The Adviser is a New York-based private equity management firm that provides investment advisory services to pooled investment vehicles which are exempt from registration under the Investment Company Act of 1940, as amended (“Clients”). The funds the Adviser manages presently are:
• HCP Fresh Investors LP, which closed on July 31, 2017 (“HCP Fresh”); HCP Fresh is the majority owner of a single underlying portfolio company;
• Harkness Capital Partners I LP, a pooled investment vehicle which had its initial closing on January 31, 2019 and its final closing on October 14, 2020 (“HCP I”); HCP I has made investments in three portfolio companies to date, one of which was sold on March 31, 2022, and a potential fourth platform investment remains pending;
• Harkness Cyclone Co-Investment LP, which closed on August 31, 2022 (“Cyclone Co-Invest”); Cyclone Co-Invest is a single purpose, co-investment vehicle formed in connection with an acquisition made principally by HCP I on August 31, 2022; and
• Harkness Capital Partners II LP, a pooled investment vehicle which had its initial closing on March 13, 2024 (“HCP II”), (each a “Fund” and collectively, the “Funds”). The Adviser was formed in 2014 and its majority owner is Edward V. Dardani, Jr. Harkness focuses on making investments in lower middle market service businesses, primarily operating in the United States. The Adviser provides advisory services with respect to equity investments in private companies operating in the following sectors: (1) transportation, logistics and distribution; (2) rental and equipment services; (3) infrastructure and industrial services; (4) facility and field services; and (5) other outsourced services. Interests in the Funds generally are privately offered to qualified limited partners and other qualified purchasers based largely in the United States, although the single largest investor in HCP I is based outside the United States. The Funds make direct equity investments into lower middle-market companies,

typically those with annual EBITDA ranging from $5 million to $20 million. The Adviser’s investment advisory services consist of identifying and evaluating investment opportunities, conducting rigorous due diligence on those opportunities, negotiating the terms of purchase and sale agreements and the ancillary agreements for the investments, and thereafter providing day-to-day managerial support services to its portfolio companies. All investments to date have been made in privately held companies. From time to time, the senior principals of the Adviser or other individuals chosen by the Adviser may serve on portfolio companies’ respective boards of directors or otherwise act to influence control over management of portfolio companies held by the Funds. The Adviser tailors its advisory services to the individual needs of each of its Clients based on the specific characteristics of such Client, including but not limited to the stage in the investment period of each Client, and any other restrictions set forth in the private placement memorandum, limited partnership agreement, investment advisory agreement and other governing documents of the applicable Fund (individually and collectively, “Governing Documents”). The limited partnership agreements for each of HCP I and HCP II prohibit investments in certain industries, including real estate, oil and gas production properties, gambling, alcoholic beverages and meat processing. The Adviser does not tailor its investment advisory services to the individual needs of investors in the Clients. The Adviser does not participate in wrap fee programs. The Adviser has approximately $299,357,000 in regulatory assets under management, $158,409,000 of which are managed on a discretionary basis (HCP I and HCP II) and $140,948,000 of which are managed on a non-discretionary basis (HCP Fresh and Cyclone Co-Invest). The foregoing dollar amounts reflect valuations as of December 31, 2023 for HCP Fresh, HCP I and Cyclone Co-Invest, and as of March 13, 2024 for HCP II, the date of its initial closing.