ARIEL ALTERNATIVES, LLC

About the Firm Ariel Alternatives, LLC (“Ariel Alternatives”), a Delaware limited liability company and registered investments adviser, is a private asset management enterprise offering a patient, focused and non-consensus approach to private equity. Ariel Alternatives and its affiliated investment advisers provide investment advisory services to investment funds privately offered to qualified investors in the United States and elsewhere. Ariel Alternatives commenced operations in February 2021 and is a wholly-owned subsidiary of Ariel Investments Holding Company, LLC (“Ariel Investments HoldCo”). Ariel Investments HoldCo is the holding company of entities affiliated with Ariel Investments, LLC, a U.S. registered investment adviser (“Ariel Investments”) founded in 1983. The controlling owners of Ariel Investments HoldCo are Ariel Investments Co-CEOs John W. Rogers and Mellody Hobson. Major business leaders from a variety of disciplines have come together to serve on Ariel Alternatives’ board of managers (the “Board of Managers”). The Board of Managers is responsible for overseeing the business and management of Ariel Alternatives and Ariel Alternatives provides compensation to the members of the Board of Managers in exchange for their service. Effective November 1, 2023, the Board of Managers was expanded to include additional members, all of whom had previously served as members of Ariel Alternatives’ board of advisers (the “Advisory Board”). The members of the Advisory Board, who together with the members of the Board of Managers, were sometimes and previously referred to as “accelerants,” and certain members of the Advisory Board historically provided advice and consultation to the Board of Managers and Ariel Alternatives. Effective October 31, 2023, the Advisory Board was dissolved in an effort to streamline the governance of Ariel Alternatives. Ariel Alternatives’ Advisory Services Ariel Alternatives’ clients include the following (each, a “Fund,” and collectively with any future private investment fund to which Ariel Alternatives and/or its affiliates provide investment advisory services, the “Funds”): •

Project Black, LP, a Delaware limited partnership;

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Project Black NUS, LP, a Delaware limited partnership (together with Project Black, LP, “Project Black Fund”);Project Black Coordinated Participation Fund, LP, a Delaware limited partnership (“Project Black CP Fund”); and

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Project Black Sparta II Inclusion Co-Investment, LLC, a Delaware limited liability company (“Project Black Sparta Fund;” and together with Project Black CP Fund, the “Co-Invest Vehicles;” and collectively with Project Black Fund and Project Black CP Fund, “Project Black”).

The following general partner or manager entities are affiliated with Ariel Alternatives (each, a “General Partner,” and collectively with any future general partners or managers that may be formed from time to time, the “General Partners”):

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Project Black GP, LP, a Delaware limited partnership;

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Project Black Coordinated Participation Fund GP, LP, a Delaware limited partnership; and

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Project Black Sparta II Inclusion Co-Investment Manager, LP, a Delaware limited partnership.

:Each General Partner is subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”) pursuant to Ariel Alternatives’ registration in accordance with SEC guidance, and any future relying advisers that may be formed from time to time (the “Relying Advisers,” and collectively with Ariel Alternatives and the General Partners, “Ariel Alternatives” or the “Firm”) will be registered under the Advisers Act pursuant to Ariel Alternatives’ registration. This Brochure also describes the business practices of the General Partners and the Relying Advisers, which collectively operate as a single advisory business together with Ariel Alternatives. The Funds are private equity funds and invest through negotiated transactions in operating entities, generally referred to herein as “portfolio companies.” Ariel Alternatives’ 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 permitted. From time to time, where such investments consist of portfolio companies, the senior principals or other personnel of Ariel Alternatives 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. Ariel Alternatives’ advisory services to the Funds are detailed in the relevant private placement memoranda or other offering documents (each, a “Memorandum”), investment management agreements, limited partnership or other operating agreements (each, a “Partnership Agreement” and, together with any relevant Memorandum, the “Governing Documents”) and are further described below under “Methods of Analysis, Investment Strategies and Risk of Loss.” Investors in the Funds participate in the overall investment program for the applicable Fund, but in certain circumstances are excused from a particular investment due to legal, regulatory or other agreedupon circumstances pursuant to the Governing Documents; for the avoidance of doubt, such arrangements generally do not and will not create an adviser-client relationship between Ariel Alternatives and any investor. The Funds or the General Partners are authorized to enter 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 Governing Documents with respect to such investors. Additionally, from time to time and as permitted by the Governing Documents, Ariel Alternatives expects to provide (or agree to provide) co-investment opportunities (including the opportunity to participate in co-invest vehicles) to certain current or prospective investors or other persons, including other sponsors, market participants, finders, consultants, including Operations Group members (as defined below), and other service providers, Ariel Alternatives’ personnel and/or certain other persons associated with Ariel Alternatives and/or its affiliates (e.g., a vehicle formed by Ariel Alternatives’ principals to co-invest alongside a particular Fund’s transactions). Such co2

investments typically involve investment and disposal of interests in the applicable portfolio company at the same time and on the same terms as the Funds making the investment. However, from time to time, for strategic and other reasons, a co-investor or co-invest vehicle (including a co-investing Fund) purchases 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 selldown or transfer), which generally will have been funded through Fund investor capital contributions and/or use of a Fund credit facility. Any such purchase from a Fund by a co-investor or co-invest vehicle generally occurs shortly after such Fund’s completion of the investment to avoid any changes in valuation of the investment. Where appropriate, and in Ariel Alternatives’ sole discretion, Ariel Alternatives reserves the right to charge interest on the purchase to the coinvestor or co-invest vehicle (or otherwise equitably to adjust the purchase price under certain conditions), 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. Regulatory Assets Under Management As of December 31, 2025, Ariel Alternatives managed $1,490,202,525, in client assets on a discretionary basis. Item 5 – Fees and Compensation

Fees and Expenses In general, Ariel Alternatives receives a management fee and the relevant General Partner receives a carried interest allocation in connection with the provision of services to its clients. Each Fund’s management fee and carried interest rates are specified in the Governing Documents. Generally, management fees are paid quarterly in advance, out of the assets of the Fund. Ariel Alternatives or its affiliates receive additional compensation in connection with management and other services performed for portfolio companies of the Funds and such additional compensation will offset in whole or in part the management fees otherwise payable to Ariel Alternatives to the extent provided by the Governing Documents. In addition, in certain circumstances, Ariel Alternatives receives compensation for management and other services performed in connection with coinvestments made in portfolio companies of the Funds. Investors in a Fund also bear their pro rata portion of the initial organization and offering expenses, as well as ongoing operating, administrative, and other expenses, of such fund. More information about a Fund’s expenses are contained in the Governing Documents. Other Compensation to Ariel Alternatives To the extent specified in a Fund’s Governing Documents, Ariel Alternatives or its affiliates may receive additional compensation in connection with management and other services performed for such Fund or its portfolio companies(e.g., monitoring fees, consulting fees, other similar fees paid by any portfolio company, closing fees,). Such additional compensation will offset in whole or in part the management fees otherwise payable to Ariel Alternatives to the extent provided by a Fund’s Governing Documents and only to the extent of the Fund’s relative ownership (or anticipated ownership) of such investment or potential investment on a fully diluted basis.

In addition, in certain circumstances, Ariel Alternatives is typically paid fees of the type referred to in the preceding paragraph from, on behalf of or with respect to co-investors in an investment, as well as other fees relating to the structuring and administration of co-investment arrangements. The receipt of such fees will not reduce the Management Fee payable by Project Black Fund or any other investment vehicles or accounts managed by Ariel Alternatives that have also invested in such investment, and as a result Project Black Fund will, in most cases, only benefit with respect to the relevant allocable portion on a fully diluted basis of any such fee and not the portion of any fee that relates to such co-investors or potential co-investors (which could include co-investment vehicles managed by Ariel Alternatives, third parties, portfolio company management or employees and/or others), which have the potential to be significant. Additionally, as further described below and in the Governing Documents, it is Ariel Alternatives’ practice to use or retain certain members of the Operations Group (as defined below) to provide services to (or with respect to) certain portfolio companies in which one or more Funds invest. The Operations Group generally receives compensation and other amounts described herein from the relevant portfolio companies or Funds to which they provide services, but no such amounts will offset or reduce the Management Fee. For the avoidance of doubt, Ariel Alternatives also will not offset compensation received from outside sources, such as residual employee board seats at entities that are no longer Fund portfolio companies. The Governing Documents generally permit Ariel Alternatives to waive or agree to reduce the Management Fee. Certain waived portions of the Management Fee are treated by the Governing Documents as a deemed capital contribution by the relevant General Partner, which is effectively invested in the relevant Fund on such General Partner’s behalf, and operates to reduce the amount of capital such General Partner would otherwise be required to contribute to the Fund. The limited partners of the relevant Fund would, in such circumstances, be required to make a pro rata contribution according to their respective Commitments to fund any contribution that would otherwise be required of the relevant General Partner in connection with any such waiver or reduction as described above and, as a result, the exercise of such waiver often will result in an acceleration (or delay) of investor capital contributions. Waived or reduced Management Fees are not subject to the Management Fee offsets described above, and the amount of such waived or reduced Management Fees has the potential to be significant. Due to waived or reduced Management Fees by Ariel Alternatives and/or timing of receipt of compensation subject to offsets (as described above), it is possible that Management Fee offsets will be delayed. In certain circumstances, it is possible that one Fund will pay an expense or obligation common to multiple Funds and/or co-investors (including, without limitation, legal expenses for a transaction in which all such Funds and/or co-investors participate, or other fees or expenses in connection with services the benefit of which are received by other Funds and/or co-investors over time), and be reimbursed by the other Funds by their share of such expenses or obligations, without interest. To the extent a paying Fund makes use of a credit facility to pay such expense, it generally will not be reimbursed separately by other Funds for use of the facility. While Ariel Alternatives believes such circumstances to be highly unlikely, it is possible that one of the other Funds could default on its obligation to reimburse the paying Fund. In certain circumstances, Ariel Alternatives, the relevant General Partner or an affiliate thereof is expected to advance amounts related to the foregoing and receive reimbursement from the Funds, without interest, to which such expenses relate.

As described above, in certain circumstances, the relevant General Partner is expected to permit certain investors to co-invest in portfolio companies alongside one or more Funds, subject to Ariel Alternatives’ related policies and practices and the Governing Documents and/or Side Letter(s). Where a co-invest vehicle is formed, such entity generally will bear expenses related to its formation and operation, many of which are similar in nature to those borne by the Funds. It is expected that representatives of the Co-Invest Vehicles and JPM will from time to time be invited to and attend meetings of the Limited Partners related to Project Black Fund matters and, in such cases, Ariel Alternatives intends to cause the attending co-investors to bear their pro rata share of the expenses related to such meetings (based on aggregate capital commitments) as a condition to attendance. In the event that a transaction in which a co-investment was planned, including a transaction for which a co-investment was believed necessary in order to consummate such transaction or would otherwise be beneficial, in the judgment of the General Partner, ultimately is not consummated, the full amount of any fees and expenses generated in the course of evaluating any such proposed transaction generally would be borne by the Fund, and not by any potential co-investors, that were to have participated in such transaction. To the extent that such co-investors have already invested in a co-investment or other vehicle in connection with such transaction, such vehicle is expected to bear its share of such broken deal expenses where permitted by such vehicle’s Governing Documents. To the extent a Fund makes use of a credit facility to invest in a portfolio company or pay related expenses, it generally will not be reimbursed separately by co-investors for use of the facility. Ariel Alternatives and/or its affiliates generally have discretion over whether to charge Supplemental Fees to a portfolio company and, if so, the rate, timing, method and/or amount of such compensation, as well as to charge such amounts at varying levels in a portfolio company’s holding or operating structure. In most circumstances, such compensation is not reviewed or approved by an independent third party. The receipt of Supplemental Fees generally will give rise to potential conflicts of interest between the Funds, on the one hand, and Ariel Alternatives and/or its affiliates on the other hand. Ariel Alternatives is permitted to exempt certain “affiliated partner” investors in the Funds from payment of all or a portion of Management Fees and/or carried interest, including Ariel Alternatives and any other person designated by Ariel Alternatives, such as “friends and family” of Ariel Alternatives or its personnel, or other investors meeting certain qualification requirements based on commitment size or other strategic or relationship factors. The General Partner reserves the right to make any such exemption from fees and/or carried interest by a direct exemption, a rebate by Ariel Alternatives and/or its affiliates, or through other Funds which co-invest with a Fund. For example, in instances where an Ariel Alternatives professional (or an affiliated entity thereof) invests in a Fund, such professional (or such affiliated entity) generally will be exempt from payment of the Management Fee and carried interest with respect to such Fund. Additionally, to the extent permitted by the Governing Documents, certain Firm entities have the right to permit investors, affiliated with Ariel Alternatives or otherwise, to invest through the relevant General Partner or other vehicles that do not bear Management Fees and/or carried interest. In general, the Management Fee offsets described above apply only with respect to the capital commitments of fee-paying investors. Ariel Alternatives retains flexibility to structure its compensation from investors and expects in certain circumstances to agree to invoice an investor directly for

Management Fees or other compensation, rather than deducting such amounts from the investor’s capital account(s). Operations Group Additionally, as further described herein and in the Governing Documents, it is Ariel Alternatives’ practice to employ, use or retain an operations group (the “Operations Group”), typically comprised of (i) certain employees of Ariel Alternatives, (ii) persons that are employees of an affiliate of Ariel Alternatives and/or (iii) independent contractors, in each case (including entities formed for the benefit of such persons and/or to facilitate the provision of their services), to provide services to (or with respect to) one or more Funds or certain current or prospective portfolio companies in which one or more Funds invest. The Operations Group generally provides services in relation to the manufacturing, sales, marketing, finance, tax, technology, operations, financing, legal, consulting, real estate/facilities management, human resources, acquisition integration/rationalization and/or other operations services, acquisition or other due diligence, or similar services. In certain circumstances, these services also include serving in management or policy-making positions for portfolio companies. The Operations Group receives compensation, including, but not limited to cash fees, retainers, discretionary bonuses (whether or not based on pre-determined milestones), transaction fees, a profits, participation or equity interest in a portfolio company or holding company, incentive equity and stock awards, profits or equity interests in one or more Funds or General Partners, remuneration from Ariel Alternatives and/or its Funds or affiliates, guaranteed minimums or other compensation, the amount of which typically is determined according to one or more methods, including the value of the time (including an allocation for overhead and other fixed costs) of the Operations Group, a percentage of the value of the portfolio company, the invested capital exposed to such portfolio company, amounts believed to be charged by other providers for comparable services and/or a percentage of cash flows from such portfolio company. Compensation in the form of profits or equity interests in a portfolio company or intermediate holding company generally has a dilutive impact on the Fund’s investment, and the relevant Fund typically will bear the costs of the Operations Group’s compensation, as well as fees, costs and expenses of structuring Operations Group arrangements. The Operations Group will also generally be reimbursed for certain travel and other costs in connection with their services. As described above, no such amounts will offset or reduce the Management Fee. As described above, members of the Board of Managers are permitted to be designated as members of the Operations Group. While all compensation or expenses associated with the Board of Managers is borne by Ariel Alternatives, such persons are permitted to receive additional compensation or remuneration from the Fund, the Co-Invest Vehicles and/or their respective affiliates and/or portfolio companies (including in the form of cash fees, retainers, transaction fees, guaranteed minimums, profits or equity interests and incentive equity or other stock awards as well as reimbursement for related overhead and/or out-of-pocket expenses paid to Ariel Alternatives, the Project Black Fund and the Co-Invest Vehicles) in their capacities as members of the Operations Group. Any such compensation or remuneration does not offset or otherwise reduce the Management Fee. To be clear, all compensation or expenses related to or associated with ay person’s role as a member of the Board of Managers is borne by Ariel Alternatives.

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General Ariel Alternatives is a private asset management enterprise offering a patient, focused and nonconsensus approach to private equity. Ariel Alternatives’ first strategy, Project Black, is a longdated, closed-end fund that invests in middle-market companies. Both Ariel Alternatives and the Project Black Fund are certified as minority-owned business enterprises (“MBEs”). Ariel Alternatives may seek MBE certification for the Project Black portfolio companies based on the Fund’s ownership. Through Project Black, Ariel Alternatives seeks to scale sustainable businesses to serve as leading suppliers to Fortune 500 companies. Investment and Operating Strategy Deal Sourcing and Due Diligence. Ariel Alternatives seeks to source deals through its network of corporate executives, principals, leading institutional limited partners, and other industry relationships across the targets industries in which it expects to invest. Once a potential investment

is identified, Ariel Alternatives will examine historical and projected financial performance, review the product and service capabilities, and study in-depth company fundamentals, with the goal of gathering a large quantum of information from a variety of resources to better understand relevant issues, risks and opportunities. As part of its diligence process, Ariel Alternatives, members of its Operations Group, and its third-party consultants, will meet with management teams and complete a detailed analysis of an industry, which may include interviews with competitors, customers and suppliers, and other industry experts. Develop Restructuring and Operating Plan. One or more of Ariel Alternatives’ principals and their associates, including operating staff of Ariel Alternatives and its affiliates, intend to develop a 100day business plan prior to the close of each transaction identifying short- and long-term priorities informed by the target’s strengths, weaknesses, competitive position, industry trends, operating, financial and impact metrics, and other relevant factors. Empower Management Team. Ariel Alternatives works with existing management team to identify opportunities to augment leadership capabilities. Where gaps are identified and additional talent is needed, Ariel Alternatives leverages its deep network of highly skilled and experienced executives to ensure strong company governance and enhance the C-Suite. In certain instances, operating professionals of Ariel Alternatives or its affiliates are expected to serve in significant management roles at portfolio companies (including chief executive officer or chief financial officer) on an interim basis immediately following closing until a professional management team can be assembled. Active Engagement with Portfolio Companies. Ariel Alternatives aims to assist with developing metrics, systems and analyses that drive operational and strategic decisions. Ariel Alternatives will serve as a resource to portfolio company management teams and typically serve as active members of the portfolio company’s board of directors. Ariel Alternatives also expects to, among other things, encourage management to pursue internal and external growth initiatives, implement operational initiatives to capture efficiencies, enhance productivity and manage costs, align compensation and equity incentives with clear goals to build long-term value, elevate business diversity and engage new and existing corporate relationships to satisfy constrained demand for minority suppliers. Internal Growth and Add-on Acquisitions. Once the above strategies have been implemented, Ariel Alternatives will seek to develop a five-year business plan in coordination with portfolio company management teams and, where needed, Ariel Alternatives’ operating executives. The five-year plan is expected to set forth financial and business objectives designed to maximize long-term growth, integrate impact imperatives with financial goals, and build relationships with Fortune 500 companies and other companies of comparable scale. Exit Strategy. Once a portfolio company has met its growth objectives, Ariel Alternatives will seek to optimize the long-term value of such portfolio company by seeking strategic exits via initial public offerings or strategic sales or mergers. Factors considered include the company size, company growth rate, industry and competitive dynamics, and capital market conditions.

Risks of Investment Each Fund and its investors bear the risk of loss that Ariel Alternatives’ investment strategy entails. The risks involved with Ariel Alternatives’ investment strategy and an investment in a Fund include, but are not limited to: Investment Risks Business Risks. The Fund’s investment portfolio is expected to consist primarily of securities issued by privately held companies, and operating results in a specified period will be difficult to predict. Such investments involve a high degree of business and financial risk that can result in substantial losses. Ariel Alternatives and the Fund are also subject to the general business risk that one or more of their counterparties defaults on its obligations which could impact Ariel Alternatives or the Fund’s contractual agreements. This may impact Ariel Alternatives’ clients or Fund investors. Future and Past Performance; Loss of Principal. The Fund is a newly organized entity that has no prior operating history or track record. Accordingly, the Fund does not have performance history for a prospective investor to consider. In considering the prior performance information of any other investments in which Ariel Alternatives’ affiliates participated in, prospective investors should understand that an investment in the Fund does not represent an interest in such investment or investment portfolio. Information about the prior performance of such investments is not necessarily indicative, or a guarantee, of the Fund’s future results, and there can be no assurance that the Fund will achieve comparable results. An investor should not rely on any expectation and there can be no assurance that the risk/return profile of an investment in the Fund will resemble that of prior investments in which Ariel Alternatives’ affiliates participated. An investor should only invest in the Fund as part of an overall investment strategy, and only if the investor is able to withstand a total loss of its investment in the Fund. While the General Partner intends for the Fund to make investments that have estimated returns commensurate with the risks undertaken, there can be no assurances that any targeted internal rate of return will be achieved. On any given investment, loss of principal is possible. Investment in Junior Securities. The securities in which the Fund will invest may be among the most junior in a portfolio company’s capital structure and, thus, subject to the greatest risk of loss. Generally, there will be no collateral to protect the Fund’s investment once made. Concentration of Investments; Lack of Diversification. The Fund is expected to invest in a limited number of portfolio companies and may seek to make several investments in a single industry or industry segment, in a limited geographic area and/or within a short period of time, which could create conditions for a portfolio of investments that exhibit a very high degree of correlated returns. As a result, the Fund’s investment portfolio could become highly concentrated, and the performance of a few holdings or of a particular industry may substantially affect its aggregate return. Furthermore, since the Fund expects to invest in a limited number of portfolio companies, the impact that losses on any one investment could have on the Fund’s overall portfolio could be significant. To the extent that the capital raised is less than the targeted amount, the Fund may invest in even fewer portfolio companies and thus be less diversified.

The Fund is permitted to provide bridge financing to facilitate portfolio company investments. It is possible that all or a portion of a bridge financing will not be recouped within the time period specified in the Governing Documents, in which case the investment would be treated as a permanent investment of the Fund. As a result, the Fund’s portfolio could become more concentrated with respect to such investment than initially expected or otherwise provided for under the investment limitations set forth in the Governing Documents. Unspecified Investments. Limited Partners will be relying on the ability of the General Partner to locate and evaluate the investments to be made by the Fund using the proceeds of the Fund’s offering. The activity of identifying, structuring, completing and realizing private equity investments involves a high degree of uncertainty and is subject in some cases to the prevailing capital market, regulatory and political environment. There can be no assurance that the General Partner will be able to identify, or the Fund will be able to complete, portfolio investments that satisfy the Fund’s rate of return objectives or, if completed, realize such investments for fair or attractive values or that the Fund will be able fully to invest its committed capital. Lack of Sufficient Investment Opportunities. The business of identifying, structuring and completing private equity transactions is highly competitive. The Fund will encounter competition from other entities having similar investment objectives. Potential competitors include other investment partnerships and corporations, strategic industry acquirers and other financial investors, including other private equity funds, investing directly or through affiliates. Over the past several years, an ever-increasing number of investment funds have been or are being formed, and many fund sponsors have increased the size of successor funds as compared to their corresponding prior funds. Other investment funds with similar investment objectives to the Fund may be formed in the future by other unrelated parties. Some of these competitors may have more relevant experience, greater financial resources, a greater willingness to take on risk, and/or more personnel than the General Partner, the Fund and their respective affiliates. To the extent that the Fund encounters significant competition for investments, returns to limited partners may decrease. In addition, it is possible that the Fund will never be fully invested if enough sufficiently attractive investments are not identified and consummated. Regardless of the extent to which the Commitments of the limited partners are invested, the limited partners will be required to bear Management Fees through the Fund during the commitment period based on the entire amount of the limited partners’ Commitments and other expenses as set forth in the Governing Documents. Dynamic Investment Strategy. While the General Partner generally intends to seek attractive returns for the Fund primarily through making private equity investments as described herein, the General Partner is permitted to pursue additional investment strategies and may modify or depart from its initial investment strategy, investment process and investment techniques as it determines appropriate. The General Partner is permitted to pursue investments outside of the industries and sectors in which the principals have previously made investments or have internal operational experience. Impact of Government Regulation, Reimbursement and Reform. Certain industry segments in which the Fund invests, including various segments of the healthcare, industrial, media and marketing, outsourcing, manufacturing, and packaging, technology, transportation and logistics,

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Ariel Alternatives provides investment advice solely to its Fund clients, and references throughout this Brochure to “clients” and to Ariel Alternatives’ related duties to and practices on behalf of its clients and/or investors should be construed accordingly. The Funds generally include investment partnerships or other investment entities formed under domestic or foreign laws and operated as exempt investment pools under the Investment Company Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Investment Company Act”). The investors participating in the Funds generally include, but are not limited to, individuals, banks or thrift institutions, other investment entities, university endowments, sovereign wealth funds, family offices, trusts, estates or charitable organizations or other corporations or business entities and from time to time include, directly or indirectly, principals or other employees of Ariel Alternatives and its affiliates and members of their families, the Operations Group or other service providers retained by Ariel Alternatives, as well as executives of portfolio companies. The relevant General Partner also generally is permitted from time to time to establish Funds that are alternative investment vehicles in order to permit certain investors to participate in one or more particular investment opportunities in a manner desirable for tax, regulatory or other reasons. Alternative investment vehicle sponsors generally have limited discretion to invest the assets of these vehicles independent of limitations or other procedures set forth in the organizational documents of such vehicles and the Governing Documents related Fund. Project Black generally has a minimum investment amount of $100 million for third-party investors, and Fund interests are offered and sold solely to persons that are (i) “accredited investors,” as that term is defined in Regulation D promulgated under the U.S. Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder (the “Securities Act”), (ii) “qualified clients,” as that term is defined under the Advisers Act and (iii) unless waived in the discretion of Ariel Alternatives, “qualified purchasers,” as that term is defined under the Investment Company Act. Ariel Alternatives generally is permitted to waive such minimum investment amount.

As described under “Fees and Compensation,” the relevant General Partner generally receives a carried interest allocation on certain realized profits in the relevant Fund. The existence of performance-based compensation has the potential to create an incentive for a General Partner to make more speculative investments on behalf of a Fund than it would otherwise make in the absence of such arrangement, although Ariel Alternatives generally considers performance-based compensation to better align its interests with those of its investors, particularly in instances where the Governing Documents include terms requiring clawback or giveback of performance-based compensation amounts at the end of the relevant Fund’s life or at certain interim intervals.

Ariel Alternatives Entities Ariel Alternatives is affiliated with other Ariel Alternatives investment advisers, including the General Partners and equivalent entities formed from time to time and subject to the Advisers Act pursuant to Ariel Alternatives’ registration in accordance with SEC guidance. These entities operate as a single advisory business together with Ariel Alternatives and serve as managers or general partners of Funds and other pooled vehicles and generally share common owners, officers, partners, employees, consultants, or persons occupying similar positions. Ariel Investments, LLC Ariel Alternatives is also affiliated with Ariel Investments, an investment adviser registered with the SEC. Ariel Investments is a money management firm managing various investment strategies for registered investment companies (including Ariel Investment Trust), pooled private investment vehicle, and managed account clients for institutional investors. Ariel Alternatives and Ariel Investments have entered into a shared services agreement wherein Ariel Investments has agreed to provide certain personnel, space, equipment, telephones and all other goods, services and other things required by Ariel Alternatives. Specifically, personnel from Ariel Investments’ legal, compliance, finance, human resources, technology, operations, marketing, and institutional client & investor relations departments provide services to Ariel Investments, Ariel Alternatives, Project Level Management Company, and their affiliates.

Ariel Distributors, LLC Ariel Distributors, LLC (“Ariel Distributors”), a broker-dealer registered with the Financial Industry Regulatory Authority, Inc. and a member of the Securities Investor Protection Corporation, is a wholly-owned subsidiary of Ariel Investments HoldCo and an affiliate of Ariel Alternatives. Ariel Distributors acts as placement agent for the Funds. Some of Ariel Distributors registered representatives receive incentive compensation from Ariel Distributors that is based on their institutional business development efforts to increase the assets managed by Ariel Alternatives. These supervised persons are salespersons and/or institutional business development personnel (not management persons of Ariel Alternatives). Some incentive compensation is calculated using a mathematical formula. Other compensation is not formulaic; rather, it is a factor that is considered as part of a comprehensive qualitative review. Ariel Distributors’ registered representatives do not sell non-Ariel investment products or services. Ariel Distributors’ registered representatives have a conflict of interest because they have an incentive to sell the products or services of Ariel Alternatives and/or those of its affiliates based on their own anticipated compensation rather than those of Ariel Alternatives client and/or Fund investors. Ariel Alternatives addresses the conflict through disclosure in this brochure. Project Level Management Company, LLC Project Level Management Company, LLC (“Project Level Management”) is a U.S. registered investment adviser that provide investment advisory services solely to private funds offered to U.S. and non-U.S. qualified investors. Ariel Investments and Project Level Management have entered into a shared services agreement wherein Ariel Investments has agreed to provide certain personnel, space, equipment, telephones and all other goods, services and other things required by Project Level Management. Specifically, personnel from Ariel Investments’ legal, compliance, finance, human resources, technology, operations, marketing, and institutional client & investor relations departments provide services to Ariel Investments, Project Level Management, and their affiliates.

Code of Ethics Ariel Alternatives, Ariel Investments, Ariel Investment Trust, and Project Level Management (together, “Ariel” or the “Ariel entities”) have adopted a combined Code of Ethics (the “Code”), which states that our primary mission is to place the interests of our clients first. The Code describes the Ariel entities’ policies and procedures pertaining to personal securities transactions, insider trading, giving and accepting gifts and entertainment, and outside business activities. The proprietary investing of the Ariel entities is subject to all sections of the Code pertaining to their respective investments in securities. Personal securities transactions of all Ariel entities’ employees are subject to compliance with the Code. Generally, the Code prohibits the Ariel entities and their employees from buying or selling securities owned in the portfolios of the clients of the Ariel entities or securities being considered

for purchase or sale for Ariel entities’ clients. Also, Ariel Alternatives’ employees (including employees that also are employees of Ariel Investments) cannot buy or sell securities held by any Ariel Alternatives client or securities being considered for purchase by or for any Ariel Alternatives client. The Ariel entities and their employees may buy and sell shares of Ariel Investment Trust-advised mutual funds and other non-proprietary open-end mutual funds to which the Ariel entities provide investment management services, subject to the Code’s requirements. Ariel Alternatives Chief Compliance Officer may grant exceptions for Ariel Alternatives or its employees’ purchase or sale of securities owned in clients’ portfolios or being considered for purchase or sale for clients. One such exception is a de minimis exception applicable to the sale of securities owned in clients’ portfolios or being considered for purchase or sale for clients. Another exception is to allow an Ariel entity’s supervised person’s spouse to operate an investment firm, subject to various undertakings and conditions. In general, the Ariel entities’ employees also are prohibited from profiting from transactions in the same or equivalent security within 60 calendar days after the trade date and must hold Ariel Investments-advised mutual fund shares for a minimum of 60calendar days after trade date. An exception to these personal trading prohibitions includes trades in accounts that are separately managed by the Ariel entities on behalf of themselves or their employees. Ariel Alternatives and its affiliates, principals and employees expect from time to time to carry on investment activities for their own account, for personal or employee investment vehicles and, potentially, for family members, friends or others who do not invest in a Fund, as well as give advice and recommend securities to vehicles which may differ from advice given to, or securities recommended or bought for, any Fund, even though their investment objectives may be the same or similar. The Governing Documents and investment programs of certain Funds generally restrict, limit or prohibit, in whole or subject to certain procedural requirements, investments of certain other vehicles in issuers held by such Funds or give priority with respect to investments to such Funds. Some of these restrictions could be waived by investors (or their representatives) in such Funds or be subject to limitations (e.g., by time or percentage of capital deployed). The Code prohibits employees of the Ariel entities from: •

transacting in any security, either personally or on behalf of others, when in possession of material, nonpublic information 1 regarding the security; and/or communicating material nonpublic information regarding a security to others who then transact in the security. 0F

•

In light of certain restrictions imposed on Ariel entities and team members due to Project Level’s sports investing activity, the Code also prohibits employees from owning certain gambling entities, including a casino, sportsbook or other establishment or business that offers commercial gambling.

1 Prior to engaging an expert network firm in connection with investment research, the employee must obtain, among other

things, prior written approval from Ariel Alternatives’ CEO and the Chief Compliance Officer to ensure controls are implemented pertaining to the receipt of material non-public inside information.

The Code requires all employees of the Ariel entities to report: • •

upon hire and annually, all Reportable Securities 2 in which they have beneficial ownership and the accounts that hold Reportable Securities (“Reportable Accounts”); and on a quarterly basis, all Reportable Securities transactions. 1F

The Code requires employees of Ariel entities to obtain the written consent of such entity’s Chief Compliance Officer prior to executing most transactions in Reportable Securities and opening certain reportable accounts. Other reportable accounts must be immediately reported to the Chief Compliance Officer (same day as the account’s inception). From time to time, a General Partner reserves the right to advance funds on behalf of a Fund and contribute such amounts to the relevant Fund as a special interim capital contribution for investment, to be redeemed at a later date. A yield amount in connection with such borrowing typically is borne by the relevant Fund, consistent with the Governing Documents. Similarly, Ariel Alternatives or an affiliate from time to time is expected to sign non-disclosure agreements or other deal documentation in view of future participation by one or more Fund(s), although this typically is done as a courtesy and without compensation from a Fund. Ariel Alternatives will effect such borrowings consistent with a Fund’s Governing Documents and in a manner it believes to be fair and equitable under the circumstances to the relevant Fund. The Code’s gift and entertainment provisions prohibit employees of Ariel from giving or accepting any cash gifts, non-cash gifts having a value of more than $100, or excessive entertainment to or from a client, prospective client, or any person or entity that does or seeks to do business with the Ariel entities. The Code permits the providing or accepting of a business entertainment event of reasonable value, so long as the person or entity providing the entertainment is present. The Code requires employees to report to the Chief Compliance Officer all gifts and entertainment received and given. The Code requires employees to obtain prior approval from the Chief Compliance Officer, the Chief Human Resources Officer and the employee’s supervisor before accepting outside employment, outside investment service (defined as a role on any board or committee for any organization which has decision-making authority over the organization’s securities investments) or a position with a governmental entity. The Chief Compliance Officer will consider various factors in evaluating whether such outside employment conflicts with, or generates risk for, the respective Ariel entities’ businesses. Certain employees of the Ariel entities’ serve as directors of public companies. The Ariel entities mitigate the potential conflicts of interest by (1) requiring the written approval of the Ariel entity’s Chief Compliance Officer prior to any employee serving as a director of any public company and (2) Ariel not buying for its clients the securities issued by a public company for which an Ariel employee serves as a director. That said, employees serving on corporate or non-profit boards of directors may receive material, nonpublic inside information about public companies. These employees must contact the Chief Compliance Officer in accordance with the procedures set forth

As defined by the Advisers Act and the Investment Company Act rules pertaining to codes of ethics.

in Ariel’s Insider Trading Policy and Procedures. As of December 31, 2025, the public company boards on which Ariel employees served were: JPMorgan Chase & Co. (and certain subsidiaries thereof), The New York Times Company, NIKE, Inc., and Ryan Specialty Group Holdings Inc.. The Code provides for the imposition of sanctions against those persons who violate the Code and for oversight of the Code’s administration by the Ariel entity’s Chief Compliance Officer, who annually reports to the Boards of the Ariel entities: (i) on the Code’s adequacy and effectiveness, (ii) any issues arising under the Code, and (iii) certifies that the Ariel entities have adopted procedures reasonably designed to prevent violations. The foregoing description of the Ariel entities’ Code does not reflect all provisions of the Code. A client or prospective client may request a copy of the Code by calling 800-725-0140, emailing ClientserviceIR@arielinvestments.com, or writing to Ariel Alternatives, LLC, Attention: Institutional Client & Investor Relations, 200 East Randolph Street, Suite 2900, Chicago, IL 60601-6505. Political Activities Policy and Procedures The Ariel entities have adopted a policy and procedures relating to political activities. The policy requires the Ariel entities, their employees and their spouses and dependent children to obtain prior approval from Ariel Investments’ Chief Compliance Officer before making, or directing or soliciting any other person to make, any political contribution or provide anything else of value, including volunteer services, to an existing state or local official, candidate for state or local position, political organization or candidate for federal office who holds a state or local position. Additionally, the policy and procedures prohibit the Ariel entities, their employees and their spouses and dependent children from coordinating or soliciting any person to make any: (i) contribution to an official of a government entity to which an Ariel entity is providing or seeking to provide investment advisory services; or (ii) payment to a state or local political party where an Ariel entity is providing or seeking to provide investment advisory services. The policy and procedures are designed to comply with various federal, state and local laws restricting “pay-toplay” activities of investment advisers. Charitable Contributions The Ariel entities make charitable contributions and sponsor charitable events. We do not make any contributions or sponsor events in order to obtain or retain advisory clients. The Ariel entities have procedures to monitor its charitable activities.

Ariel Alternatives focuses on securities transactions of private companies and generally purchases and sells such companies through privately-negotiated transactions in which the services of a broker-dealer may be retained. However, Ariel Alternatives reserves the right to distribute securities to investors in a Fund or sell such securities, including through using a broker-dealer, such as where a public trading market exists. Although Ariel Alternatives does not intend to regularly engage in public securities transactions, to the extent it does so, it intends to follow the brokerage practices described below.

If Ariel Alternatives sells publicly traded securities for a Fund, it is responsible for directing orders to broker-dealers to effect securities transactions for accounts managed by Ariel Alternatives. In such event, Ariel Alternatives will seek to select brokers on the basis of best price and execution capability. In selecting a broker to execute client transactions, Ariel Alternatives reserves the right to consider a variety of factors, including: (i) execution capabilities with respect to the relevant type of order; (ii) commissions charged; (iii) the reputation of the firm being considered; and (iv) responsiveness to requests for trade data and other financial information. Ariel Alternatives has no duty or obligation to seek in advance competitive bidding for the most favorable commission rate applicable to any particular client transaction or to select any broker on the basis of its purported or “posted” commission rate, but will endeavor to be aware of the current level of the charges of eligible brokers and to reduce the expenses incurred for effecting client transactions to the extent consistent with the interests of such clients. Although Ariel Alternatives generally seeks competitive commission rates, it may not necessarily pay the lowest commission or commission equivalent. Transactions may involve specialized services on the part of the broker involved and thereby entail higher commissions or their equivalents than would be the case with other transactions requiring more routine services. Consistent with Ariel Alternatives seeking to obtain best execution, brokerage commissions on client transactions are permitted to be directed to brokers in recognition of research furnished by them, although Ariel Alternatives generally does not make use of such services at the current time and has not made use of such services since its inception. Ariel Alternatives does not anticipate engaging in significant public securities transactions; however, to the extent that Ariel Alternatives engages in any such transactions, orders for the purchase or sale of securities placed first will be executed first, and within a reasonable amount of time of order receipt. To the extent that orders for Funds are completed independently, Ariel Alternatives also reserves the right to purchase or sell the same securities or instruments for several Funds simultaneously. From time to time, Ariel Alternatives expects, but is not obligated, to purchase or sell securities for several client accounts at approximately the same time. Such orders may be combined or “batched” to facilitate obtaining best execution and/or to reduce brokerage commissions or other costs. Batched transactions are executed in a manner intended to ensure that no participating Fund of Ariel Alternatives is favored over any other Fund. When an aggregated order is filled in its entirety, each participating Fund generally will receive the average price obtained on all such purchases or sales made during such trading day. To the extent such orders are not batched, they may have the effect of increasing brokerage commissions or other costs. When an aggregate order is partially filled, the securities purchased or sold will normally be allocated on a pro rata basis to each Fund participating in such buy or sell order in accordance with the number of securities originally requested for such Funds. Each Fund generally will receive the average price obtained on all such purchases or sales made during such trading day. Exceptions to pro rata allocations are permissible provided Ariel Alternatives believes they are fair and equitable to its clients under the circumstances over time. In Ariel Alternatives’ private company securities transactions on behalf of the Funds, Ariel Alternatives reserves the right to retain one or more broker-dealers or investment banks, the costs

of which will be borne by the relevant Fund and/or its portfolio companies. In determining to retain such parties, Ariel Alternatives reserves the right to consider a variety of factors, including: (i) capabilities with respect to the type of transaction being contemplated; (ii) commissions or fees charged; (iii) reputation of the firm being considered; and (iv) responsiveness to requests for information. As a result, although Ariel Alternatives generally will seek reasonable rates for such services, the market for such services involves more subjective evaluations than public securities brokerage transactions, and the Funds may not pay the lowest commission or fee for such services.

Ariel Alternatives and/or its affiliates provide certain business or consulting services to companies in a Fund’s portfolio and expect to receive compensation from these companies in connection with such services. As described in the Governing Documents, this compensation may, in many cases, offset a portion of the Management Fees paid by such Fund. However, in other cases (e.g., reimbursements for out-of-pocket expenses directly related to a portfolio company), these fees are in addition to Management Fees. See “Fees and Compensation.” Ariel Alternatives reserves the right from time to time to enter into solicitation arrangements pursuant to which it compensates third parties for referrals that result in a potential investor becoming a limited partner in a Fund. Any fees payable to any such placement agents generally will be borne by Ariel Alternatives indirectly through an offset against the Management Fee under the Governing Documents, although related expenses incurred pursuant to the relevant placement agent or similar agreement, including but not limited to placement agent travel, meal and entertainment expenses, typically are borne by the relevant Fund(s). Ariel Distributors served on a fee-free basis as distributor to sell interests of Project Black. Although there are potential conflicts of interest inherent in using an affiliated broker-dealer and its personnel to place securities, Ariel Alternatives believes these to be substantially mitigated by the fact that the arrangement did not involve the payment of placement fees to Ariel Distributors. However, there can be no assurance that another service provider could not provide the same or similar services to Ariel Alternatives.

Ariel Alternatives and its management persons have not been subject to any material legal or disciplinary events required to be disclosed in this Brochure.

The investments made by the Funds are generally private, illiquid, and long-term in nature. Accordingly, the review process is not directed toward a short-term decision to dispose of securities. However, Ariel Alternatives monitors companies in which the Funds invest, and the Chief Compliance Officer periodically checks to confirm that each Fund is maintained in accordance with its stated objectives. Each Fund generally will provide to its limited partners (i) annual GAAP audited and quarterly unaudited financial statements, (ii) annual tax information necessary for each limited partner’s tax return, (iii) a third-party valuation of each portfolio company as of the expiration of the Investment Period, as defined in the Governing Documents, and each of the tenth, fifteenth and twentieth anniversary of the final closing date, and (iv) periodic reports providing a narrative summary of the status of each portfolio company investment.

Ariel Alternatives maintains custody of assets held in the name of each of the relevant Funds with qualified custodians as required by Rule 206(4)-2(b)(4) under the Advisers Act (the “Custody Rule”). Further, Ariel Alternatives , complies with the private fund audit requirements with respect to the relevant Funds, as provided under the Custody Rule. Ariel Alternatives has implemented written policies and procedures to ensure compliance with the Custody Rule’s requirements and periodically reviews the effectiveness of its custody controls.

Ariel Alternatives has discretionary authority to manage investments on behalf of each Fund, although investors in the co-investment funds have certain consent rights in relation to the making of certain co-investments. As a general policy, Ariel Alternatives does not allow clients to place limitations on this authority. Pursuant to the terms of the Governing Documents, however, Ariel Alternatives and/or its affiliates have entered into Side Letters with certain limited partners whereby the terms applicable to such limited partner’s investment in a Fund are altered or varied, including, in some cases, the right to opt-out of certain investments for legal, tax, regulatory or other similar reasons. Ariel Alternatives assumes this authority pursuant to the terms of the Governing Documents and powers of attorney executed by the limited partners of such Fund.

Ariel Alternatives does not anticipate that its clients will own public equity securities in the near future. In advance of Ariel Alternatives deciding to own such securities for its clients or of one of its portfolio companies going public, Ariel Alternatives will establish the requisite policies and procedures, inclusive of proxy voting guidelines, to ensure compliance with the SEC’s proxy voting requirements, including Rule 206(4)-6 of the Advisers Act. These procedures will address conflicts of interest in voting proxies and consider seeking approval from the LPAC.

Ariel Alternatives does not require prepayment of management fees more than six months in advance or have any other events requiring disclosure under this item of the Brochure.

ADDITIONAL INFORMATION Privacy Notice Ariel’s most important asset is its relationship to clients. Ariel’s entire staff is dedicated to serving clients, which includes protecting the privacy and security of clients’ data. The Gramm-LeachBliley Act and SEC Regulation S-P (“Reg S-P”) apply to non-public personal information (“NPPI”) and, under the recently amended Reg S-P, “customer information,” which now includes any record containing NPPI about a customer, whether collected by Ariel or received from another financial institution. provided by clients who obtain financial products and services from Ariel and its affiliates. Ariel’s Privacy Policy/Notice is posted on Ariel Investments’ website, and Ariel’s compliance manual contains the Privacy Policies and Procedures adopted by Ariel and its affiliates have adopted in order to comply with various requirements aimed at protecting personal information. A Privacy Rights Request form is available at https://www.arielinvestments.com/privacy-rights-request/. Ariel strives to maintain clients’ trust and confidence, and it is Ariel’s policy not to share clients’ personal information with anyone unless it is for one of the following reasons: (i) at a client’s direction; (ii) to provide a client with requested services or information about Ariel’s services; (iii) to maintain Ariel’s high standards of performance and compliance, such as by sharing information with our outside professionals; (iv) to ensure the security and integrity of our services and operations or to verify or maintain the quality or safety of our services; (v) to provide advertising and marketing services; (vi) to identify and repair errors impairing system functionality; (vii) to undertake internal research; (viii) to transfer data in the possible event of a merger, sale, reorganization or other transaction involving all or part of Ariel’s business, or associated diligence; (ix) to respond to the requests of government agencies, regulators and law enforcement; or (x) as otherwise required by law. Clients, upon opening an account and on an as-needed basis, submit to Ariel a variety of personal data and NPPI, including address, telephone number, Social Security number, beneficiary information, and certain tax and financial information. Ariel generates reports, such as account statements, to service client accounts, and receives reports from custodians and brokers. To provide quality services when placing orders or executing transactions, Ariel discloses information to others on a limited basis. These entities include custodians, brokers, affiliates, and service providers performing business-support functions such as systems maintenance, data processing, and global trading operations, as well as accountants, attorneys, and other vendors assisting with compliance and performance standards. Ariel maintains administrative, technical, and physical safeguards designed to protect the confidentiality and security of client information. Consistent with amended Reg S-P, Ariel has adopted a written incident response program reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer information, including: assessing the nature and scope of any incident, containing and controlling incidents, and taking appropriate remediation steps. In accordance with amended Reg S-P, Ariel will provide clear and timely notice to affected individuals whose sensitive customer information was or is reasonably likely to have been

accessed or used without authorization, as soon as practicable but no later than 30 days after becoming aware of the incident, subject to limited exceptions. Ariel also maintains a service-provider oversight program that includes due diligence, monitoring, and contractual requirements designed to ensure that service providers protect customer information. Ariel requires third parties to whom we provide access to NPPI furnish assurances that they in turn will protect the privacy of this information and will only use the information for the business purpose for which Ariel has provided it. As required under the amended rule, service providers must notify Ariel within 72 hours after becoming aware of any incident involving unauthorized access to customer information. A former client’s information is protected to the same extent as that of a current client. Ariel’s relationship with its clients is governed by U.S. securities laws and applicable state or local law, as indicated in each client’s investment management agreement. Under Reg S-P, clients retain the right to opt out of the disclosure of their NPPI to non-affiliated third parties. Individuals in certain jurisdictions may also have rights to: (i) request access to,rectification of, or erasure of their personal data; (ii) restrict or object to the processing of their personal data; and (iii) obtain a copy of their personal data in a portable format. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority or agency. Ariel will review and respond to such requests within the time provided by applicable law without prejudice to our view of the controlling law. Non-U.S. Data Subject Rights: Individuals in Andorra, Argentina, Australia, Canada, Cayman Islands, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, México, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: •

Request access to, correction of, and deletion of your personal data that Ariel holds;

•

Restrict or object to certain processing of your data by Ariel;

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Obtain a copy of their personal data in a portable format and/or request transfer of their personal data to a third party;

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Request the information on the recipients or categories of recipients with whom Ariel shares their personal data; and

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Lodge a complaint about the processing of personal data with a data protection authority or agency.

Special Notice for Residents of California: Ariel complies with the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA” and together with the CCPA, the “CCPA/CPRA”). The CCPA/CPRA does not apply to personal information (PI) collected about current or former investors whose information is protected by federal financial privacy law under the Gramm Leach Bliley Act (“GLBA”) and the SEC’s Reg S-P. Personal data of California residents not subject to the GLBA and Reg S-P is covered by the CCPA/CPRA.

California residents have the right to request their PI be deleted or inaccurate PI be corrected. They have the right to request that Ariel disclose to them the categories of PI it has collected about them, the sources of the data, the business purpose, the categories of third parties to whom Ariel discloses the PI, the specific pieces of PI that Ariel has collected about them, the retention period for each category of PI (including SPI), and the criteria used to determine such period of retention. California residents have the right to ask Ariel to disclose to them: (a) the categories of PI that it has collected about the resident; (b) the categories of PI that Ariel has sold or shared about them and the categories of third parties to whom the PI was sold or shared, by category of PI for each category of third party, and (c) the categories of their PI that Ariel disclosed for a business purpose and the categories of persons to whom it was disclosed. California residents have the right to opt out of the sale or sharing of their PI to third parties by directing Ariel not to sell or share their PI. They also have the right to direct Ariel to limit its use of their SPI. California residents have the right to exercise these rights without any retaliation or discrimination, such as denying services, charging different rates for services, providing a different level of service, or suggesting the person will receive a different price or rate for services or different quality of service. California residents can make a request to exercise their rights under the CPRA by contacting us by email at privacy@arielinvestments.com or by calling us at 800-725-0140. A Privacy Rights Request form is available at https://www.arielinvestments.com/privacy-rights-request/. Ariel will review requests and respond accordingly. The rights described herein are not absolute and are subject to exceptions. Ariel’s Privacy Policy is online at https://www.arielinvestments.com/privacy-notice/. Ariel’s Privacy Policies and Procedures contained in Ariel’s compliance manual may be made available upon request by emailing clientserviceIR@arielinvestments.com.