ParkerGale, a Delaware limited liability company and a registered investment adviser, and its affiliated investment advisers provide investment advisory services to investment funds privately offered to qualified investors in the United States and elsewhere. ParkerGale is controlled by Devin Mathews, James Milbery, David Milligan and Corey Dossett (each, a “Partner,” and collectively, the “Partners”). ParkerGale commenced operations in April 2015. ParkerGale’s current clients are the following (each, a “Fund,” and together with any future private investment fund to which ParkerGale or its affiliates provide investment advisory services, the “Funds”):
• ParkerGale Capital, LP
• ParkerGale Capital II, LP
• ParkerGale Capital III, LP The following general partner entities (each, a “General Partner”, and collectively, together with any future affiliated general partner entities, the “General Partners”) are affiliated with ParkerGale:
• ParkerGale Management, LP
• ParkerGale Management II, LP
• ParkerGale Management III, LP Except where specified, references to an “Adviser” in this Brochure refer to any of the adviser entities (including the General Partners) described above, and references to the “ParkerGale” collectively refer to all Advisers, and their affiliated entities. Each General Partner is deemed registered and subject to the Advisers Act pursuant to ParkerGale’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 ParkerGale. The Funds are private equity funds and invest through negotiated transactions in operating entities, generally referred to herein as “portfolio companies.” ParkerGale’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. ParkerGale’s’s advisory services to the Funds are detailed in the applicable private placement memoranda or other offering documents (each, a “Memorandum”), limited partnership or other operating agreements or governing documents (each, a “Partnership Agreement” and, as applicable, together with any relevant Memorandum, the “Governing Documents”) and are further described below under “Methods of Analysis, Investment Strategies and Risk of Loss.” ParkerGale predominantly makes investments in non-public companies. However, investments in public companies are permitted under certain conditions. The Partners or other personnel of ParkerGale

or its affiliates generally serve on portfolio companies’ respective boards of directors or otherwise act to influence control over management of portfolio companies in which the Funds have invested. Investors in the Funds participate in the overall investment program for the applicable Fund, and may only 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 have entered into side letters or other similar agreements (“Side Letters”) with certain investors that have the effect of establishing rights under, or altering or supplementing the terms (including economic or other terms) of, the relevant Partnership Agreement with respect to such investors. Additionally, as permitted by the relevant Governing Documents, ParkerGale reserves the right to provide (or agree to provide) investment or co-investment opportunities (including the opportunity to participate in investment vehicles established for the purpose of making an investment into a specific, pre-determined investment (a “co-investment vehicle”) to certain current or prospective investors or other persons, including other sponsors, market participants, finders, consultants and other service providers, portfolio company management or personnel, ParkerGale personnel and/or certain other persons associated with ParkerGale and/or its affiliates. Such co-investments typically involve investment and disposal of interests in the applicable portfolio company at the same time and on the same terms as the Fund making the investment. However, for strategic and other reasons, a co-investor or co-investment vehicle may 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. Where appropriate, and in ParkerGale’s sole discretion, ParkerGale reserves the right to charge interest on the purchase to the co-investor or co-investment vehicle (or otherwise equitably adjust the purchase price under certain conditions) and to seek reimbursement to the Fund for related costs. However, to the extent any such amounts are not so charged or reimbursed (including charges or reimbursements required pursuant to applicable law), they generally will be borne by the Fund. As of December 31, 2023, the Firm managed $547,348,089 in client assets on a discretionary basis.