General Description of the Advisory Firm Apogem Capital LLC (“Apogem” or “we”), a Delaware limited liability company, is an investment advisory firm founded in April 2020. Apogem is a wholly owned subsidiary of New York Life Insurance Company (“New York Life”) through New York Life Investment Management Holdings, LLC, a wholly owned subsidiary of New York Life. New York Life is a mutual life-insurance company and does not have shareholders. Description of Advisory Services Apogem provides investment management services to commingled and single investor private funds (each a “Fund”) and separately managed accounts (“Managed Accounts”, and together with Funds, “Clients”). Apogem generally offers the following strategies:
• Private equity, including limited partnership interests in private investment funds; equity co- investments in portfolio companies; real assets; and general partner stakes in management companies of private equity sponsors; and
• Private credit, including middle market senior loans and mezzanine debt, as well as equity investments in borrowers of Apogem’s private credit originated loans. The investment management services provided by Apogem are provided on either a discretionary or non- discretionary basis and are typically provided to Clients through single or multi-investor funds, direct investments, collateralized loan obligation vehicles, and/or Managed Accounts. Apogem serves as investment manager to Funds, and in many cases, Apogem or its affiliates serve as general partner to Funds organized in various jurisdictions and corporate structures, including as Delaware limited partnerships, Cayman Islands exempted limited partnerships, Jersey private companies incorporated with limited liability, and Canadian (Ontario) limited partnerships. We either enter into an investment management agreement (or

collateral management agreement) with each Client or the terms of our engagement are set forth in the operating agreements of our Funds. These investment management agreements, operating agreements, and other governing documents establish each Client’s investment strategy and the other terms, limitations and conditions of our engagement. Except as otherwise set forth in a multi-investor Fund’s offering documentation, side letter agreement, or investment management agreement, Apogem neither tailors its advisory services to the individual needs of multi-investor Fund investors nor accepts investor-imposed investment restrictions. In cases where Fund investors negotiate side letter agreements with the general partner of the Fund in which they are investing, such side letter agreements will likely impose significant additional limitations on our authority with respect to the Fund and the investors therein. For single-investor Funds and Managed Accounts, we manage each in accordance with its investment objectives, strategies, restrictions and guidelines, which are set forth in an investment management agreement with the Client or are otherwise incorporated into the Client’s governing documents. Single- investor Fund and Managed Account investment objectives, fee arrangements and terms are individually negotiated. Managed Account relationships are generally subject to account minimums. Regulatory Assets Under Management As of December 31, 2023, Apogem’s total regulatory assets under management (“RAUM”) was approximately $41,789,132,849 (discretionary RAUM $40,690,884,650, non-discretionary RAUM $1,098,248,199). Please see Apogem’s Form ADV Part 1A – Item 5.F at www.adviserinfo.sec.gov for more information.