Westech Investment Advisors LLC

Westech Investment Advisors LLC (also referred to in this Brochure as “Westech”, “WTI” or the “Firm”), is a California limited liability company founded in 1980 that is registered as an investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”). WTI serves as an investment manager for (i) a number of serial institutional venture debt funds that have elected to be treated as business development companies (“BDCs”) under the Investment Company Act of 1940, as amended (“1940 Act”), (ii) corresponding LLCs (as described below) and (iii) a limited partnership that invests primarily in venture equity (“Equity Fund”). Each BDC is wholly-owned by a limited liability company (“LLC”) through which investors subscribe. Each BDC and its corresponding LLC is referred to as a “Debt Fund,” and the Debt Funds and the Equity Fund are referred to collectively as the “Funds”. Each LLC and the Equity Fund would be an investment company but for Section 3(c)(1) or 3(c)(7) of the 1940 Act. The “Debt Funds” are: Venture Lending & Leasing IV, LLC (“LLC IV”); Venture Lending & Leasing V, LLC (“LLC V”); Venture Lending & Leasing VI, LLC (“LLC VI”); Venture Lending & Leasing VII, LLC (“LLC VII”); Venture Lending & Leasing VIII, LLC (“LLC VIII”); Venture Lending & Leasing IX, Inc. (“Fund IX”), which is wholly-owned by Venture Lending & Leasing IX, LLC (“LLC IX”); WTI Fund X, Inc. (“Fund X”), which is wholly-owned by WTI Fund X, LLC (“LLC X”) WTI Fund XI, Inc. (“Fund XI”), which is wholly-owned by WTI Fund XI, LLC (“LLC XI”) Each Debt Fund’s investment objective is to achieve a superior risk-adjusted investment return. Each Debt Fund’s primary investment strategy is to provide debt financing, in the form of secured loans to venture backed companies and secondarily, to provide debt financing to public and laterstage private companies. These “venture loans” generally consist of a promissory note secured by all of the borrower’s assets. The interest rate and amortization terms of venture loans are individually negotiated between the Debt Funds and each borrower. These loans are held by the BDC in the structure. In addition, the Debt Funds could invest in direct equity investment opportunities such as convertible debt, secondary common stock purchases or other equity instruments issued by companies with diverse capitalization and creditworthiness. In addition to the LLCs and the BDCs, Westech serves as the investment adviser to an Equity Fund, which invests primarily in venture equity, WTI Equity Opportunity Fund I, L.P. (“EOF I”). The investment objective of EOF I is to give existing investors in the Debt Funds the opportunity

for more concentrated equity exposure through Westech’s relationships with underlying portfolio companies. The Firm provides investment management services to each of the Funds in accordance with the private placement memorandum, management agreement and limited partnership agreement (or analogous organizational document) of such Fund and/or side letters with investors (collectively, the “Governing Documents”). Investment advice is provided directly to the Funds and not individually tailored to the investors in the Funds. Investment restrictions for the Funds are generally established in the Governing Documents of the applicable Fund. As of October 13, 2022, the Firm became a wholly-owned subsidiary of Ridgepost Capital, LLC, a Delaware limited liability company, which is indirectly owned by Ridgepost Capital, Inc. (NYSE: PX), a publicly held company (“Ridgepost”). A representative of Ridgepost sits on the Firm’s board of managers. Through the Ridgepost ownership structure, the Firm is affiliated with a number of investment advisers, each independently operated and separately registered as an investment adviser with the SEC. Additional information regarding these relationships is set forth in Item 10 below. The Firm manages $2,017,502,061 in client assets on a discretionary basis and no assets on a nondiscretionary basis (calculated as of December 31, 2025).

The Firm or an affiliated managing member or general partner receives from the Funds management fees and (for certain Funds) incentive compensation. In connection with the Ridgepost transaction, certain principals and employees of the Firm established and own VLL Legacy LLC, which receives incentive compensation from certain of the Funds. In accordance with the Governing Documents, these fees and compensation are deducted directly from Fund accounts. The Firm and VLL Legacy LLC have, and could continue to, waive, reduce or calculate differently all or a portion of any management fees and incentive compensation for one or more investors, including for certain affiliates of the Firm. The precise amount of, and the manner and calculation of, the management fees in certain cases differ from one Fund to another, and these are set forth in such Fund’s Governing Documents received by each investor prior to investment in a Fund. WTI will generally calculate management fees on a quarterly basis, in arrears. Each quarter, the previous quarter’s calculation of management fees is reviewed in case there has been a change and, if necessary, a “true-up” adjustment is made to the current quarter calculation. Management fees are based on information as of the last day of the quarter and are not prorated for capital contributions and withdrawals made during the applicable calendar quarter. Any underpayments or overpayments are adjusted and paid with the following quarter’s payment. Performance-based compensation payable to the Firm, affiliated general partner or VLL Legacy LLC is payable quarterly, annually or more frequently as described in the applicable Governing Documents.

The Firm charges each Debt Fund similar (although not identical) management fees based on either a cost basis of assets, the fair value of assets, or committed capital, and VLL Legacy LLC or affiliated general partner charges each Debt Fund an incentive allocation, typically 20% of profits, so long as an identified “hurdle” rate of return for the Debt Fund is reached. The Firm charges the Equity Fund a management fee of 0.5% of the cost basis of such Equity Fund’s investments, and affiliated general partner receives an incentive allocation of 15% of profits up to and until a hurdle is reached, after which the incentive allocation is increased to 20% of profits. The management fee and incentive allocation charged to the Funds by Westech and VLL Legacy LLC or affiliated general partner respectively are summarized below. Investors should refer to the Governing Documents of each Fund for a full description of management fees and performancebased compensation. Effective October 1, 2015, the Firm has waived all management fees for LLC IV. LLC IV pays VLL Legacy LLC an incentive allocation of 20% of total profits so long as the preferred return of 8% per annum, cumulative but not compounded, on unreturned capital is maintained. Effective February 20, 2017, the Firm has waived all management fees for LLC V. LLC V pays VLL Legacy LLC an incentive allocation of 20% of profits so long as the preferred return of 8% per annum, cumulative but not compounded, on unreturned capital is maintained. Effective June 28, 2020, the Firm has waived all management fees for LLC VI. LLC VI pays VLL Legacy LLC an incentive allocation of 20% of total profits so long as the preferred return of 8% per annum, cumulative but not compounded, on unreturned capital is maintained. Effective December 18, 2022, the Firm has waived all management fees for LLC VII. LLC VII pays VLL Legacy LLC an incentive allocation of 20% of total profits so long as the preferred return of 8% per annum, cumulative but not compounded, on unreturned capital is maintained. Effective August 12, 2025, the Firm has waived all management fees for LLC VIII. LLC VIII pays VLL Legacy LLC an incentive allocation of 20% of total profits so long as the preferred return of 8% per annum, cumulative but not compounded, on unreturned capital is maintained. Fund IX and LLC IX and WTI Fund X and LLC X and Fund XI and LLC XI pay fees in the same manner. In particular, each Fund pays a combined fee calculated as a percentage of committed equity capital, as follows:

Management Fee

Fund IX & Fund X & Fund XI Investment Management Fee

LLC IX and LLC X Management Fee

Year 1:

1.75%

1.575%

0.175%

Year 2:

2.00%

1.600%

0.400%

Year 3:

2.25%

1.575%

0.675%

Total

Management Fee

Fund IX & Fund X & Fund XI Investment Management Fee

LLC IX and LLC X Management Fee

Year 4:

2.50%

1.500%

1.000%

Year 5:

2.50%

1.250%

1.250%

Year 6:

2.25%

0.900%

1.350%

Year 7:

2.00%

0.600%

1.400%

Year 8:

1.75%

0.350%

1.400%

Year 9:

1.50%

0.150%

1.350%

Year 10:

1.50%

0.000%

1.500%

Total

Management fees are not payable for Fund IX or LLC IX, WTI Fund X or LLC X and WTI Fund XI or LLC XI for any fiscal quarter commencing following the ten-year anniversary of the initial contribution date. Additionally, LLC IX, LLC X and LLC XI each pay a managing member affiliated with the Firm an incentive allocation of 20% of total profits once a preferred return of 8% per annum, cumulative but not compounded, on unreturned capital is reached. EOF I pays the Firm a management fee of 0.5% of the cost basis of its investments. Additionally, a general partner affiliated with the Firm receives an incentive allocation of 15% of EOF I’s profits up to and until a hurdle is reached, after which the incentive allocation is increased to 20% of profits. Expenses Debt Fund Expenses All expenses incurred by each Debt Fund will be paid by that Debt Fund, or the Firm or its affiliates on behalf of the Debt Fund, in connection with the organization of the Debt Fund and the initial offering of its interests. In connection with the organization and initial offering of interests in the Debt Fund, the Debt Fund will pay all expenses incurred by the Debt Fund or its general partner (or its affiliates) on behalf of the Debt Fund up to a maximum of $1,000,000 less the amount of organizational and offering expenses paid by the Debt Fund. Except those specifically required to be borne by the Firm, each Debt Fund will pay all of its operating expenses, including: (i)

brokerage, legal, accounting and commission fees and expenses and other transaction costs related to acquisitions, dispositions, structurings and/or restructurings (including collection and/or workout costs and expenses) of

investments (including investments that are not consummated, and including the costs associated with forming, maintaining and liquidating blocker entities), any hedging transactions with respect thereto and the creation and perfection of security interests with respect thereto; (ii)

federal, state and local taxes and fees, including transfer taxes and filing fees, incurred by or levied upon the Debt Fund;

(iii)

interest charges and other fees and expenses incurred in connection with borrowings (including without limitation costs and expenses incurred in connection with negotiating with one or more lenders to the Debt Fund (including prospective lenders) to structure, such as obtaining a loan syndicate and to satisfy any conditions imposed by lenders to the Debt Fund), such as obtaining a security bond;

(iv)

SEC fees and expenses, including the expenses of compliance by the Debt Fund and its directors with SEC rules, regulations, and filing requirements, and any fees and expenses of other federal or state securities or other regulatory authorities;

(v)

expenses of preparing, printing and distributing Debt Fund reports and notices;

(vi)

costs of proxy solicitation;

(vii)

costs of meetings of stockholders, Advisory Board and the Board of Directors;

(viii) charges and expenses of the Debt Fund’s custodian, transfer and dividend disbursing agents; (ix)

any fees and expenses incurred to conduct background checks on the management personnel of prospective Debt Fund investments;

(x)

compensation and expenses of the Debt Fund’s disinterested directors, expenses of directors in attending board meetings, expenses of directors’ and officers’ liability insurance, and payments under indemnification agreements;

(xi)

expenses of administrators, custodians, counsel and auditors;

(xii)

costs of any certificates representing the shares of stock of the Debt Fund, if any;

(xiii) costs of stationery and supplies; (xiv)

the costs of membership by the Debt Fund in any trade organizations;

(xv)

expenses associated with the preparation of tax returns, and financial statements and K-1 s and obtaining accounting and tax advice;

(xvi)

all costs and expenses associated with litigation involving the Debt Fund and the amount of any judgment or settlement in connection therewith;

(xvii) costs and expenses incurred in connection with valuing the Debt Fund’s investments, including valuation software and the retention of any valuation expert; and (xviii) other extraordinary or non-recurring expenses (such as litigation expenses or indemnification expenses). The operating expenses required to be borne by the Firm are limited to: (i)

all costs and fees incident to the selection and investigation of prospective Debt Fund investments, such as travel expenses and professional fees (but excluding broker, legal and accounting fees and other costs incident to the documentation, closing or consummation of such transactions, and further excluding any fees and expenses incurred to conduct background checks on the management personnel of prospective Debt Fund and investments);

(ii)

the cost of adequate office space for the Debt Fund and all necessary office equipment and services, including telephone service, heat, utilities and similar items;

(iii)

the cost of providing the Debt Fund with such corporate, administrative and clerical personnel (including officers and directors of the Debt Fund who are interested persons of the Firm and are acting in their respective capacities as officers and directors, except as specifically carved out above as a Debt Fund expense) as a Debt Fund’s Board of Directors reasonably deems necessary or advisable to perform the services required to be performed by the Firm under the investment management agreement;

(iv)

the cost of providing the BDCs with such corporate, administrative and clerical personnel as the Firm reasonably deems necessary or advisable to perform the services required to be performed by it under the operating agreement of the BDCs, except as specifically carved out above as a Debt Fund expense; and

(v)

costs and expenses associated with the Firm’s registration or compliance with, or examination by the SEC with respect to the Advisers Act (other than charges and expenses of the Debt Funds’ or the BDC custodian, transfer and dividend disbursing agents or any other costs or expenses associated with the acquiring, holding or disposing of the Funds’ or the assets, whether required by the Advisers Act (or similar state laws) or otherwise).

Equity Fund Expenses EOF I will bear all expenses incident to EOF I’s organization, the general partner and related entities, as well as offering and other similar expenses related to EOF I. In addition, EOF I will also bear all costs incurred by it, the general partner and the Firm on behalf of EOF I in connection with operation of its business, including all costs and expenses incurred in respect of:

(i)

the purchase, holding or sale or other disposition of securities;

(ii)

federal, state and local taxes and fees incurred by or levied upon EOF I, including real property or personal property taxes on investments, filing fees, brokerage fees, taxes and fees applicable to EOF I on account of its operations (including fees incurred in connection with the maintenance of bank or custodian accounts, as well as any fees payable to transfer or dividend disbursing agents);

(iii)

legal, audit, and other expenses incurred in connection with the registration of EOF I’s portfolio securities under the applicable securities laws;

(iv)

brokerage, legal, accounting and commission fees and expenses incurred in connection with the purchase or sale or other disposition of securities (whether or not such purchase, sale or other disposition is ultimately consummated), or in connection with the restructuring or hedging of any investment by EOF I;

(v)

interest charges and other fees and expenses incurred in connection with any permitted borrowings (including without limitation costs and expenses incurred to satisfy any conditions imposed by lenders to EOF I);

(vi)

any fees and expenses associated with complying with requirements imposed by any federal and state securities or other regulatory authorities, including the expenses of compliance by EOF I with federal and state securities rules, regulations and filing requirements;

(vii)

fees and expenses of investment advisers and independent consultants incurred in investigating and evaluating investment opportunities (including any fees incurred to conduct background checks on the management personnel of prospective investments);

(viii) fees of any independent certified public accountants incurred in connection with the annual audit of EOF I’s books and the preparation of EOF I’s annual tax return, costs of independent appraisers, legal and (ix)

custodian expenses of EOF I, expenses of EOF I’s administrators and accounting expenses paid to third parties for the maintenance of EOF I’s books and records and preparation of reports;

(x)

costs of stationary and supplies;

(xi)

premiums associated with insurance, if any, to insure against any claims that could be made directly against EOF I, the general partner or the Firm (or any other persons entitled to indemnification under the terms of EOF I’s partnership agreement) or that could give rise to a fund liability to indemnify any such persons pursuant to the partnership agreement;

(xii)

preparation and other expenses associated with notices and annual and other reports to the partners of EOF I, costs associated with any EOF I information meetings,

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The following is a summary of the investment strategies and methods of analysis employed by the Funds. This summary as well as the descriptions set forth in this Brochure should not be understood to limit in any way the Firm’s investment activities. The Firm may offer any advisory services, engage in any investment strategy and make any investments, including any not described in this Brochure, that the Firm considers appropriate, subject to the investment objectives and guidelines contained in the Governing Documents for each Fund. Specific descriptions of such strategies and methods are included in each Fund’s Governing Documents. The Fund’s investment objectives, investment policies and investment guidelines (other than BDC requirements) are not fundamental policies and can be changed by the Board of Directors at any time. The Firm’s investment strategy for each of the Debt Funds is to provide debt financing, primarily in the form of secured loans, to companies backed by venture capital (“VC”) investors and debt financing to public and later-stage private companies. The Debt Funds invest in special situations, including convertible debt instruments, and in convertible debt or other equity instruments issued by companies of diverse capitalization and creditworthiness, including, without limitation, earlystage private companies, public and late-stage private companies, and companies undergoing restructuring or recapitalization of their existing debt or equity financing. In addition, the Debt Funds can invest in direct equity investment opportunities (including equity securities of companies whose loans are held by the Fund) up to a proportion of their assets subject to and in accordance with the Fund’s Governing Documents; these investments are in addition to any equity received as a result of the exercise of warrants or venture loans. The Equity Fund primarily makes investments in a subset of those opportunities to purchase equity interests in companies in which LLC VIII, LLC IX, or LLC X (or any subsequent LLC) has invested or is investing and where the

opportunity to make such investment is permitted pursuant to the terms of Governing Documents of the applicable Debt Funds. The Firm evaluates potential investments on a case-by-case basis, using both credit and “venture capital” approaches. The initial phase includes the collection of relevant materials such as business plans, financials and pro-forma projections, capitalization tables, management biographies, and corporate documents. Additionally, the WTI investment team meets with the CEO and management team of the prospective companies. Reference checks could be performed by contacting venture capitalists, customers, and competitors. A credit and/or equity file is created to serve as the basis to monitor progress of the company against its expected milestones. The Funds typically use a buy-and-hold strategy where investments are held to maturity or exit. All securities are evaluated on a regular basis to determine whether there should be any change to this strategy. Some debt investments are restructured, which results in the extension of the original maturity date or other change in the instrument, including but not limited to, conversion of all or part of the instrument to equity. The Funds typically do not purchase publicly held securities; however, some publicly-held securities are acquired through warrant exercises, mergers, acquisitions, and IPOs of the companies in which investments are made. Additionally, in some cases, public securities are issued in conjunction with loans made to public companies. When a company’s securities become publicly traded, a Fund can hold these securities and sell them or choose to distribute the securities directly to its investors. If held, publicly-traded securities are monitored on an on-going basis, and a variety of factors regarding the company (e.g., trend in stock price, underlying business fundamentals and potential for growth, information regarding the lock-up) are used to determine when to sell these securities. Risks The following is a summary of the material risks involved in the investment strategies and methods of analysis that the Firm employs. This Brochure is not intended to address every potential risk and investors in the Funds should refer to the Governing Documents of the applicable Fund for more information on risk factors. There can be no assurance that the investment objectives of any client will be achieved. Investing in securities involves risk of loss that clients should be prepared to bear. Reliance on Management The Debt Funds have an initial investment period of four years (subject to extensions as set forth in the Governing Documents of each Fund), and the Equity Fund has an initial investment period of ten years, and each could require a substantial amount of this time to become fully invested (if at all). Pending investment, all cash that the Funds have received pursuant to capital calls will be committed to short-term, high-grade investments that present relatively low investment risk but provide a correspondingly lower return (e.g. overnight money market funds). The Funds do not intend to call upon their respective investors to contribute more capital than is expected to be needed to fund loans or equity, pay expenses or meet investment commitments that are outstanding or expected to be entered into within a reasonable time after such capital call. The Funds are wholly dependent for the selection, structuring, closing and monitoring of their investments on the

diligence and skill of the Firm, acting under the supervision of the Funds’ Boards of Directors and/or Advisory Boards. Although the principals of the Firm have several decades of combined experience in investing in venture lending transactions and equity investments, there can be no assurance that the Funds will achieve their investment objectives. Furthermore, the Firm does not have substantial experience in investing in special situations such as convertible and subordinated debt of public and late-stage private companies. The investment team of the Firm will have primary responsibility for the selection of the companies in which the Funds will invest, the negotiation of the terms of such investments and the monitoring of such investments after they are made. Although the investment team intends to devote such time as is necessary to the affairs of the Funds, they are not required to devote full time to the management of the Funds. Furthermore, there can be no assurance that any investment team member will remain associated with the Firm or that, if an investment team member ceases to be associated with the Firm, the Firm would be able to find a qualified person or persons to fill their positions. Limits on Transferability and Long-Term Investments Other than as described below, interests in the Funds have not been and will not be registered under the federal or state securities laws and are subject to substantial restrictions on transfer. There will be no trading market for the interests in the Funds, and investors of the Funds most likely will have to hold their interests until the final liquidation of the applicable Funds. In certain instances, the liquidation process of a particular Fund might not be completed for a significant period after the Fund’s termination date. For example, of all of the Prior Funds, only Funds I, II, and Fund III have completed the liquidation process. Funds I and II, which were established in 1994 and 1997, and their related LLCs did not liquidate until 2010 and 2012 respectively. Fund III was established in 2000 and liquidated on October 2, 2017. An investment in the Funds is, therefore, illiquid and should be considered only by investors financially able to maintain their investment for the long term. Competition Other entities and individuals compete for investments similar to those proposed to be made by the Funds, some of whom, with respect to investments in the form of loans, and many of whom, with respect to the equity investments and convertible and subordinated debt, have greater resources than the Funds. Furthermore, competition could increase given the low barriers to entry in the industry. Additionally, the BDCs need to comply with provisions of the 1940 Act pertaining to BDCs and, if a BDC qualifies as a regulated investment company (“RIC”), provisions of the Internal Revenue Code of 1986, as amended (the “Code”), pertaining to any RICs, which might restrict such BDC’s flexibility as compared with its competitors. The need to compete for investment opportunities could make it necessary for the Funds to offer borrowers or companies in which it makes debt and/or equity investments more attractive terms than otherwise might be the case.

Diverse Investor Group The investors can have conflicting investment, tax, and other interests with respect to their investments in the Funds. The conflicting interests of individual investors relates to or arises from, among other things, the nature of investments made by the Funds, the structuring or the acquisition of investments, and the timing of disposition of investments. Consequently, conflicts of interest arise in connection with decisions made by the Firm, including with respect to the nature or structuring of investments that could be more beneficial for one investor than for another investor, particularly with respect to investors’ individual tax situations. In selecting and structuring investments appropriately for the Funds, the Firm will consider the investment and tax objectives of each of the Funds as applicable, and the investors as a whole, and not the investment, tax, or other objectives of any investor individually. Equity and Convertible Debt The Debt Funds invest in special situations, including convertible debt instruments, including those issued by companies of diverse capitalization including, without limitation, early-stage private companies, public and late-stage private companies, and companies undergoing restructuring or recapitalization of their existing debt or equity financing. Convertible debt generally offers lower interest yields than nonconvertible debt of similar quality and often will offer conversion into the next round of financing at a discount to the final valuation. The conversion price is the predetermined price at which the debt instrument could be exchanged for the associated stock. In most cases of a convertible debt investment, the investment is considered by the Firm to be the equivalent of an equity investment and is treated as such during the diligence process. Further, in most cases, the instrument does not have a redemption option and will automatically convert once the next round of financing is raised. Subordinated Debt The Debt Funds invest in special situations, including subordinated debt instruments, which tend to be predominantly high-yield non-convertible debt securities without a first lien position. Investments in high-yield securities involve substantial risk of loss. Sub-investment grade nonconvertible debt securities, or comparable unrated securities, are commonly referred to as junk debt and are considered speculative with respect to the issuer’s ability to pay interest and principal, and are susceptible to default or decline in market value due to adverse economic or business developments. If publicly-traded, the market values for high- yield securities tend to be very volatile, and these securities are less liquid than investment-grade debt securities. In certain situations, a Debt Fund could also choose to make a subordinated debt investment in companies that already have an existing debt provider. Further, a Debt Fund could also choose to subordinate existing outstanding debt as part of a restructuring or work-out arrangement in order to allow the company to successfully complete a transaction such as an acquisition or round of financing. There can be no assurance that the subordination will work to the benefit of the applicable Debt Fund. Interest Rate Risk The Debt Funds make loans to portfolio companies in which the interest rate is fixed upon funding. Changes in the external interest rate could adversely affect a Fund’s performance due to such

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The Firm provides investment advisory services to the Funds. Investors participating in the Funds are (i) “accredited investors” within the meaning of Rule 501 of Regulation D under the Securities Act of 1933, as amended; and (ii) “qualified purchasers” as defined in Section 2(a)(51)(A) of the 1940 Act; or (iii) “knowledgeable employees” within the meaning of Rule 3c-5 of the 1940 Act. Investors in the Funds are not clients of the Firm. The minimum investment amount is stated in the Governing Documents, and Westech or its affiliates can reduce or waive the minimum investment at its discretion.

As stated above in Item 5, VLL Legacy LLC or a managing member or an affiliated general partner receives performance-based compensation through allocations of income and ordinary and capital gains based on client assets, after certain hurdle rates have been met. These compensation arrangements create incentives for the Firm or affiliates to recommend investments that have a higher degree of risk or are more speculative than those that would be recommended under a different fee arrangement, and this creates an incentive to favor Funds that pay higher performance compensation over other Funds. Similarly, performance-based fees incentivize the Firm or affiliates to make decisions regarding the timing or structure of investment realizations that might not be in the best interest of investors. Investments with higher yield potential are generally riskier or more speculative, which could result in increased risk to the Fund’s investors. The Firm seeks

to mitigate the conflicts of interest created by this incentive through its investment allocation policies and procedures, described in Item 10 below. As stated above in Item 4 and described below in Item 10, the Firm’s investment professionals operate independently of Ridgepost and its affiliates. Ridgepost affiliates and the Firm share various operational resources and systems of Ridgepost. The Firm’s investment committee or team makes all investment and allocation decisions with respect to the Funds’ investment strategies, processes and policies, separate and apart from each Ridgepost affiliate’s strategies, processes and policies.

The Firm’s principals and employees can engage in outside business activities, including serving as outside directors of companies that are not portfolio companies. Before doing so, the outside activity must be approved by the Firm’s compliance department. There are certain relationships involving some of the Firm’s principals and employees that present conflicts of interest. The Firm can, and sometimes does, recommend that the Funds invest in companies in which a principal or employee has a prior personal investment or for which a principal or employee served as a director or advisor. The Firm or its affiliates can, and sometimes does, recommend that the Funds invest in companies in which venture capital funds, private equity funds or other institutional investors (“Unaffiliated Funds”) also have made investments, where one or more principals or employees of the Firm has made an investment in, or served as an advisor to, an investing Unaffiliated Fund. The Firm believes that these relationships generally benefit the Funds in that they provide the Firm’s principals and employees with access to investments and information that might not otherwise be available to the Firm and the Funds. Nonetheless, the relationships present conflicts of interest in that the relationship could provide the Firm principal or employee in question with an incentive to influence the Firm’s decision to recommend an investment in the company in question. They also present conflicts of interest in that the Firm principal or employee in question could use information acquired through association with the Firm to influence or benefit Unaffiliated Funds’ investment decisions. The Firm addresses these conflicts through internal policies and procedures designed to insulate its investment decision-making process and its research from these incentives. For example, principals with a prior investment in a company are recused from the investment decision-making process with respect to that company. The Firm’s principals or employees who are serving as advisors to Unaffiliated Funds can be, and sometimes are, called upon to make investment recommendations to these Unaffiliated Funds. These investments can be, and sometimes are, the same as those in which the Funds are making an investment, and the Firm has policies and procedures in place to require that these are first offered to the Funds and only subsequently offered to the Unaffiliated Fund once declined by the Funds. In addition, compensation from a board of a portfolio company or from advisory

relationships is assigned to the Firm. The Firm also addresses these conflicts of interest through the provisions of its Code of Ethics, as described below. Fund IX, Fund X, Fund XI and the Equity Fund have a general partner that is an affiliate of the Firm, and this relationship causes conflicts of interest to arise that could impact the management of these Funds. As described in Item 6, the general partner can receive performance-based fees in connection with the services provided to these Funds, and the conflicts of interest created by performance-based fees are discussed further in response to Item 6. The Firm maintains policies and procedures reasonably designed to manage the conflicts of interest related to performancebased fees. Through the Ridgepost ownership structure, the Firm is affiliated with a number of separately registered investment advisers. In addition to the Firm, Ridgepost is the indirect parent company of the following SEC registered investment advisers: Enhanced Capital Partners, LLC; Five Points Capital, LLC; Truebridge Capital Partners, LLC; RCP Advisors, LLC; and RCP Advisors 2, LLC and its relying advisers, RCP Advisors 3, LLC, Hark Capital Advisors, LLC and Bonnacord Capital Advisors, LLC and Qualitas Equity Funds SGEIC, S.A. which is registered with the CNMV, Spain’s securities regulator (together, the “Ridgepost Subsidiaries”). Notwithstanding the common ownership between the Firm and the Ridgepost Subsidiaries, the Firm operates independently from each of the Ridgepost Subsidiaries and maintains a separate investment program from the Ridgepost Subsidiaries, while sharing various operational resources and systems of Ridgepost. Investment Allocation Policies and Procedures As a fiduciary, the Firm is committed to allocating investment opportunities among the Funds in a manner that is fair and equitable to each Fund over time, taking into account the terms of the relevant Governing Documents. To guide the determination of such allocations, the Firm has adopted policies and procedures that seek to mitigate conflicts of interest that arise from the Firm’s compensation arrangements and other incentives. The BDCs are regulated under the1940 Act. The 1940 Act generally prohibits “joint” transactions with an affiliate (as well as with affiliates of those affiliates), which could include co-investments in the same portfolio company by two or more Funds. The Boards of Directors of the BDCs (including a majority of the disinterested directors and a majority of the directors having no financial interest in the transactions (“required majority”)) and the advisory boards of the LLCs (“Advisory Boards”) have each adopted procedures (“Procedures”) that allow the Debt Funds to co-invest in portfolio companies with other Funds, subject to compliance with the Conditions, as described above under the caption “Regulation.” Under these Conditions, the Firm must determine that participation in any such investment is appropriate for each BDC, and a required majority of the Board of Director of each such BDC must make certain conclusions in connection with a coinvestment transaction, including, but not limited to, that (1) the terms of the potential coinvestment transaction, including the consideration to be paid, are reasonable and fair to the BDC and its shareholders and do not involve overreaching on the part of any person concerned and (2) the potential co-investment transaction is consistent with the interests of the shareholders of the BDC and with the BDC’s objectives and strategies.

As a general matter, if two BDCs are each making active investments, they will generally make debt investments in the same portfolio companies, with the amount of the investment allocated among them on a fair and equitable basis as determined by the Firm considering all of the circumstances and in accordance with the Procedures described above. A required majority of the Board of Directors of each such BDC must approve, and can adjust, the allocation amount of any investment recommended by the Firm in which two BDCs are investing. Under the Procedures, it is expected that allocations will be equal, until such time as one BDC runs low on investable capital, at which time, the allocation may be based on the remaining capital available for investment, or, subject to approval by a required majority of the Boards of Directors of the respective BDCs, another methodology that takes into account the BDCs’ investment pace, remaining commitment periods, and other relevant factors. The Procedures apply both to first-time and to follow-on debt and equity investments in portfolio companies. The Firm generally negotiates to obtain, in connection with debt investments, warrants to purchase equity in the applicable portfolio company and contractual rights to participate in future equity offerings (“Participation Rights”) by the portfolio company. Warrants are generally distributed by the BDC that receives them to its parent LLC, at or shortly following their acquisition. When obtained, these warrants and Participation Rights are generally allocated to the LLCs in the same proportions as the related debt investment and can be exercised by the LLCs subject to the Procedures. Where the Firm only negotiates price and no other terms, the LLCs can exercise Participation Rights in pre-existing portfolio companies after evaluating factors that generally include the dilutive effect, the stage of the Fund’s investment cycle, the amount of equity the LLC already holds, its amount of available capital, and other factors, and the Firm will prepare a written statement describing the allocation decision, pursuant to SEC staff guidance. Opportunities to make an equity investment in a pre-existing or a potential new portfolio company can arise separately from the terms of debt investment activity (i.e., other than as a result of the exercise of warrants or Participation Rights). A Debt Fund can also have an opportunity to acquire equity in a pre-existing or a potential new portfolio company in an amount that exceeds what the Firm deems to be a prudent investment for the Debt Fund. In these cases, the equity investment will be allocated in a manner that is fair and equitable to the Debt Funds and the Equity Fund over time, taking into account a number of factors, including the risk and return profile of the investment, the stage of the Debt Fund’s investment cycle, the amount of equity the Debt Fund or the Equity Fund already holds, their amounts of available capital, and other factors.

Trading The Firm has established a Code of Ethics that applies to all of our associated persons, including WTI’s principals, partners, certain officers, employees (or other persons occupying a similar status or performing a similar function) and any other person who provides advice on its behalf and is subject to our supervision and control (“Supervised Persons”). As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Our Code of Ethics requires our associated persons to place the interests of the Funds and investors ahead of the Firm’s and their personal interests at all times, to not take inappropriate advantage of their positions, and to conduct their personal securities transactions consistent with the Code of Ethics. Our fiduciary duty to our clients

is considered the core underlying principle for our Code of Ethics, which also includes insider trading and personal securities transactions policies such as preclearance. We require all of our Supervised Persons to conduct business with the highest ethical standards and to comply with federal and state securities laws. Upon employment or affiliation and at least annually thereafter, all Supervised Persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and Supervised Persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided upon request. The investments made by our Firm’s principals and employees are discussed in Item 10 above.

As the Funds invest primarily in privately-placed securities purchased from issuers, neither they nor Westech will generally engage broker-dealers or other intermediaries to execute such securities transactions. However, as permitted by the Governing Documents, the Funds generally will sell in the public markets equity securities of portfolio companies that have gone public and listed their stock. In these circumstances, Westech will generally have discretionary authority to select the broker or dealer used to execute transactions on behalf of each Fund and to negotiate the commission cost to be paid by the Fund. Brokers and dealers generally are selected in a manner consistent with the Firm’s duty to seek to obtain best execution (i.e., the most favorable results reasonably attainable under the circumstances, taking into account a variety of factors, including price and costs as well as qualitative factors), including based on their ability to handle transactions involving restricted securities, commission rates or spreads, and breadth of market in particular securities. The applicability of specific criteria will vary depending upon the nature of the transaction, the market in which it is executed, and the extent to which it is possible or practical to select from among multiple brokers or dealers. While Westech considers fees and would assess the reasonableness of the compensation, Westech would not necessarily select the broker that offers the lowest commission, consistent with its duty to seek best execution. No soft dollar arrangements are entered into. If the Funds decide to distribute shares directly to investors, the Firm will review the brokerage options and will choose a broker or dealer based on a number of factors, including pricing and the number of shareholders who have existing relationship with any brokerage. To the extent that Westech is purchasing or selling the same security for more than one client, Westech can aggregate orders in an effort to reduce transaction costs and will seek to allocate such transactions fairly and equitably among the clients over time. As described in Item 4 and Item 10 above, through the Ridgepost ownership structure, Westech is affiliated with several investment advisers. The Firm and the Ridgepost Subsidiaries operate their respective investment programs independently and have established and maintain procedures to minimize conflicts in making investments.

We do not currently directly or indirectly compensate any person who is not a supervised person for client referrals.

Neither the Firm, nor any management person, has had legal or disciplinary events (e.g., certain criminal or civil actions in domestic, foreign or military court, administrative proceedings before the SEC or any other federal regulatory agency or any state regulatory agency, or self-regulatory organization) that are material to evaluating the Firm’s advisory business or its integrity.

The Firm regularly monitors the Funds’ investments and investment opportunities. The Firm’s investment team meets regularly to discuss new investment opportunities, the evolving venture capital landscape and other pertinent information such as pricing and competition. Members of the investment team closely monitor existing portfolio companies. The team members discuss business progress with portfolio company management and review detailed financial and other portfolio company-related information on a regular basis. A subset of the Firm’s investment partners form a credit committee for each prospective investment and this committee is responsible for approving the investment and reviewing and approving any subsequent changes. Reporting The Firm provides statements of account to all of the Funds’ investors on a quarterly basis. Fund IX LLC, Fund X LLC, Fund XI LLC, LLC IV, LLC V, LLC VI, LLC VII, LLC VIII and the Equity Fund report financial statements, portfolio and other information quarterly to their shareholders or members. Investors receive annual audited financial statements within 120 days of the end of each fiscal year. In addition, each investor will be provided annually with an IRS Schedule K-1.

The Firm is not a qualified custodian, and its practice is not to take actual or physical custody of client assets (and if it received such funds inadvertently, would handle them in compliance with SEC rules and guidance). Notwithstanding the foregoing, the Firm recognizes that by serving as managing member or general partner for the LLCs and Equity Fund it is deemed to have custody of these Funds’ funds and securities for purposes of Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). In circumstances where the Firm is deemed to have custody, it complies with the requirements of the Custody Rule, which requires, among other things, that a qualified custodian (for example, a bank or broker-dealer) maintain all client funds and securities, with certain exceptions for privately placed securities. The LLCs and Equity Fund are subject to an annual qualifying audit pursuant to an exception under the Custody Rule, under which these Funds: 1) conduct an annual financial statement audit by an independent public accountant that is registered with and subject to regular inspection by the Public Company Accounting Oversight Board; and 2) distribute audited financial statements prepared in accordance with generally accepted accounting principles (GAAP) to the pool’s investors. Under this exception, these Funds are not subject to the annual surprise audit, notice, and account statements provisions of the Custody Rule.

Investment advice is provided directly to the Funds, and not individually to the investors in the Funds. Services are provided to the Funds in accordance with the Governing Documents of the

applicable Fund. Investment restrictions for the Funds, if any, are generally established in the Governing Documents of the applicable Fund.

The Firm has adopted written policies and procedures with respect to the proxies it votes on securities owned by the Funds (the “Proxy Policies”). The Proxy Policies set forth the Firm’s policies for voting equity securities acquired by the Funds through the exercise of warrants or purchased directly from the issuer. The Firm will generally (i) refrain from voting equity securities unless the amount of such securities is equal to or greater than 2.0% of all securities of the issuer entitled to vote at that meeting, and (ii) if such threshold is exceeded, vote the equity securities and report its vote, together with its rationale, to the board of directors or advisory board of the relevant Fund. If there is a conflict of interest between Westech and the Funds with respect to voting their securities, it will be resolved in accordance with the Proxy Policies. The Firm has adopted policies and procedures that are reasonably designed to ensure it votes Fund securities in the best interest of the Fund. Copies of the relevant proxy logs, identifying how proxies were voted in connection with a Fund are available to Fund investors and copies of the Proxy Policies are available to any person at no charge upon written request to: Western Technology Investment, 104 La Mesa Drive, Suite 102, Portola Valley, CA 94028, Attention: Chief Compliance Officer or by submitting a request to compliance@westerntech.com.

The Firm does not have any financial condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to clients.