Bandera Partners LLC

Overview of Bandera Bandera Partners LLC (“Bandera” or the “Firm”) provides investment advisory services to Bandera Master Fund L.P. (“Master Fund”), and its U.S.-based feeder fund, Bandera Value Fund LLC (“Onshore Fund”). Bandera makes its investment decisions through the Master Fund. Bandera Partners Management LLC, an affiliate of Bandera, serves as the general partner of the Master Fund (the “General Partner”). Bandera Offshore Value Fund Ltd., a Cayman Islands exempted company (the “Offshore Fund”), is an additional feeder fund that invests in the Master Fund. Participation in the Offshore Fund by investors that are individual retirement accounts subject to Section 4975 of the U.S. Internal Revenue Code of 1986, as amended, is “significant.” Bandera Offshore Value Fund Ltd. (the “Offshore Fund”) is structured to invest substantially all of its assets in the Master Fund and it has no flexibility to make any other investments. The inclusion of the Offshore Fund as a private fund in this Form ADV is not to be deemed an admission that Bandera or any of its related persons is a fiduciary of the Offshore Fund or any investor in the Offshore Fund with respect to the Offshore Fund’s assets for purposes of the Employee Retirement Income Security Act of 1974, as amended, or the Internal Revenue Code of 1986, as amended. The Master Fund, the Onshore Fund and the Offshore Fund are collectively referred to herein as the “Funds.” Presently, neither Bandera nor the General Partner has any advisory clients other than the Funds. Bandera Partners LLC is a Delaware limited liability company founded in 2006 by Gregory Bylinsky, Jefferson Gramm and Natalie Banas. Bandera began providing investment advisory services to the Master Fund in November 2006. Bandera’s clients are solely Funds, and as such, Bandera does not tailor its advisory services to the needs of individual investors. Bandera generally does not accept investor restrictions on taking positions in certain types of securities. Advisory Services Provided by Bandera Bandera, on behalf of the Master Fund, primarily seeks to make investments that will achieve long-term growth of capital, with dividends and income being secondary considerations. Bandera seeks to commit capital as a long-term shareholder to companies whose market capitalizations are significantly below their intrinsic value, and to make investments in special situations, such as spin-offs and reorganizations. Bandera’s strategies are implemented using fundamental analysis of companies and financial statements. This fundamental analysis yields Bandera’s estimate of a company’s intrinsic value, which is necessarily measured using a combination of objective and subjective factors. Some of those factors include an assessment of the company’s business model and markets, the quality of management and other risks associated with the projected future stream of

earnings. The Master Fund will typically hold between five and thirty stocks at any given time. The Master Fund will invest in companies of any market capitalization. A key part of Bandera’s approach is to concentrate its analytical resources on companies that are likely to be undervalued. Bandera seeks investments that it believes present a low risk of permanent capital loss. Bandera undertakes intensive research on companies that are candidates for inclusion in the Master Fund. Bandera typically examines in detail the financial statements and business model of a company, as well as a company’s industry as a whole. Companies chosen from this process for inclusion in the Master Fund’s portfolio generally will be perceived by Bandera to be trading at a significant discount to their intrinsic value, be reasonably financially stable, possess some advantage or advantages over other companies in their industry (e.g., they have a legal or geographic product protection, they are the lowest-cost producer or they have a superior product), and have the potential for significant appreciation in their stock price over time. Bandera particularly seeks stable and growing companies that generate significant amounts of free cash flow. Bandera also seeks out special situations, such as opportunities arising from corporate mergers, spin-offs, bankruptcies, restructurings, distressed debt and other events, to incorporate into the Master Fund’s portfolio. Bandera particularly seeks special situations that it believes are minimally correlated with the direction of the broader securities markets. Up to 100% of the Master Fund’s portfolio may be invested at any time in special situations, and the Master Fund may from time to time use leverage, short selling and warrants, options and other securities to take advantage of special situations. Such investments may also be in thinly traded, low-priced and low market value securities that carry risks of illiquidity and delisting (see Item 8 below). From time to time, Bandera may take an activist stance in selected investments where Bandera believes that activism may greatly increase profit potential. Activist investments can be time-consuming and often require meeting with company management and other investors, sending public letters to company management and boards of directors, and on some occasions, becoming directors of companies. Although Bandera generally seeks to invest for the long term (with the exception of many special situations), Bandera may sell securities regardless of how long the securities have been held, especially in cases where the fundamentals of a company have changed. Bandera may also change the investment strategies of the Master Fund if it believes that such change is in the interest of the Master Fund. Bandera generally sells a stock when it reaches or exceeds Bandera’s estimate of its intrinsic value. Bandera’s purchase and sale decisions will generally be made without regard to tax ramifications, but it expects to generally implement a mid- to low-turnover, long-term holding strategy. The Master Fund primarily invests in the securities of U.S. and non-U.S. companies but may also engage in other transactions to the extent deemed appropriate by Bandera, including, without limitation, transactions involving closed-end and open-end mutual fund shares, risk arbitrage, private equity and control situations,

“going private” issuers, bonds, options and cash equivalents, private placements and direct or indirect investments in intellectual property assets, viatical settlements or litigation claims, as well as – to a limited extent – transactions involving (i) foreign currency forward contracts, options on foreign currencies and foreign currencies related thereto and (ii) commodity futures contracts, options on commodity futures contracts, and commodities. The Master Fund may also sell securities short and purchase securities on margin and may acquire exposure to certain securities synthetically through swaps or contracts for differences (CFDs) or similar instruments. Certain of the above investments may be illiquid and/or difficult to value. Bandera may cause the Master Fund to depart from its normal investment policies—for instance, by allocating all or substantially all of the Master Fund’s assets to cash reserves— in response to extraordinary market, economic, political or other conditions. There is no assurance that the performance goals of the Master Fund will be realized. Ownership of Bandera Bandera’s principal owners (the “Principals”) are its two Managing Partners, Jefferson Gramm and Gregory Bylinsky. Client Assets Under Management As of December 31, 2025, the net asset value of client assets managed by Bandera on a discretionary basis was approximately $244.1 million. Bandera does not currently manage any client assets on a non-discretionary basis.

The information set forth below details the fees, expenses and compensation borne by the Funds. Description

Amount

When Paid

Brokerage and transaction costs and investmentrelated expenses

As incurred by the Master Fund. The As billed Onshore Fund and the Offshore Fund will bear their pro rata share of all such costs and expenses incurred in connection with the Master Fund’s investment activities.

Management fee

The Master Fund pays Bandera a monthly Monthly in arrears management fee equal to 1/12th of one percent (approximately 1% annually) of the net asset value of the Master Fund as of the last business day of each calendar month (before giving effect to any monthend redemptions and distributions), adjusted for certain amounts indicated

below. For purposes of calculating the management fee, the net asset value of the Master Fund is determined before reduction for the management fee and performance-based fees accrued or payable as of the calculation date. In certain circumstances, management fees will be prorated. The Onshore Fund and the Offshore Fund will bear their pro rata share of the management fees. Seed investor fees and other participations in net management fee income are allocated to the Funds’ seed investors on an ongoing basis. All such amounts effectively reduce the management fees payable to Bandera, and the total of such amounts and the management fees payable to Bandera do not exceed 1% annually. Administration fees and expenses

Fees payable to the Master Fund Monthly in arrears administrator by the Master Fund are charged at the administrator’s customary rates for the performance of the administrative services and the provision of corporate offices. Fees of the administrator vary with the size of the Master Fund, subject to an annual minimum fee. In addition, the Funds will reimburse their respective administrators for certain out of-pocket expenses. The Onshore Fund and the Offshore Fund will bear their pro rata share of such fees and expenses.

Legal, audit, and ongoing offering expenses, banking fees, and operational and extraordinary fees and expenses.

As incurred by the Funds. The Onshore As billed Fund and the Offshore Fund will bear their pro rata share of all fees and expenses incurred by the Master Fund, as well as such entity’s own fees and expenses.

Bandera, in its sole and absolute discretion, may waive, reduce or grant rebates of the management fees chargeable with respect to certain investors.

Advisory fees are not paid in advance; therefore redeeming investors are not owed a refund. Investors in the Funds are charged profit allocations, which are described in greater detail in the relevant Fund’s offering memorandum and below.

Analysis Methods and Investment Strategies Information regarding the methods of analysis and investment strategies of Bandera employed in providing investment advisory services to the Master Fund is described above in Item 4. Material Risk Factors Investment in the Funds is speculative and is suitable only for investors who can tolerate substantial risks. An investor may lose some or all of its investment. There is no assurance that the Funds will be successful and will achieve their investment objectives. A subscription for Shares should be considered only by sophisticated investors who have carefully read the Offering Memorandum(s), which contains a more complete description of the risk factors associated with the investment, and who understand the risks involved. An investment in the Funds should be made only after consulting with independent, qualified sources of investment, legal, tax, accounting and other advice. The risks of investing in the Funds include, without limitation, those set forth below. Dependence on Investment Manager and Key Personnel The investment activities of the Funds will be conducted exclusively by Bandera. Members will not have the opportunity to evaluate fully for themselves relevant economic, financial and other information regarding the investments of the Funds. The Funds may choose not to disclose to Members the individual securities or other investments held by the Funds. Members are dependent on the Bandera’s judgment and abilities. Accordingly, no person should invest in the Funds unless he or she is willing to entrust all aspects of the investment activity of the Funds to Bandera. The Funds rely in large measure on Bandera’s qualitative and quantitative analysis to invest in equities and other securities and investments. No assurance as to the future performance of the Funds can be provided. To the extent that Bandera’s decisions are incorrect, the Funds’ portfolio will be subject to loss. Furthermore, the death, incapacity or retirement of Gregory Bylinsky or Jefferson Gramm may adversely affect investment results. Market Risk The performance of the Master Fund is dependent in part on the performance of the securities markets. Specifically, the Master Fund is subject to market risk, including the possibility that stock prices overall will decline over short or even long periods. Stock market gyrations may lead to losses in the Master Fund, and losses may occur frequently and over a significant period of time. Market movements are difficult to predict and are influenced by many factors. Bandera believes that investment in the Funds is appropriate only for investors with an investment horizon of a minimum of three years, and Bandera discourages investments by short-term investors. The Funds are also subject to investment style risk, which is the possibility that returns from value stocks will trail returns from other asset classes, investment styles or the overall

stock market. “Value” stocks (as typically categorized by reference to value indexes or value factors) tend to go through cycles of doing better—or worse—than common stocks in general. These periods have, in the past, lasted for as long as several years. Because of the nature of the Master Fund’s investment activities, the results of the Funds’ operations may fluctuate from month to month and from period to period. Accordingly, investors should understand that the results of a particular period may not necessarily be indicative of results in future periods. Economic Conditions The success of the Master Fund’s investment activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, changes in laws, technological developments and national and international political circumstances, trade wars, governmental or regulatory intervention in capital markets, currency exchange controls and failures of major financial institutions, as well as changes in the financial condition of the issuers of the Master Fund’s investments and the Master Fund’s brokers and dealers and other custodians and counterparties due to other factors. Such conditions may affect the level and volatility of securities prices and the liquidity of the Master Fund’s investments. Volatility or illiquidity in the financial markets could impair the Master Fund’s profitability or result in losses. The Master Fund may maintain substantial investment positions that can be adversely affected by such volatility or illiquidity; the larger the positions, the greater the potential for loss. Moreover, economic slowdowns or downturns may lead to losses. Risk of Epidemics and Pandemics The value of the Master Fund’s investment portfolio may decline due to disruptions caused by the spread of large-scale epidemics and pandemics. Future health crises and the governmental and social responses intended to minimize their impact, may cause significant disruptions to global and national economies and result in instability in the financial markets. New outbreaks could cause additional, extended or more restrictive quarantines, business and school shutdowns, mass cancellations of events and travel, substantial reductions in consumer demand and the volume of business activity and financial transactions, labor shortages, further supply chain and distribution channel interruptions, and disruptions in the provision of healthcare services, any of which may contribute to economic and financial market instability. In addition to contributing to general economic disruptions and financial market instability, any large-scale epidemic or pandemic may adversely affect underlying portfolio companies more directly, including by negatively impacting (i) their respective operating statuses and their employees, (ii) their supply chains and distribution channels, (iii) the ability of their customers to conduct business with them, and (iv) the industries in which they operate generally, all of which could have a significant impact on their financial conditions. Issuers may experience reduced cash flows and the loss of key employees due to decreased demand for products or services.

Concentration Risk The Master Fund will generally maintain between five investments and thirty investments at any one time. The Master Fund may hold one or more positions that are relatively large in relation to the Master Fund’s capital and are concentrated in a single issuer or a group of related issuers in a single industry. The result of such concentration of investments is that a loss in any one such position could materially reduce the Master Fund’s capital. Purchases of Securities as Value Investments Bandera will purchase securities that it believes are significantly undervalued. There can be no assurance that securities that Bandera believes are undervalued will in fact prove to be undervalued, or that undervalued securities will increase in value. Equity Securities Generally Bandera is permitted to invest in common and preferred stock and other equity securities, including both public and private equity securities. Equity securities generally will be subordinate to the debt securities and other indebtedness of the issuers of such equity securities. Prices of equity securities generally fluctuate more than prices of debt securities and are more likely to be affected by developments in the issuer’s business, poor economic or market conditions, general stock market fluctuations, inclusions in and deletion from market indexes, and changes in market confidence and perceptions of their issuers. Investor perceptions are based on various and unpredictable factors, including expectations regarding governmental, economic, monetary and fiscal policies, inflation and interest rates, economic expansion or contraction, and global or regional political, economic or financial crises. In some cases, the issuers of such equity securities may be highly leveraged or subject to other risks such as limited product lines, markets or financial resources. Some of the small and mid-cap issuers of equity securities in which the Master Fund may invest may be more vulnerable than larger companies to adverse business or market developments, may have limited markets or financial resources and may lack experienced management. In addition, some equity securities may be illiquid. Due to perceived or actual illiquidity or investor concerns regarding leveraged capitalization, certain equity securities often trade at significant discounts to otherwise comparable investments or are not readily tradable. Such securities generally do not produce current income for the Master Fund and may also be speculative. In addition, actual and perceived accounting irregularities may cause dramatic price declines in the equity securities of companies reporting such irregularities or that are rumored to be subject to accounting irregularities. Investment in Distressed or Bankrupt Companies Bandera may invest in securities of companies that have become financially distressed as a result of unexpectedly or chronically poor operating results, an excessive debt burden, facing special competitive or product obsolescence problems or a substantive liability. For example, if a company in financial distress announces a restructuring plan, either in the form of a court-supervised bankruptcy or insolvency proceeding, or an out-of-court

restructuring of its indebtedness and other liabilities, and Bandera believes that a successful restructuring or reorganization is likely to be completed and that the value of the new securities to be received, plus cash or any other consideration, if any, exceeds the current market price of such securities, Bandera may purchase such distressed company’s securities. Securities or other assets or investments acquired by Bandera may have to be held for extended periods of time. The market prices of such securities are also subject to abrupt and erratic market movements and above-average price volatility, and there may be wide spreads between the bid and asked prices of such securities. Proposed reorganizations of distressed companies may not be consummated, or may be significantly delayed, for several reasons, including: opposition by the management or shareholders of the company or companies involved in the reorganization or opposition by regulatory agencies whose approval may be required; discovery of undisclosed facts during the process of legal or commercial due diligence or by other means; a dispute over price or other terms among the parties to a negotiated reorganization; litigation; a material adverse change in the business of the company or companies involved in the reorganization or the securities markets generally; passage of legislation by governmental entities restricting certain types of reorganizations; and the failure to meet certain conditions customarily specified in acquisition agreements. The level of analytical sophistication, both financial and legal, necessary for successful investment in companies experiencing significant business and financial difficulties is particularly high. Such types of securities require active monitoring and may, at times, require participation in bankruptcy or reorganization proceedings by Bandera on behalf of the Master Fund. To the extent that Bandera becomes involved in such proceedings, the Master Fund may have a more active participation in the affairs of the issuer than that assumed generally by an investor, and restrictions may be imposed that limit the Master Fund’s ability to liquidate its position in the securities of the company. The Master Fund, however, does not generally make investments for the purpose of exercising day-to-day management of any issuer’s affairs. Special Situations The Master Fund may also make purchases of “special situation” securities. Such purchases may include securities that Bandera believes to be undervalued due to an arbitrage, liquidity or other event, or legal or litigation issues, or may involve situations where a significant position in the securities of a particular company has been acquired by other persons or where companies in the same or a related industry have recently been the target of acquisition attempts. If the Master Fund purchases securities in anticipation of an acquisition attempt or reorganization, and no acquisition attempt or reorganization occurs during the timeframe anticipated by Bandera, the Master Fund may sell the securities at a loss. A substantial period of time may elapse between the Master Fund’s purchase of the securities and the acquisition attempt or reorganization. During such period, a portion of the Master Fund’s assets would be committed to the securities purchased, and the Master Fund will continue to pay interest on any funds borrowed by the Master Fund to finance such purchases. In liquidations and other forms of corporate reorganizations, there is a risk that the reorganization will be unsuccessful, will be delayed or will result in a distribution

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Bandera currently provides investment advice solely to pooled investment vehicles, including the Master Fund. Investors in the Onshore Fund and the Offshore Fund may include individuals, entities, trusts, investment companies and individual retirement accounts. The minimum initial investment for interests in the Onshore Fund and the Offshore Fund is generally $1,000,000, and subsequent additional investments must be at least $100,000, although Bandera may in its discretion reduce such amounts (generally to not less than $250,000 with respect to the minimum initial investment).

Investors in the Funds are charged profit allocations (“performance-based fees”) in connection with their investments in the Funds. Performance-based fees are calculated and charged at the Master Fund level and are subject to recouping a “loss carryforward.” Performance-based fees accrue monthly and are paid annually. If an investment is redeemed prior to the end of a calendar year, a performancebased fee will be computed and charged with respect to such investment as though the redemption date were at the end of that calendar year. The rate at which performancebased fees are charged to investors in the Funds currently is 10% of such investor’s pro rata share of the Master Fund’s net new profits, depending on the class of interests held by such investor. In addition, performance-based fees charged to certain “seed investors” holding classes of securities that are no longer offered by the Funds are subject to a “hurdle” (such that performance-based fees may not be charged to such investors until net new profits have been achieved for any given year in excess of the hurdle). Performance-based fees accrue on net new profits after the deduction of management fees, but before the deduction of performance-based fees. The Master Fund’s net new profits for any period includes all net realized and unrealized investment gains or losses plus dividend, interest and other investment income less interest, operating and other expenses incurred by the Funds (including management fees). Performance-based fees are determined individually with respect to each investor in the Funds. The performance-based fees are paid to the “allocation partners” of the Master Fund, including the General Partner. The performance-based fees are described in greater detail in the confidential offering memoranda of the Onshore Fund and the Offshore Fund. Bandera has no side-by-side management arrangements.

Neither Bandera nor its Principals are currently registered or have registrations pending as a broker-dealer or as a registered representative of a broker-dealer, or as a futures commission merchant, commodity pool operator or commodity trading advisor or as an associated person of any of such entities. As disclosed in Part 1 of Form ADV, the General Partner, an affiliate of Bandera, serves as general partner of the Master Fund. The performance-based fee arrangement described above in Item 6 may create an incentive for Bandera to make investments that are more speculative or subject to a greater risk of loss than would be the case if no such performance-based fee arrangement existed and could result in allocations to the General Partner that are greater than the amounts allocable to managers and general partners of similar funds. In addition, the General Partner may have conflicts of interest in connection with decisions taken for the Master Fund, such as the valuation of illiquid securities, that affect Bandera. Natalie Banas, a minority owner of Bandera, is the controlling principal of Gallatin Capital LLC (“Gallatin”) and portfolio manager of Gallatin Trading LLC (the “Gallatin Fund”). Ms. Banas is an investor in the Onshore Fund. Jefferson Gramm and Gregory Bylinsky, majority principal owners of Bandera, are investors in Gallatin Trading LLC and minority owners of Gallatin. Mr. Bylinsky is also a Director of Gallatin. Gallatin shares office space with Bandera. The investment strategies of the Bandera funds are different from the quantitative investment strategies of the Gallatin Fund. However, Gallatin’s securities trading and the timing of its trades could potentially present a conflict of interest with the Bandera funds. Bandera has compliance procedures in place to address these potential conflicts of interest.

Personal Trading Bandera has adopted a Code of Conduct and Ethics (“Code”) which is available to any investor or prospective investor upon request. Among other things, the Code sets forth policies and procedures designed to manage the potential conflicts of interest associated with personal securities transactions. Principals and employees of Bandera also devote personal resources and time to private investments which are not held by the Master Fund, including Gallatin. All trading and investment by principals and employees of Bandera are subject to Bandera’s code of ethics. The policy generally prohibits the purchase or sale of securities within one calendar day of fund trades and requires preclearance of trades in equity-based securities, such as shares, warrants, or options on shares, of a single issuer, securities, and contains a compliance process for overseeing its affiliated entities’ securities transactions. The Code further requires periodic reporting of personal securities transactions, except that Covered Persons are not required to report certain exempted securities.

Broker Selection Bandera has discretion in the selection of broker-dealers for the execution of securities transactions on behalf of the Master Fund. The Master Fund will execute, clear and settle any securities and foreign currency transactions that it may enter into with firms that are registered under the U.S. Securities Exchange Act of 1934, as amended (the “1934 Act”), as broker-dealers or that are registered or licensed in a comparable capacity with the regulatory authorities of other applicable jurisdictions and that Bandera believes are reputable, reliable, financially responsible and well established, and offer the best combination of timely execution and low costs. Bandera selects broker-dealers on the basis of its belief that such broker-dealers will further its goal of seeking “best execution” of client securities transactions. When considering best execution, Bandera seeks not necessarily only the lowest commission price, but rather the best overall qualitative execution in the particular circumstances. Bandera places particular emphasis on using brokers that offer the lowest commission price and those that offer liquidity in the companies Bandera trades. Factors that Bandera believes contribute to efficient execution include, among other things, size of the order, difficulty of execution, operational capabilities, facilities and the financial condition of the broker or dealer involved, whether that broker or dealer has risked its own capital in positioning a block of securities or other assets, and the prior experience of the broker or dealer in effecting transactions of the type in which the Fund or the Master Fund will engage. Bandera does not have an obligation to seek the lowest available commission cost or solicit competitive bids. Soft Dollars In selecting brokers or dealers to execute particular transactions, Bandera may also consider “brokerage and research services” (as those terms are defined in Section 28(e) of the 1934 Act) that fall within the Section 28(e) safe harbor. Brokerage and research

services typically are obtained by investment managers through so-called “soft dollar” arrangements with a broker or dealer in exchange for the direction by the investment manager of brokerage transactions for the account of the funds it managers to the broker or dealer for execution, and thus are effectively purchased with the resulting commissions. Bandera does not currently receive research or other products or services other than execution from a broker-dealer or third party (e.g., “soft dollar benefits”) in connection with securities transactions on behalf of the Master Fund. Brokerage for Client Referrals Bandera does not receive investor referrals from broker-dealers or their affiliates and has not referred trades on behalf of the Master Fund to broker-dealers as compensation for referrals. Directed Brokerage Bandera does not employ directed brokerage in connection with the investment advisory services provided to the Master Fund. Trade Aggregation Currently, the Master Fund is the sole investment portfolio for which Bandera provides investment advisory services. Accordingly, it is not necessary for Bandera to aggregate trades for its client accounts.

No person who is not a client of Bandera provides an economic benefit to Bandera for providing investment advice or other advisory services to the Master Fund. Neither Bandera nor any of its related persons directly or indirectly compensates any person for client referrals.

None of Bandera, the General Partner or the Principals has been subject to any material legal or disciplinary events as of the date of this Part 2A.

Bandera’s portfolio managers review the Master Fund’s holdings on a continuous basis. In the normal course of its internal daily reporting and at the end of each month, the Chief Financial Officer reviews the income and expense allotments to the accounts of investors in the Funds to ascertain that those allocations are correct. The Chief Compliance Officer reviews this reporting and maintains records of the review. See Item 15, below, for additional information about reports provided to investors in the Funds.

Bandera does not maintain physical custody of client assets, however the SEC deems us to have constructive custody of certain client assets as a result of, among other things, the control that Bandera or the General Partner may exercise over such assets. Accordingly,

Bandera reports having custody of investor assets under Item 9 of Part 1 and Part 2 of Form ADV, and is required under Rule 206(4)-2 of the Advisers Act to obtain an audit to verify assets over which we have authority as General Partner. Where an adviser serves as the General Partner for a limited partnership pooled investment vehicle and that pooled investment vehicle is subject to an audit as defined in Regulation S-X, this custody requirement is satisfied when an audit is completed by a Public Company Accounting Oversight Board (“PCAOB”) registered accountant within 120 days of the end of the partnership’s fiscal year end. Bandera uses “qualified custodians,” as the term is described in Rule 206(4)-2 of the Adviser Act, to maintain actual custody of securities and other assets of the Master Fund. Those custodians send reports to the Master Fund on a monthly basis and make reports available electronically to the Funds on a daily basis. Bandera utilizes these reports to create daily and monthly internal reports which are then compared on a monthly basis to reports prepared by the Administrator. The Master Fund’s qualified custodians do not send reports directly to investors. The Administrator of the Funds sends monthly net asset value statements to investors in the Funds, including authorized thirdparty custodians and representatives of the investors. Investors should note the Administrator does not verify the accuracy of Bandera’s fee calculation. Investors in the Funds should carefully review the monthly statements and audited financial statements that they receive from the Administrator.

Bandera has full discretionary authority to manage securities and other assets on behalf of the Master Fund. This discretionary investment authority is set forth in the organizational and governing documents of the Onshore Fund and the Master Fund, including the limited liability company agreement of the Onshore Fund, the limited partnership agreement of the Master Fund and the investment management agreement entered into between the Master Fund and Bandera.

Bandera will vote proxies for portfolio securities held by the Master Fund consistent with the best interest of the Master Fund. For this purpose, the Master Fund’s “best interest” means the economic interest in maximizing the value of the Master Fund’s portfolio holdings over the anticipated time horizon for each holding. Bandera will use its best judgment to vote proxies in the manner it deems to be in the best interest of the Master Fund. Bandera generally votes in favor of routine corporate housekeeping proposals, such as the election of directors and selection of auditors, absent conflicts of interest raised by an auditor’s non-audit services, and against proposals that cause board members to become entrenched or cause unequal voting rights. In reviewing proposals, Bandera considers management’s opinion and the effect on management, shareholder value, and the issuer's business practices. In addition, Bandera will review publicly available information to determine if an issuer has made available additional information regarding any issues subject to a proxy vote. We strive to ensure that proxy votes are not submitted before all relevant available information is made available by the issuer or otherwise. Should Bandera vote differently than with management

recommendations, Bandera will memorialize the reasons supporting that judgment and retain a copy of those records in its files. Additionally, Bandera’s Chief Compliance Officer will periodically review the voting of proxies for consistency with Bandera’s fiduciary duties. Bandera reserves the right to abstain from proxy voting at times when Bandera is unable to vote proxies and in circumstances where the cost of voting the proxy exceed the expected benefits. Bandera will furnish its proxy voting record and its proxy voting policies and procedures to investors in the Funds upon request.

Bandera does not solicit or require prepayment of any fees by the Funds of more than $1,200 per Fund, six months or more in advance. As of the date of this Part 2A, there are no financial conditions to report that are reasonably likely to impair Bandera’s ability to meet contractual commitments to the Onshore Fund or the Master Fund. Bandera has never been the subject of a bankruptcy petition.