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Greylock Capital Management, LLC: investment adviser

Greylock Capital Management, LLC is an investment adviser registered with the SEC (file 801-65137, CRD 137825). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$313.9M
Discretionary
100%
Accounts
5
Employees
6
In advisory roles
4
Disclosures
0

Company page · SEC adviser record · Full Form ADV (PDF)

The firm reports that it or a related person has custody of client cash and securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles3$87.2M27.8%
Charities1$226.4M72.1%
State and local governments1$205.1K0.1%

How it is paid

  • A percentage of assets under your management
  • Performance-based fees

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)
  • Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Greylock Capital Associates, LLCCompany (U.S.)MemberE 75% or moreJan 2004Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
Willem Johannes HumesGreylockPersonD 50% to 75%Yes
Ajata NMN MedirattaGreylockPersonC 25% to 50%Yes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

The firm answered No to every disciplinary question on Form ADV (Item 11).

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Greylock Capital Management, LLC Form ADV Part 2A - 2026, filed Mar 30, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

Greylock Capital Management, LLC (“Greylock Capital”) is a Delaware limited liability company organized in 2003. Greylock Capital is a wholly owned subsidiary of Greylock Capital Associates, LLC (“GCA”), a Delaware limited liability company organized in 2003. Greylock Capital and its predecessor entities have been in business since 1997. The principal owners of Greylock Capital are Willem J. Humes and Ajata Mediratta. Greylock Capital provides discretionary and non-discretionary investment management services to its clients, which are certain private funds (the “Greylock Global Funds”) and separate accounts for institutional investors.

Read the rest of Item 4 (205 more words)

Greylock Capital may advise other clients in the future, including pooled investment vehicles and separate accounts, and may provide both discretionary and non-discretionary advisory services to clients. Greylock Capital focuses primarily on distressed debt, event-driven and high-yield investment strategies in the global fixed income markets. However, Greylock Capital is generally granted broad investment authority with respect to the management of the accounts of its clients and invests across a broad range of financial instruments in the execution of its investment strategies. Greylock Capital clients, including the Greylock Global Funds, may maintain investment guidelines or restrictions from time to time, including guidelines or restrictions regarding investment concentration in particular financial instruments, issuers, industries or geographical regions. Investors and prospective investors in each Greylock Global Fund should refer to the confidential private placement memorandum, limited partnership agreement and other governing documents for each Greylock Global Fund (the “Governing Documents”) for more complete information on the investment objectives and investment restrictions of a particular Greylock Global Fund. There is no assurance that any of the Greylock Global Funds’ investment objectives will be achieved. As of December 31, 2025, Greylock Capital has approximately $313,675,075 in regulatory assets under management on a discretionary basis, and $205,076 on a non-discretionary basis.

Item 5. Fees and compensation

The fees applicable to each Greylock Global Fund are set forth in detail in the relevant Greylock Global Fund’s Governing Documents. Greylock Capital charges a management fee equal to an annual percentage of the net assets of each Greylock Global Fund, which may be paid in arrears or in advance (the “Management Fee”), and an incentive allocation equal to a percentage of the amount by which (i) the net asset value of each investor’s holding in a Greylock Global Fund as of the end of each incentive period, exceeds (ii) the net asset value of such investor’s holding as of the beginning of such incentive period, subject to a “high water mark” (the “Incentive Allocation”). In certain cases, the Incentive Allocation may also be calculated with reference to performance in excess of an external performance standard, such as

Read the rest of Item 5 (477 more words)

the 90-day U.S. Treasury Bill rate. The Incentive Allocation is usually paid annually and may be allocated to an affiliate of Greylock Capital. Greylock Capital may, in its discretion, reduce, waive or calculate differently the Management Fee or the Incentive Allocation with respect to certain clients or investors, including members, officers, affiliates or employees of Greylock Capital or its affiliates, or any such person’s family members and trusts or other entities established for the benefit of such person or his or her family. Greylock Capital may also enter into “side letters” or similar agreements with certain investors in the Greylock Global Funds, granting such investors specific rights, benefits, or privileges that are not made available to investors generally. The fees applicable to clients of Greylock Capital other than the Greylock Global Funds are negotiated directly with such clients and are reflected in the investment advisory agreement between each client and Greylock Capital. The specific manner in which fees are charged and deducted is set forth in each client’s written agreement with Greylock Capital, which may include payment of fees in advance. Greylock Capital generally accrues fees monthly and the account administrator for pooled vehicles, including Greylock Global Funds, deducts them directly from each client account when they become payable Separate account clients are typically sent an invoice and remit payment to Greylock Capital. Upon termination of any client account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Refunds of fees paid in advance are generally calculated on a pro rata basis, based on the remaining portion of the relevant period to which the applicable fee relates. Clients of Greylock Capital also generally pay all costs and expenses incurred in connection with the investments in their accounts, including but not limited to brokerage commissions, custodial fees, interest on margin accounts and other indebtedness, custodial fees, bank service fees, accounting and legal expenses, costs of any appraiser, accountant, attorney or other expert or consultant engaged in connection with the investments or operations of the client’s account, insurance costs, filing fees and expenses (including preparation and filing expenses for regulatory filings made in respect of the client or the client's assets), and any other expenses reasonably related to the purchase, sale, holding, transmittal, enforcement and collection of investments made by a client, expenses in connection with proposed transactions (including transactions that fail to close), costs related to any litigation, arbitration, investigation or other proceeding related to the investments or operations of the client's account, as described in greater detail in the Governing Documents for each Greylock Global Fund or in the investment management agreement between Greylock Capital and the client, as applicable.

Item 12 below further describes the factors that Greylock Capital considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).

Item 6. Performance-based fees and side-by-side management

Greylock Capital, or an affiliate designated by Greylock Capital, is eligible to receive an Incentive Allocation in respect of each Greylock Global Fund and has other client relationships in which a performance-based fee may be payable. Please refer to the Governing Documents of each Greylock Global Fund for more complete information on the performance-based compensation arrangements of each of the Greylock Global Funds. Different client accounts may be subject to different performance-based compensation arrangements. All performance-based fee or Incentive Allocation arrangements discussed above comply with Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”).

Read the rest of Item 6 (238 more words)

Performance-based fee arrangements may create an incentive for Greylock Capital to recommend investments that may be riskier or more speculative than those that it would recommend under a different fee arrangement. Greylock Capital simultaneously provides advisory services to clients that are charged different levels of performance-based fees or incentive allocations and may also provide advisory services to clients that are not charged such a fee. The potential for Greylock Capital to receive greater fees or allocations from performance-based accounts or accounts paying higher fees creates a potential conflict of interest with respect to the allocation of investment opportunities, as Greylock Capital may be motivated to allocate investments in favor of an account that pays a higher performance-based fee or allocation. To alleviate potential conflicts of interest, the allocation of investment opportunities with respect to each client is made by Greylock Capital in accordance with its investment allocation policy, so that such allocations are fair and equitable to each account over time, taking into account all relevant facts and circumstances applicable to each client. The factors that are considered by Greylock Capital in allocating trades among client accounts include: investment objectives, strategies, guidelines and restrictions applicable to each client; each client’s risk profile or tax status; restrictions under ERISA or other applicable laws or regulations; cash availability; portfolio diversification; account size; and geographical, industry and security weightings. Greylock Capital’s allocation policy is reviewed periodically and is subject to change.

Item 7. Types of clients

Greylock Capital provides advice to the Greylock Global Funds and to a limited number of separately managed accounts. The limited partners and shareholders of the Greylock Global Funds may include public or private benefit plans, endowments, foundations, healthcare organizations, sovereign wealth funds or quasi-governmental organizations, insurance companies, banks or broker dealers, funds of funds, trusts, estates, family offices and high net worth individuals. The clients for which Greylock Capital may manage separately

Read the rest of Item 7 (135 more words)

managed accounts are similarly varied. The Greylock Global Funds are offered in the United States to “accredited investors” as defined under Regulation D under the Securities Act of 1933, as amended (the “Securities Act”), and to “qualified purchasers” as defined under Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Investment Company Act”), and are therefore not required to register as investment companies under the Investment Company Act in reliance upon the exemption under Section 3(c)(7) of the Investment Company Act for funds whose securities are not publicly offered. In addition to the eligibility requirements described above, investors in the Greylock Global Funds are generally required to make a minimum initial investment, the amount of which varies among the Greylock Global Funds, although Greylock Capital may accept lower amounts in its discretion.

Item 8. Methods of analysis, investment strategies and risk of loss

Greylock Capital seeks capital appreciation on behalf of its clients through opportunistic investments in undervalued securities, with a focus on global, non-investment grade debt securities. Greylock Capital strives to achieve this through three principal types of investments: (i) restructurings, (ii) event-driven situations, and (iii) securities that Greylock Capital believes to be generally undervalued when evaluated on their credit characteristics.

Read the rest of Item 8 (4,288 more words)

Combining performing and non-performing assets in a unified investment approach enables Greylock Capital to take advantage of the idiosyncratic return profile associated with distressed situations, while simultaneously seeking to generate returns from the high current income and price appreciation of undervalued performing fixed income assets. Greylock Capital’s investment strategies are primarily focused on U.S. dollar or Eurodenominated debt and debt-like or related investments such as global high yield debt, Eurobonds (both sovereign and non-sovereign issuers), money market instruments, performing and non-performing loans (including loans made to debtors-in-possession), trade receivables, local currency debt securities and letters of credit. Greylock Capital may also invest on behalf of its clients in currencies, equities, futures and options and other instruments. The above description is only a summary, and under the Governing Documents of each Greylock Global Fund and the investment management agreements with respect to other clients, Greylock Capital generally has broad discretion to employ investment strategies not described above that Greylock Capital may, from time to time, consider appropriate. The investment programs of the Greylock Global Funds and of other clients of Greylock Capital are speculative and entail substantial risks. There can be no assurance that Greylock Capital’s investment objectives will be achieved. Accordingly, Greylock Capital’s investment strategies could result in substantial losses to its clients under certain circumstances. Greylock Capital generally accepts only clients that are able to bear the financial risk of the investment strategy for an indefinite period of time and are able to sustain the loss of all or a

significant part of their investment. Prospective investors in the Greylock Global Funds should carefully review the risks described in the Governing Documents for the applicable Greylock Global Fund and should evaluate the merits and risks of an investment in the context of their overall financial circumstances. The risk factors below are not intended to be exhaustive and should be considered carefully by prospective investors together with the full text of the applicable Governing Document or client agreement. Prospective investors should consult their own independent advisors with respect to any additional risk factors applicable to an investment in a Greylock Global Fund that are specific to their situation (including with respect to taxation). Risk Factors International Non-Investment Grade Debt Securities. A substantial percentage of the assets in which Greylock Capital invests are international, non-investment grade debt securities, including short-term and long-term securities denominated in various currencies. These securities may be unrated or rated in the lower rating categories by the various credit rating agencies. These securities may be subject to greater risk of loss of principal and interest than higher-rated securities and are generally considered to be predominantly speculative with respect to the issuer's capacity to pay interest and repay principal. They are also generally subject to greater risk than securities with higher credit ratings in the case of deterioration of general economic conditions. Additionally, evaluating credit risk for non-U.S. debt securities involves greater uncertainty than such evaluation of U.S. debt securities, because credit rating agencies throughout the world have different standards, making comparisons across countries difficult. Because investors generally perceive that there are greater risks associated with lower-rated securities, the yields or prices of such securities may tend to fluctuate more than those for higher-rated securities. The market for certain international, non-investment grade debt securities may be thinner and less active than that for higher-rated securities, which can adversely affect the prices at which securities are sold. Adverse publicity and investor perceptions about international, non-investment grade debt securities, whether or not based on fundamental or technical analysis, may be a contributing factor in a decrease in the value and liquidity of such securities. In addition, remedies from defaults on certain sovereign debt obligations, unlike those on private debt, must, in some cases, be pursued in the courts of the defaulting party itself or may even be precluded (or limited) under principles of sovereign immunity. Distressed Investments. Greylock Capital may invest in debt and equity securities, accounts and notes payable, loans, private claims and other financial instruments and obligations of distressed companies which may result in significant returns, but which involve a substantial degree of risk. Clients of Greylock Capital may lose their entire investment in a distressed company, may be required to accept cash or securities with a value less than the client’s investment and may be prohibited from exercising certain rights with respect to such investment. Investments in distressed companies may not show any returns for a considerable period of time. Funding a plan of reorganization involves additional risks, including risks associated with equity ownership in the reorganized entity. Distressed investments may be adversely affected by state and federal laws relating to, among other things, fraudulent conveyances, voidable preferences, lender liability and a bankruptcy court's

discretionary power to disallow, subordinate or disenfranchise particular claims. Investments in securities and private claims of distressed companies made in connection with an attempt to influence a restructuring proposal or plan of reorganization in a bankruptcy case may also involve substantial litigation. Illiquidity of Debt Instruments. Debt instruments and interests in debt instruments have significant liquidity risks and market value risks since they are not generally traded on organized exchange markets but are traded by certain financial institutions and other institutional investors. In such cases, the primary resale opportunities for such debt instruments are privately negotiated transactions with a limited number of purchasers. This may restrict the ability of Greylock Capital to dispose of investments in a timely fashion and/or at a favorable price. The inability to dispose of a debt instrument could result in losses to clients of Greylock Capital, including the loss of their entire investment. The debt of highly leveraged companies or companies in default also may be less liquid than other debt instruments. If Greylock Capital voluntarily or involuntarily sold its interest in those types of debt instruments, its clients may not receive the full value that Greylock Capital expected. Non-U.S. Securities. Greylock Capital may invest a substantial portion of its clients’ assets in securities of companies domiciled or operating outside the United States. Investing in these securities involves certain considerations not typically associated with investing in securities of U.S. companies. These considerations may include changes in exchange rates and exchange control regulations, political and social instability, potential expropriation, imposition of taxes, less liquid markets, less available information than is generally the case in the United States, higher transaction costs, less government supervision of exchanges, brokers and issuers, difficulty in enforcing contractual obligations, lack of uniform accounting and auditing standards and greater price volatility. The application of non-U.S. tax laws (e.g., the imposition of withholding taxes on capital gains or dividend or interest payments) or confiscatory taxation may also affect investments in non-U.S. securities. In certain circumstances, the United States, the European Union, the United Nations, or other international actors may impose embargoes or sanctions that impair the economic or business activities of, or the trading of securities issued by, a particular country or company in which clients of Greylock Capital have invested. Sanctions or embargoes may restrict the ability of Greylock Capital to trade securities in its clients’ portfolios and may impair the economic prospects of the countries or companies that have issued such securities. It may be difficult or impossible to determine when sanctions will be imposed or lifted, and sanctions may have a significant impact on the liquidity and value of these investments. Emerging and Frontier Markets. A substantial percentage of the assets of clients of Greylock Capital may be invested in securities of issuers located in emerging or frontier market countries. Investing in the securities markets of emerging or frontier market countries involves certain risks including defaults and other special considerations not typically associated with investing in other more established economies or securities markets. Such risks may include (a) the risk of nationalization or expropriation of assets or confiscatory taxation; (b) social, economic and political uncertainty; (c) dependence on exports and the corresponding importance of international trade and commodities prices; (d) severe price fluctuations due to smaller, less liquid securities markets; (e) currency exchange rate

fluctuations; (f) potentially higher rates of inflation (including hyper-inflation); (g) controls on foreign investment and limitations on repatriation of invested capital and the client's ability to exchange local currencies for U.S. dollars; (h) government decisions to discontinue support for economic reform programs and imposition of centrally planned economies; (i) differences in auditing and financial reporting standards which may result in the unavailability of material information about issuers; (j) less extensive regulatory oversight of securities markets; (k) longer settlement periods for securities transactions; (l) less stringent laws regarding the fiduciary duties of officers and directors and protection of investors; (m) certain consequences regarding the maintenance of portfolio securities and cash with sub-custodians and securities depositories in emerging and frontier market countries; and (n) less developed infrastructure. Non-U.S. markets may also have different clearance and settlement procedures, and in certain markets there have been times when settlements have failed to keep pace with the volume of securities transactions, making it difficult to conduct such transactions. Delays in settlement could result in periods when assets of the Fund are not invested, and no return is earned thereon. The inability of Greylock Capital to make intended investments due to settlement problems or the risk of intermediary counterparty failures could cause clients of Greylock Capital to miss investment opportunities. The inability to dispose of an investment due to settlement problems could result either in losses to clients of Greylock Capital due to subsequent declines in the value of such investment or, if such clients have entered into a contract to sell a security, could result in possible liability to the purchaser. Transaction costs of buying and selling non-U.S. securities, including brokerage, tax and custody costs, may be higher than those involved in U.S. transactions. Furthermore, certain non-U.S. financial markets, while generally growing in volume, may have substantially less volume than U.S. markets, and securities of many non-U.S. companies may be less liquid and their prices more volatile than securities of comparable U.S. companies. Creditors' Committees. Some investments by Greylock Capital may require active monitoring and representation on an official and/or unofficial creditors' or equity holders' committee for a company or sovereign involved in a reorganization proceeding or restructuring. Accordingly, Greylock Capital may seek representation on such committees from time to time if Greylock Capital, in its discretion, determines that such representation is necessary or advisable to protect or further its clients’ interests. Serving on an official or unofficial committee increases the possibility that Greylock Capital will be deemed an “insider” or a “fiduciary” of the company or sovereign and may restrict the trading of its clients’ investments in such company or sovereign. Should such assistance be provided before a company enters bankruptcy proceedings, a bankruptcy court, under certain conditions such as a finding of inequitable conduct may invoke the doctrine of “equitable subordination” with respect to any claim or equity interest held by clients of Greylock Capital in such company and subordinate any such claim or equity interest in whole or in part to other claims or equity interests in such company. Claims of equitable subordination may also arise outside of the context of Greylock Capital's committee activities. In addition, if representation by Greylock Capital on a creditors' committee of a company or sovereign causes its clients to be deemed affiliates of the company or sovereign, the securities of such company or sovereign held by clients of Greylock Capital may become restricted securities, which may not be freely tradable. Clients of Greylock Capital may indemnify a person serving on a committee on their

behalf for certain claims arising from service in such capacity, and indemnification payments could adversely affect the return on the client’s investment. Loans. Greylock Capital may invest in corporate secured or unsecured loans acquired through assignment or participations. In purchasing participations, clients of Greylock Capital will usually have a contractual relationship only with the selling institution, and not the borrower. Clients of Greylock Capital generally do not have the right to directly enforce compliance by the borrower with the terms of the loan agreement, or any rights of set-off against the borrower, nor does it have the right to object to certain changes to the loan agreement agreed to by the selling institution. Clients of Greylock Capital may not directly benefit from the collateral supporting the related secured loan and may not be subject to any rights of set-off the borrower has against the selling institution. In addition, in the event of the insolvency of the selling institution, under the laws of the United States and the states thereof, clients of Greylock Capital may be treated as general creditors of such selling institution and may not have any exclusive or senior claim with respect to the selling institution's interest in, or the collateral with respect to, the secured loan. Consequently, clients of Greylock Capital may be subject to the credit risk of the selling institution as well as of the borrower. Certain of the secured loans or loan participations may be governed by the law of a jurisdiction other than a United States jurisdiction which may present additional risks as regards the characterization under such laws of such assignment or participation in the event of the insolvency of the selling institution or the borrower. Special Situations. Greylock Capital may invest in companies involved in restructurings, work-outs, liquidations, spin-offs, reorganizations, bankruptcies and similar transactions, or in markets or companies in the midst of a period of economic or political instability. In any investment opportunity involving any such type of business enterprise, there exist a number of risks, such as the risk that the transaction either will be unsuccessful, take considerable time or will result in a distribution of cash or a new security the value of which will be less than the purchase price of the security or other financial instrument in respect of which distribution is received. Similarly, if an anticipated transaction does not in fact occur, Greylock Capital may be required to sell its investment at a loss. Further, in any investment in an unstable political or economic environment, there exists the risk of default as to debt securities and bankruptcy or insolvency with respect to debt or equity securities. Because there is substantial uncertainty concerning the outcome of transactions involving financially troubled companies or situations in which Greylock Capital may invest, there is a potential risk of loss by Greylock Capital of its entire investment in such companies. Currency Risks. Investments that are denominated in a non-U.S. currency and, to a lesser extent, investments that are U.S. dollar-denominated, are subject to the risk that the value of such a particular currency will change in relation to one or more other currencies. Among the factors that may affect currency values are trade balances, the level of short-term interest rates, differences in relative values of similar assets in different currencies, long-term opportunities for investment and capital appreciation and political developments. Greylock Capital may try to hedge these risks by investing in currencies, currency futures contracts and

options thereon, forward currency exchange contracts, or any combination thereof, but there can be no assurance that such strategies will be effective. Short Sales. Greylock Capital’s investment program may include short selling. Short selling, or the sale of securities not owned by a client of Greylock Capital, necessarily involves certain additional risks. Such transactions expose a Greylock Capital client to the risk of loss in an amount greater than the initial investment, and such losses can increase rapidly and in the case of equities, theoretically without an effective limit. There is the risk that the securities borrowed by a client of Greylock Capital in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur, wherein the client might be compelled, at a disadvantageous time, to replace borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. Derivatives in General. Greylock Capital may make use of various derivative instruments, such as convertible securities, options, futures, forwards and interest rate, credit default, total return, equity and other swaps. The use of derivative instruments involves a variety of material risks. The derivatives markets are frequently characterized by limited liquidity, which can make it difficult as well as costly to close out open positions in order to either realize gains or limit losses. The pricing relationships between derivatives and the instruments underlying such derivatives may not correlate with historical patterns, resulting in unexpected losses. Use of derivatives and other techniques such as short sales for hedging purposes involves certain additional risks, including (i) dependence on the ability to predict movements in the price of the securities hedged; (ii) imperfect correlation between movements in the securities on which the derivative is based and movements in the assets of the underlying portfolio; and (iii) possible impediments to effective portfolio management or the ability to meet short term obligations because of the percentage of a portfolio's assets segregated to cover its obligations. In addition, by hedging a particular position, any potential gain from an increase in the value of such position may be limited. Credit Derivatives. Credit derivatives are contracts that transfer price, spread and/or default risks of debt and other instruments from one party to another. Greylock Capital may utilize credit derivatives (including credit default swaps) for hedging or speculative purposes. Such instruments derive their value from securities issued by one or more debtors or a basket of securities. The market for credit derivatives may be relatively illiquid, and there are considerable risks that may make it difficult either to buy or sell the contracts as needed or at reasonable prices. Sellers of credit derivatives carry the inherent price, spread and default risks of the debt instruments covered by the derivative instruments. Buyers of credit derivatives carry the risk of non-performance by the seller due to an inability to pay. There are also risks with respect to credit derivatives in determining whether an event will trigger payment under the contract and whether such payment will offset the loss or payment due under another instrument. In the past, buyers and sellers of credit derivatives have found that a trigger event in one contract may not match the trigger event in another contract, exposing the buyer or the seller to further risk.

Credit Default Swap Agreements. The buyer of a credit default contract is obligated to pay the seller either a lump sum payment or a periodic stream of payments over the term of the contract in return for a contingent payment upon the occurrence of a credit event with respect to an underlying reference obligation or entity. Generally, a credit event means bankruptcy, failure to pay, cross default/acceleration, obligation acceleration, repudiation/moratorium, restructuring, or rating decline. Clients of Greylock Capital may be either the buyer or seller in a transaction. If a client of Greylock Capital is a buyer and no credit event occurs, the client will have made fixed payments and received nothing. However, if a credit event occurs, the client, as a buyer, typically will receive full notional value for a reference obligation that may have little or no value. As a seller, a client of Greylock Capital receives a fixed rate of income throughout the term of the contract, which typically is between one month and five years, provided that no credit event occurs. If a credit event occurs, the seller may pay the buyer the full notional value of the reference obligation which may have little or no value. In addition to general market risks, credit default swaps are subject to liquidity risk and counterparty risk. Certain swap contracts are not substantially regulated, and as a consequence, investors in such contracts do not benefit from regulatory protections that might otherwise be available. The selling of credit default swaps involves greater risks than if a client of Greylock Capital had invested in the reference obligation directly. If a credit event were to occur, the value of the reference obligation received by the seller, coupled with the periodic payments previously received, may be less than the full notional value it pays to the buyer, resulting in a loss of value. The buyer of credit default swaps will incur a loss if the seller fails to perform on its obligation should a credit event occur. In certain circumstances, the buyer can receive the notional value of a credit default swap only by delivering a physical security to the seller and is at risk if a deliverable security is unavailable or illiquid. Currency Forward Contracts. Greylock Capital may enter into currency forward contracts (agreements to exchange one currency for another at a future date) on behalf of its clients to manage currency exchange rate risks, to protect against adverse changes in exchange rates, to facilitate transactions in non-U.S. securities or to enhance total return. Currency forward contracts involve a risk of loss if Greylock Capital fails to predict accurately the direction of currency exchange rates. For example, a client may experience a loss if Greylock Capital increases its exposure to a non-U.S. currency and that currency's value in relation to the U.S. dollar subsequently falls. In addition, forward contracts are not guaranteed by an exchange or clearinghouse. Futures Contracts. Greylock Capital may invest in commodities futures contracts and options thereon both for hedging purposes and to increase the total return on its clients’ portfolios. Trading in futures contracts and options is a highly specialized activity which, while it may increase the total return of a client’s portfolio, may entail greater than ordinary investment risks. Specifically, investing in futures may result in increased leveraging of the portfolio and increased volatility of the portfolio’s returns. There is settlement risk associated with futures investing and the risk that the counterparty to a futures contract may default on its obligations. Additionally, the portfolio’s position in a futures contract may be illiquid at certain times, such as when a futures exchange imposes price movement limits on the contract.

Portfolio Illiquidity. Greylock Capital may invest its clients’ assets in non-public, restricted and illiquid securities. At various times, the markets for securities purchased or sold by such clients may be “thin” or illiquid, making purchase or sale of securities at desired prices or in desired quantities difficult or impossible. There may be no market for unlisted securities traded by Greylock Capital. In some cases, Greylock Capital may be contractually prohibited from disposing of such securities for a specified period of time. Further, the sale of any such investments may be possible only at substantial discounts and such investments may be extremely difficult to value. In addition, Greylock Capital's (or any of its officers, employees or affiliates) active involvement in the companies in which it invests (such as serving as a member of a company's board of directors or creditors’ committee) may restrict or limit Greylock Capital's ability to trade securities of the subject company. Lack of Diversification. Certain client portfolios will be focused on debt securities and may not be diversified among a wide range of issuers or areas. As part of the investment mandate granted to Greylock Capital, certain client portfolios may be intentionally and significantly concentrated in a limited range of financial instruments, issuers, industries, sectors, strategies, countries or geographic regions. Such concentration of risk may increase losses. In addition, it is possible that Greylock Capital may select investments for a client portfolio that are concentrated in a limited number of types of financial instruments. This limited diversity could expose the client portfolio to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements in those financial instruments. Accordingly, such investment portfolios may be subject to more rapid change in value than would be the case with a wide diversification among investment areas, securities and types of securities and other instruments were maintained. Valuation. Greylock Capital may make investments on behalf of its clients in illiquid or thinlytraded securities that may be extremely difficult to accurately value. In light of the foregoing, there is a risk that an investor in a Greylock Global Fund who withdraws all or part of such investor’s investment while the Greylock Global Fund holds such illiquid or thinly traded investments will be paid an amount less than such investor would otherwise be paid if the value of such investments is higher than the value designated by the Greylock Global Fund. Similarly, there is a risk that such investor might, in effect, be overpaid if the value of the illiquid or thinly-traded investment is lower than the value designated by the Greylock Global Fund. In addition, there is a risk that an investment in a Greylock Global Fund by a new investor (or an additional investment by an existing investor) could dilute the value of such illiquid or thinly traded investments for the other investors if the actual value of such investments is higher than the value designated by the Greylock Global Fund. Because of overall size or concentration in particular markets of positions held by clients of Greylock Capital, the value at which its investments can be liquidated may differ, sometimes significantly, from the interim valuations arrived at using the valuation methodology adopted by Greylock Capital. In addition, the timing of liquidations may also affect the values obtained on liquidation. Securities to be held by clients of Greylock Capital may trade with bid-ask spreads that may be significant. Third party pricing information may not be available for certain positions held by clients of Greylock Capital, including the Greylock Global Funds.

Item 9. Disciplinary information

Greylock Capital and its principals have not been the subject of any legal proceeding required to be disclosed in response to this item.

Item 10. Other financial industry activities and affiliations

Registered Broker-Dealers. None of Greylock Capital or any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Registered Futures Commission Merchants, Commodity Pool Operators and Commodity Trading Advisors. None of Greylock Capital or any of its principals or employees are registered as or affiliated with a registered futures commission merchant, commodity pool operator or commodity trading advisor. Relationships with Related Persons. Greylock Capital GP LLC, a Delaware limited liability company that is under common control with Greylock Capital, serves as the general partner of certain Greylock Global Funds.

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Greylock Capital and its related persons, including Greylock Capital GP LLC, are, directly or indirectly, the general partner, limited partners and/or managing members of the general partner of each of the Greylock Global Funds. Selection or Recommendation of Other Advisers. Greylock Capital does not recommend or select other investment advisers for its clients or receive compensation from such advisers in a manner that would create a material conflict of interest. Greylock Capital does not have other business relationships with other advisers that create a material conflict of interest.

Item 11. Code of ethics, participation in client transactions and personal trading

Code of Ethics. Greylock Capital has adopted a Code of Ethics (the “Code”) in an effort to address possible conflicts of interest, the inappropriate use of material non-public information and to ensure the propriety of its clients’ and employees’ trading activities. The Code incorporates the following general principles that all employees are expected to uphold: employees must at all times place the interests of clients first; all personal securities transactions must be conducted in a manner consistent with the Code and any actual or potential conflicts of interest or any abuse of an employee’s position of trust and responsibility must be

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avoided; employees must not take any inappropriate advantage of their positions; and information concerning the identity of, securities held by, and financial circumstances of, clients and the Greylock Global Funds, including investors in the Greylock Global Funds, must be kept confidential. The Code also places restrictions on personal trades by employees, including requiring that they disclose their personal securities holdings and transactions to Greylock Capital on a periodic basis, and requires that employees preclear certain types of personal securities transactions.

As part of the Code, Greylock Capital maintains insider trading policies and procedures (the “Insider Trading Policies”) that are designed to prevent the misuse of material non-public information. Greylock Capital’s personnel are required to certify their compliance with the Code, including the Insider Trading Policies, when they begin employment and any time there is a material change in the Code. The Insider Trading Policies prohibit Greylock Capital and its personnel from trading for the Greylock Global Funds or themselves, or recommending trading, in public securities of a company while in possession of material non-public information about the company, and from disclosing such information to any person not entitled to receive it. By reason of its various activities, Greylock Capital may have access to such information or be restricted from effecting transactions in certain investments that might otherwise have been initiated. Greylock Capital has designed and implemented policies and procedures to control and monitor the flow of potential inside information to and within Greylock Capital, as well as to prevent trading in public securities based on such information. Clients or prospective clients may request a copy of the Code by contacting Greylock Capital at the address or telephone number listed on the cover page of this document. Participation or Interest in Client Transactions; Personal Trading. Greylock Capital may, with the prior approval of the clients involved to the extent required by law, cause one or more of its clients to buy securities from, or sell securities to, other clients of Greylock Capital at current market prices, including accounts in which Greylock Capital, its principals or employees are investors or in which such persons may have a financial interest, either directly or indirectly, due to either a direct investment in such account, or to the payment of an Incentive Allocation (or some other performance-based fee) by such client. Greylock Capital will only engage in such “cross trades” if the sale and purchase are consistent with Greylock Capital’s fiduciary obligations to each client. Cross trades may include rebalancing transactions that are undertaken so that, after withdrawals or contributions to accounts advised by Greylock Capital have occurred, the portfolio compositions of similarly managed accounts remain substantially similar. Greylock Capital has a potential conflict of loyalties and responsibilities regarding both parties to any cross trades. Where required by applicable law, any such transaction will be approved in advance by the client or an independent representative thereof in accordance with Section 206(3) of the Advisers Act. On occasion, Greylock Capital and its principals and employees may buy and sell securities for themselves that they also recommend to clients. Greylock Capital and its principals and employees are investors in some of the investment funds managed by Greylock Capital. The Code contains policies and procedures designed to prevent improper practices with respect to such transactions, and compliance with the Code by Greylock Capital, its principals and employees is the primary method employed by Greylock Capital to address the conflicts of interest that arise with respect to these transactions. For example, the principals and employees of Greylock Capital are generally not permitted to execute a personal securities transaction if any account managed by Greylock Capital has a position in the same security unless they have written approval from the Chief Compliance Officer (the “CCO”).

Item 12. Brokerage practices

Subject to the investment objectives, policies and restrictions of each Greylock Global Fund as set forth in the applicable Governing Documents, and for each advisory client as set forth in the applicable investment advisory agreement, Greylock Capital has discretionary authority to select the broker-dealers used to execute client transactions as well as the commissions paid to such broker-dealers.

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In determining the broker-dealer through which client transactions are to be effected, it is Greylock Capital’s policy to seek best execution by considering various relevant factors including, but not limited to: (i) the financial stability of the broker-dealer; (ii) the actual executed price of the security and the commission rates; (iii) the size and type of the transaction; (iv) research (including economic forecasts, investment strategy advice, fundamental and technical advice on individual securities, valuation advice and market analysis), custodial and other services provided by such broker-dealers that are expected to enhance Greylock Capital’s general portfolio management capabilities; (v) the difficulty of execution and the ability to handle difficult trades; (vi) the operational facilities of the broker-dealers involved (including the location of such broker-dealers and their back office efficiency); (vii) whether the broker-dealer makes a market in, or otherwise regularly deals in, a particular security; and (viii) the ability to handle a block order for securities and distribution capabilities. Section 28(e) of the Securities Exchange Act of 1934 (the “Exchange Act”) provides a safe harbor that permits advisers, when selecting broker-dealers to execute transactions for client accounts, to take into account certain research products and services provided to the adviser by the broker-dealers. Clients may pay higher commissions than are obtainable from other broker-dealers as a result of the consideration of research services as a factor in the selection process, provided that Greylock Capital determines in good faith that the amount of commissions charged is reasonable in relation to the value of the brokerage and research services provided by such broker-dealer. Research services provided to Greylock Capital by broker-dealers may include research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from brokers on order execution; and certain proxy services. Greylock Capital does not currently engage in any soft dollar arrangements in which Greylock Capital receives third-party services. However, Greylock Capital engages in soft dollar arrangements of the type described in Section 28(e) of the Exchange Act that are intended to augment Greylock Capital’s own internal research and investment strategy capabilities, provided that such arrangements are consistent with seeking best execution for clients. Receipt of research services from broker-dealers may provide Greylock Capital with a benefit because it will not have to produce or pay for the research, products or services. Greylock Capital may have an incentive to select a broker-dealer based on its interest in receiving the research or other products or services, rather than on a client’s interest in receiving most favorable execution. Research services obtained with the use of commissions arising from

portfolio transactions may be used by Greylock Capital in its investment activities for all of its clients, and, therefore, any particular client may or may not, in any particular instance, be the direct or indirect beneficiary of the research or services provided. Directed Brokerage. Greylock Capital does not have any arrangements with any clients that require Greylock Capital to execute transactions through a specified broker-dealer. Trade Aggregation. Investment opportunities are allocated among clients as described in Item 6. When more than one of Greylock Capital’s client accounts, including the Greylock Global Funds, trades in the same security at the same time may be aggregated. However, Greylock Capital has no obligation to obtain any particular investment opportunity for any particular client, and Greylock Capital may be precluded from offering particular securities to certain clients in certain situations, including where Greylock Capital or its affiliates have a prior contractual commitment with other accounts or clients. If any aggregated order is not filled at the same price, securities may be allocated on an average price basis and transaction costs shared pro rata based on each client’s order size. If an aggregated order is not fully executed under prevailing market conditions, securities will be allocated among the different accounts pro rata unless Greylock Capital determines that another allocation is appropriate in the circumstances. There is no assurance that all clients of Greylock Capital will hold the same investments or perform in a substantially similar manner as other clients of Greylock Capital with similar strategies.

Item 13. Review of accounts

Greylock Capital performs various periodic reviews of client portfolios, on a daily, weekly, monthly and annual basis. Such reviews are conducted by Greylock Capital’s investment professionals, including the principals of Greylock Capital who comprise the Greylock Capital Investment Committee. Among other criteria, the portfolios are reviewed in the context of each client’s investment objectives and guidelines. Greylock Capital ordinarily provides its clients with, at minimum, an unaudited monthly review of their account showing performance and may also provide a review of Greylock Capital’s investment activities of the past month. Certain investors and clients have requested oral and written reviews on a quarterly or monthly basis.

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Investors in separately managed accounts receive regular and occasionally real-time reports on their account. Investors in each Greylock Global Fund also receive such Greylock Global Fund’s audited financial report and the information necessary for the investor to complete an annual U.S. federal income tax return, if applicable.

Item 14. Client referrals and other compensation

Economic Benefits Received from Third Parties Greylock Capital is compensated exclusively by its clients and investors for providing investment advice.

Third Party Compensation for Client Referrals Greylock Capital has entered into, and may in the future enter into, arrangements with unaffiliated third parties whereby Greylock Capital or its affiliates compensate such third parties for referrals of clients or of investors in the Greylock Global Funds. In general, such compensation is paid by Greylock Capital (or its affiliates) and comprises a portion of the Management Fee and Incentive Allocation received by Greylock Capital or its affiliate from such clients or with respect to such investors’ investment in a Greylock Global Fund. Any such arrangements will be disclosed to clients and investors in accordance with, and otherwise comply with, Rule 206(4)-1 under the Advisers Act.

Item 15. Custody

Greylock Capital does not maintain physical custody of cash or securities for its clients, however, Greylock Capital (or its affiliate) may be deemed to have custody of the assets of certain Greylock Global Funds as a result of its position as general partner of such Greylock Global Funds. Greylock Capital causes each Greylock Global Fund to be audited annually and to distribute audited financial statements, prepared in accordance with the requirements of Rule 206(4)2(b)(4) to its investors no later than 120 days after the end of each fiscal year.

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All securities in the accounts of Greylock Capital clients, including the Greylock Global Funds, will be held by a qualified custodian, except in certain situations where such securities are not required to be maintained with a qualified custodian under Rule 206(4)-2, including certain privately offered, uncertificated securities that are recorded on the books of the issuer or its transfer agent in the name of the relevant Greylock Global Fund or client.

Item 16. Investment discretion

Subject to the investment objectives, policies and restrictions of each client of Greylock Capital, as set forth in the Governing Documents of a Greylock Global Fund or the investment advisory agreement between Greylock Capital and such client, Greylock Capital generally has discretionary authority to determine the type, amount and price of securities and investments to be bought and sold on behalf of each client for which it serves as discretionary investment manager, including the selection of, and commissions paid to, broker-dealers. Greylock Capital enters into a written investment advisory agreement or other agreement with each client appointing Greylock Capital as investment adviser and granting such discretionary authority, which agreement may include a power of attorney in certain circumstances.

Item 17. Voting client securities

Greylock Capital invests in fixed income instruments and private investments that involve voting (which includes written consents for purposes of this policy) on various issues but not

as regularly as publicly-listed equity securities. Greylock Capital generally retains voting authority with respect to securities purchased for its clients, and will vote securities in the best interest of its clients and in accordance with these policies and procedures. Greylock Capital considers each proposal regarding a fixed income security on a case-bycase basis taking into consideration any relevant contractual obligations as well as other relevant facts and circumstances at the time of the vote.

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Prior to exercising its voting authority Greylock Capital reviews the financial implications and other relevant facts regarding proposals to be voted. Greylock, and makes recommendations specific for each advisory client that holds the related security. If a material conflict of interest regarding any vote exists with respect to only certain personnel, such personnel will abstain from participation in discussing and determining the voting decision. In other circumstances, the CCO will determine, taking into account any relevant client agreement provisions, what actions Greylock Capital should take regarding voting, including possibly disclosing the conflict to affected clients and giving them the opportunity to determine the vote for their own holdings. Depending on the particular circumstances involved, the appropriate resolution of a conflict may differ from one client to another. In addition, resolution of a particular conflict of interest may differ from the resolution of another conflict of interest, even though the general facts underlying both conflicts may be similar or identical. Greylock Capital may abstain from voting or determine not to vote if it determines such action is in the best interest of clients. Factors considered in making such decisions include, but are not limited to, (i) how significant the impact on the portfolio holdings value would be, (ii) the costs associated with voting, and (iii) any legal restrictions on trading that might result from voting. Clients may contact Greylock Capital at the e-mail address or telephone number on the cover page of this Form ADV Part 2A in order to obtain information on how Greylock Capital voted such client’s proxies and to request a copy of the Voting Policies.

Item 18. Financial information

On January 31, 2021, Greylock Capital Associates, LLC, the holding company of Greylock Capital, filed a voluntary petition for relief under Chapter 11 of the Bankruptcy Code, for the purpose of rejecting certain contracts and restructuring certain liabilities. Greylock Capital continued to maintain operations in a manner similar to pre-bankruptcy management. The case was voluntarily dismissed on April 13, 2021, on terms that provided for full payment of allowed claims.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.