Inverness Graham Investments, Inc., a Pennsylvania corporation (“Inverness Graham, the “Firm” or “we”), is a Philadelphia based buyout firm that acquires innovative companies where technology is transforming traditional industry. Inverness Graham focuses on high-growth businesses leveraging technology in Healthcare, Software, and Advanced Manufacturing. In addition, the Firm also targets technology-enabled businesses where environmental sustainability is a key driver of accelerating growth. Inverness Graham was formed in 1996. Inverness Graham is wholly owned by Kenneth A. Graham, its Senior Managing Principal. We provide investment advisory services to pooled investment vehicles that are exempt from registration under the Investment Company Act of 1940, as amended, and whose securities are not registered under the Securities Act of 1933, as amended. As of December 31, 2023, we provide investment advice to Inverness Graham Investments II, L.P., Inverness Graham Investments III, L.P., Inverness Graham Investments III-A, L.P., Inverness Graham Investments III-B, L.P., Inverness Graham Investments III-C, L.P., Inverness Graham Investments IV, L.P., Inverness Graham Investments IV-A, L.P., Inverness Graham Investments IV-B, L.P., Inverness Graham Investments IV-C, L.P., IGI I Annex Fund, L.P., Datasource Co-Invest (IGI-II), L.P., Swipeclock Co-Invest (IGI III), L.P., GPS Co-Invest (IGI III), L.P., EiKO Co-Invest (IGI III), L.P., Investment Graham Investments V, L.P., Investment Graham Investments V-A, L.P., Investment Graham Investments V-B, L.P., Investment Graham Investments V-C, L.P., Innovia Co-Invest (IGI-IV), L.P., Inverness Graham Green Light Fund, L.P., Inverness Graham Green Light Fund A, L.P, Inverness Graham Green Light Fund B, L.P., and Inverness Graham Green Light Fund C, L.P (the “Green Light Fund”) and collectively, (the “Funds”).1 We may advise other funds in addition to those listed herein in the future. The Firm, or its affiliates, may also advise other funds and separate investment vehicles on bespoke investment strategies that include investment in new markets , potential “GP-led” secondary transactions, continuation vehicles, or other investment transactions, including co-investments made alongside unaffiliated investors such as family offices, independent sponsors, and private capital fund managers, or strategies that may include “GP stakes” and “GP seeding” transactions. As investment adviser for each Fund, Inverness Graham identifies investment opportunities and participates in the acquisition, management, monitoring, and disposition of investments for each Fund. Inverness Graham provides these investment advisory services to each Fund pursuant to separate investment advisory agreements (each an 1 With respect to certain of the Funds, Inverness Graham provides its services indirectly through wholly owned subsidiaries. "Advisory Agreement").2 The terms of the investment advisory services to be provided by Inverness Graham to a Fund, including any specific investment guidelines or restrictions, are set forth in such Fund's Advisory Agreement and/or in its Limited Partnership Agreement (collectively, the “Fund Documents”). We tailor our advisory services to the individual needs of each of the Funds, not to each underlying investor. Individual needs are identified

through a review of each Fund's overall investment guidelines and objectives, as well as specific investment goals. Inverness Graham has entered, and may in the future enter, into side letters or other similar arrangements with certain investors that have the effect of establishing rights under, supplementing, or altering a Fund’s partnership agreement or an investor’s subscription agreement. Such rights or alterations could be regarding economic terms, fee structures, excuse rights, information rights, co-investment rights (including the provision of priority allocation rights to limited partners who have capital commitments in excess of certain thresholds to one or more Funds), or transfer rights. For the most part, any right established, or any term altered or supplemented, will govern only the investment of the specific investor and not the terms of a Fund as a whole. Certain such additional rights, but not all rights, terms, or conditions, may be elected by certain investors with “most favored nation” rights pursuant to their own side letters. We do not participate in any wrap fee programs. As of December 31, 2023, our regulatory assets under management ("Regulatory AUM") totaled approximately $1,310,751,851. This Regulatory AUM figure represents the sum of the fair market value of the assets held by the Funds as of December 31, 2023, plus the aggregate amount of uncalled capital commitments to the Funds. We manage all of the assets in the Funds on a discretionary basis. We do not manage any assets on a non- discretionary basis. We intend to advise other investment entities that are forecasted to be formed after the date of the filing of this Form ADV. Such additional future investment entities may include and are not limited to, (i) new investment strategies, (ii) future co-investment vehicles (iii) entities formed in connection with the formation of a General Partner led transaction in which ownership of an investment from an existing Fund is sold to a newly created Special Purpose Vehicle (SPV), (iv) a “Strip Sale” transaction in which secondary investors contribute new capital to a Fund, which is utilized to execute a distribution to the Fund’s Limited Partners, (v) continuation vehicle transactions, and (vi) other types of transactions as secondary markets continue to evolve. Some of these future investments may include involvement with other members of the Graham Group alliance, as defined in Item 5. 2 With respect to certain of the Funds, Inverness Graham provides its services indirectly through wholly owned subsidiaries. As of December 2023, we manage two separate investment strategies. Since 2003, Inverness Graham has historically focused on its “Flagship Funds” investment strategy, in which it targets lower middle market businesses, primarily high growth, technology- enabled manufacturing and service companies. Our second investment strategy being pursued by the Green Light Fund, which was formed in March 2023, focuses on pursuing investments in lower middle market buyouts of businesses where environmental sustainability is a key driver of growth. One of our goals when investing in such companies is to help them achieve a reduced carbon footprint and/or protect and maximize natural resources as these companies serve both target and ancillary non-environmental end markets.