Pinegrove Venture Partners, LLC

1. Company History Pinegrove Venture Partners, LLC (also known as “Pinegrove,” “Adviser,” “we,” “us,” “our”), a Delaware limited liability company formed in 2023 as a wholly owned direct subsidiary of PVP HoldCo, LLC, is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Brookfield Sierra Holdco LLC (together with its affiliates, “Brookfield”) and HRTG PV, L.P. (formerly known as SCHF (M) PV, L.P.) (together with its affiliates, “HRTG Partners” (formerly known as Sequoia Heritage), and together with Brookfield, the “Sponsors”) indirectly hold a controlling interest in PVP HoldCo, LLC and therefore indirectly control Pinegrove as well as the General Partners (as defined below). Brookfield Sierra Holdco LLC is an indirect subsidiary of Brookfield Corporation and Brookfield Asset Management Ltd., each of which is publicly traded. Prior to Pinegrove’s formation and assumption of the role of investment adviser to the Funds in 2023, the Funds were managed by SVB Financial Group through its SVB Capital division, which was founded in 1999 and affiliated with Silicon Valley Bank. On September 26, 2024, the Sponsors acquired control over PVP HoldCo, LLC. After the change in control, the advisory business began operating under the names “Pinegrove Venture Partners” and “Pinegrove.” Effective April 7, 2025, SVB Capital Management, LLC formally amended its legal name to Pinegrove Venture Partners, LLC. On December 31, 2025, the Sponsors acquired full ownership of the Parent Company. Members of senior management of Pinegrove no longer own an equity interest in the Parent Company but will continue to participate in the success of the firm through profit sharing arrangements. 2. Advisory Services Pinegrove provides advisory services to private investment funds, including pooled investment vehicles, co-investment vehicles, and single-investor vehicles (collectively, the “Funds”). The Funds rely on exemptions from registration under the Investment Company Act of 1940 and the Securities Act of 1933. Pinegrove’s advisory services include identifying and evaluating investment opportunities, conducting due diligence, structuring, and negotiating investment terms, managing, and monitoring portfolio investments, and executing dispositions. Pinegrove Venture Partners, LLC manages multiple investment strategies, as described below. Certain affiliated entities under common ownership sponsor or advise other investment vehicles with related or complementary strategies. These relationships are described further below and in Item 10 – Other Financial Industry Activities and Affiliations.

3. Investment Strategies This section describes the investment strategies offered by Pinegrove Venture Partners, LLC. Pinegrove Strategic Partners Pinegrove Strategic Partners encompasses the Fund-of-Funds investment strategy and CoInvestments investment strategy. Fund-of-Funds Investment Strategy Pinegrove forms and advises Funds that invest in other private investment funds across a diversified range of managers, sectors, and strategies. These vehicles seek to provide investors with broad exposure to private markets through a fund-of-funds structure. Co-Investments Investment Strategy Pinegrove facilitates co-investments alongside other Pinegrove-advised Funds into portfolio companies. Pinegrove Credit Partners Pinegrove advises credit funds (the “Credit Funds”) that provide loans and other debt investments to operating companies and private funds. This investment strategy focuses on direct lending and structured credit transactions. In certain circumstances, a portfolio company or issuer may be suitable for investment by more than one Fund (whether in the same strategy or across the equity and credit strategies). Pinegrove’s allocation policies are designed to allocate investment opportunities over time in a manner it believes is fair and equitable, considering factors such as investment mandate, strategy, available capital, risk profile, and other considerations it deems relevant. Pinegrove seeks to address such conflicts through its allocation policies and other compliance procedures. See Item 10 for additional information. 4. Affiliated Advisory Strategy Pinegrove Adviser LLC and its relying adviser Pinegrove Opportunity Partners LLC (together, “Pinegrove Adviser”) serve as the registered investment advisers to the Pinegrove Secondaries strategy. The Secondaries strategy offers investors opportunities to acquire interests in existing private investment funds and portfolio company securities in secondary transactions. Pinegrove Adviser and Pinegrove Venture Partners, LLC are under common control by the Sponsors and are therefore affiliates. This brochure describes the advisory activities of Pinegrove Venture Partners, LLC only. Investors seeking additional information about Pinegrove Adviser should refer to its separate Form ADV brochure. Because the Strategic, Credit, and Secondaries strategies may pursue investments in overlapping asset classes, issuers, or transactions, and may share certain personnel, resources, or infrastructure, potential conflicts of interest may arise, including with respect to investment allocation, information sharing, and branding or marketing activities. Pinegrove has adopted policies and procedures designed to manage these conflicts in a manner it believes is fair and equitable to its clients.

Additional information regarding these affiliations and related conflicts is provided in Item 10 – Other Financial Industry Activities and Affiliations. 5. The Funds and General Partner Structure Each Fund has an entity designated as its general partner (each, a “General Partner”). The General Partners are affiliated entities that operate as part of Pinegrove’s single advisory business. This brochure outlines the business practices of the General Partners as they pertain to Pinegrove’s advisory activities. For a more detailed discussion of Pinegrove’s investment activities, refer to Item 8 below. Pinegrove advises the Funds in accordance with the terms of the applicable Fund’s governing documents (the “Governing Documents”), investment management agreements, and other similar instruments. All terms applicable to a Fund are established at or around the time of the formation of such Fund and are only terminable as set forth in such Fund’s Governing Documents. Pinegrove may pursue investment strategies not specifically described herein, provided such activities are consistent with the applicable Fund’s disclosed investment objectives and governing documents. There can be no assurance that the Funds’ objectives will be achieved, and investment results may vary substantially. Investors in the Funds participate in the overall investment program for the applicable Fund(s). General Partners from time to time enter into Side Letters or similar agreements with certain Investors that establish different or preferential rights or terms, including but not limited to different management fees and carried interest percentages, co-investment rights, reporting obligations, rights required due to legal, regulatory, or tax circumstances, and transfer rights. Such rights and terms alter or supplement the Governing Documents with respect to those Investors. Pinegrove maintains written allocation policies and procedures designed to allocate investment opportunities among the Funds in a manner that it believes is fair and equitable over time, consistent with each Fund’s investment mandate, strategy, available capital, risk profile, and other relevant factors. Where Pinegrove determines that a proposed allocation deviates from its standard allocation methodology, the matter may be reviewed by the applicable Investment/Allocation Committee. Such review considers, among other things, potential conflicts of interest, the best interests of the relevant Funds, and consistency with fiduciary obligations and applicable Governing Documents. In certain circumstances, Pinegrove may permit supervised persons, affiliates, or unaffiliated third parties to participate in investment opportunities alongside a Fund, including where a Fund elects not to participate in an investment or where an investment opportunity exceeds a Fund’s desired exposure. Any such participation is subject to review by Pinegrove’s Chief Compliance Officer or designee to evaluate potential conflicts of interest and confirm alignment with Pinegrove’s fiduciary duties and disclosures. Where Pinegrove determines that an allocation decision presents a material conflict of interest, Pinegrove may, to the extent required or appropriate under the applicable Governing Documents, disclose such matter to, or seek consent from, the applicable advisory committee.

6. Wrap Fee Programs Pinegrove does not sponsor or participate in any wrap fee programs. 7. Regulatory Assets Under Management As of December 31, 2025, Pinegrove managed approximately $13,717,473,648 in regulatory assets under management on a discretionary basis.

8. Additional Disclosure All discussions of the Funds in this brochure, including but not limited to their investments, the strategies used in managing the Funds, the fees and other costs associated with an investment in the Funds, and other terms, are qualified in their entirety by reference to each Fund’s respective Governing Documents. Pinegrove provides investment advice directly to the Funds and not individually to the limited partners (each, a “Limited Partner” or “Investor”) in the Funds.

Pinegrove provides investment advisory services to each of the Funds pursuant to an investment management services agreement. The applicable Governing Documents set forth in detail the fee structure relevant to each Fund, but in general, Pinegrove receives compensation from each of its clients based on the percentage of assets under management (i.e., Management Fee(s) (as defined below)) and/or performance-based allocation/fees based on capital appreciation or realized gains (i.e., Carried Interest (as defined below) or other similar economic interests). All Investors and prospective Investors in a Fund should review the Governing Documents of each Fund in which they have invested or intend to invest in conjunction with this brochure for complete information on the fees and compensation payable with respect to a particular Fund. The precise amount and calculation of fees are set forth in the applicable Fund’s Governing Documents received by each investor prior to investment in such Fund. Fees are established pursuant to and as set forth in each Fund’s Governing Documents. Pinegrove may waive, reduce, or modify fees in accordance with the applicable Governing Documents, including pursuant to Side Letter or similar arrangements. Management Fees are paid directly from the applicable Fund’s assets. With respect to new Funds launched by Pinegrove under the Sponsors’ indirect ownership (the “New Funds”), Pinegrove has offered preferential or no fees to the Sponsors and to certain Investors with larger and/or earlier capital commitments. Please refer to Item 10 for further details on the potential conflicts that may arise from the arrangements with the Sponsors. Management Fees and Carried Interest The Adviser receives a management fee (the “Management Fee”) from each Fund as set forth in each Fund’s Governing Documents. The Management Fee is typically based on a percentage of committed capital or actively invested capital. Management Fees are typically charged quarterly in advance and are prorated for any period that is less than a full three-month period. In the event an advisory relationship is terminated during a billing period, any prepaid Management Fee attributable to the period following termination will be refunded or credited in accordance with the applicable Fund’s Governing Documents. Pinegrove has offered the Sponsors and certain Investors who make larger and/or earlier capital commitments preferential or no Management Fees. A portion of each Fund’s net investment profit is generally allocated to the General Partner or its affiliates as “Carried Interest.” Pinegrove typically structures this performance-based compensation with respect to each Fund as profit-sharing allocation through general partner interests that the applicable General Partner holds in such Fund. Sometimes our performancebased compensation is subject to a preferred return requirement. In these cases, the General Partner or its affiliates receive a performance profit allocation when cumulative distributions to a Limited Partner are sufficient to provide such Limited Partner with a specified return (i.e., a hurdle). Generally, any affiliate of Pinegrove or eligible employee, officer, advisor, consultant, advisory board member, operating partner and similar person in respect of Pinegrove, a Fund or any of their respective affiliates (collectively, “Affiliated Partners”) who invests their own capital in the applicable Fund will not bear or pay any Carried Interest. Similarly, with respect to the New Funds, Pinegrove has offered the Sponsors preferential or no Carried Interest rates, and certain Investors who make larger and/or earlier capital commitments preferential Carried Interest rates. For the avoidance of doubt, the Sponsors shall not be considered “Affiliated Partners.”

Typically, the capital contributions of the General Partner and Affiliated Partners, when combined, will represent only a small portion of the Fund’s overall capital. As a result, Limited Partners will typically invest greater amounts and may receive a proportionately smaller amount of the profits of the Fund than the General Partner. The General Partner’s Carried Interest in the Fund may create an incentive for the General Partner to make riskier investments than it would make if it were investing exclusively its own funds. Similarly, the Pinegrove investment professionals making investment decisions on behalf of the Funds will typically be entitled to Carried Interest that may create an incentive for such investment professionals to make riskier investments on behalf of the Fund than they would make if investing exclusively their own funds. Pinegrove and its affiliates may receive director’s fees (including options or stock), transaction fees, break-up fees, advisory fees, monitoring fees and other similar fees from portfolio companies or portfolio funds (or their respective affiliates) in connection with the consummation, holding or disposition of a Fund’s investments or the termination of an unconsummated investment proposed to be made by a Fund. Such fees net of any unreimbursed expenses generally reduces the Management Fee of the applicable Fund on a dollar-for-dollar basis as set forth in the applicable Governing Documents. Conflicts may arise in connection with the payment of such fees. Neither Pinegrove nor any of Pinegrove’s supervised persons accepts compensation for the sale of securities or other investment products. Other Fees and Expenses All clients bear various costs, fees, and expenses in addition to the compensation payable to Pinegrove. All Investors and prospective Investors should review the Governing Documents for each applicable Fund, which discuss the expenses borne by that Fund. Some of the costs, fees, and expenses our Funds typically incur may include, but are not limited to:

Audit fees; Brokerage commissions and other transaction costs; Clearing and settlement charges; Custodial fees; Interest expense; Foreign exchange and hedging related fees and expenses; Loan servicing fees; Debt issuance costs; Credit facility fees; Consulting, legal, accounting, and other professional and consulting fees relating to investments, including fees incurred in connection with due diligence and negotiating terms; Research-related costs; Travel expenses and entertainment expenses, which must be related to the identification, evaluation, negotiation, monitoring, or disposition of investments or to investor-related activities of the Fund;

Legal expenses, including those related to investments and fund governance, such as expenses of revising Governing Documents; Systems and technology costs; Market data and risk management expenses; External valuation expenses; Administrative expenses, including those related to services performed by each Fund’s administrator; Costs of liability insurance; Tax preparation and compliance fees and taxes, registration fees, and other government charges; Expenses related to Limited Partner meetings, including the advisory committee meetings; Litigation or investigation costs related to investment activities (including costs of any judgment or settlement amounts); Fundraising and organizational costs; Expenses of dissolving, liquidating, or terminating a Fund; Any other fees and expenses approved by a Fund’s advisory committee; and Regulatory costs.

In addition: • Any Fund that conducts most or all its investment activities through a master fund bears its share of the expenses incurred by the applicable master fund. See Item 10 for further information. • Co-investment vehicles established in connection with Fund investments may bear expenses related to their organization, administration, and investment activities. Where Pinegrove incurs expenses on behalf of such vehicles, such expenses may be reimbursed by the applicable vehicle. • In certain circumstances, portfolio companies may reimburse Pinegrove for expenses incurred in connection with evaluating, structuring, monitoring, or exiting investments. Such reimbursable expenses may include legal, accounting, consulting, travel, diligence, and transaction-related costs. To the extent Pinegrove receives transaction fees, monitoring fees, break-up fees, director fees, or other similar compensation from portfolio companies or related entities, such amounts will be treated in accordance with the applicable Fund’s Governing Documents. In most cases, such amounts (net of unreimbursed expenses) will reduce the Management Fee otherwise payable by the applicable Fund, unless otherwise disclosed in the Governing Documents. The list we have enumerated above does not necessarily contemplate every type of fee or expense our Funds may incur. See Item 10 for additional details regarding fees and expenses that may be borne by Funds. If Pinegrove determines that expenses were incurred for the benefit of more than one Fund, coinvestment vehicle or affiliated entity, Pinegrove seeks to allocate the expense in a manner that we determine is fair and equitable, based on its good faith determination of relative benefit received. Please refer to the applicable Fund’s Governing Documents for additional information. See Item 10 for additional detail regarding Pinegrove’s methodologies for allocating shared expenses among

Funds. Expense Allocation Methodology for Mature Funds From time to time, Pinegrove may modify the methodology used to allocate certain administrative, operational, or compliance-related expenses among the Funds in order to reflect changes in the scale, activity level, or remaining asset base of particular Funds. In certain circumstances, Pinegrove may determine that it is appropriate to allocate certain expenses to Funds that continue to maintain a meaningful level of assets while excluding Funds that have largely completed their investment programs and maintain only a small residual asset base. For example, Pinegrove may determine not to allocate certain expenses to legacy Funds whose net asset value has declined to a level that Pinegrove believes would cause such expenses to have a disproportionate impact on the remaining investors in those Funds. As part of this approach, Pinegrove may apply objective criteria—such as a Fund’s net asset value relative to total investor commitments—to determine whether a Fund should bear certain expenses. Funds that have a net asset value below a threshold determined by Pinegrove (for example, where net asset value represents less than a specified percentage of total commitments) may be excluded from certain categories of newly allocated expenses. This practice creates a potential conflict of interest because Pinegrove determines which Funds bear particular expenses. Any such determinations will be made by Pinegrove in good faith and in a manner it believes to be fair and reasonable to investors, considering the age of the Fund, the remaining level of investment activity, administrative practicality, and the relative impact of such expenses on the Fund’s remaining assets.

Methods of Analysis and Investment Strategies Pinegrove utilizes particular investment strategies and methods of analysis described in each Fund’s offering materials and Governing Documents, which are provided to such Fund’s Investors prior to their investment. The information contained herein is a summary only, and Investors and prospective Investors should refer to the applicable Fund’s offering materials and Governing Documents for a complete overview of Pinegrove’s methods of analysis and investment strategies and the risks associated therewith. All investing involves a risk of loss, and all clients and Investors should be prepared accordingly. Pinegrove advises the Funds in allocating capital to private equity, venture capital, and debt investments, both within the U.S. and internationally, in accordance with the investment strategies and objectives outlined in the applicable Fund’s Governing Documents. Our recommendations primarily include: (i) equity investments in other private investment funds focused on a diversified set of strategies (“Fund of Fund Investments”) (ii) equity investments, or co-investments, in private operating companies (“Co-Investments”) and (iii) loans to, and other debt investments in, operating companies and private funds (“Credit Investments”). Pinegrove may recommend Fund of Fund Investments, Co-Investments, and Credit Investments (collectively, “Investments”) across a broad range of sectors, stages, geographies, and manager types in line with the Governing Documents of each respective Fund. Pinegrove’s investment objective is to recommend investments for each Fund in alignment with the investment objectives set forth in such Fund’s Governing Documents. We seek to focus on these investment objectives at each stage of our investment recommendation and monitoring process, particularly as it relates to sourcing, performing due diligence, structuring, negotiating, executing, and monitoring a Fund’s Investments. Pinegrove’s investment advisory services consist of identifying and evaluating investment opportunities, due diligence, structuring, negotiating the terms of investments, managing and monitoring investments, and disposing of such investments. In addition to individuals associated with Pinegrove, Pinegrove may utilize personnel and resources of the Sponsors, Pinegrove’s affiliates, or their related operating businesses and portfolio companies to assist with matters related to the services that Pinegrove provides, which includes, but is not limited to, the analysis of prospective or existing investments and the development and execution of Pinegrove’s investment strategy. However, for the avoidance of doubt, the Sponsors or such affiliates of Pinegrove are not responsible, directly, or indirectly, for making, monitoring, or disposing of the Funds’ investments. Pinegrove Fund Families Pinegrove’s investment strategies are classified within the following fund families. Limited Partners should refer to each Fund’s offering materials and Governing Documents for a more detailed description of each strategy.

Fund of Funds The general strategy of the Fund of Funds is to realize long-term appreciation primarily from investments in underlying venture capital funds (the “Underlying Funds”). This strategy may invest in both established and emerging funds and will consider a range of relevant factors when making allocations. Pinegrove may also make direct equity co-investments into portfolio companies in Pinegrove’s capacity as investor in the Underlying Funds. Pinegrove aims to build venture allocations that are appropriately diversified across sector, stage and geography based on the parameters laid out in the Fund’s Governing Documents.

With respect to Fund of Fund Investments, we seek to select several private investment partnerships that we believe have the potential to generate attractive risk-adjusted investment returns relative to their peers. o Our evaluation of Fund of Fund Investments considers several factors, such as the investment track record of the portfolio managers and/or Fund of Fund Investment, the merits and historical discipline of the investment strategy, organizational sustainability, opportunity for co-investment and other economic and legal considerations. Due diligence may involve, but is not limited to, quantitative analysis of the investment track record of a firm’s previous and current investments, meetings and phone calls with the Fund of Fund Investment management team, discussions with management of past and current portfolio company investments and customary legal diligence. o In addition to relying on publicly reported information, we analyze the offering and due diligence materials for each Fund of Fund Investment. We analyze the backgrounds of important investment professionals, often through discussions with other investment professionals, portfolio company executives, co-investors, and other relevant industry contacts.

Co-Investment Funds Pinegrove’s Co-Investments investment strategy aims to lead and price second-institutional rounds by leveraging the Pinegrove network to source, proactively engage, finance, and add value to leading founders and entrepreneurs. The Co-Investments investment strategy focuses on finding Investments with capital-efficient business models and seek to build a concentrated portfolio of core investments, complemented by several earlier stage positions in core sectors of conviction.

With respect to Co-Investments, we select private operating companies where we believe there is an opportunity to generate returns for our investors consistent with the offering materials and Governing Documents of the applicable Fund, whether through the strategic and operating value-add of the broader Pinegrove network or otherwise. o Our evaluation of Co-Investments may include, depending on the specific circumstances, analysis of historical financial statements and future projections of

the underlying business; meetings with management; visits to key company locations; discussions with key customers, suppliers, and competitors; background checks and reference checks of senior management; legal, accounting and related due diligence; and the investigation of other important risks associated with each potential investment. In addition to company-specific considerations, we may evaluate the underlying industry, including major growth trends, current market dynamics, potential for new competitive entrants and substitutes, and the impact of potential future socio-economic, market and political trends. Credit Funds The Credit Funds – both levered and unlevered – seek to invest in diversified portfolios of debt and debt-like investments (which may be accompanied by warrants to purchase equity and other related equity investments) that are primarily in growth companies focused on technology, life sciences, and healthcare. They aim to generate (i) current income through interest income and fees and (ii) capital appreciation through accompanying warrants to purchase equity and other related equity investments. The Credit Funds seek to drive returns through cash yields, fees, equity stakes (typically taken through warrants or rights to invest), and, for levered Credit Funds, varying amounts of leverage. The Credit Funds typically seek to manage risk through asset selection, certain structural protections (which may include a senior position in the capital structure, liens on assets, amortization, and covenants) and strong backing from the borrower’s venture capital investors and/or private equity sponsor. This strategy’s distinct industry focus in the technology, life science and healthcare sectors differ from broad middle market lending or collateralized loan obligation debt. The Credit Funds’ portfolio of debt investments primarily includes first lien and second lien senior secured debt and unitranche loans (including first-out and last-out structures). Credit Funds may also invest in secured convertible debt and other debt and debt-like instruments. We use a data-led underwriting process that typically focuses on the borrower’s proprietary intellectual property, operating metrics, customer traction, financial sponsor backing, disruptive potential of product offerings, size of addressable markets, management team experience, and financial or business milestones (e.g., clinical trials, regulatory approvals, or revenue targets).

With respect to Credit Investments, we select debt investment opportunities in private operating companies. Our goal is to generate current income through interest income and fees and capital appreciation through accompanying warrants to purchase equity and other related equity investments in a manner consistent with the offering materials and Governing Documents of the applicable Fund. Credit investment opportunities may be sourced through Pinegrove’s network, including relationships with financial institutions and other market participants (including Silicon Valley Bank, a division of First Citizens Bank and Trust), as well as direct outreach. o Our evaluation of Credit Investments may include, depending on the specific circumstances, business model and technology assessments; review of historical operational execution; review and analysis of historical financial statements and future projections of the underlying business; evaluation of investor syndicate; product/service review; market analysis; competitive analysis; performance

benchmarking against competitors; management review; business risk analysis; transaction size, pricing, return and structural analysis; quantitative financial modeling; investor diligence calls; and customer reference calls. Summary of Material Risk Factors An investment in the Funds involves a significant degree of risk, relating both to the types of investments contemplated by the Funds as well as the Funds’ ability to achieve their investment objectives and therefore should be undertaken only by those investors capable of evaluating the risks of the Funds and bearing the risks they represent. Before purchasing the Interests, prospective Investors should carefully consider, among other factors, the following risk factors, as well as other information provided in the offering materials and the Governing Documents. The following risk factors do not purport to be a complete list or explanation of all risks involved in an investment in the Funds. Additionally, each of the risk factors listed below, on its own, could have a material adverse effect on a Fund or the value of an investment in a Fund. Prospective Investors should not construe the performance of earlier investments in which professionals at Pinegrove have been involved as providing any assurances regarding the future performance of a Fund. There can be no assurance that a Fund will meet its investment objectives or that a Limited Partner will receive a return of its capital. As such, a Limited Partner should have the ability to sustain the loss of its entire investment in a Fund. Prospective Investors must rely on their own examination of, and their own ability to evaluate, the nature of an investment in Interests, including all the risks involved in making such an investment. Prospective Investors should consult their own legal, tax, investment, and accounting advisors in connection with evaluating the purchase of Interests. In pursuing its investment objectives, a Fund may invest directly or indirectly in a variety of asset types and transaction structures, as permitted under the applicable Governing Documents. Such investments may be made directly in portfolio companies or other assets, or indirectly through private or public funds or other pooled investment vehicles managed by third-party general partners or managers (each, an “Underlying Fund”). Investments made through Underlying Funds are subject not only to the risks associated with the underlying portfolio investments, but also to additional risks inherent in investing in pooled investment vehicles, including limited transparency, limited liquidity, reliance on third-party managers, layered fees and expenses, and limited control over investment decisions. Unless otherwise indicated, the risks described below generally apply to both direct investments and investments made indirectly through Underlying Funds. 1. Risks Associated with Market Conditions General Economic Conditions. Changes in general global, regional and/or U.S. economic and geopolitical conditions may affect the Funds’ activities. Interest rates, general levels of economic activity, the price of securities and participation by other investors in the financial markets may affect the market in which the Funds make investments or the value and number of investments made by the Funds or considered for prospective investment. Material changes and fluctuations in the economic environment, particularly of the type experienced in the years following 2008 that caused significant dislocations, illiquidity and volatility in the wider global economy, and the market changes that have resulted from the novel coronavirus (“COVID-19”) may affect the Funds’ ability to make or dispose of investments and the value of investments held by the Funds. These

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Pinegrove provides advisory services to private investment funds, including pooled investment vehicles, co-investment vehicles, and single-limited-partner vehicles (“Single Investor Funds”). Pinegrove provides investment advisory services solely to the Funds and not to the individual Limited Partners or Investors. Certain legacy fund entities include the acronym “SMA” in their legal name; however, such entities are Single Investor Funds and are not separately managed accounts. Pinegrove does not currently provide advisory services to separately managed accounts. Interests in each Fund (“Interests”) are offered in reliance on exemptions from registration under the Securities Act of 1933 and the Investment Company Act of 1940. Accordingly, Interests are offered and sold only to investors who meet applicable eligibility requirements under such laws, including “accredited investors,” “qualified purchasers,” “knowledgeable employees,” and certain non-U.S. persons. Minimum investment amounts, if applicable, are set forth in the relevant Governing Documents. Pinegrove may accept subscriptions for lesser amounts in accordance with such Governing Documents. This brochure is not an offer to sell or a solicitation of an offer to invest in any Fund.

Performance Based Fees As described in Item 5 above, the General Partner receives performance-based compensation from the Funds in accordance with each Fund’s Governing Documents. Although this method of compensation is generally used to align the General Partner’s interests with those of its Funds’ Limited Partners, the existence of this arrangement could create an incentive for Pinegrove in its capacity as investment adviser to the Funds to make riskier or more speculative investments or dispose of its Funds’ investments at a time and in a sequence that would generate more compensation for the General Partner than would be the case if such performancebased compensation were not part of its overall compensation structure. Pinegrove, as an investment adviser, addresses such conflicts pursuant to its compliance manual and its written allocation policy, which are designed to allocate investment opportunities over time in a manner Pinegrove believes is fair and equitable under the circumstances. Side-by-Side Management Subject to the terms of each Fund’s applicable Governing Documents, Pinegrove may commence the operation of a successor Fund with overall objectives substantially like those of a predecessor Fund. If a successor Fund and a predecessor Fund have overlapping investment periods or investment mandates, Pinegrove will allocate investment opportunities between such Funds in accordance with its investment allocation policies and procedures. From time to time, Pinegrove may provide concurrent advisory services to clients that are not charged a performance-based fee or allocation by Pinegrove or its related persons and clients that are charged a performance-based fee or allocation by Pinegrove or its related persons (and, in certain circumstances where a performance-based fee is charged, the performance-based fee that is charged may differ across clients). As a result, the potential for Pinegrove and/or its related persons to receive greater fees or allocations from performance-based accounts creates a conflict of interest with respect to the allocation of investment opportunities, as Pinegrove may have an incentive to direct the best investment ideas to, or to allocate investments in favor of, accounts that pay a performance fee or allocation (or the highest performance-based fee). Allocation decisions are made in accordance with Pinegrove’s written allocation policies, which consider factors such as investment mandate, strategy, available capital, and other relevant considerations.

Financial Industry Activities Neither Pinegrove nor any of its management persons are registered as or have an application pending to register as a broker-dealer, registered representative of a broker-dealer, a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. The General Partners of the Funds have filed with the National Futures Association a notice of exemption from registration as a commodity pool operator with the U.S. Commodity Futures Trading Commission (the “CFTC”) with respect to the Funds pursuant to the exemption under CFTC Rule 4.13(a)(3) for privately-offered commodity pools that meet certain de minimis trading limits and whose participants are limited to certain sophisticated classes of investors. As a result of claiming the exemption under CFTC Rule 4.13(a)(3), the General Partners are not required to comply with the disclosure, reporting and recordkeeping requirements generally applicable to registered commodity pool operators, including delivery to participants in the pool of a disclosure document and a certified annual report designed to meet CFTC requirements. Pinegrove is exempt from registration with the CFTC as a commodity trading advisor pursuant to Section 4m(3) of the U.S. Commodity Exchange Act, as amended, with respect to advice that it provides to the Funds, and as such, it will not be required to satisfy certain disclosure and other requirements under the CFTC rules. Pooled Investment Vehicles Pinegrove organizes and sponsors the Funds. Each Fund is controlled by a General Partner that is affiliated with Pinegrove. Pinegrove, as investment adviser to the Funds, is responsible for all decisions regarding portfolio transactions of the Funds and has full discretion over the management of the Funds’ investment activities. While the General Partners are not separately registered as an investment adviser with the SEC, all of their investment advisory activities are subject to the Advisers Act and the rules thereunder. In addition, any employees and persons acting on behalf of the General Partners are subject to the supervision and control of Pinegrove. Thus, the General Partners, employees of the General Partners other than employees whose functions are clerical or ministerial and the persons acting on the General Partners’ behalf would be “persons associated with” the registered investment adviser so that the SEC could enforce the requirements of the Advisers Act on the General Partners. Master Funds Some of the private investment funds that we manage make certain of their investments through other master funds we manage. These master funds do not contain any investors other than our Funds. Investing the assets of our Funds into another managed master fund presents the potential opportunity for Pinegrove to charge investors fees at multiple levels. However, while our Funds indirectly bear all investment and operating expenses, we do not charge these master funds any management or performance fees in connection with our management services and therefore our Funds do not pay to us further management or performance fees at the master fund level in addition

to those that we charge at the Fund level. In addition, since we do not allow investors other than our Funds to invest in these master funds, these vehicles do not compete with our clients for investments. Affiliations and Conflicts of Interest Investors should note that the Governing Documents may contain provisions that, subject to applicable law, (a) reduce or modify the duties (including any fiduciary or other duties owed to the applicable Fund(s) and the Limited Partners) to which the General Partners or Pinegrove would otherwise be subject, (b) waive duties or consent to conduct of the General Partners that might not otherwise be permitted pursuant to such duties and (c) limit the remedies of Limited Partners with respect to breaches of such duties. Additionally, the Governing Documents may contain exculpation and indemnification provisions that, subject to the specific exceptions enumerated therein, provide that the General Partners and Pinegrove and their respective affiliates will be held harmless and indemnified for matters relating to the operation of the Funds, including matters that may involve one or more potential or actual conflicts of interest. The discussion below describes certain material relationships and arrangements that Pinegrove has with the Sponsors and Pinegrove Adviser, and enumerates certain actual and potential conflicts of interest that are expected to arise in connection with such relationships. A key element of the Funds’ strategies is to leverage the capabilities and resources of the global platforms provided by the Sponsors. Pinegrove believes that this is in the Funds’ and their investments’ best interests. However, the involvement of the Sponsors, in light of their respective broader platforms, and the Sponsors’ interests in Pinegrove and the General Partners, may give rise to actual or potential conflicts of interests, and there is no guarantee that such involvement, separate from the impact of any actual or potential conflicts of interests, will ultimately provide a benefit to or be in the best interests of the Funds or their investments. The discussion below also enumerates other actual and potential conflicts of interest that are expected to arise in connection with the Pinegrove business in general. These conflicts of interest do not purport to be a complete list or explanation of all actual or potential conflicts of interest that could arise in connection with an investment in the Funds. Dealing with conflicts of interest is difficult and complex, and it is not possible to predict all the types of conflicts that may arise. Pinegrove will monitor potential conflicts of interest and manage such conflicts of interest with regard to the interests of the Funds and Pinegrove; however, conflicts may not always be resolved in a manner that is favorable to the Funds. For the avoidance of doubt, Pinegrove is not required to and generally does not expect to seek consent or approval of a Fund’s advisory committee to manage the conflicts of interest described herein or other potential conflicts of interest that may arise from time to time unless required by applicable law or such Fund’s Governing Documents. By acquiring an Interest in a Fund, each Limited Partner will be deemed to have acknowledged the existence of such actual and potential conflicts of interest and, to the extent permitted by applicable law, to have waived any and all claims with respect to the existence of any such conflicts of interest and any actions taken or proposed to be taken in respect thereof. To the extent that prospective Investors would benefit from an independent review, such benefit is not available through a Fund’s counsel or through the General Partners, Pinegrove, or any of their affiliates. Prospective Investors are encouraged to seek the advice of independent legal counsel in evaluating the conflicts involved in the offering and operation of a Fund.

Considerations Relating to Sponsors’ Ownership of, and the Sponsors’ and Pinegrove Adviser’s Involvement in, the Pinegrove Business Relationship with the Sponsors The Sponsors indirectly control Pinegrove and have governance rights pursuant to their participation on a board of managers of the Parent Company, which membership consists of two managers appointed by Brookfield, two managers appointed by HRTG Partners, one managing partner of Pinegrove Adviser, one managing partner of Pinegrove Venture Partners and any other Person jointly appointed by the Sponsors. The Sponsors, acting through the board of managers, delegate authority for the day-to-day management of Pinegrove’s affairs to the operating committee of Pinegrove (the “Operating Committee”) and retain the ability to modify the delegation of authority as well as the power to terminate the chief executive officer of Pinegrove at their election. The Sponsors are not voting members of the investment committee of a Fund, but any member of the investment committee of a Fund selected by the Operating Committee must be approved by the board of managers. Moreover, the Sponsors provide working capital for Pinegrove, are making certain capital commitments to the Funds, and may make sizeable commitments to New Funds. Moreover, the Sponsors are entitled to receive their share of Management Fee distributions in accordance with the governing documents of Pinegrove’s direct and indirect parent entities. Similarly, one or more funds managed by Pinegrove Adviser are entitled to receive certain Carried Interest and Management Fee distributions in accordance with the governing documents of the General Partners and Pinegrove’s direct parent entity. In determining whether to pursue a particular opportunity on behalf of a Fund, Pinegrove may be incentivized to consider Pinegrove’s ongoing relationship with the Sponsors and Pinegrove Adviser. In addition, the Funds may invest or enter arrangements with institutions, corporations, and advisors that the Sponsors have long-term relationships with (the “Sponsor Relationships”), and the relationship with the Sponsors may influence the decisions made by the General Partners with respect to such investments. Moreover, certain investments targeted by a Fund may choose not to engage in a transaction with the Fund due to Pinegrove’s relationships with the Sponsors and/or Pinegrove Adviser (e.g., if one or both Sponsors or Pinegrove Adviser is a competitor to the fund manager of a target investment). In such a case, Pinegrove’s ability to acquire information on targeted investments and to consummate transactions may become limited due to its relationship with the Sponsors and/or Pinegrove Adviser. Relationship with Pinegrove Adviser Pinegrove is affiliated through common ownership with Pinegrove Adviser (together with the Sponsors, the “Material Related Persons”). As part of the acquisition of Pinegrove by the Sponsors, Pinegrove Adviser is entitled to receive certain carried interest and management fee distributions from Pinegrove in respect of certain of the Funds. Moreover, certain management personnel of Pinegrove Adviser are eligible to receive Carried Interest and Management Fee distributions from the Funds. In addition, one or more Funds sponsored by Pinegrove and certain Pinegrove personnel have made capital commitments to Pinegrove Adviser’s initial fund.

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Transactions and Personal Trading Code of Ethics Pinegrove has adopted a Code of Ethics in accordance with Rule 204A-1 under the Advisers Act. As a registered investment adviser, Pinegrove owes a fiduciary duty to its clients, which are the Funds it advises. This fiduciary duty requires Pinegrove and its personnel to act in the best interests of the Funds and to place the Funds’ interests ahead of their own personal interests, consistent with applicable law. Pinegrove’s Code of Ethics establishes standards of business conduct and addresses, among other matters: • Conflicts of interest • Personal securities transactions • Gifts and entertainment • Outside business activities • Political contributions (including compliance with the “pay-to-play” rule) • Protection of material non-public information • Reporting of violations and disciplinary measures A copy of Pinegrove’s Code of Ethics is available to any client, Investor, prospective client, or prospective Investor upon request at: compliance@pinegrove.vc. Participation or Interest in Client Transactions Pinegrove, its affiliates, and related persons may have financial interests in investments that are also held by, or recommended to, the Funds. These interests may arise in several ways, including: • General partner interests and carried interest arrangements; • Co-investments alongside the Funds; • Investments by affiliates or other Pinegrove-advised vehicles in the same issuers; • Cross-fund investments across distinct parts of a portfolio company’s capital structure; and • Investments in or transactions with portfolio companies affiliated with the Sponsors or other related entities. These arrangements create conflicts of interest because Pinegrove or its affiliates may have incentives that differ from those of a particular Fund, including incentives relating to performancebased compensation, allocation decisions, timing of dispositions, or structuring of transactions. Pinegrove seeks to address these conflicts through: • Written allocation policies and procedures; • Internal conflict review processes; • Recusal where appropriate; • Advisory committee approvals where required by Governing Documents; and • Compliance oversight. Additional information regarding related-party investments and affiliated transactions is provided in Item 10 of this brochure.

Personal Trading Pinegrove has adopted personal trading policies designed to prevent conflicts between the personal trading activities of its personnel and the interests of the Funds. Under Pinegrove’s Code of Ethics: • Personnel may not trade in single-name securities or securities of issuers included on Pinegrove Adviser’s or HRTG Partners’ Restricted List. • Personnel may not trade securities that satisfy a Fund’s investment criteria unless the applicable Fund has first been given the opportunity to invest or appropriate internal approval has been obtained. • Certain securities and derivatives transactions require pre-clearance from compliance personnel. • Personnel must submit quarterly transaction reports and annual holdings reports, subject to limited exceptions. • Trading restrictions apply to household family members. These policies are designed to prevent personnel from engaging in trading that could disadvantage the Funds, including trading ahead of client transactions or engaging in contemporaneous transactions that create conflicts of interest. Although it is rare for personal trading activities to limit the Funds’ investment opportunities, such situations may arise from time to time. Cross Trades and Principal Transactions When permitted by applicable law and subject to and in accordance with the terms of the applicable Governing Documents, a General Partner may (but is under no obligation to) cause a Fund to acquire or dispose of investments in cross trades between such Fund and other Funds or effect principal transactions where the General Partner causes a Fund to purchase investments from or sell investments to Pinegrove or certain other Funds; provided that, any such transaction be approved to the extent required by the applicable Governing Documents and applicable law. Under the Governing Documents, certain of such transactions will require consent of a Fund’s advisory committee (subject to certain exceptions), which approval will be deemed to constitute the approval of, and be binding upon, such Fund and all the Limited Partners. Whether a transaction is a “principal trade” under the Advisers Act, and therefore requires consent of an advisory committee, depends on the precise structure of such transaction. In certain circumstances, a General Partner may structure a transaction in a manner so that such transaction is not considered a “principal trade.” There may be potential conflicts of interest or regulatory issues relating to these transactions which could limit a General Partner’s decision to engage in these transactions for a Fund. In connection with a cross trade or a principal transaction, a General Partner and its affiliates may have a potentially conflicting division of loyalties and responsibilities regarding the applicable Fund and the other parties to trade and have developed policies and procedures in relation to such transactions and conflicts. However, there can be no assurance that such transactions will be affected, or that such transactions will be affected in the manner that is most favorable to such Fund as a party to any such transaction. For the avoidance of doubt, subject to the terms of the applicable Governing Documents and to the fullest extent permitted by applicable law, acquisitions or dispositions among certain investments and investments owned by one Fund will not be treated as cross trades or principal transactions of another Fund and will not require consent of the such other Fund’s advisory

committee or any other consent. Material Non-Public Information; Trading Restrictions; Information Not Made Available. The ability of the Funds to buy or sell certain securities or take other actions is expected to be restricted in certain circumstances, including by applicable securities laws, regulatory requirements, contractual obligations, and/or reputational risk considerations applicable to Pinegrove (and/or its internal policies designed to comply with these and similar requirements). For example, Pinegrove, or a Pinegrove employee, may possess material, non-public information about issuers that would limit the ability of the Funds to buy and sell securities related to those issuers. Due to these restrictions, the Funds may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Notwithstanding the foregoing, Pinegrove may determine, in its sole discretion at any time, that such information could impair its ability to effect certain transaction on behalf of the Funds, whether for legal, contractual, or other reasons. Accordingly, Pinegrove may elect not to receive such information or may restrict access to such information to certain personnel that are placed behind an “information wall.” Lack of access to any such information may adversely affect the Funds’ investments that in some cases may have been avoided had Pinegrove had such information. See “Considerations Relating to Sponsors’ Ownership of, and the Sponsors’ and Pinegrove Adviser’s Involvement in, the Pinegrove Business” in Item 10 above.

The Funds may purchase or sell securities in privately negotiated transactions, or, at the recommendation of Pinegrove from time to time, may use specific brokers and dealers to execute, settle, and clear securities transactions. Pinegrove has discretion in deciding which brokers or dealers are to be used for a particular transaction. However, the commission rates Pinegrove pays for these transactions are negotiated by brokers or driven by the market. Pinegrove does not conduct formal competitive bidding for each transaction and does not select brokers solely based on the lowest stated or “posted” commission rate. As a fiduciary, Pinegrove seeks to obtain best execution for client transactions, which means seeking execution on terms that Pinegrove believes are most favorable to the applicable Fund under the circumstances. In evaluating brokers, Pinegrove considers a range of factors, including execution capability, reliability, market conditions, transaction size, liquidity, and overall transaction costs. Pinegrove monitors prevailing commission and transaction cost levels and seeks to ensure that expenses incurred in effecting transactions are reasonable in relation to the value of the brokerage and execution services provided. Pinegrove seeks to obtain best execution for all transactions and evaluates brokers and dealers based on a variety of factors, not solely on the lowest commission or transaction cost. Best execution involves seeking the most favorable overall result for the applicable Fund under the circumstances. In selecting brokers and dealers (including prime brokers) to execute transactions, provide financing and securities lending, hold cash, and short balances, or provide other related services, Pinegrove may consider factors such as execution capability, market access, reliability, financial stability, operational efficiency, and the quality of services provided. Brokers and dealers may also provide additional services, including capital introduction, access to company management, introductions to potential personnel, operational or technology consulting, marketing assistance, or access to transaction opportunities. Pinegrove evaluates such services considering its best execution obligations and does not select brokers solely based on these additional services. If orders for the same security for more than one client are placed with the same broker, Pinegrove may aggregate or “bunch” such orders across client accounts (including accounts advised by certain affiliates), although it will have no obligation to do so. If orders are aggregated, they will be allocated across the client accounts so that no account will be treated less favorably than another over time. While in some cases the aggregation of orders could have a detrimental effect upon the price or value of a security for a particular account, or upon the ability to complete an entire order, in other cases coordination and the ability to participate in volume transactions may be beneficial to the account. Pinegrove may in its discretion choose not to aggregate orders, for example, where portfolio management decisions for clients are made separately or where aggregation could result in less favorable execution for a particular client. Certain securities positions held by one or more Funds are maintained in custody at Merrill Lynch, Pierce, Fenner & Smith Incorporated (“Merrill Lynch”). With respect to such positions, transactions

may be effected exclusively through Merrill Lynch pursuant to custodial, operational, or other account requirements. When securities are required to be transacted through Merrill Lynch, Pinegrove will not seek to execute such transactions through an alternative broker-dealer, even if another broker-dealer might provide more favorable execution terms. Accordingly, Pinegrove may not seek best execution for transactions required to be executed through Merrill Lynch, and the Funds may not obtain the most favorable price, commission rate, or overall execution terms that might otherwise be available. This directed brokerage arrangement may result in higher transaction costs or less favorable execution outcomes than would otherwise be available if Pinegrove were free to select among multiple broker-dealers. Pinegrove discloses this arrangement so that Investors understand the potential impact on transaction execution quality. As a matter of practice, Pinegrove currently does not engage in soft dollar transactions, and although we are permitted to do so and may engage in soft dollar transactions in the future in accordance with the limitations of Section 28(e) of the Exchange Act, it is not anticipated that we will do so. Although Pinegrove may receive proprietary research from certain brokerage firms, it does not take the value of such research into account when selecting brokers.

Pinegrove’s officers and employees may participate on the boards of directors (or equivalent governing body) of the Funds’ portfolio investments. Currently, Pinegrove employees, in most cases, act as board observers or are appointed to an advisory committee and are not on the board of directors (or equivalent governing body). While it is possible, under certain circumstances, to receive compensation or other benefits from the portfolio investments in connection with these governance roles, it is not expected that compensation would be paid due to the traditional practices of the Funds’ investment sectors. However, if compensation in the form of cash or equity is paid to an employee for serving as Pinegrove’s representative on a Fund’s portfolio investment’s governing body, the Governing Documents of Funds generally provide mechanisms where compensation is remitted to the relevant Funds in the form of fee and expense offsets. Additionally, employees serving as Pinegrove’s representative on a portfolio investment’s governing body, may also, at times, receive certain non-equity and non-cash benefits that they retain related to meeting attendance (for example, unlimited complimentary flights and other travel accommodations). The Funds, the General Partner, Pinegrove, or their affiliates may engage placement agents in connection with the organization of the Funds and the offering of interests therein. Any such placement agents may be compensated through fixed or contingent fees, as well as reimbursed for expenses. As set forth in the Governing Documents, the Funds may pay such fees and expenses, but the Management Fee payable by the Funds may be reduced by the amount of any placement fees and expenses paid by the Fund. In addition to such placement fees charged to the Funds, placement agents may charge any Limited Partner that is also a client of such placement agent an additional placement fee, which shall be due directly to such placement agent and will be in addition to those fees and expenses to be paid by the Funds. For the avoidance of doubt, any such placement fees shall be in addition to the amount required to be contributed by such Limited Partner to the Funds. Placement agents engaged by the Funds, the General Partner, Pinegrove, or their affiliates may include placement agents affiliated with Brookfield. The compensation paid to any Brookfield placement agent with respect to the placement of the Interests will be from Brookfield and not from the Funds or any Limited Partner (unless specifically disclosed to the applicable Limited Partner). As of the date of this brochure, Pinegrove does not currently compensate third parties for client referrals, although it may do so in the future in accordance with applicable law and the Governing Documents.

Pinegrove and its employees have not been involved in any legal or disciplinary events in the past 10 years that would be material to a client’s evaluation of the company or its personnel. Pinegrove Innovation Credit Fund VIII, L.P. (formerly known as SVB Innovation Credit Fund, VIII, L.P. (“Fund VIII”)), was subject to a regulatory action initiated by the California Department of Financial Protection on April 16, 2021. Fund VIII is currently managed by Pinegrove. As a result of an acquisition transaction that occurred on December 23, 2020, the control and management of Fund VIII was changed to a new (and current) general partner, SVB Innovation Credit Partners VIII, LLC. Note that, upon the change of control, notice to the California Department of Financial Protection and Innovation (DFPI) was initiated to change Fund VIII’s address, name, contact information, and other management information. These changes were approved by the DFPI on or about June 4, 2021. Unfortunately, Fund VIII inadvertently missed the deadline to file its Annual Report with the DFPI by March 15, 2021, as required by California Financial Code 22159. This was partially due to Fund VIII not receiving notices sent by the DFPI to CFL licensees between December 2020 and March 2021 since the DFPI had not yet completed the process to change Fund VIII’s contact and other information as mentioned above. On April 16, 2021, the DFPI Commissioner issued an Order Summarily Revoking California Finance Lenders License Pursuant to Financial Code Section 22715 for CFL License Number 60DBO-65349 (“Summary Revocation Order”). On April 29, 2021, Fund VIII became aware of the Summary Revocation Order, and on April 30, 2021, Fund VIII submitted its Annual Report to the DFPI. On May 6, 2021, the DFPI Commissioner and Fund VIII entered a Consent Order that rescinded the Summary Revocation Order thereby reinstating Fund VIII’s CFL license. Anuj Ranjan is a member of the Board of Managers of the Parent Company and is a former director of PenBrook Capital Advisors Private Limited (“PenBrook”). An administrative proceeding filed against (i) PenBrook, the investment manager of Peninsula Brookfield India Real Estate Fund (the “Peninsula Fund”), (ii) PenBrook’s current and former directors, including Anuj Ranjan (as former director) and Sridhar Rengan (as current director) and (iii) Peninsula Brookfield Trustee Private Limited, the trustee of the Peninsula Fund ((i), (ii), and (iii) collectively, the “Noticees”), was settled on January 28, 2022. The proceeding involved allegations brought by the Securities and Exchange Board of India (“SEBI”) that the Noticees accepted impermissibly small investments from certain investors in the Peninsula Fund, failed to maintain sufficiently large investments themselves in the Peninsula Fund, and extended the tenure of the Peninsula Fund beyond the permissible period, in violation of the Securities and Exchange Board of India Act of 1922. SEBI further alleged that the annual compliance test report for the Peninsula Fund did not reflect the non-compliance matters associated with the alleged violations. Prior to acquisition by the Sponsors, SVB Capital operated as a division of SVB Financial Group, the former holding company of Silicon Valley Bank. Silicon Valley Bank was closed by the California Department of Financial Protection and Innovation on March 10, 2023, and the Federal Deposit Insurance Corporation was appointed receiver. On March 17, 2023, SVB Financial Group filed a voluntary petition for relief under Chapter 11 of the United States Bankruptcy Code, and exited bankruptcy on November 7, 2024. SVB Capital was not a debtor in those proceedings and continued to operate independently under its ownership structure during those proceedings.

The Funds’ investment positions and accounts are monitored on an ongoing basis, and a complete list of the accounts and positions is more formally reviewed, as necessary. Such reviews are generally conducted by one or more members of Pinegrove’s Investment Committee. The Funds are audited on an annual basis by a Public Company Accounting Oversight Board member firm. Certain events may require an account review other than the periodic reviews. Such events include a transfer or withdrawal of an Investor’s Interest in a Fund or a material change in the business of a portfolio investment. Pinegrove makes available the books and records of a Fund to its Investors as provided in its Governing Documents.

Pinegrove is deemed to have custody of client funds and securities within the meaning of Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) because it serves as investment adviser to the Funds and related persons serve as general partners of the Funds. Pinegrove relies on the annual audit exception available to advisers to pooled investment vehicles under Rule 206(4)-2(b)(4). In accordance with this exception: • Each applicable Fund is audited at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board; • Audited financial statements are prepared in accordance with U.S. accepted accounting principles; and • Audited financial statements are distributed to each Fund’s investors generally within 120 days of the Fund’s fiscal year end (or within 180 days in the case of a fund of funds), as applicable. Upon liquidation of a Fund, audited financial statements will be distributed promptly following completion of the liquidation audit, as required by the Custody Rule. Assets of the Funds are maintained with qualified custodians. Because Pinegrove relies on the annual audit exception, investors should not expect to receive separate account statements directly from custodians.

Pinegrove exercises discretionary authority in managing the Funds. Pursuant to the applicable Governing Documents, Pinegrove has the authority, without obtaining prior consent from Investors, to determine the securities or other investments to be purchased or sold, the amount of such investments, the timing of transactions, and, where applicable, the brokers or counterparties used to effect such transactions on behalf of the Funds. Pinegrove’s discretionary authority is subject to the investment objectives, strategies, limitations, and other terms set forth in the applicable Governing Documents. Pinegrove manages the Funds in accordance with those governing terms and applicable law.

Because the Funds generally invest in non-public securities, proxy voting opportunities are limited. However, from time to time Pinegrove may receive proxy materials, consents, or similar matters requiring action on behalf of a Fund. In accordance with its fiduciary duty and Rule 206(4)-6 under the Advisers Act, Pinegrove has adopted written proxy voting policies and procedures designed to ensure that proxies are voted in the best interests of the applicable Fund and in a manner consistent with the Fund’s investment objectives. As a general matter, Pinegrove does not vote proxies for securities held by the Funds. Pinegrove will not vote proxies unless it determines, in its sole discretion, that a compelling economic or other material interest exists that warrants voting. In circumstances where Pinegrove determines that voting is appropriate, it will vote proxies in a manner it believes is consistent with its fiduciary duties and in the best interests of the applicable Fund. Pinegrove may also determine not to vote a proxy where it concludes that the costs of voting exceed the expected benefits to the Fund. Conflicts of interest may arise between the interests of a Fund and those of Pinegrove or its affiliates. If Pinegrove identifies a material conflict of interest in connection with a proxy vote, it will address such conflict in accordance with its written proxy voting policies and procedures, which may include internal review, recusal, or other appropriate measures. A copy of Pinegrove’s proxy voting policies and procedures and information regarding how Pinegrove voted proxies on behalf of a Fund are available upon written request at: compliance@pinegrove.vc.

Pinegrove does not require or solicit the prepayment of fees six months or more in advance and therefore is not required to include a balance sheet pursuant to this Item. Pinegrove does not have a financial condition that is likely to impair its ability to meet contractual commitments to clients. Pinegrove has not been the subject of a bankruptcy petition at any time during the past ten years. Pinegrove’s former parent entity, SVB Financial Group, filed for bankruptcy protection in March 2023 and exited bankruptcy in November 2024. Pinegrove was not a debtor in those proceedings and continued to operate independently under its ownership structure during those proceedings.