Spring Lake Equity Management LLC (“Spring Lake Equity Management”, “Us” or “We”) is a limited liability company primarily formed for the purpose of managing private equity funds. These funds invest in operating companies, generally companies whose equity securities are privately held. A Fund (as defined below) may temporarily invest cash in short-term instruments such as money market instruments, certain government securities or bank certificates of deposit. We began operations in July 2013. We are the non-discretionary adviser to several private equity funds managed by affiliated limited liability companies of which we are the managing member. At present, those funds are:
• Spring Lake Equity Partners LLC (“Spring Lake Equity Partners”)
• Spring Lake Equity Partners II LLC (“Spring Lake Equity Partners II”)
• Spring Lake/MM Co-Investment LLC (“Spring Lake/MM Co-Investment”)
• Spring Lake/MM Co-Investment III LLC (“Spring Lake/MM Co-Investment III”)
• Spring Lake Equity Partners III LLC (“Spring Lake Equity Partners III”)
• Spring Lake /WK Co-Investment LLC ("Spring Lake/WK Co-Investment”) We refer to these funds collectively as the “Spring Lake Funds” or “Clients” and individually as a “Fund” or “Client”. The co-investment Funds are each invested in a single operating company. We have entered into an amended and restated sub-advisory agreement with WestRiver Management, LLC (“WestRiver Management”), pursuant to which WestRiver Management provides investment advisory and related services, as requested, with respect to Spring Lake Equity Partners II. See Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” / “Certain Other Conflicts of Interest”). Affiliates that serve as managing members of the Spring Lake Funds are:
• Spring Lake Equity GP LLC (“Spring Lake Equity GP”) serves as managing member of Spring Lake Equity Partners.
• Spring Lake Equity II GP LLC (“Spring Lake Equity II GP”) serves as managing member of Spring Lake Equity Partners II.
• Spring Lake/MM Co-Investment GP LLC (“Spring Lake/MM Co-Investment GP”) serves as managing member of Spring Lake/MM Co-Investment.
• Spring Lake/MM Co-Investment III GP LLC (“Spring Lake/MM Co-Investment III GP”) serves as managing member of Spring Lake/MM Co-Investment III.
• Spring Lake Equity III GP LLC serves as managing member of Spring Lake Equity Partners III
• Spring Lake/WK Co-Investment GP LLC (“Spring Lake/WK Co-Investment GP”) serves as the managing member of Spring Lake/WK Co-Investment We refer to these entities collectively as the “Spring Lake Equity GP Entities.” We are the managing member of each of the Spring Lake Equity GP Entities, and, in our capacity, control each of them. Spring Lake Equity Management and each of the Spring Lake Equity GP Entities share office space and personnel. They have

a common Code of Ethics and Chief Compliance Officer. The Spring Lake Equity GP Entities, the Spring Lake Funds, and the Spring Lake Equity Management do business under the name “Spring Lake Equity Partners.” Our principal owners are Robert F. Forlenza (“Mr. Forlenza”) and Carmen J. Scarpa Jr. (“Mr. Scarpa”). WestRiver Management is also a direct minority owner of Spring Lake Equity Management. Our management services are tailored to the objectives of each Fund and reflect any restrictions set forth in a Fund’s governing documents or other written instructions. Spring Lake Equity Partners and Spring Lake Equity Partners II have certain large investors referred to as “Anchor Investors.” The Anchor Investors, either directly or through WestRiver Equity Partners, LLC (“WestRiver Equity”), a fund sponsored by WestRiver Management, have invested in Spring Lake Equity Partners and Spring Lake Equity Partners II, and one or more of the Anchor Investors has invested in each of Spring Lake/MM Co-Investment, Spring Lake/MM Co-Investment III and Spring Lake/WK Co-Investment either directly or through WestRiver Equity or an affiliate. Currently, each of the Spring Lake Equity GP Entities, other than the General Partners for Co- investment funds, has an advisory committee (as to each Fund, the “Advisory Committee” and as to the Funds, the “Advisory Committees”). The Spring Lake Equity GP Entities select the members of the respective Advisory Committees. The principal purpose of each Advisory Committee is to provide such advice and counsel to the Spring Lake Equity GP Entities as may be requested from time to time. Each of the Spring Lake Equity GP Entities expects to consult the pertinent Advisory Committee in the ordinary course on potential investments, although all decisions with respect to such investments remain vested in the Spring Lake Equity GP Entities. The responsibilities of the Advisory Committees are detailed in the Funds’ offering documents. Anchor Investors have entered into “side letters” with some of the Spring Lake Equity GP Entities that afford them certain rights, including, co-investment rights under certain circumstances and more favorable economic terms. Some other investors have entered into “side letters” with some of the Spring Lake Equity GP Entities that afford them more favorable economic terms. See Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” / “Certain Potential Conflicts.”) Spring Lake Equity Management provides nondiscretionary advisory services to the Spring Lake Equity GP Entities, but does not itself have regulatory assets under management, as defined by the Securities and Exchange Commission, because we do not act beyond providing our investment advice. Each of the Spring Lake Equity GP Entities has discretionary authority with respect to the Spring Lake Fund for which it serves as managing member.