A. Advisory Business Grain Management, LLC, a Delaware limited liability company, is a registered investment adviser under the Advisers Act. The Advisor provides investment advisory services to Grain Communications Opportunity Fund II, L.P. (together with related investment vehicles “GCOF II”), Grain Communications Opportunity Fund III Master, L.P. (together with its parallel funds, feeder funds, related investment vehicles and any alternative investment vehicles, “GCOF III”), Grain Spectrum Holdings IV Master, L.P. (together with its parallel funds, feeder funds, related investment vehicles and alternative investment vehicles, “GSH IV”) and Grain Communications Opportunity Fund IV-A, L.P. (together with its parallel funds, feeder funds, related investment vehicles and any alternative investment vehicles, “GCOF IV”). GCOF IV is managed by GCOF IV Management, L.P., a relying advisor of Grain Management, LLC. GCOF II, GCOF III, GSH IV and GCOF IV (collectively the “Funds” or the “Clients”) are private pooled investment vehicles that, during their respective investment periods, focus on investments in direct acquisition of fiber-optic communications networks, radio frequency spectrum licenses, cell towers, ancillary systems, and other communications assets (collectively, “Communications Assets”), equity investments in companies that own or operate Communications Assets or that provide services to companies that own or operate Communications Assets, and investments in other securities that represent interests in Communications Assets (collectively, “Communications Companies”). Grain Management has also raised and manages other private vehicles, including Grain Infrastructure Fund II, L.P (together with its subsidiaries, collectively, “GIF II”) Grain Communications Opportunity Fund, L.P. (together with its subsidiaries, collectively, “GCOF”), and Grain Spectrum Holdings III, L.P. (together with its subsidiaries, feeders and related investment vehicles, “GSH III”). Grain previously managed two proprietary investment vehicles, Grain Spectrum Holdings, LLC (together with its subsidiaries, collectively, “GSH”) and Grain Spectrum Holdings II, LLC (together with its subsidiaries, collectively, “GSH II”) and the private vehicle, Grain Infrastructure Fund, L.P. (together with its subsidiaries, collectively “GIF”). GIF, GSH and GSH II have been fully liquidated and dissolved. Grain GP II, LLC, a Delaware limited liability company, is the general partner for GIF II, GCOF GP, LLC, a Delaware limited liability company, is the general partner for GCOF, and GSH III GP, LLC, a Delaware limited liability company, is the general partner for GSH III. GIF, GIF II, GCOF, GSH, GSH II, and GSH III (the “Other Investment Vehicles”) made or make investments primarily in hard assets such as communication towers or radio frequency spectrum licenses and related telecommunications infrastructure and systems. Given the nature of the investments made by the Other Investment Vehicles, Grain Management believes that the Other Investment Vehicles are not considered “clients” for the purposes of this Form ADV, and, therefore, the assets of the Other Investment Vehicles managed by Grain Management are not included in the calculation of Grain Management’s regulatory assets under management (“RAUM”). As of December 31, 2023, the remaining Other Investment Vehicles have in the aggregate invested $2.1 billion of capital and have an additional

$182.3 million in remaining capital commitments. The Other Investment Vehicles have returned a total of $810.5 million to the investors in such vehicles. Grain Management was formed by David Grain in 2010.1 David Grain is the Chief Executive Officer of Grain Management and owns 100% of Grain Management. The Advisor is led by David Grain and its Managing Directors: Chad Crank; Jenny Kashdan, Ted Manvitz; Michael McKenzie; Raghav Nayar; Ricardo Rodriguez; Nikola Trkulja; Kevin Naughton, Chief Capital Formation and Investor Relations Officer;; Doug Loveland; and Don Carey. Mr. Grain, Mr. Crank, Ms. Kashdan, Mr. Manvitz, Mr. McKenzie, Mr. Nayar, Mr. Rodriguez and Mr. Trkulja have significant experience in sourcing, evaluating, structuring, capitalizing, and negotiating acquisitions and divestitures in the communications industry. Each of the other Managing Directors have significant expertise in their respective operational areas. B. Types of Advisory Services Offered The Advisor provides investment advisory services for the Clients, each of which are privately offered investment vehicles that primarily focus on making private equity investments in Communications Assets. The services include advice regarding the selection of investments, recommending strategies for the management and disposition of investments, monitoring the performance of the investments, and preparing reports necessary or appropriate for compliance with the governing documents for each Client. Investments in the Funds are offered only to qualified investors, typically institutional investors and eligible high net worth individuals. Grain Management also provides certain back- and middle-office management services to the Funds pursuant to management agreements between Grain Management and the Funds. C. Services Tailored to Individual Needs of Clients The Advisor provides investment advice in accordance with the constituent documents and investment management agreements for each of the Funds. The constituent documents disclose the investment objectives, parameters and restrictions to investors in each Fund before they invest. The Funds have entered into side letters or other writings with specific investors in the Funds which alter or supplement the terms of the constitutional documents only for the specific investor to whom such letter or writing is addressed. Such side letters can impose restrictions on participation in certain investments or types of investments and certain other benefits that are only available to the specific investor. Side letters provide specific investors rights or altered or supplemented provisions regarding management fees, carried interest, distributions, co-investment, excuse or exclusion from investments, transfers of interests in the Funds, tax and structuring matters, reporting and information rights, confidentiality, notice requirements, compliance with specified laws or regulations and other representations, warranties or diligence confirmations. D. Wrap Fee Programs The Advisor does not participate in any wrap fee programs. E. Client Assets As of December 31, 2023, the Advisor had $6,268,301,103 in RAUM that it manages on a discretionary basis. 1 Prior to the formation of Grain Management, LLC, Mr. Grain conducted investment activities through Grain Communications Group, Inc., an operating company founded by Mr. Grain in 2007.