Advisory Business SPC Management Co., Inc. (the “Management Company” or “SPC”), a California S-corporation, is a private equity manager that invests in private companies in the consumer sector. Founded in 1996, SPC focuses on building and growing consumer businesses. SPC is operated by partners with a diverse combination of private equity, consulting, investment banking and operating experience. The Management Company provides discretionary investment advisory services to its clients, which consist of the following private investment-related funds: SPC Partners IV, L.P.; SPC Partners V, L.P., SPC Partners VI L.P.; SPC Partners VII L.P.; and Swander Pace Capital CT Fund I, L.P. In limited circumstances, as more fully described in Item 7 below, the Firm permits certain investors and third parties to co-invest alongside a Fund directly into a portfolio company (or its holding or blocker entity). Such direct co-investments are not considered Funds or clients of SPC. Each Fund is affiliated with a general partner (“General Partner”) with authority to make investment decisions on behalf of the Funds. The General Partners are deemed registered under the Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”), pursuant to SPC’s registration in accordance with SEC guidance. The applicable General Partner retains investment discretion and investors in the Funds do not participate in the control or management of the Funds. While the General Partners maintain ultimate authority over the respective Funds, SPC has been designated the role of investment adviser. For purposes of this Brochure, references to SPC shall include the General Partners, unless the context otherwise requires. For more information about the Funds and General Partners, please see SPC’s Form ADV Part 1, Schedule D, Section 7.A. and Section 7.B.(1). Advisory Services SPC provides investment advisory services as a private equity fund manager to its Funds. The Funds generally invest through negotiated transactions in operating companies, generally referred to herein as “portfolio companies”, in the consumer industry. Each portfolio company has its own independent management team responsible for managing its day-to-day operations, although (i) when a control investment, members of SPC or representatives appointed by the Firm are expected to serve on the boards of, or otherwise act to influence control of the management of, such portfolio companies and will therefore have a significant impact on the long-term direction of the company, including the selection of management team members and (ii) in some cases, SPC will more directly influence the day-to-day management of a portfolio company by recruiting and installing certain individuals in various leadership roles, such as

chief executive officer, chief operating officer, chief financial officer or in other roles. SPC’s investment advisory services to the Funds consist of identifying and evaluating investment opportunities, negotiating the terms of investments, managing and monitoring investments and achieving dispositions of such investments. Investments are made predominantly in non-public companies, although investments in public companies are permitted in certain instances. SPC’s investment advice and authority for each Fund is tailored to the investment objectives of that Fund; SPC does not tailor its advisory services to the individual needs of investors in its Funds. The Fund investment objectives are described in and governed by, as applicable, the private placement memorandum, limited partnership agreement, subscription agreements, investment advisory agreements, side letter agreements and other governing documents of the relevant Fund (collectively, “Governing Documents”) and investors determine the suitability of an investment in a Fund based on, among other things, the Governing Documents. The Firm does not seek nor require investor approval regarding each investment decision. Investors in the Funds participate in the overall investment program for the applicable Fund, but may be excused from a particular investment due to legal, regulatory or other applicable constraints. In accordance with industry common practice, the Funds or SPC have entered into side letters or similar agreements with certain investors that have the effect of establishing rights under, or altering or supplementing a Fund’s Governing Document, including by providing, among others, notification provisions, reporting requirements and “most favored nations” provisions, among others. These rights, benefits or privileges are not always made available to all investors, consistent with the Governing Documents and general market practice. Commencing in March 2025, SPC will make required disclosure of certain side letters to all investors (and in certain cases, to prospective investors) in accordance with the new Private Fund Rule. Side letters are negotiated at the time of the relevant investor’s capital commitment, and once invested in a Fund, investors generally cannot impose additional investment guidelines or restrictions on such Fund. There can be no assurance that the side letter rights granted to one or more investors will not in certain cases disadvantage other investors. Principal Ownership The Management Company is owned by Andrew Richards. Regulatory Assets Under Management As of December 31, 2023, SPC managed $1,165,086,284 in client assets on a discretionary basis. SPC does not manage any client assets on a non-discretionary basis.