New Harbor Capital New Harbor Capital Management, LP is a Delaware limited partnership and a registered investment adviser. New Harbor Capital Management, LP, New Harbor Capital Fund GP, LP; New Harbor Capital Fund II GP, LP; and New Harbor Capital Fund III GP, LP (each, a “General Partner” and, collectively, the “General Partners”), its affiliated general partner entities (together with New Harbor Capital Management, LP and their affiliated entities, “New Harbor Capital,” “NHC” or the “Advisers”), provide investment advisory services to investment funds privately offered to primarily qualified investors in the United States and elsewhere. New Harbor Capital Management, LP commenced operations in 2013. Each General Partner is subject to the Advisers Act pursuant to New Harbor Capital Management, LP’s registration in accordance with SEC guidance. This Brochure also describes the business practices of the General Partners, which operate as a single advisory business together with New Harbor Capital Management, LP. New Harbor Capital Management, LP’s clients include the following (each, a “Fund” and, together with any future private investment fund to which New Harbor Capital Management, LP or its affiliates provide investment advisory services, the “Funds”):
• New Harbor Capital Fund, LP
• New Harbor Capital Fund-A, LP
• New Harbor Capital Fund II, LP
• New Harbor Capital Fund II-A, LP
• New Harbor Capital Fund III, LP
• New Harbor Capital Fund III-A, LP
• New Harbor Associates, LLC The Funds are private equity funds that invest through negotiated transactions in operating entities, generally referred to herein as “portfolio companies.” Each General Partner serves as a general partner to the relevant Fund and has the contractual authority under the limited partnership agreement or other operating agreements or governing documents of the relevant Fund (each, a “Partnership Agreement”) to make investment decisions for, and to provide day-to-day advisory services to, such Fund. New Harbor Capital’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 for such investments. Although investments are made predominantly in non-public companies, investments in public companies are also permitted. From time to time, where such investments consist of portfolio companies, the senior principals or other personnel of New Harbor Capital or its affiliates generally serve on such portfolio companies’ respective boards of directors or otherwise act to influence control over management of portfolio companies in which the Funds have invested. New Harbor Capital’s advisory services to the Funds are detailed in the applicable

private placement memorandum or other offering documents (each, a “Memorandum”) and the Partnership Agreements and are further described below under “Methods of Analysis, Investment Strategies and Risk of Loss.” Investors in the Funds (generally referred to herein as “investors” or “limited partners”) participate in the overall investment program for the applicable Fund, but, if appropriate, expects to be excused from a particular investment due to legal, regulatory or other agreed-upon circumstances pursuant to the relevant Partnership Agreement. The Funds or the General Partners generally enter into side letters or other similar agreements (“Side Letters”) with certain investors that have the effect of establishing rights (including economic or other terms) under, or altering or supplementing the terms of, the relevant Partnership Agreement with respect to such investors. Additionally, from time to time and as permitted by the relevant Partnership Agreement, New Harbor Capital expects to provide (or agree to provide) certain investors or other persons, including New Harbor Capital’s personnel and/or certain other persons associated with New Harbor Capital and/or its affiliates (to the extent not prohibited by the applicable Partnership Agreement), co-investment opportunities (including the opportunity to participate in co- investment vehicles) that will invest in certain portfolio companies alongside a Fund. Such co- investments typically involve investment and disposal of interests in the applicable portfolio company at the same time and on substantially the same terms as the Fund making the investment. However, from time to time, for strategic and other reasons, a co-investor or co-investment vehicle can be utilized to purchase a portion of an investment from one or more Funds after such Funds have consummated their investment in the portfolio company (also known as a post-closing sell- down or transfer). Any such purchase from a Fund by a co-investor or co-investment vehicle generally occurs shortly after the Fund’s completion of the investment to avoid any changes in valuation of the investment, but in certain instances could be well after the Fund’s initial purchase. Where appropriate, and in New Harbor Capital’s sole discretion, New Harbor Capital is authorized to charge interest on the purchase to the co-investor or co-investment vehicle, and to seek reimbursement to the relevant Fund for related costs. However, to the extent such amounts are not so charged or reimbursed, they generally will be borne by the relevant Fund. As of December 31, 2023, New Harbor Capital managed approximately $901 million in client assets on a discretionary basis. New Harbor Capital is ultimately owned and controlled by Thomas J. Formolo and Ed Lhee, who are responsible for guiding the overall activities of New Harbor Capital.