Granahan Investment Management, LLC

December 31, 2025; updated investment management products available to clients;

3.

Table of Contents

4.

Advisory Business .............................................................................................................................. 4

5.

Fees and Compensation .................................................................................................................... 6

6.

Performance-Based Fees and Side-by-Side Management ................................................................ 7

7.

Types of Clients ................................................................................................................................ 7

8.

Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 8

9.

Disciplinary Information ................................................................................................................. 10

10.

Other Financial Industry Activities and Affiliations........................................................................ 11

11.

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 11

12.

Brokerage Practices ....................................................................................................................... 12

13.

Review of Accounts ........................................................................................................................ 14

14.

Client Referrals and Other Compensation ..................................................................................... 15

15.

Custody .......................................................................................................................................... 15

16.

Investment Discretion.................................................................................................................... 16

17.

Voting Client Securities .................................................................................................................. 16

18.

Financial Information ..................................................................................................................... 16

Table of Contents 2. Material Changes ............................................................................................................................... 2

Brochure Supplement .................................................................................................................... 17

4.

Advisory Business

Granahan Investment Management (“GIM”) is an independent, employee-owned firm that was founded in 1985 by investment professionals with a passion for small capitalization equity investing. GIM is principally owned by GIM Holdings, Inc. Since its founding, GIM has remained committed to the smaller cap area of the market and has dedicated its investment expertise to serving institutions and family offices. As of December 31, 2025, GIM managed $2,362,974,589 in total assets on a discretionary basis. GIM currently does not manage non-discretionary assets. Typically, GIM’s products are not tailored to the individual needs of clients. In certain circumstances, GIM allows clients in certain circumstances to restrict and/or limit certain investments in their portfolio. GIM currently offers these investment management products: Small Cap Core Growth ($963 million AUM): Our Small Cap Core Growth product was started in 1993 and has a focus on stocks with market capitalizations between $200 million and $2 billion at the time of purchase. The client portfolio generally carries 140-160 stocks, and focuses on companies with strong and/or accelerating earnings growth. This product is offered as a subadvised ETF and on a separate account basis. Granahan Focused Growth ($1.23 billion AUM): Our Focused Growth product was first offered by GIM in January of 2012. The portfolio consists of 30-40 stocks with market capitalizations up to $2 billion at purchase, generally in the consumer and technology sectors, which have the potential for strong earnings growth in the portfolio manager’s opinion, and offer favorable return potential according to a proprietary risk/reward calculation. The Focused Growth product’s portfolio manager managed this product at another investment adviser prior to his joining GIM in December of 2011. This product is offered as a sub-advised mutual fund and on a separate account basis. It is also offered to non-US clients through Granahan Funds plc, established in Ireland during 2014. Small Cap Discoveries ($1 million AUM): Our Small Cap Discoveries product was created in 2004. The product focuses on companies with market capitalizations up to $700 million that exhibit a critical combination of superior growth prospects and attractive risk reward profile. The portfolio generally carries 70 to 90 stocks. This product is offered as a sub-advised mutual fund and on a separate account basis. Small Cap Select ($149 million AUM): Our Small Cap Select product was created in March 2015. The Small Cap Select product invests in stocks of companies with market capitalizations typically between $200mm and $3 billion at purchase. The Small Cap Select product seeks to invest in the stocks of companies in the small cap sector of the market that have the ability to sustain growth through market disruption. The Small Cap Select product is a high conviction portfolio containing +/-50 stocks with the top 15 holdings typically representing >60% of the portfolio.

SMID Cap Select ($2 million AUM): Our SMID Cap Select product was created in March 2015. The SMID Cap Select product invests in stocks of companies with market capitalizations typically between $500mm and $20 billion at purchase. The SMID Cap Select product seeks to invest in the stocks of companies in the SMID cap sector of the market that have the ability to sustain growth through market disruption. The SMID Cap Select product is a high conviction portfolio containing +/-50 stocks with the top 15 holdings typically representing >60% of the portfolio. Small Cap Explorer ($3 million AUM): Our Small Cap Explorer product was started at the founding of the firm in 1985. This product is invested in stocks of companies with market capitalizations between $500 million and $10 billion at the time of purchase. The portfolio generally carries between 155 and 175 stocks. This product focuses on companies exhibiting the potential for increased earnings growth. This product is offered as a sub-advised mutual fund and on a separate account basis. Microcap Growth ($15 million AUM): Our Microcap Growth product was started on July 31, 2020. Our Microcap Growth Strategy is a high-conviction, bottom-up equity approach focused on identifying emerging growth companies at the smallest end of the market capitalization spectrum (typically $50 million–$750 million at purchase). The Strategy typically holds approximately 45 companies and is diversified across LifeCycles, with sector exposures secondary to security selection with particular strength in healthcare. This product is offered as a sub-advised mutual fund and on a separate account basis. Future Pathways ($2 million AUM): Our Future Pathways product was started on August 31, 2020. Future Pathways is built on the core philosophy of meeting clients’ investment goals while supporting companies dedicated to making a positive difference in the world. Future Pathways seeks to identify, analyze, and invest in companies making a difference externally by aiding individuals, companies, and governments in meeting their sustainability goals. As a firm focused on small- and midcap companies, we believe that smaller companies — through their products and services — have an advantage in helping larger businesses meet their sustainability objectives. This product features forerunner businesses in sectors such as renewable energy, healthcare, and technology. Companies in this product will address climate change, reduce pollution, promote renewable energy, contribute to social justice, and — most importantly — provide larger institutions and governments with the tools to innovate themselves. This product is offered as a sub-advised mutual fund and on a separate account basis. Granahan Funds plc, Dublin, Ireland: On April 11, 2014, the US Focused Growth Fund was launched in Ireland. The US Focused Growth Fund is a fund of the umbrella company Granahan Funds plc, an Irish investment company established under the laws of Ireland, regulated by the Central Bank of Ireland under the European Communities UCITS regulations (Undertakings for Collective Investment in Transferable Securities). The fund’s investment strategy is to mimic, in

so far as regulations allow, the Granahan Focused Growth strategy mentioned above. This fund is only available to non-US clients. Non-discretionary “Model” clients: In limited cases, we provide our investment management services on a non-discretionary basis through a “Model”. GIM does not have discretion over the model client’s assets and therefore the client is responsible for selecting the broker and executing trades in the market. The client, however, is not obligated to use our recommendations and therefore we do not know if or how much of the recommended trades were completed. This is a conflict of interest because we could be competing with the model client for the same trade. GIM communicates model changes to the model client at the end of the day. For securities held in both discretionary and model accounts, the discretionary clients will trade before model clients are made aware of the recommendation. This could result in model clients and discretionary clients receiving different prices.

5.

Fees and Compensation

We manage advisory accounts solely on an investment basis. We charge clients a fee based on a percentage of assets managed. Fees are generally negotiated, using the following standard fee schedules as a starting point. For accounts in the “Small Cap Core Growth”, “Small Cap Explorer”, and “Small Cap Select” products this percentage is on a sliding scale as follows: Assets in Account FIRST $15 MILLION NEXT $35 MILLION NEXT $50 MILLION ABOVE $100 MILLION

Annual Percentage Fee: 1.00% 0.80% 0.60% 0.73%

The standard fee schedule for accounts in the “Small Cap Focused Growth” product is as follows: FIRST $15 MILLION 1.00% NEXT $35 MILLION 0.90% ABOVE $50 MILLION 0.85% For accounts in the “Small Cap Discoveries” product, the standard fee rate is 1.25% of the Account Assets. Granahan Funds plc (Irish UCITS): The fees earned on assets in the Irish domiciled Fund vary from 0.5% to 1.5%, depending on the particular share class subscribed. The Focused Growth Fund also offers share classes with a base fee plus a performance fee component which is accrued over time and paid once per year based on the dollar gains in the account above the benchmark Russell 2000 Growth index. New share classes or negotiated rebates can increase or decrease the fee rate paid by individual clients. The Fund fee is calculated on a daily basis by the administrator of the Fund and is reflected in the daily Net Asset Value. The fee is paid to GIM, the investment manager, on a quarterly basis, in arrears. To protect its shareholders from excessive expenses at lower asset levels, we have agreed to reimburse the Fund for operating expenses which exceed a specified Net Asset Value percentage (specific to each share class).

This Fund is open to non-US investors only. Fund prospectuses and more information can be found at www.granahanfunds.com. Fees are generally billed to the client and payable quarterly in arrears based upon the average value of the assets in the account on the last day of each month in the quarter, though some clients may use average daily assets. Contracts generally can be terminated by the client on 30-60 days’ notice, and assets under management withdrawn with 5 business days advanced notice. Fees are generally negotiable and several of our clients pay lower fee rates than those shown above. Lower fee rates can be a result of the level of assets managed, number of products managed, the type and frequency of service level provided by us, the inception date of the client relationship, whether there is a performance-based component, or other factors. A performance-based fee schedule is in place with certain clients. Assets of approximately $19.9mm of the total assets under management shown above are non-fee-paying. Other Non-Advisory Fees: In addition to the fees paid to GIM, clients may incur other fees. These fees may be assessed by custodians, brokers, and other third parties. They include commissions, custodial fees, odd-lot differentials, taxes, wire transfer and electronic fund fees, as well as other miscellaneous fees. Mutual funds and ETFs also charge internal management fees, which are disclosed in each fund’s prospectus.

6.

Performance-Based Fees and Side-by-Side Management

The investment team is responsible for managing portfolios in the products GIM currently offers. Fees can and currently do vary among products and clients, including clients with performance-based fees, creating conflict whereby the investment team may be incentivized to favor a client or product with a higher fee. GIM has adopted policies and procedures designed to prevent and detect favoritism among clients. Some of these policies and procedures include: - Policies for aggregating trades across accounts; - Policies for the allocation of IPO’s; - Periodic transaction, holding, and performance reviews; and - Periodic portfolio risk and diversification reviews.

7.

Types of Clients

GIM has a $10 million minimum account size for its clients in the Small Cap Core Growth Strategy. All other products have a $3 million minimum for separate accounts, though the firm manages accounts below that minimum. GIM products are designed to serve the following types of clients:

Registered Investment Companies Corporations

8.

Read the rest in the brochure