Overview of the Firm Private Capital Management, LLC (“PCM” or “we”), is a boutique investment and wealth advisory firm located in Naples, FL. PCM was founded in 1986 as an extension of a family office, and operated as Private Capital Management, L.P. until 2013, when it became wholly employee owned. Gregg J. Powers is PCM’s Lead Portfolio Manager for all PCM value equity strategies. PCM primarily manages separate accounts for institutional and high net worth clients. PCM also implements its value equity strategies through a number of pooled vehicles. PCM’s value equity investment strategies are grounded in a fundamental research, value based investment discipline that focuses on identifying companies whose equity securities trade at a valuation that in our view represents a significant discount to the company’s intrinsic value. Additional investment strategies and wealth advisory services offered by PCM are overseen by PCM investment professionals other than members of PCM’s value equity investment team. PCM generally operates under the trade name Private Capital Wealth or Harmonic Investors with respect to these strategies and services. Mr. Powers also serves as PCM’s CEO and is the controlling owner of PCM (indirectly) through Pelican Bay Holdings, LLC (“Pelican Bay Holdings”), a holding company that serves as general partner of Private Capital Management Holdings, L.P. (“PCM Holdings”), PCM’s controlling parent. In addition to Mr. Powers, seven senior PCM employees hold limited partnership interests in PCM Holdings (“Partners”). Pelican Bay Holdings also owns PCM’s broker-dealer affiliate, Carnes Capital Corp. (“Carnes”). PCM owns and controls three Special Purpose Vehicle (limited liability company) subsidiaries (each, an “SPV”). These SPVs serve as either the general partner or managing member of private investment funds offered to eligible clients. The oversight and management of the SPVs has been delegated to Partners other than Mr. Powers. See Item 4 — Special Purpose Vehicles. In addition to its main office, PCM maintains a research office in Miami, FL. Value Equity Strategies PCM’s value equity strategies invest primarily in publicly traded small-cap equity securities (stocks) that trade on North American (predominantly U.S.) exchanges. On occasion, these investments may include publicly traded limited partnerships. For certain clients (including most clients invested in our Value Focus Strategy and the private funds we manage), PCM has the ability to invest in a range of financial instruments or options, as well as non-equity securities such as corporate debt. PCM also has the ability to execute short sales for clients that have margin accounts and have permitted short selling. While the securities in which we invest typically trade on North American exchanges, those securities may be issued by companies that (i) are based or domiciled in, or have significant operations within, foreign countries or (ii) derive a significant portion of their revenues from outside North America. PCM generally considers a security domestic (i.e., non-foreign) so long as it maintains a U.S. or Canadian exchange listing or trades in the U.S. over-the-counter market, regardless of company domicile. Private Capital Management, LLC – Form ADV Part 2A Page 5 PCM manages two small-cap focused value equity strategies in which separate account clients may invest: PCM’s Value Focus Strategy and PCM’s somewhat less concentrated Value Equity Strategy. Both strategies are grounded in PCM’s bottom-up investment approach described in Item 8. Separate account clients who participate in PCM’s Value Equity Strategy are allowed to impose reasonable restrictions on their accounts, including limitations on investments in specific securities, industries, or sectors. Because of its more concentrated nature, a client’s ability to impose investment restrictions on a Value Focus Strategy account may be more limited. PCM may decline to accept a new value equity account, or may terminate an existing advisory relationship, if a client’s investment guidelines or restrictions significantly impair PCM’s ability to manage the portfolio in accordance with our investment discipline. PCM’s value equity strategies employ a single fundamental research, value based investment discipline. PCM’s value equity strategies are intended for individuals and institutions with a long- term investment horizon that have the capacity to bear market risk, including the risk of loss of invested capital. Wealth Advisory Services PCM provides wealth advisory

services to clients under the trade name Private Capital Wealth. PCM maintains continuous supervision of client wealth management assets invested in passive and active strategies or vehicles (primarily exchange-traded funds (“ETFs”) and mutual funds) that are not managed by PCM or an affiliate. In accordance with the delegation made by the client, PCM manages wealth management accounts either on a fully discretionary basis or through recommendations that are subject to client approval. The majority of Private Capital Wealth clients have elected to have PCM manage their accounts on a fully discretionary basis. In the case of non-discretionary wealth advisory services, the client retains investment discretion over their PCM account(s), meaning that PCM does not independently direct transactions for these wealth advisory client accounts. Wealth advisory clients may elect to provide PCM varying levels of investment discretion with respect to investing, rebalancing and reallocating assets held in their wealth advisory account(s). As a part of its wealth advisory services PCM utilizes PCM managed proprietary separate account strategies and funds, including the PCM Value Fund and Harmonic Investors private funds. PCM wealth advisory clients will pay two levels of management fees on assets allocated to strategies or vehicles managed by third parties. Unless otherwise agreed with the client, wealth advisory clients do not pay two levels of management fee on assets allocated to strategies or vehicles managed by PCM or its affiliates. Harmonic Investors Strategies Through its subsidiary Harmonic Investors LLC, PCM offers several private fund strategies to qualified investors that are designed to embrace varying levels of equity market risk. Harmonic Investors LLC is a multi-series limited liability company organized under Delaware law. Harmonic Investors private fund offerings include Harmonic Investors LLC Fund I (“Harmonic Fund I”), Harmonic Investors LLC Navigator Fund (“Harmonic Navigator”), Harmonic Investors LLC Hedged Partners Fund (“Harmonic Hedged Partners”) and Harmonic Investors LLC Opportunity Partners Fund (“Harmonic Opportunity Partners”). Other than Harmonic Opportunity Partners – which is overseen by PCM’s value equity investment team – Harmonic Investors Private Capital Management, LLC – Form ADV Part 2A Page 6 strategies are managed and overseen by PCM investment professionals who are not members of PCM’s value equity investment team. Wrap Fee Program and Individual Client Sub-Advisory Accounts PCM manages a number of accounts under a sub-advisory agreement with an unaffiliated investment adviser. This relationship is subject to a tiered fee structure. PCM does not assess the extent or value of services provided by any third-party adviser; generally, we do not have access to the information necessary to make such an assessment. Adviser and Sub-Adviser to Pooled Vehicles PCM acts as investment adviser to the Entrepreneurial Value Fund, L.P. (the “EVF”), and The Collier Fund, Ltd. (the “Collier Fund”) and one SEC registered mutual fund, the Private Capital Management Value Fund (the “PCM Value Fund”). Through Harmonic Investors Managing Member LLC (“Harmonic Managing Member”), PCM also serves as adviser to Harmonic Fund I, Harmonic Navigator, Harmonic Hedged Partners and Harmonic Opportunity Partners, which are also private funds. Harmonic Managing Member is a wholly owned subsidiary (SPV) of PCM. See Item 4 — PCM Special Purpose Vehicles. PCM also serves directly as the sub-adviser to Harmonic Fund I’s concentrated value equity strategy allocation. PCM Special Purpose Vehicles PCM owns and controls the general partners of the EVF and the Collier Fund (respectively, PCM Entrepreneurial GP, LLC and PCM Collier GP, LLC) as well as the managing member (Harmonic Managing Member LLC) of Harmonic Fund I, Harmonic Navigator, Harmonic Hedged Partners and Harmonic Opportunity Partners. Each of these Special Purpose Vehicles (each, an “SPV”) is managed by senior officers/Partners of PCM who are not members of PCM’s value equity strategies investment team. Any investment authority held by an SPV is exercised and controlled by PCM. Chad Atkins serves as an officer of each SPV while Jeffrey M. Fortier serves as an officer of Harmonic Managing Member. Chad Atkins also serves as PCM’s CCO and as a member of PCM’s Compliance Committee. Each SPV is subject to PCM’s compliance policies and oversight, as well as PCM’s Code of Ethics. Assets Under Management PCM managed approximately $1.1 billion in assets as of December 31, 2023.