Bain Capital Credit, LP

Bain Capital Credit, LP, a Delaware limited partnership wholly owned by Bain Capital, LP (“Bain Capital”), provides investment advisory services across a diverse range of credit and special situation strategies. For purposes of this brochure, Bain Capital Credit, LP, along with its affiliated relying advisers and subsidiaries, are collectively referred to as “Bain Capital Credit.” Bain Capital Credit provides investment advisory services to pooled investment vehicles and single limited partner partnerships that are exempt from registration under the Investment Company Act of 1940 (the “1940 Act”) and whose securities are not registered under the Securities Act of 1933 (the “Securities Act,” and such investment vehicles and partnerships are referred to as “Bain Capital Credit Partnerships”). Bain Capital Credit also provides investment management services to clients in separately managed accounts (“Separate Account Clients”), which may be structured in various forms. Additionally, Bain Capital Credit and its affiliates provide advisory or sub-advisory services to registered investment companies and business development companies (“1940 Act Funds”). 1 Bain Capital Credit also provides collateral management services to entities structured as collateralized loan obligations (“CLOs”). The Bain Capital Credit Partnerships, the CLOs, and the 1940 Act Funds are collectively referred to as “Bain Capital Credit Funds.” The Bain Capital Credit Funds and Separate Account Clients are referred to collectively as “Bain Capital Credit Clients.” Bain Capital Credit’s investment advisory activities include providing investment advice to Bain Capital Credit Clients that have several main strategies: •

Credit investing, including in bank loan and multi-sector credit, structured credit, and private credit (including mezzanine & junior capital and global direct lending), and

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Special situations investing, including providing capital solutions and investing across all market cycles in credit, equity, corporate, and real estate assets.

As the investment manager, investment adviser or sub-adviser to each Bain Capital Credit Client, Bain Capital Credit (along with, in the case of each Bain Capital Credit Partnership, the general partner of such Bain Capital Credit Partnership (each a “General Partner”)), identifies investment opportunities for, and participates in the acquisition, management, monitoring, and disposition of investments of, each Bain Capital Credit Client. The 1940 Act Funds carry additional regulatory obligations and restrictions. These restrictions may not apply to other Bain Capital Credit Clients.

Bain Capital Credit generally uses fundamental credit analysis to seek to identify attractive investment opportunities, primarily in credit products and fixed-income investments. Bain Capital Credit provides investment advice regarding investments in performing and distressed bank loans, high yield bonds, investment grade bonds, mortgages, mezzanine & junior capital, structured products (including CLOs and mortgage-backed securities), credit based securities, swap transactions (including total rate of return swaps and credit default swaps), derivative instruments, equities, short sales, currency hedging transactions, securities lending arrangements, repurchase agreements, investments as a limited partner in partnerships, and other assets. Bain Capital Credit Clients can use leverage directly and/or indirectly. Use of leverage will increase the volatility of levered investments. Relying Advisers Bain Capital Credit has several relying investment advisers that serve as collateral managers to CLOs. These advisers constitute Bain Capital Credit CLO Advisors, LP; Bain Capital Credit U.S. CLO Manager, LLC; Bain Capital Credit U.S. CLO Manager II, LP; and Bain Capital Credit CLO Management III (DE), LP. Bain Capital Special Situations, LP (“Bain Capital Special Situations”), a Delaware limited partnership, is also a relying adviser to Bain Capital Credit, LP. Bain Capital Special Situations provides investment advice regarding capital solutions, hard assets, and distressed investments. The primary focus of Bain Capital Special Situations’ investment advisory activity is researching and advising on a wide array of special situations opportunities, including providing bespoke financing solutions for companies, which often include convertibility, warrants, fees or minority equity participation, asset-based investments across a variety of asset classes, and cyclical distressed opportunities. Lastly, Bain Capital Credit Manager (EU), LLC is a relying adviser to Bain Capital Credit, LP. It manages middle market funds. Advisory Agreements Bain Capital Credit provides investment advisory services to each Bain Capital Credit Client pursuant to separate advisory, investment management, or collateral management agreements (each, an “Advisory Agreement”) or separate subadvisory agreements (each, a “Sub-Advisory Agreement”). Bain Capital Credit provides investment advisory services to each of the Bain Capital Credit Partnerships pursuant to the Advisory Agreements. Investment advice is provided by Bain Capital Credit directly to Bain Capital Credit Partnerships, subject to the direction and control of the affiliated General Partner

of such Bain Capital Credit Partnership and not individually to investors in the Bain Capital Credit Partnerships. Any restrictions on investments in certain types of securities are established by the General Partner of the applicable Bain Capital Credit Partnership and set forth in the offering documentation provided to each limited partner prior to investment in a Bain Capital Credit Partnership. Once invested in a Bain Capital Credit Partnership, investors generally cannot impose restrictions on the types of securities in which such Bain Capital Credit Partnership may invest. Bain Capital Credit provides investment management services to each Separate Account Client in accordance with the terms and conditions of the Advisory Agreement. The terms of these documents, including any restrictions on investments in certain types of securities, are generally established at the time of the formation of the applicable separate account and are the result of negotiations with the applicable Separate Account Client. The Advisory Agreement of a Separate Account Client may be changed by such Separate Account Client only to the extent permitted by the applicable Advisory Agreement. With respect to the 1940 Act Funds, Bain Capital Credit provides investment advisory services in accordance with the relevant 1940 Act Fund’s investment policies and restrictions, as stated in such 1940 Act Fund’s then-current prospectus, statement of additional information, and/or other public filings. Bain Capital Credit provides collateral management services to each CLO in accordance with the terms and conditions of the applicable collateral management agreement, indenture, and other related documents of each such CLO. The terms of the Advisory Agreements and other related documents of each CLO were generally established at the time of the formation of the applicable CLO and are the result of negotiations with certain potential investors in the applicable CLO. Other Advisory Affiliates In addition to the relying advisers above, Bain Capital Credit has other advisory subsidiaries and/or affiliates based in the United States and other countries, including: •

BCSF Advisors, LP and BCPC Advisors, LP, Delaware limited partnerships and SEC-registered investment advisers, which provide advisory and subadvisory services to registered investment companies, including business development companies;

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Bain Capital Credit, Ltd., a UK-based and FCA registered firm, which provides collateral management services to CLOs;

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Bain Capital Investments (Ireland) Limited, based in Dublin, a Central Bank of Ireland authorized firm and an Alternative Investment Fund Manager (“AIFM”);

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Bain Capital Credit (Australia), Pty. Ltd., an Australian Securities and Investments Commission licensed firm, which provides consulting advice to Bain Capital Credit;

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Bain Capital (Hong Kong), Limited, a Hong Kong-based and Securities & Futures Commission licensed firm, which provides consulting advice to Bain Capital Credit; and

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Bain Capital (Singapore) PTE Ltd, a Monetary Authority of Singapore licensed firm, which provides consulting advice to Bain Capital Credit. 2

In addition, Bain Capital Credit is affiliated with Bain Capital Investments (Europe), Ltd., an FCA registered firm and an AIFM. 2 Bain Capital Credit also has other affiliated entities, including asset servicers, joint ventures, and certain vehicles that will engage in proprietary trades and/or other activities for its benefit. Bain Capital Credit, LP provides consulting services to Bain Capital Credit, Ltd., in connection with the latter’s role as collateral manager to certain CLOs. In certain limited circumstances, Bain Capital Credit acts as agent for such facilities. Bain Capital Credit, LP also provides portfolio management services to Bain Capital Investments (Europe), Ltd. and Bain Capital Investments (Ireland), Ltd. in connection with their roles as an AIFM. In addition, Bain Capital Credit, LP provides certain resources and services to other subsidiaries, including BCSF Advisors, LP, BCPC Advisors, LP, and Bain Capital Credit CLO Advisors, LP. Lastly, Bain Capital Credit U.S. CLO Manager, LLC, Bain Capital Credit U.S. CLO Manager II, LP and Bain Capital Credit CLO Management III (DE), LP delegate directly or indirectly activities related to the business of acting as a collateral manager or sponsor of CLOs to Bain Capital Credit, LP and/or Bain Capital Credit, Ltd. Bain Capital Credit has been in business since 1997. Bain Capital Credit has advisory offices across major global financial markets. As of January 1, 2026, Bain Capital Credit and its subsidiaries manage approximately $81,689,141,717 client assets, which are predominantly managed on a discretionary basis. 3 This list does not represent all of Bain Capital Credit’s subsidiaries or affiliates. For purposes of this Form ADV, references to Bain Capital Credit subsidiaries should be read to include Bain Capital Investments (Europe), Ltd. This AUM figure includes all vehicles managed by Bain Capital Credit, LP, its relying advisers, and its

Fees As compensation for investment advisory services rendered to Bain Capital Credit Clients, Bain Capital Credit generally receives an advisory fee (“Advisory Fee”). Advisory Fees billed to Bain Capital Credit Clients vary client by client and are generally payable quarterly in advance, quarterly in arrears, semi-annually in arrears, or a combination thereof. 4 Advisory Fees paid by a Bain Capital Credit Client are indirectly borne by the investors in such Bain Capital Credit Client. The fee structures described above are modified from time to time. In respect to the 1940 Act Funds, Bain Capital Credit receives either an advisory fee payable by the relevant 1940 Act Fund pursuant to an Advisory Agreement between Bain Capital Credit and the 1940 Act Fund or a sub-advisory fee payable by the relevant 1940 Act Fund’s investment adviser pursuant to a Sub-Advisory Agreement between Bain Capital Credit and each such investment adviser. Such fees are generally paid quarterly in arrears. The precise amount of, and the manner and calculation of, the Advisory Fee for each Bain Capital Credit Fund (except for the 1940 Act Funds) is established by Bain Capital Credit and set forth in such Bain Capital Credit Fund’s Advisory Agreement and/or other offering documentation provided to each investor prior to investment in such Bain Capital Credit Fund. In particular, for CLOs, the Advisory Fee is set in the collateral management agreement or related documentation. The Advisory Fees for CLOs may include both a base and subordinated collateral management fee. Advisory Fees billed to Separate Account Clients are individually negotiated. Upon termination of an Advisory Agreement, appropriate treatment, including, where applicable, returning prepaid Advisory Fees on a prorated basis, will be given to Advisory Fees collected in advance. Advisory Fees sometimes differ from one Bain Capital Credit Fund or Separate Account Client to another, as well as among investors in the same Bain Capital Credit Fund. In addition, Bain Capital Credit is entitled to certain incentive compensation when certain conditions are met. In certain circumstances, Bain Capital Credit generally may elect to defer payment or distribution of its Advisory Fee and/or incentive compensation. If deferred, Bain Capital Credit may be entitled to receive interest on the deferred portion of the management fee and/or incentive fee. See Item 6 (“Performance-Based Fees and Side-By-Side Management”) for more information on incentive fees. Bain Capital Credit also may elect to waive payment or distribution of its fees. subsidiaries (including those that file separate Form ADVs), and includes credit vehicles managed by Bain Capital Investments (Europe), Ltd. Some Bain Capital Credit Clients pay fees on different schedules.

Expenses While Bain Capital Credit Clients generally bear their own expenses, these expenses vary among Bain Capital Credit Clients and are subject to the terms and conditions set forth in the applicable Bain Capital Credit Client’s offering materials, governing documents, or other analogous organizational documents. The expenses generally borne by Bain Capital Credit Funds are outlined below. Certain Separate Account Clients bear similar expenses to Bain Capital Credit Funds, depending on the terms of the Advisory Agreement negotiated with the applicable Separate Account Client. The 1940 Act Funds may bear similar expenses pursuant to their governing documents and may also bear, among other expenses, transfer agency and distribution related expenses. To the extent not paid by portfolio companies or other investment vehicles, and unless otherwise specified herein, each eligible Bain Capital Credit Fund bears its organizational (which shall be allocated among Bain Capital Credit Fund limited partners as set forth in the applicable Advisory Agreements), operational, and offering expenses and obligations, which include, to the extent applicable: •

all expenses (including for services performed either by internal staff of Bain Capital Credit, the General Partner, or affiliates) of (i) organizing and establishing any General Partner, each Bain Capital Credit Fund, any intermediate investment vehicle or respective affiliates and (ii) the offering of interests in each Bain Capital Credit Fund (including legal and accounting expenses, filing fees and expenses, travel, meals, entertainment, accommodation and related expenses, printing costs, costs and expenses relating to the acceptance and redemption of any seed commitment, or any other expenses incurred with respect to the offering of such interests);

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all investment-related expenses (including any such expenses incurred in connection with potential investments, platform companies and add-on acquisitions, in each case, whether or not completed), including expenses relating to identifying, discovering, sourcing, developing (including any retainers, success and finder’s fees and other compensation paid to contractors, senior advisers, joint venture partners, fundless sponsors and sourcing and operating partners), evaluating, valuing, researching, investigating, structuring (including rating agency fees and expenses), diligencing, monitoring, maintaining, servicing, purchasing, making, holding, acquiring, registering (including notary and “gestoria” costs), selling (or potentially selling), refinancing (including any brokerage, borrowing and financing fees or expenses) or restructuring investments (whether or not completed, including broken deal and reverse break-up fees, liquidated damages, forfeited deposits, reverse termination fees or similar payments);

all lodging, travel, transportation (including the use of private/chartered, first class or business class travel and taxis and car rentals and any form of other transportation), meals, entertainment and related expenses (including any of these incurred by an investment team or other member of the General Partner or Bain Capital Credit or their affiliates whether or not traveling) incurred in connection with the Bain Capital Credit Funds’ affairs, including travel-related expenses in connection with evaluating, making and monitoring investments; professional costs and expenses (including legal, compliance, tax, financial, accounting, actuarial, valuation, advisory and consulting/experts (including consultants or experts for industry-specific matters, due diligence, reference checks, sourcing or introductions and other similar costs)); brokerage commissions, hedging costs, expenses relating to short sales, prime brokerage fees, custodial expenses, clearing and settlement charges, private placement fees, syndication fees, solicitation fees, arranger fees, sales commissions, pricing and valuation fees (including appraisal fees), underwriting commissions and discounts, investment banking fees, advisory fees, and bank charges, and custodial, trustee, transfer agent, government and/or regulatory filing, recordkeeping and other administrative costs; fees of servicers of any investment (including servicers of pools of loans and arrangements providing for profits or other incentive-based compensation); and salaries, bonuses and fringe benefits payable to employees of Bain Capital Credit or its affiliates who are retained to provide operational support (including servicing) to a Bain Capital Credit Fund or its investments or any intermediate investment vehicle and portions of rent, utilities, information technology, other real-estate related expenses and other similar items and related overhead expenses associated with the retention of such employees; and experts or consultants serving as executives or directors for portfolio companies; •

all expenses incurred in connection with the ongoing operation and administration of the Bain Capital Credit Funds, including any legal, tax, auditing, financial, accounting, administrative, domiciliation, consulting, environmental, social and governance (“ESG”), procurement, technology, cybersecurity, bookkeeping, recordkeeping, reporting and clerical services, and expenses related to acquiring, developing, implementing or maintaining related software;

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all costs and expenses incurred in connection with financings (including financing fees, legal fees and expenses, agent fees and other fees and expenses incurred in connection therewith);

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all fees, taxes and expenses associated with the Bain Capital Credit Funds’ or any investment vehicle’s audits, financial statements, or tax reporting (including fees and expenses associated with preparing tax information,

returns and elections but excluding, for the avoidance of doubt, taxes treated as distributed to any fund partner), including fees and expenses associated with preparing, filing or distributing tax information, returns or elections and complying with any tax audit, investigation, settlement or review; expenses incurred in connection with the preparation and maintenance of the Bain Capital Credit Funds’ and any investment vehicle’s books and records and account holder diligence; expenses incurred in connection with the preparation and delivery of wires and distributions, financial and other reports, circulars, forms, notices, valuations, investment summaries and other information (including courier and delivery expenses), including the cost of auditing reports; expenses incurred by any partnership representative or “designated individual” in connection with the Bain Capital Credit Funds or any investment vehicle and expenses incurred in connection with the dissolution, winding up and liquidation of the Bain Capital Credit Funds and any investment vehicle; •

all expenses and fees of any administrator, depositary and/or custodian and any other service provider;

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all fees, costs and expenses incurred in connection with litigating or owning any investments of the Bain Capital Credit Funds (including servicing fees, including master servicing, primary servicing, special servicing, asset or property advisory fees, and the fees and expenses of any individual hired to manage, service or dispose of any assets) or litigation related to the Bain Capital Credit Funds; legal fees incurred in servicing loans and financings, advisory fees (including income-based repayments, receivership costs and similar fees and costs), value-added taxes and taxes incurred in connection with investments;

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all research and data expenses (including news and quotation subscriptions, market research, costs of attending or hosting conferences (including those related to developing potential investment ideas, trends and themes within industries, sectors or geographies) and networking events, including those organized by the Bain Capital Credit or a portfolio company, and travelrelated expenses, information technology expenses (including technology service providers) and expenses related to acquiring, utilizing, developing, implementing, or maintaining related hardware and software and other information technology expenses (including any investment management systems and phone and information charges) and total logistic control expenses;

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all fees, expenses and costs in connection with any legal and/or regulatory compliance (including anti-financial crime compliance and any compliance obligations that arise from any law, rule, regulation, policy, directive or special

measure (including those relating to privacy, protecting confidential information, data protection, know-your-customer, anti-money laundering, sanctions or anti-terrorism considerations)), participation in or costs arising from, any law, regulation, policies, programs or industry initiatives concerning ESG compliance, data collection, reporting or other best practices and any government and/or regulatory filings related to the Bain Capital Credit Funds or the offering of interests in the Bain Capital Credit Funds or the Bain Capital Credit Funds’ investments (including regulatory filings of Bain Capital Credit and its affiliates relating to the Bain Capital Credit Funds, including without limitation Form PF, the Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on alternative investment fund managers, as amended by Directive (EU) 2024/927 of 13 March 2024 as regards delegation arrangements, liquidity risk management, supervisory reporting, the provision of depositary and custody services and loan origination by alternative investment funds, as published in the Official Journal of the European Union on 26 March 2024, and as may be amended from time to time, and any laws, rules or regulations promulgated thereunder including any Commission delegated regulation published in the Official Journal of the European Union from time to time and, where relevant, any implementing measure adopted in any relevant member state of the European Economic Area (including in Ireland by the European Union (Alternative Investment Fund Managers) Regulations 2013, as amended from time to time), the U.K. Alternative Investment Fund Managers Regulations 2013 as amended including by the Alternative Investment Fund Managers (Amendment etc.) (EU Exit) Regulations 2019 and Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector filings (“SFDR”) and Regulation EU/2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending SFDR, but not, for the avoidance of doubt, filings solely related to the operation of Bain Capital Credit, the AIFM or their respective affiliates generally), whether, for the avoidance of doubt, they are incurred once or on a periodic basis during the life of the Bain Capital Credit Funds, and the costs of maintaining the Bain Capital Credit Funds in compliance with all applicable laws (including anti-financial crime compliance); •

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of Analysis and Investment Strategies Bain Capital Credit manages Bain Capital Credit Clients in accordance with their investment strategy, applicable Advisory Agreements, and other governing documents. Certain strategies and agreements may place more significant restrictions on Bain Capital Credit’s ability to make certain investments.

Bain Capital Credit Bain Capital Credit monitors investments in its liquid, structured, and private credit strategies based on an analytical approach that generally involves evaluating the following investment characteristics:

Idea Generation Bain Capital Credit (including its relying CLO advisers) generally identifies new investment opportunities generally through three avenues: first, through industry analysis and relative value screens conducted by Bain Capital Credit’s investment professionals; second, through investment opportunities brought to Bain Capital Credit, including by private equity sponsors, fundless sponsors, law firms,

restructuring advisers, commercial and investment banks, Bain Capital Credit affiliates, and ventures with other investment advisers; and third, through Bain Capital Credit’s proprietary sourcing efforts.

Company Evaluation Market Definition. Traditionally, the first step in Bain Capital Credit’s fundamental competitive analysis is defining, as accurately as possible, the market in which a company competes. Market definition generally requires an assessment of the customer needs driving the consumption of a company’s products and services. If the market is defined too narrowly, substitute goods or services may be overlooked, and a company’s ability to affect pricing may be overestimated. Likewise, if the market is defined too broadly, competitive advantage may be underestimated. Many of the tools used in the definition process are derived from methodologies developed at consulting firms, market research firms, banks, and rating agencies. Market Size and Prospects for Growth. Once a market is defined, the next step in Bain Capital Credit’s analysis is to attempt to determine the dollar size of the market and to assess its growth prospects. Although market information may often be available through publicly available information, Bain Capital Credit’s professionals are trained to question the available data because of the inherent biases of the reporting authorities (e.g., trade publication, industry group and “independent” consultants). Bain Capital Credit seeks to identify the primary drivers of growth (i.e., demographic trends, buying habits, technological shifts) to validate conclusions drawn by the public information. If validation is not possible, Bain Capital Credit often derives its own industry growth model through primary source research. Margin Analysis and Cost Structure. After examining the market environment in which a company operates, Bain Capital Credit typically scrutinizes the company’s historical performance and prospects. This analysis centers around the company’s sustainable margins and its quality of earnings. Bain Capital Credit professionals attempt to assess the sustainability of a company’s margins over time by tracking and projecting pricing trends in the industry (based on research regarding market definition, size, and growth characteristics) and the company’s cost structure relative to its competitors. Bain Capital Credit generally assesses a company’s quality of earnings through detailed margin analyses as well as evaluation of a company’s return on assets, paying particular attention to one-time charges and extraordinary events. Competitive Landscape. In evaluating a company’s prospects, Bain Capital Credit seeks to identify and assess the current and prospective competitors of that company. The scale economies, technological advantages, and cost efficiencies

available to such competitors are generally compared and contrasted in order to benchmark a company’s relative strengths and weaknesses. Although a company may participate in a large, growing and otherwise attractive market, its prospects depend on its ability to maintain a competitive advantage. Bain Capital Credit professionals are trained to analyze a competitive landscape in order to determine whether a company can be expected to perform at levels consistent with the business plan proffered by the company’s management or other sponsors. A significant portion of this analysis is often conducted through interviews of portfolio company executives, other industry contacts, as well as competitors and suppliers. Corporate Structure and Access to Capital Markets. Bain Capital Credit generally reviews the corporate structure of each of its investments to understand how the company’s assets are distributed, which subsidiaries have the support of those assets and how any guarantees, liens or pledges will affect an investment in the company. Bain Capital Credit also analyzes an issuer’s capitalization, its financial flexibility, debt amortization requirements, and the covenants, terms and conditions of the issuer’s outstanding debt and equity securities. Reviewing the various covenant levels and compliance issues is an important part of Bain Capital Credit’s investment monitoring system. Bain Capital Credit’s professionals have extensive experience analyzing the corporate structure and covenant issues in each of the targeted asset classes. Third Party Diligence. As part of the diligence process for certain investments, Bain Capital Credit typically hires third party firms to conduct accounting, tax, valuation, legal, environmental, and other diligence, as well as perform background checks on principals or management teams where appropriate. Regulatory, Tax and Legal Environment. As part of its review process for certain investments, Bain Capital Credit generally performs a review of potential regulatory, tax and legal contingencies to assess any potential negative impact on the company’s value or ability to continue as an ongoing concern. Portfolio Management. Bain Capital Credit manages portfolio risk by monitoring issuer and industry diversification, interest rate risk, currency risk and other risks applicable to Bain Capital Credit Clients. On-going Investment Monitoring. Bain Capital Credit believes that closely monitoring financial performance and market developments of portfolio investments is critical to successful investment management. Accordingly, Bain Capital Credit is actively involved in an on-going portfolio review process. To the extent a portfolio investment is not meeting its plan, Bain Capital Credit takes corrective action when appropriate.

Bain Capital Special Situations Prior to making an investment, Bain Capital Special Situations analyzes a target investment’s position and prospects. The investment strategy will focus on detailed fundamental business, industry, and competitive diligence. Given the wide variety of assets and structures, not all steps in the investment process will apply to every investment analyzed. The dimensions of such investment strategy generally include the following: Market definition, sizing, trends. In evaluating potential investments, Bain Capital Special Situations completes an assessment of a market’s size and growth prospects, seeking to identify the primary drivers of growth (e.g., demographic trends, buying habits, technological shifts) and often use this to derive its own industry growth model. Competitive Advantage. Special Situations assesses the current and prospective competitors for each investment, with a focus on “reason to exist” and sustainability of competitive position. Contributors to this analysis include portfolio company executives and other industry contacts, competitors, suppliers, customers and regulators. This process seeks to create differential insights, positive or negative, relative to the views of other market participants. Margin Analysis and Quality of Earnings. Bain Capital Special Situations reviews a company’s historical performance, focusing on quality of earnings and sustainability or growth prospects for margins. Pricing and cost trend analysis and extensive benchmarking often identify important opportunities or issues. Quality of earnings is assessed through detailed financial statement analysis. Asset Valuation. Valuation analysis may include discounted cash flows, traded and transaction comparable values, sum-of-the parts valuations and liquidation valuations. Bain Capital Special Situations draws on Bain Capital’s global platform and local offices to provide market intelligence to refine our valuations. Bain Capital Special Situations usually seeks to pre-identify a buyer universe during the underwriting process. Corporate and Capital Structure. Bain Capital Special Situations reviews the corporate structure of each investment to understand the location of key assets and any competing claims. To the extent a given transaction doesn’t reset a capital structure, Bain Capital Special Situations will understand an issuer’s capitalization in detail, including debt serviceability, covenants, undertakings, intercreditor agreements, shareholder obligations etc. Third-party Diligence. As part of the diligence process, Bain Capital Special

Situations typically hires third-party firms to conduct commercial, accounting, tax, legal, technical and environmental diligence where appropriate. Risks Investing in loans, debt and equity securities (including special situations investments), and other types of assets involves a substantial degree of risk. Bain Capital Credit Clients are in a position to lose all or a significant portion of their investments, and Separate Account Clients and investors in Bain Capital Credit Funds must be prepared to bear the risk of loss, including total loss, of their investments. In addition, material risks relating to the investment strategies and methods of analysis described above, and to the types of securities typically purchased by or for Bain Capital Credit Clients in connection with those strategies and methods, include the following: Nature of Bain Capital Credit Client Investments

Competitive Environment The business of investing in assets meeting Bain Capital Credit Clients’ investment objectives is highly competitive. Competition for investment opportunities includes a growing number of non-traditional participants, such as hedge funds, private and public mezzanine, and subordinated debt funds, including business development companies, and other private investors, as well as more traditional lending institutions and competitors. Some of these competitors may have access to greater amounts of capital and to capital that may be committed for longer periods of time or may have different return thresholds than Bain Capital Credit Clients, and thus these competitors may have advantages not shared by Bain Capital Credit Clients. Increased competition for, or a diminishment in the available supply of, investments suitable for Bain Capital Credit Clients could result in lower returns on such investments. In addition, issuers may prefer to take advantage of favorable high yield or second-lien markets and issue subordinated debt in those markets, which could result in fewer investment opportunities for Bain Capital Credit Clients. Moreover, the identification of attractive investment opportunities is difficult and involves a high degree of uncertainty. Bain Capital Credit Clients may incur significant expenses in connection with identifying investment opportunities and investigating other potential investments which are ultimately not consummated, including expenses relating to due diligence, transportation, legal expenses and the fees of other third-party advisers.

Concentration of Investments Except as set forth in the applicable Advisory Agreement, Bain Capital Credit Clients are generally not limited in the amount of capital that may be invested in any one investment, industry or sector, geography, or similar category or asset class. The economy of a particular country in which Bain Capital Credit Clients may invest is influenced by economic and market considerations in other countries in the region, particularly emerging market countries, and the rest of the world. Investors' reactions to events in one country can have adverse effects on the securities of companies and the value of property and related assets in other countries in which Bain Capital Credit Clients may invest. As such, Bain Capital Credit Clients’ assets may not be diversified. Any such non-diversification would increase the risk of loss to a Bain Capital Credit Client if there were a decline in the market value of any security, category or asset class in which a Bain Capital Credit Client invested a large percentage of its assets. If a large portion of the assets of a Bain Capital Credit Client is held in cash or cash-like instruments, such Bain Capital Credit Client’s performance would likely be adversely affected. Investment in a non-diversified fund will generally entail greater risks than investment in a “diversified” fund.

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Bain Capital Credit currently provides investment advisory services to Bain Capital Credit Funds. Investment advice is provided directly to Bain Capital Credit Funds (subject to, in the case of Bain Capital Credit Partnerships, the direction and control of the General Partner of each Bain Capital Credit Partnership) and not individually to investors in any Bain Capital Credit Fund. Bain Capital Credit also

provides investment advisory and investment management services to various entities that are Separate Account Clients. In addition, Bain Capital Credit also provides certain resources and services to several of its subsidiaries. Except for the 1940 Act Funds, interests in Bain Capital Credit Funds are offered pursuant to applicable exemptions from registration under the Securities Act and the 1940 Act. Investors in Bain Capital Credit Funds (except for the 1940 Act Funds) include high net worth individuals, banks, thrift institutions, pension and profit-sharing plans, sovereign wealth funds, trusts, estates, charitable organizations, university endowments, corporations, limited partnerships, and limited liability companies or other business entities. Minimum investment commitments are established for limited partners in Bain Capital Credit Partnerships, which are no less than the legal eligibility requirements. Bain Capital Credit and, in the case of each Bain Capital Credit Partnership, the General Partner of such Bain Capital Credit Partnership, in its sole discretion, have in certain circumstances permitted investments that are less than the minimum investment commitment of such Bain Capital Credit Fund. Bain Capital Credit seeks to establish separately managed accounts with approximately a $100,000,000 base, although Bain Capital Credit, in its sole discretion, has in the past permitted, and has discretion to permit in the future, investments that are less than such amount.

Some, but not all, Bain Capital Credit Clients pay carried interest and other similar incentive fee arrangements (“Incentive Fees”). Additionally, certain investors in Bain Capital Credit Funds incur lower or no Incentive Fees. Incentive Fees often differ from one Bain Capital Credit Client to another, as well as among investors in the same Bain Capital Credit Fund. The payment by some, but not all, Bain Capital Credit Clients of Incentive Fees or the payment of Incentive Fees at varying rates (including varying effective rates based on the past performance of a Bain Capital Credit Client) creates an incentive for Bain Capital Credit to disproportionately allocate time, services, or functions to Bain Capital Credit Clients paying Incentive Fees or Bain Capital Credit Clients paying Incentive Fees at a higher rate, or allocate investment opportunities to such Bain Capital Credit Clients. Please see Item 10 (“Other Financial Industry Activities and Affiliations Related General Partners”) for additional information relating to how conflicts of interests are generally addressed by Bain Capital Credit. While certain Bain Capital Credit Clients and parallel vehicles, directly or indirectly, generally are expected to make each investment on a side-by-side basis, the structure of certain transactions and/or legal, tax, regulatory or other considerations, including ERISA, may result in a Bain Capital Credit Client or parallel vehicle not making an investment made by other Bain Capital Credit Clients or parallel vehicles or calling capital or investing or exiting in different proportions or on different terms or at different times than the other Bain Capital Credit Clients or parallel vehicles, in each case, as determined by Bain Capital Credit. As a result, the returns realized by one Bain Capital Credit Client or parallel vehicle may differ significantly from those of a different Bain Capital Credit Client or parallel vehicle.

Partners Various entities serve as General Partners. One of several limited liability companies serves as the General Partner or in a similar capacity of the General Partner of each Bain Capital Credit Partnership. Affiliated Advisers Bain Capital Credit has affiliated advisers based in the U.S., many of which focus primarily on a different area of investment management, although such areas overlap from time to time (such advisers, the “U.S. Affiliate Advisers”). Each U.S. Affiliate Adviser is registered as an investment adviser with the SEC. The U.S. Affiliate Advisers currently include but are not limited to: -

Bain Capital Crypto, LP, whose primary objective is investing capital, knowledge, and time to enhance protocol or company growth in crypto and blockchain technology sectors.

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Bain Capital Double Impact, LP, which focuses on equity investing in impact- or mission-oriented companies and more traditional companies with positive impact products and services;

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Bain Capital Insurance Solutions, LP, which advises private funds focused on investing in insurance companies, subadvises insurance dedicated funds, and provides certain advisory services to insurance companies;

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Bain Capital Life Sciences, LP, which focuses on equity investing in biopharmaceutical, medical device, diagnostics, and enabling life science technology companies;

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Bain Capital Private Equity, LP, which focuses on leveraged buyouts and growth capital in a wide variety of industries;

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Bain Capital Real Estate, LP, whose primary objective is to research and advise on real estate and real estate-related investments;

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Bain Capital Tech Opportunities, LP, which focuses on equity investing in technology and technology-enabled companies;

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Bain Capital Ventures, LP, which focuses on seed through late-stage growth equity investing in software, hardware, information, healthcare, and technology-driven business services companies;

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Bain Capital Asset Management, LP, (“BCAM”) which focuses on providing alternative investment opportunities to current and former personnel of Bain Capital and invests primarily in third-party private fund managers via managed funds of funds and direct investments. In addition, BCAM related persons also serve as the general partners to investment vehicles whose primary purpose is to invest in, or coinvest with, funds managed by the Advisers and other Affiliate Advisers (as defined below) for the benefit of employees and former employees of Bain Capital, LP and its affiliates. BCAM also provides certain advisory services to insurance company clients and subadvises insurance dedicated funds.

In addition to the U.S. Affiliate Advisers, Asset Resurgence Mauritius Manager, Bain Capital (Singapore) Pte. Ltd., Bain Capital (UK) Limited, Bain Capital Advisors (India) Pvt. Ltd., Bain Capital Asset Manager Mauritius, Bain Capital Credit (Asia) Ltd., Bain Capital Credit (Australia) Pty. Ltd., Bain Capital Credit, Ltd., Bain Capital Investments (Europe) Ltd., Bain Capital Investments (Ireland) Ltd., Bain Capital Investments (Luxembourg) Sarl, Bain Capital Private Equity (Asia) Ltd., Bain Capital Private Equity (Europe), LLP, Bain Capital Private Equity (Japan), LLC, and India Resurgence Asset Management Business Pvt. Ltd., affiliates of Bain Capital, are licensed in their applicable jurisdictions with various regulators (together with the U.S. Affiliate Advisers, the “Affiliate Advisers”). The Affiliate Advisers’ investment activities are generally conducted independently, but the Affiliate Advisers may provide sourcing opportunities and access to vertical industry expertise to Bain Capital Credit. Bain Capital has established other non-investment advisory related entities which

are affiliates of the Affiliate Advisers. These entities do not provide investment advisory services and have been organized primarily to provide services incidental to the services of the Affiliate Advisers. Affiliated Broker-Dealer Bain Capital Markets is an affiliated broker-dealer registered with the SEC and is a member of FINRA. Bain Capital Markets places securities and instruments issued by certain private investment funds that Bain Capital Credit and its affiliates manage and provides certain Capital Markets Services (as defined above) for certain portfolio companies of such private investment funds. Affiliated Insurance Business Federal Life Group, Inc. (together with its subsidiaries, “Federal Life”) is an insurance carrier that provides life, health, and annuity products across individual and institutional markets. Conflicts of Interest The discussion below reflects both historical and current practices of Bain Capital Credit and Bain Capital Credit Clients. Practices vary among Bain Capital Credit Clients. Please refer to the governing and/or disclosure documents of the applicable Bain Capital Credit Clients for details regarding these practices. As a diversified investment firm, Bain Capital and its affiliates, including Bain Capital Credit, engage in a broad range of activities, including investment activities for their own account (such as co-investment vehicles) and for the account of other investment funds or accounts and provide advisory, management and other services to funds and operating companies. The funds and accounts managed by the Affiliate Advisers are referred to as “Related Clients.” 5 In the ordinary course of conducting its activities, the interests of a Bain Capital Credit Client will, on occasion, conflict with the interests of Bain Capital Credit, other Bain Capital Credit Clients, Related Clients, or their respective affiliates. Resolution of Conflicts of Interest Bain Capital Credit and each of the other Affiliate Advisers will deal with all conflicts of interest using its best judgment, but in its sole discretion. When For purposes of this Form ADV, references to Related Clients should not be read to include credit investment vehicles managed by Bain Capital Investments (Europe), Ltd.

conflicts arise between a Bain Capital Credit Client and Related Clients, Bain Capital Credit will represent the interests of the Bain Capital Credit Client, and the other participating Affiliate Adviser will represent the interests of the other Related Client it advises. In resolving conflicts, Bain Capital Credit and the other Affiliate Advisers will generally consider various factors, including the interests of the course of dealing among Bain Capital Credit Clients and the Related Clients. Bain Capital has a firm-level Allocation Committee (the “Allocation Committee”) that oversees the process and ultimate allocations for investment opportunities that touch more than one Affiliate Adviser (i.e., pursued jointly or separately) and serves as an escalation point for potential conflicts of interest between and among Affiliate Advisers. The Allocation Committee generally does not oversee allocations of investments with advisers, as those are governed by respective adviser allocation protocols (as applicable). The Allocation Committee is comprised of senior Bain Capital personnel. From time to time, the Advisers and the Affiliate Advisers may determine to refer certain conflicts of interest to the Allocation Committee (for review and resolution, particularly in situations where the Advisers and the Affiliate Advisers are unable to resolve such conflicts. Similarly, the Allocation Committee may in its sole discretion determine to review and make determinations regarding certain conflicts of interest. When conflicts arise between a Bain Capital Credit Client and another Bain Capital Credit Client, Bain Capital Credit will resolve the conflict. In doing so, it will generally consider various factors, including the interests of such Bain Capital Credit Client and the other Bain Capital Credit Client with respect to the immediate issue and/or with respect to the longer-term course of dealing among Bain Capital Credit Clients. In the case of all conflicts involving a Bain Capital Credit Client, Bain Capital Credit’s determination as to which factors are relevant, and the resolution of such conflicts will be made in Bain Capital Credit’s sole discretion. There can be no assurance that Bain Capital Credit will be able to resolve all conflicts in a manner that is favorable to each Bain Capital Credit Client. While Bain Capital Credit has procedures in place designed to mitigate conflicts of interest among Bain Capital Credit Clients and other Related Clients, there can be no guarantee that these procedures will be successful. Sources of Conflicts of Interest There are numerous perceived and actual conflicts of interest among and between Bain Capital Credit, the Affiliate Advisers, other Related Clients and Bain Capital Credit Clients. The conflicts of interest that may be encountered by a Bain Capital Credit Client include those discussed below, although such discussion does not describe all of the conflicts that may be faced by such Bain Capital Credit Client. Other conflicts are discussed throughout this document and this document should be read in its entirety for other conflicts. Dealing with conflicts of interest

is complex and difficult, and new and different types of conflicts are likely to subsequently arise. Conflicts Relating to the General Partner, Bain Capital Credit and Certain Affiliate Advisers

Bain Capital Credit Personnel Personnel responsible for managing Bain Capital Credit Clients have responsibilities with respect to other funds or accounts managed by Bain Capital Credit, including funds and accounts that are raised in the future. Under resource sharing agreements, Bain Capital Credit, LP has agreed to provide resources to BCSF Advisors, LP, Bain Capital Credit U.S. CLO Manager, LLC, Bain Capital Credit CLO Advisors, LP, and Bain Capital Credit U.S. CLO Manager, LP, which will enable them to fulfill their obligations under the applicable Advisory Agreements. The resource sharing agreements provide that Bain Capital Credit, LP will make available experienced investment professionals and access to other resources for purposes of evaluating, negotiating, structuring, closing, and monitoring investments. Substantial time will be spent by such officers and employees monitoring the investments of other vehicles managed by Bain Capital Credit. In addition, certain members of Bain Capital Credit Clients’ investment committees could be personnel of other Affiliate Advisers. Similarly, certain Bain Capital Credit personnel have responsibilities serving on the investment committees of other Affiliate Advisers and perform other work for Affiliate Advisers. Such individuals have responsibilities to such other Affiliated Advisers and with respect to other current or future Related Clients advised or managed by such Affiliated Advisers, including funds or accounts that may be eligible to invest in assets eligible for purchase by Bain Capital Credit Clients, as well as to the portfolio companies and investment activities of such Related Clients. Conflicts of interest may arise if these personnel do not have adequate time or resources available to support both Bain Capital Credit and the relevant Affiliated Adviser. Personnel have an incentive to allocate more time, services, or functions to Bain Capital Credit Clients and/or Related Clients from which such personnel derive a higher economic benefit.

Advisory Services to the Bain Capital Credit Clients, Portfolio Companies and Investment Vehicles Bain Capital Credit and/or its affiliates are expected to perform a variety of services for or in respect of and will receive fees or other compensation in respect of such services from, actual or prospective portfolio companies or investment or holding vehicles of Bain Capital Credit Clients (including insurance companies)

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Personal Trading Code of Ethics Bain Capital Credit has adopted a Code of Ethics policy (the “Code of Ethics”) for its personnel. The Code of Ethics describes personnel standard of conduct and fiduciary duties and limits personal trading by its personnel and their immediate family/household members in a wide range of securities, including common and preferred stock, debt instruments, securities that are convertible or exchangeable for equity or debt securities, derivative instruments, and certain registered investment vehicles with which Bain Capital Credit and its subsidiaries has entered into a sub-advisory relationship. Personnel must report every account that they or their immediate family member use for trading securities covered by the Code of Ethics and, if they directly or indirectly influence or control trading in the account, they must generally pre-clear covered securities transactions and have copies of trade confirmations and periodic account statements sent by their broker to the Bain Capital Compliance Department. Controlled trading by personnel and their immediate family/household members is prohibited in a wide range of securities that appear on restricted lists and confidential watch lists, and additional steps are taken to ensure that personnel and their immediate family/household members are not permitted to trade for their personal account in securities selected for Bain Capital Credit Clients and to ensure personnel do not engage in “front-running” of the Bain Capital Credit Clients’ investment opportunities. Personnel are required to promptly report any violation of the Code of Ethics , of which they become aware. Personnel are required to annually certify compliance with the Code of Ethics . A copy of the Code of Ethics is available to Bain Capital Credit Clients, prospective clients, limited partners, and prospective limited partners of a Bain Capital Credit Partnership during the investment due diligence process. A copy may be obtained by contacting the Bain Capital Credit Compliance Department. Related Person Investment For further detail regarding circumstances in which Bain Capital Credit or a related person (a) recommends to clients, or buys or sells for client accounts, securities in which Bain Capital Credit or a related person has a material financial interest, (b) invests in the same securities that Bain Capital Credit or a related person recommends to clients, or (c) recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that Bain Capital Credit or a related person buys or sells the same securities for Bain Capital Credit’s own

(or the related person’s own) account, as well as related conflicts of interest, please see “Code of Ethics” above. In addition, Bain Capital Credit personnel may buy securities in transactions offered to but rejected by Bain Capital Credit Clients. Such transactions are subject to the policies and procedures set forth in Bain Capital Credit’s Code of Ethics. The investment policies, fee arrangements, and other circumstances of these investments may vary from those of the Bain Capital Credit Clients. If Bain Capital Credit personnel have made large capital investments in or alongside the Bain Capital Credit Clients, they may have conflicting interests with respect to these investments. For further details regarding these arrangements, as well as related conflicts of interest, please see Item 10 (“Other Financial Industry Activities and Affiliations Related General Partners”).

In choosing broker-dealers for execution of securities transactions, Bain Capital Credit, or a related person of Bain Capital Credit, considers various relevant factors, including without limitation, pricing terms offered by the broker-dealer, the ability of the broker-dealer to deliver prompt and reliable execution, the size and type of the transactions, the nature and character of the market for the securities, operational efficiency with which transactions are effected, the brokerdealer firm’s financial stability, confidentiality, back office stability, trading desk capacities, referrals, custody, settlement, familiarity with derivative securities strategies, and the overall value and quality of the services offered by the brokerdealer firm. Bain Capital Credit receives research, statistical and quotation services, data, information, and other services and materials that assist Bain Capital Credit in the performance of its investment advisory responsibilities from broker-dealer firms that execute transactions for Bain Capital Credit Clients. Where such services are provided, Bain Capital Credit may agree to compensate such broker-dealer or third party in either “hard” dollars (directly paid by Bain Capital Credit, although certain Advisory Agreements and Sub-Advisory Agreements permit some or all of such costs to be borne by the relevant Bain Capital Credit Client), “soft dollars” (commission generated) or some combination of the two. A broker-dealer providing such research services will at times receive a commission that is in excess of the amount of commission another broker-dealer would have received for effecting that transaction, provided Bain Capital Credit determines in good faith that such commission was reasonable in relation to the value of the research and brokerage services provided by the broker-dealer. Any such research service could be broadly useful and of value to Bain Capital Credit in rendering investment advice to all or a significant portion of the Bain Capital Credit Clients, or could be relevant and useful for the management of one Bain Capital Credit Client’s account

or only a few Bain Capital Credit Clients’ accounts, regardless of whether such account or accounts paid commissions to the broker-dealer through which the research service was provided. Bain Capital Credit will only make securities transactions that it in good faith believes are in the best interest of the Bain Capital Credit Client. A conflict of interest exists when a broker-dealer provides such research services, as Bain Capital Credit will have an incentive to favor such broker-dealer over others that charge lower commissions. To address this conflict, Bain Capital Credit will consider the reasonableness of commission rates or spreads charged by other market participants for similar transactions. While it may enter into such agreements in the future, Bain Capital Credit does not currently utilize any soft dollar arrangements.

Directed Brokerage If a Separate Account Client requests or directs Bain Capital Credit to place transactions for its separate account with one or more specified broker-dealers (“Directed Brokerage”), Bain Capital Credit will accept Directed Brokerage arrangements only if certain conditions are satisfied, including that the Separate Account Client’s directions are furnished in writing and that Bain Capital Credit has informed the Separate Account Client in writing that the use of directed brokerage arrangements will at times deprive the Separate Account Client of benefits that might otherwise be obtained by aggregating the Separate Account Client’s order with orders for other Bain Capital Credit Clients and, as a result, will likely cause the Separate Account Client to pay a higher commission rate or receive less favorable execution than if Bain Capital Credit had discretion to select the broker or to negotiate the commission rate.

Aggregation of Trades Bain Capital Credit aggregates orders of more than one Bain Capital Credit Client for the purchase or sale of the same security or loan. Portfolio managers and traders often employ this practice because larger transactions generally enable them to obtain better overall prices, including lower commission costs or markups or mark-downs. In such cases, Bain Capital Credit generally aggregates trade orders for securities and loans so that each participating Bain Capital Credit Client will receive the average price for each execution of a transaction. When aggregating trades, Bain Capital Credit follows trade allocation protocols, which generally provide that such allocation is made on a pro rata/minimum allocation basis based on order size among participating Bain Capital Credit

Clients. 8 Certain exceptions will, however, be made in such allocation provided that such exceptions are to ensure that accounts are treated in a fair and equitable manner, taking into account each Bain Capital Credit Client’s best interests and to mitigate or prevent any favoring or disfavoring of any Bain Capital Credit Client or group of Bain Capital Credit Clients, and that such allocation is consistent with Bain Capital Credit’s fiduciary duties, its duty of best execution, and contractual obligations. For example, such steps can include increasing certain accounts’ allocations to meet minimum denominations for particular securities and thereby reducing the allocation amount of other participating vehicles. Other exceptions to pro rata allocations/minimum allocations will be undertaken to deal with new issue allocations (including ramp-up status of certain investment vehicles), regulatory restrictions, mandate constraints, odd lots, rounding, or other circumstances that may occur from time to time. In some situations, including certain follow-on transactions or amendments, Bain Capital Credit may consider a vehicle’s pre-existing holdings in determining the final trade allocation. Circumstances also may arise when Bain Capital Credit needs to reallocate a trade to another Bain Capital Credit Client after its initial allocation but before the settlement date. The security is typically reallocated at the original transaction price. For additional information regarding the allocation of investments among Bain Capital Credit Clients and Clients of the non-Bain Capital Credit Affiliated Advisers, please see Item 10 (“Other Financial Industry Activities and Affiliations Related General Partners”). If an order for a publicly traded security for more than one Bain Capital Credit Client cannot be executed, allocation shall be made based on Bain Capital Credit’s procedures for allocation of investment opportunities, as described in Item 10 above.

For details regarding economic benefits provided to Bain Capital Credit by nonclients, including a description of related conflicts of interest, please see Item 10 (“Other Financial Industry Activities and Affiliations Related General Partners”). In addition, Bain Capital Credit and its related persons will, in certain instances, receive discounts on products and services provided by portfolio companies.

In relation to two equity ownership reports that were inadvertently filed late in 2020 and 2022, an affiliate of Bain Capital Credit, LP, in September 2024,

voluntarily agreed, without admitting any wrongdoing, to pay a penalty as part of a settlement with the SEC. Under Section 13(D) of the Securities Exchange Act of 1934, and related rules in effect during this time, any person who has acquired beneficial ownership of more than 5% of certain equity securities must file, within 10 days, a disclosure statement with the SEC. There is no state of mind requirement for Section 13(D) reporting requirements. As the SEC found, in some private credit transactions, entities may not have knowledge of their precise holdings in an issuer until after a transaction closes, which in these instances affected the timely monitoring of changes to holdings of public securities. The SEC alleged that during the global COVID-19 pandemic, the affiliate’s internal processes did not timely identify the need to make these ownership filings, and as a result, the affiliate inadvertently filed the Schedule 13D reports for these transactions late. The SEC considered that the affiliate of Bain Capital Credit, LP took remedial steps and recognized its cooperation in the matter. The penalty was paid by the affiliate of Bain Capital Credit, LP and was not borne by any of its funds or investors in its funds.

Oversight and Monitoring The portfolio investments of each Bain Capital Credit Client are continuously reviewed by a team of investment professionals. The team includes partners and other investment professionals of Bain Capital Credit. Bain Capital Credit closely monitors the investments of Bain Capital Credit Clients and generally maintains an ongoing oversight position in such portfolio investments.

In some circumstances, due to regulatory considerations related to the 1940 Act, the 1940 Act Funds may not be considered eligible Bain Capital Credit Clients for allocation purposes. These same considerations could, in limited circumstances, result in certain non-1940 Act Funds also not being considered eligible Bain Capital Credit Clients.

Reporting Investors in the Bain Capital Credit Partnerships typically receive, among other things, a copy of audited financial statements of the relevant Bain Capital Credit Partnership within 120 days after the fiscal year end of such Bain Capital Credit Partnership . In addition, investors will receive regular reporting updates through quarterly letters, investor meetings, and other materials provided on the investor website. Bain Capital Credit and the General Partner of a Bain Capital Credit Partnership will, from time to time, in their sole discretion, provide additional information upon request relating to such Bain Capital Credit Partnership to one or more limited partners of such Bain Capital Credit Partnerships as it deems appropriate. Investors in the CLOs typically receive, from the relevant trustee and among other things, quarterly reports detailing the aggregate principal balance of the relevant CLO’s portfolio of assets and the interest and other proceeds received by such CLO from such assets and available for distribution to investors, the aggregate outstanding amount of such CLO’s outstanding debt, and details regarding certain expenses incurred by such CLO. Separate Account Clients and 1940 Act Funds generally negotiate reporting requirements specific to their account. In the event of individually negotiated terms for Separate Accounts Clients and 1940 Act Funds, Bain Capital Credit will provide the reporting mutually agreed to by the parties as evidenced in their Advisory Agreement.

Bain Capital Credit has determined that it has custody of Bain Capital Credit Partnerships’ assets for purposes of the Advisers Act, as Bain Capital Credit is a related person of the General Partner of each such Bain Capital Credit Partnership. Bain Capital Credit does not maintain custody of Separate Account Clients or CLO assets. With respect to the 1940 Act Funds, personnel shall only have power and authority as provided for in the Advisory Agreement or Sub-Advisory Agreement with such 1940 Act Fund and/or such 1940 Act Fund’s Board of Directors. It is the policy of Bain Capital Credit to comply with the Advisers Act requirements in

respect of the assets of any such Bain Capital Credit Partnership. To the extent the assets of a Bain Capital Credit Partnership are held by one or more custodial banks, such custodial banks maintaining such Bain Capital Credit Partnership assets send account statements to an independent representative of investors in the Bain Capital Credit Partnerships, who compares the account statement received from the custodial bank to the account statements Bain Capital Credit Partnerships delivers to investors. In certain other instances, Bain Capital Credit, in addition to the account statements sent by a qualified custodian, provides account statements directly to the limited partners of Bain Capital Credit Partnerships. Limited partners of Bain Capital Credit Partnerships should compare the account statements received from Bain Capital Credit with the account statements received from the qualified custodian. In accordance with SEC guidance, with respect to certain investments in privately offered securities, a specified custodian may hold only documentation relating to or referencing such investments but not the actual investment itself, and/or investments of a Bain Capital Credit Partnership may not be registered in the name of the custodian. Consequently, the custodian may not have control over the disposition of such investments, or the ability to direct delivery of sale proceeds or other distributions from such investments to the custodian. Further, for such investments, the custodian may not have the ability to validate or reconcile ownership of the investment with any third party, including the issuer.

Bain Capital Credit provides investment advisory services to each of the Bain Capital Credit Partnerships pursuant to the Advisory Agreements. Investment advice is provided by Bain Capital Credit directly to the Bain Capital Credit Partnerships, subject to the direction and control of the affiliated General Partner of such Bain Capital Credit Partnership and not individually to investors in Bain Capital Credit Partnerships. Any restrictions on investments in certain types of securities are established by the General Partner of the applicable Bain Capital Credit Partnership and set forth in the offering documentation provided to each limited partner prior to investment in a Bain Capital Credit Partnership. Bain Capital Credit provides investment management services to each Separate Account Client in accordance with the terms and conditions of the applicable Advisory Agreement. The terms of these documents are generally established at the time of the formation of the applicable separate account and are the result of negotiations with the applicable Separate Account Client. Bain Capital Credit provides collateral management services to each CLO in accordance with the terms and conditions of the applicable Collateral Management Agreement and other related documents of each such CLO. The

terms of the Advisory Agreements and other related documents of each CLO are generally established at the time of the formation of the applicable CLO and are the result of negotiations with certain potential investors in the applicable CLO. Bain Capital Credit provides investment advisory services to each 1940 Act Fund in accordance with the relevant 1940 Act Fund’s investment policies and restrictions, as stated in each 1940 Act Fund’s most current prospectus and statement of additional information.

Bain Capital Credit intends to vote proxies or similar corporate actions in accordance with the best interests of the applicable Bain Capital Credit Client, considering such factors as it deems relevant in its sole discretion. Upon receipt of a proxy request, Bain Capital Credit’s operations department contacts the senior investment professional responsible for the issuer. The senior investment professional reviews the information, determines what is in the best interests of the Bain Capital Credit Client, and ensures the vote is completed in a timely manner. Conflicts of interest will arise from time to time in relation to proxy voting requirements. Bain Capital Credit’s proxy voting policy is designed to ensure that, if a material conflict of interest is identified in connection with a particular proxy vote, the vote is not improperly influenced by the conflict. Bain Capital Credit shall monitor all proxies for any potential conflicts of interest. If a material conflict of interest arises, Bain Capital Credit will determine what is in the best interests of the relevant Bain Capital Credit Client and will seek to take appropriate steps to eliminate any such conflict. A detailed summary of Bain Capital Credit’s proxy voting policies and procedures are available to Bain Capital Credit Clients, prospective clients, limited partners, and prospective limited partners of a Bain Capital Credit Fund during the investment due diligence process, a copy of which may be obtained from Bain Capital Credit’s Corporate Actions Department. Existing Bain Capital Credit Clients may obtain copies of relevant proxy logs, identifying how proxies were voted in connection with a Bain Capital Credit Client, and copies of proxy voting policies and procedures upon written request to: Bain Capital Credit, LP 200 Clarendon Street Boston, MA 02116 Attn: Corporate Actions

Item 18. Financial Information

Item 19. Requirements for State-Registered Advisers