a list of the other ACON affiliated registered investment advisers. Investment Vehicles; and the provision of additional information, reports or access rights.6 The foregoing list is not exhaustive. We expect to enter into side letters with investors in future Investment Vehicles, the terms of which may be similar or different than those described above. As of December 31, 2023, ACON had approximately $256.8 million of client assets under management, all of which is managed on a discretionary basis.7