Stellus Capital Management, LLC (“Stellus”), a Delaware limited liability company, is an investment advisory firm, which began operations on January 3, 2012. It is headquartered in Houston, Texas, with an office in Bethesda, Maryland and Charlotte, NC. There is one principal owner, Robert Ladd. As of December 31, 2023, Stellus had regulatory assets under management of $2,685,000,000 and did not advise any non-discretionary assets. Stellus provides investment strategies focused on direct credit investing by providing debt and equity capital to small and midsized businesses in all industry sectors throughout North America. The team provides capital solutions at all levels of the capital structure, including: • Secured Debt • First Lien Debt • Second Lien Debt • Mezzanine Debt • Unitranche Debt • Senior Unsecured Loans • Subordinated Debt • Equity Securities Stellus can provide capital solutions up to $100 million for public and private entities seeking capital for various purposes, including: • Acquisitions • Recapitalizations • Growth opportunities • Leveraged buyouts • Debtor-in-possession/exit financing • Bridge loans Stellus provides discretionary investment advisory and management services to Stellus Capital Investment Corporation (“SCIC”), a non-diversified, closed-end investment management company that has elected to be regulated as a business development company (“BDC”) under the Investment Company Act. In addition, Stellus primarily provides discretionary investment advisory and management services to private funds (individually, a “Private Fund” and together, the “Private Funds”).

The Private Funds are investment vehicles that are not registered or required to be registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”). The securities of the Private Funds are not registered or required to be registered under the Securities Act of 1933, as amended (“the Securities Act”) and are privately placed to accredited and qualified investors. All but one of the Private Funds have the same broader credit focus as the BDC and may invest across the capital stack (including junior capital) while a single Private Fund is primarily focused on unitranche and senior debt (the “Senior Credit Fund”) (collectively, the “Private Funds”). One of the private funds invests substantially all of its assets into Stellus Private Credit BDC, a business development corporation that is advised by an affiliated investment adviser as discussed in Item 10. SCIC, and the Private Funds will each be referred to herein as a “Client” and collectively, the “Clients”. It should be noted that Stellus or an affiliate has entered into side letters or other similar agreements with certain investors, and may do so again in the future, whereby such investors have been granted terms and conditions that are more favorable than other investors in the Private Funds, including but not limited to, lower fees and liquidity rights. Other investors may be offered the ability to co-invest alongside the Private Funds on more favorable terms than the Private Funds including lower or no fees and no obligation to bear broken-deal expenses. For a detailed discussion of side letters and other terms, Private Fund investors should refer to each Private Fund’s offering documents.