HARLOW CAPITAL MANAGEMENT LLC

Harlow Capital Management LLC FORM CRS/ADV PART 3 March 2026 INTRODUCTION Harlow Capital Management LLC ("HCM") is a registered investment adviser with the Securities and Exchange Commission ("SEC"). Brokerage and investment advisory services and fees differ, and it is important that you understand these differences. Free and simple tools are available to research firms and financial professionals at investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing. RELATIONSHIPS AND SERVICES What investment services and advice can you provide me? CONVERSATION STARTERS (cid:127) Given my financial situation, HCM provides investment advisory services exclusively to retail and institutional clients. We do not offer brokerage services. All client accounts are managed on a discretionary basis by Colby Harlow, President and Chief Compliance Officer. Investment Advisory Services for individuals, high net worth should I choose an investment advisory service? Why or why not? (cid:127) How will you choose HCM offers portfolio management individuals, charitable organizations, pooled investment vehicles, and corporations. We tailor each investment program to the individual needs of the client based on their stated investment objectives, risk tolerance, time horizon, and financial circumstances. investments to recommend to me? (cid:127) What is your relevant (cid:127) Account Minimums: HCM does not impose a stated minimum account size for separately managed accounts. The minimum investment commitment for the Harlow Energy Infrastructure Fund I, L.P. is $250,000. Other private funds do not have stated minimums. experience, including your licenses, education, and other qualifications? What do these qualifications mean? (cid:127) Investment Authority: HCM manages all client accounts on a discretionary basis, meaning HCM has the authority to buy and sell securities without seeking your approval for each transaction, subject to any investment guidelines you have provided. (cid:127) Account Monitoring: HCM provides continuous and regular supervisory or management services to all client securities portfolios. Accounts are reviewed on an ongoing basis by Mr. Harlow. Limitations on Services HCM focuses on portfolio management for individuals, high net worth individuals, charitable organizations, and pooled investment vehicles. HCM does not provide financial planning services as a standalone offering. Other firms may offer a wider range of services. For more information about our advisory services, please visit www.harlow-capital.com. FEES, COSTS, CONFLICTS, AND STANDARD OF CONDUCT Form CRS March 2026 SEC File No. 801-63836 | CRD No. 133918  Harlow Capital Management LLC FORM CRS/ADV PART 3 March 2026 What fees will I pay? CONVERSATION STARTERS (cid:127) Help me understand how You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. Investment Advisory Fees these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me? HCM is primarily compensated through a percentage of assets under management. Advisory fees are negotiable and are set forth in each client's investment advisory agreement. HCM also charges fixed fees and, in certain circumstances, performance-based fees. HCM occasionally charges a fee to administer an estate. Because our advisory fees are based on a percentage of assets under management, we have an incentive to encourage you to increase the assets in your account. Other Fees and Costs (cid:127) Custodial Fees: Your assets are generally held at Charles Schwab & Co., Inc. You will pay custodial fees and transaction costs charged by the custodian in addition to HCM's advisory fees. (cid:127) Fund Expenses: If you invest in one of HCM's private funds (Harlow Energy Infrastructure Fund I, L.P., Harlow CPG Fund I, LP, or Harlow Aerospace Fund II, LP), you will bear a proportionate share of the fund's expenses in addition to any advisory fees. (cid:127) Insurance Products: If you purchase insurance products through HCM in its capacity as a licensed insurance agent, commissions may apply. CONVERSATION STARTERS What are your legal obligations to me when providing recommendations as my investment adviser? How else does your firm make money and what conflicts of interest do you have? (cid:127) How might your conflicts of interest affect me, and how will you address them? When we act as your investment adviser, we must act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples: (cid:127) Asset-Based Fee Conflict: Because HCM's advisory fee is based on the value of your account, we have an incentive to recommend that you increase assets in your advisory accounts. (cid:127) Performance Fee Conflict: HCM charges performance-based fees for certain client relationships and private funds, which may create an incentive to make investments that are riskier or more speculative than would otherwise be the case. (cid:127) Insurance Sales Conflict: Mr. Harlow is a licensed insurance agent and may recommend insurance products to advisory clients. If a client purchases an insurance product, Mr. Harlow receives a commission, which creates a conflict of interest. (cid:127) Private Fund Conflict: HCM and its related persons (through ARBCO, L.L.C.) serve as general partner or managing member of the private funds it manages. HCM and related persons own approximately 10%–13% of each fund, which may create a conflict when allocating investment opportunities. (cid:127) Margin Transactions: On limited occasions, Mr. Harlow has utilized margin in select client accounts to facilitate home purchases or to establish a line of credit, which presents additional risk to clients. (cid:127) Soft Dollar Benefits: HCM receives research and other products or services (soft dollar benefits) from broker-dealers in connection with client securities transactions. All such benefits are eligible research or brokerage services under Section 28(e) of the Securities Exchange Act of 1934. Standard of Conduct As an SEC-registered investment adviser, HCM is a fiduciary. We are held to a standard that requires us to act in your best interest when providing investment advice. We have an obligation to provide advice that is in your best interest and to disclose all material conflicts of interest. Our full conflicts of interest disclosure is contained in our Form ADV Part 2A Brochure, available at www.harlow-capital.com or upon request. How do your financial professionals make money? Form CRS March 2026 SEC File No. 801-63836 | CRD No. 133918  Harlow Capital Management LLC FORM CRS/ADV PART 3 March 2026 Colby Harlow, HCM's sole investment professional, is compensated through the advisory fees, fixed fees, performance fees, estate administration fees, and insurance commissions that HCM earns. As the 100% owner of HCM, Mr. Harlow receives the economic benefit of all revenue generated by the firm. He does not receive additional sales-based incentive compensation beyond his ownership interest. DISCIPLINARY HISTORY Do you or your financial professionals have legal or disciplinary history? CONVERSATION STARTERS No. Neither HCM nor Colby Harlow has any reportable disciplinary history. There are no criminal actions, regulatory actions, civil judicial actions, or other disciplinary events to disclose. (cid:127) As a financial professional, do you have any disciplinary history? For what type of conduct? You can research HCM and Mr. Harlow using the SEC's Investment Adviser Public Disclosure database at adviserinfo.sec.gov (CRD No. 133918 / SEC File No. 801-63836) or at investor.gov/CRS for free and simple search tools to research investment advisers and financial professionals. ADDITIONAL INFORMATION You can find a copy of this document and more information about our investment advisory services, including our Form ADV Part 2A Brochure, on our website at www.harlow-capital.com. CONVERSATION STARTERS (cid:127) Who is my primary contact To request a copy of our relationship summary or up-to-date information, please contact us at: Colby Harlow, President and Chief Compliance Officer Harlow Capital Management LLC person? Who can I talk to if I have concerns about how this person is treating me? 5802 Kenwood Avenue | Dallas, Texas 75206 Phone: (214) 754-0800 | Email: colby@harlow-capital.com If you have a concern about how Mr. Harlow is treating you, please contact him directly using the information above, or you may contact the SEC at investor.gov or (800) 732-2999. Form CRS March 2026 SEC File No. 801-63836 | CRD No. 133918 

Harlow Capital Management, LLC P.O. Box 190136 Dallas, Texas 75219 214.754.0800 www.harlow-capital.com March 2026 This brochure provides information about the qualifications and business practices of Harlow Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at 214.754.0800 or colby@harlow-capital.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Harlow Capital Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov.  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 Material Changes In the first quarter of 2026 Harlow Capital changed their registrations status from a registered investment advisory registered in the State of Texas to a registered investment advisor registered with the Securities and Exchange Commission ("SEC"). Two funds Harlow Capital managed: Harlow Aerospace Fund I and Harlow Special Opportunities Fund have been closed with their assets distributed to investors.  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 Table of Contents Advisory Business ........................................................................................................... 1 Fees and Compensation ................................................................................................. 2 Performance-Based Fees and Side-By-Side Management ............................................. 3 Types of Clients .............................................................................................................. 4 Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 4 Disciplinary Information ................................................................................................... 6 Other Financial Industry Activities and Affiliations ........................................................... 6 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..... 7 Brokerage Practices ........................................................................................................ 8 Review of Accounts ....................................................................................................... 11 Client Referrals and Other Compensation ..................................................................... 11 Custody ......................................................................................................................... 11 Investment Discretion .................................................................................................... 11 Voting Client Securities ................................................................................................. 12 Financial Information ..................................................................................................... 12 Disclosures..................................................................................................................... 12  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 ADVISORY BUSINESS Advisory Firm Description Harlow Capital Management, LLC (“ HCM” or the “Firm”) has been in business since 2005. The Firm is wholly owned by Colby Harlow, who makes all investment decisions for all clients. General Partner of Limited Partnerships Arbco, L.L.C., a related entity, is the General Partner for the limited partnerships which are private funds (“the Funds”) that are managed by HCM. Types of Advisory Services Separately Managed Accounts The Firm manages separate accounts on a discretionary basis (trading on behalf of to clients without obtaining permission before each trade) and has full authority determine which securities are purchased and sold, how much and when. The Firm invests in equity securities (common stocks and equivalents) traded on or in a recognized exchange. HCM uses a disciplined investment process to identify high-quality companies available at reasonable prices, using a val ue-oriented investment strategy. HCM also invests in an array of high-quality, fixed income securities including both tax- free and taxable bonds for those clients requiring balanced portfolios. Private Funds Harlow Energy Infrastructure Fund I, LP is an investment available only to accredited investors and qualified clients as further defined in the subscription documents . The investment objective of the fund is to generate high absolute returns over the long- term by investing principally in the marketable securities of energy -related master limited partnerships and their affiliates, as well as other issuers engaged in midstream energy and infrastructure energy companies . This fund is long- biased but has considerable flexibility in its investments. This is not a solicitation for investment in Harlow Energy Infrastructure Fund I, LP. Please refer to the fund’s Private Placement Memorandum for further details. Harlow Special Opportunities Fund (“HSOF”) is a single purpose vehicle with an investment in a start-up biotech entity. The fund has been closed and the assets have been distributed to investors. Harlow Aerospace Fund (“HAF”) is a single purpose vehicle with an investment in an aerospace entity. The fund has been closed and the assets have been distributed to the investors. Harlow Aerospace Fund II (“HAF2”) is a single purpose vehicle with an investment in an aerospace entity. This fund is not open to new investors. Page 1  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 Tailored Advisory Services Clients may impose restrictions on particular investments or investment classes in their separate accounts by notifying HCM at any time in writing. New clients are able to set restrictions at the onset of the relationship as well as any time during the relationship. If restrictions are in place, clients are reminded periodically that they may change their restrictions at any time. Client Assets Under Management As of March 4, 2026 HCM had $132,865,204 of discretionary assets under management. The Firm does not manage assets on a non-discretionary basis. FEES AND COMPENSATION Separate Accounts Investment Management Fees The basic fee schedule for separate accounts that HCM manages is as follows. Portfolio Size Up to $1,000,000 $1,000,001 - $5,000,000 $5,000,001 - $10,000,000 Annual Fee 2.0% 1.5% 1.0% Separately managed accounts invested solely in fixed income or mutual funds are charged an annual fee of 1.0% of assets under management. The annual fee charged by HCM is separate from and in addition to transaction, exchange, wire transfer, margin interest or account fees charged by the account custodian. Investment management fees charged by the Firm are calculated based on the portfolio valuation as determined by the account custodian at the close of market on the last business day of each quarter and are billed quarterly in arrears at the rate of one fourth of the annual fee shown above. Margin amounts and cash are included in the fee calculation, while accrued interest is not. These fees are deducted from clients’ accounts by the custodian only with prior written permission from clients. The Firm may be charging current clients higher or lower fees than those described above, so clients receiving the same service from the Firm may be paying different fees. Fees are not negotiable for new relationships. Client funds may be invested in individual equities bonds, open-end mutual funds, exchange traded funds, closed-end mutual funds, and/or money market funds. To the extent that these accounts hold mutual and/or money market funds, HCM’s fees for monitoring such assets are in addition to the fees included in the internal expenses of those funds paid to their own investment managers, which are fully disclosed in each fund’s prospectus. This prospectus is sent directly to the client by the account custodian. Page 2  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 Private Funds Management Allocations The Funds pay the investment adviser a monthly fee, which is charged in arrears and is based on the month-end value of each capital account. This fee amounts to an annual fee of 2% of the value of each partner’s balance of his/her capital account. Fees are withdrawn from each limited partner’s capital account and are not negotiable. Other Compensation life insurance products to Mr. Harlow on rare occasions will sell individual clients as appropriate. These products compensate Mr. Harlow by paying him a share of the insurance premiums. His compensation from insurance comprises a small percentage of his annual compensation. Mr. Harlow is compensated as a Director of one privately held company. In addition, Mr. Harlow receives fees for business consulting, not related to investment management or investment advice. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Performance Fees on Separately Managed Accounts The Firm charges a performance fee of 20% of excess performance above a target of 12% f or equity accounts over $1,000,000 . Performance fees are assessed annually in arrears as of December 31 for each full year of HCM’s management and are deducted from the account. (Clients leaving t he Firm during the year pay a performance fee, if appropriate, on the account’s performance year to date.) Excess performance is calculated by taking the difference between the average quarterly actual value of the account (which includes unrealized gains) and the value of the account at the 12% benchmark. Account value is based on the price quotations provided by the account custodian or by an independent pricing service if the custodian is unable to provide accurate prices. Performance fees are not negotiable, although the Firm may choose to waive all or a portion of the performance fee on any account. Performance Fees on the Funds Performance (or incentive) allocations are charged to investors in our Funds at the rate of 20% of net profits and are calculated and charged in arrears on an annual basis. Profit is calculated by taking the difference between the average quarterly capital basis of the account (which includes unrealized gains) less the expenses (including trade costs ) for the year. For anniversary dates where a performance fee has not been earned, the calculation period will carry over to the following year. Performance fees are not negotiable. The General Partner has the authority to waive all or a portion of the incentive fee for any investor. Page 3  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 Side by Side Management: Private funds and separate accounts Performance fee arrangements may create an incentive for the adviser to make investments that are riskier than would be the case in the absence of a performance fee. In order to mitigate this incentive, performance fees on separately managed accounts are subject to a maximum fee of 3% of the average capital base during the reporting period. There is also an inherent conflict of interest for the Firm due to the fact that some accounts pay a performance fee and others do not, and the Firm may have incentive to favor accounts paying performance fees. The Firm attempts to mitigate this conflict by monitoring investment objectives and seeing that all investment opportunities are provided to all clients equitably as appropriate. TYPES OF CLIENTS HCM provides investment supervisory services and manages investment advisory accounts for: • • • • • • Individuals, high net worth individuals, corporations or other businesses, trusts, charitable organizations and endowments, and private pooled funds as mentioned above under Advisory Services. Harlow Capital Management, LLC has a minimum dollar value of $250,000 in order for an account to be managed. This same minimum also applies to investing in either Fund. The firm reserves the right to waive or lower this minimum. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS HCM uses a combination of the following types of analysis in evaluating investments for client accounts: • • fundamental—Analysis of financial attributes of a company, such as revenue growth, debt to equity ratio, inventory turnover, etc. technical—Analysis which assumes past performance is a predictor of future performance. Investment strategies for separately managed accounts are structured to meet each client’s objective. Risks vary accordingly, although all accounts are subject to market risk. Some risks of our investment strategies include the following: Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Page 4  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 Leverage/Borrowing: An account may borrow against the assets held in a client’s account when we believe that the proceeds from doing so will exceed the interest paid on the borrowing. Borrowing involves risk to our clients because the interest on the borrowed amount may be greater than the income from or increase in the value of the securities purchased with the borrowed amount. Also, the value of the securities purchased with the borrowed amount can decline below the amount borrowed. Any investment profits made with the proceeds from borrowings in excess of interest paid on the borrowings will cause the income and value of a client’s account to be greater than would otherwise be the case. On the other hand, if the value of the additional securities purchased with the borrowed money does not increase enough to cover the interest paid on the borrowings, then the income and value of a client’s account will be less than would otherwise be the case. Generally, borrowing-type techniques used to increase potential returns are all forms of leverage. Options: There are risks associated with the sale and purchase of options. Our clients may invest in call and/or put options. Call options are the right to buy a security at a certain price within a defined time period. Put options are the right to sell a security at a certain price within a defined time period. A buyer of either type of option assumes the risk of losing its entire investment in the option. A buyer of a call option risks losing its investment if the particular security never reaches the designated the price within the set time period. A buyer of a put option risks losing his/her investment if the particular security does not decline enough to reach the designated price within the set time period. Short Selling: Short selling of securities occurs when we borrow securities in an account, promising to buy them at a later date. If the price drops, we can buy the securities at the lower price and make a profit on the difference. If the price of the securities rises, we have to buy them back at the higher price, and the investment loses money. Buying the securities can itself cause the price of the securities to rise further which would exacerbate the potential for loss. Risks of Investment in the Energy Industry: The companies of investment interest to HCM are sensitive to fluctuations in commodities supply and demand, interest rates, special risks of constructing and operating facilities, lack of control over pricing, merger and acquisition activity and regulation. Such fluctuations may, among other things, increase compliance costs and other costs of doing business. Historically, the markets for oil and natural gas have been volatile, and such markets are likely to continue to be volatile in the future. Prices for oil and natural gas are subject to short- term volatility due to a variety of factors, including weather, international political and economic developments, breakdowns in the facilities for the production, storage or transport of energy and energy-related products, acts of terrorism, changes in government regulation and sudden changes in fuel prices. These companies may be affected to a greater extent by any of these developments than would be the case with a more diversified portfolio of investments. New and Rapidly Evolving Nature of Healthcare/Life Sciences Sector. HCM make investments for clients across a broad spectrum of products, technologies and businesses that advance health, including, but not limited to, therapeutics, devices to improve medical diagnosis and treatment, contract service organizations and adaptation Page 5  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 of technological advances to improve drug discovery, development and marketing. The market for most of these products and technologies is rapidly evolving and, for some, only beginning to develop. Several specific risks can be typical of a market characterized by rapid change and frequent new product and service introductions. First, the public market for healthcare companies continues to be volatile. Second, products and technologies produced by certain of the companies in this industry may become obsolete. Third, these companies may have limited operating histories or histories of net losses and may expect net losses for the foreseeable future. As such, projections as to future performance of these companies may have very little performance data to support such projections. Limited History of Product Development. HCM also invests for clients in companies that have no products approved for sale. The potential products of such a company could require significant additional development and preclinical and clinical testing, as well as regulatory approval. There can be no assurance that the management of such a company will be able to successfully manage the development process for a new product, In addition, there can be no assurance that any such potential products will prove to be safe and efficacious in clinical trials, meet applicable regulatory standards, be capable of being produced in commercial quantities at acceptable costs or be successfully marketed. Investing in securities involves risk of loss that clients should be prepared to bear. The Fund documents further explain risks to investing in the Funds. to the client’s HCM manages separate accounts investment objective, usually establishing balanced and diversified portfolios. Diversification occurs across industry sectors (health care, financial, industrial, etc.) within an asset allocation strategy to most closely match a client’s investment horizon. That is, a portfolio for a younger person would be more heavily weighted in equities, and an older person’s portfolio would be more heavily weighted in bonds and cash. Risks for this investment strategy are market risks in the equity and bond markets and inflation. Please refer to the Fund documents for a more detailed discussion of the risks inherent in their investment strategies. DISCIPLINARY INFORMATION There have been no disciplinary actions against HCM or Mr. Harlow. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS HCM is the investment advisor for the Funds. Mr. Harlow is a managing member of the General Partner of the Funds, which creates a conflict with clients. This conflict is mitigated by the Firm’s policies and procedures, which require fair and equitable treatment of all investors in each Fund, the Funds and the separate accounts. Mr. Harlow also provides life insurance products as a licensed insurance agent on a commission basis. This presents a potential conflict of interest with clients to the extent Page 6  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 that he may recommend the purchase of insurance products whereby receiving a commission. This is mitigated by informing clients that they may obtain insurance coverage elsewhere and by this disclosure. Mr. Harlow spends a minimum amount of time on the insurance business. Mr. Harlow may also receive consulting fees on occasion. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics and Personal Trading Harlow Capital Management, LLC has adopted a code of ethics that emphasizes the highest standards of conduct. The Code of Ethics consists of general principles that are understood to govern the personal investment activities of the Firm’s personnel, the Firm’s fiduciary duty to clients, and the obligations of the Firm’s personnel to uphold this duty. Harlow Capital Management, LLC or individuals associated with the Firm may buy, sell, or hold in their personal accounts the same securities that the Firm recommends to its clients and in accordance with the Firm’s internal compliance procedures. Such trades must occur at least the day after trades are placed on behalf of clients or on the same day if the same price/share is obtained for all. Individuals associated with the firm may purchase open-end mutual funds for their own accounts without restriction. The Firm does not allow front running. To manage and mitigate potential conflicts of interest, the firm has established the following policies in its code of ethics, which is available to any client or investor upon request: • An officer, director, or employee of the firm shall not buy or sell securities for a personal portfolio when the decision to purchase is substantially derived, in whole or in part, by reason of employment with the firm, unless the information is also available to the investing public on reasonable inquiry. • Non-public information received by any Firm personnel is not to be communicated to others, or to be the basis of any personal or client trades. • No person associated with the firm shall prefer his or her own interest to that of any client. • Personal securities trades of IPO’s and private placements must be pre- approved by the Chief Compliance Officer. • All personal trades must be submitted on a quarterly basis for review. Annual reports of personal securities holdings are also provided to the Chief Compliance Officer for review. • Gifts received from vendors are to be of nominal value. • Firm personnel must report all outside business activities for approval from the Chief Compliance Officer, and firm personnel may be directors of publicly traded entities only with prior approval of the Chief Compliance Officer. • The Firm and its employees must always comply with all applicable securities laws. Page 7  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 Interest in Client Transactions Clients of Harlow Capital Management, LLC that are appropriately qualified invest in the Funds as appropriate for each client’s investment objective and risk tolerance. As stated above, Arbco, L.L.C. is the general partner of the Funds, and therefore collects the performance allocations when appropriate. Mr. Harlow is the managing member of Arbco, L.L.C. and benefits personally from the profitability of Arbco, L.L.C. This creates a conflict of interest with investors in the Funds, which is fully disclosed in the respective Fund documents. BROKERAGE PRACTICES Selecting broker/dealers for trades and custody of client assets The Firm recognizes its fiduciary responsibility to maintain best execution for trades executed on behalf of clients. Mr. Harlow uses a number of factors to select broker/dealers and to monitor all trade executions. These factors include: • • • • • • the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); the operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; the financial strength, integrity and stability of the broker; the broker’s risk in positioning a block of securities; the quality, comprehensiveness and frequency of available research services and other services considered by the Firm to be of value; and the competitiveness of commission rates in comparison with other brokers satisfying the Firm’s other selection criteria. broker/dealer with excellent service at extremely HCM currently conducts the majority of its trades for clients through CAPIS, a registered competitive commissions. Clients with separate accounts managed by HCM are encouraged to custody their accounts with Charles Schwab & Co., Inc.(“Schwab”) due to the quality of service, access to no transaction fee products and competitive commission structures. Brokerage firms that have custody of a Client’s assets may impose a “trade-away” fee for trades executed by other brokers. Trade Errors HCM has a policy that no client will sustain losses as a result of any trade error occurring in the account. (Schwab forgives all errors less than $100, whether generating gains or losses.) Errors are booked through an error account for Harlow Capital Management, LLC. Research and Other Soft-Dollar Benefits “Soft dollars” is a term applied to commission revenue generated by client trades which is then used to pay for services provided to an investment advisor. These services must Page 8  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 apply to benefit clients and include research and other related services as defined by Section 28(e) of the Securities and Exchange Act of 1934. Section 28 (e) provides a safe- harbor permitting an investment adviser to cause an account to pay commission rates in excess of those that another broker/dealer would have charged for effecting the same transaction. HCM may determine in good faith that the commission paid is reasonable in relation to the value of the brokerage and research services provided. This determination may be viewed in terms of either the particular transaction involved or the overall responsibilities of HCM with respect to the accounts over which it exercises investment discretion. Such research furnished by broker/dealers may be used in connection with accounts other then those that generated the soft dollars. The use of soft dollars creates a conflict of interest between HCM and its clients through the assumption that soft dollars are generated with higher commission rates than would otherwise be the case. Further, HCM may have incentive to trade through broker/dealers granting soft dollars rather than attending to the quality of client trades. These conflicts are mitigated by HCM through constant monitoring of commission rates and ensuring that rates generating soft dollars continue to be very competitive, as well as ensuring that execution quality is not sacrificed. The Firm monitors its trade execution quality on a periodic basis every year. The Firm uses products paid for with soft dollars which have “mixed-use” by benefitting both clients and HCM. Where HCM itself receives administrative benefits and research services from broker/dealers, the Firm makes a good faith allocation between the research and services directly benefitting clients, and those benefitting HCM. Only benefits accruing to clients are paid for with soft dollars. The remaining benefits or services are paid for in hard dollars by HCM. A conflict of interest exists between HCM and its clients by reason of the Firm’s allocation of the costs of soft dollar benefits and services between those that primarily benefit the Firm and those that primarily benefit its clients. The Firm maintains complete records of soft dollars generated as well as the products and services obtained with those soft dollars as well as its calculation of mixed- use items. In the prior year, HCM used soft dollars to purchase the following services: • none HCM does not allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. All soft dollars are generated through SunGard’s CAPIS due to its very competitive rates and the administrative ease of having one broker manage all soft dollar relationships, because the broker has to pay the vendors directly. Some custodians provide investment advisors with additional benefits which are not paid for with soft dollars. These additional benefits include access to national conferences and local seminars, newsletters covering compliance and practice management, research, Page 9  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 and electronic downloads of client data. These services assist HCM with its administration of client accounts, and thus slightly help its profitability, creating a potential conflict of interest with clients. HCM believes this is not a material conflict. Brokerage for Client Referrals HCM does not trade with particular broker/dealers in exchange for receiving client referrals. Directed Brokerage Some clients may direct HCM to use specific financial entities as custodians and/or brokers to execute trades for their portfolios. When directed by an individual client to use a specific broker-dealer, no attempt is generally made to negotiate commissions, and as a result, these clients may pay materially different commissions than those paid by other clients of the firm for the same trade. The firm often places block trades, in which individual trades are grouped to place a block order in the interest of receiving a better price. When different prices are given for pieces of the block, the executing broker gives an average price to all participating clients. Clients directing the firm to use specific broker-dealers may not participate in such blocked trades, and therefore may receive a different price, and may be limiting the firm’s ability to negotiate better commissions on blocked trades. Order Aggregation When the same security is purchased or sold for several client accounts at or about the same time, the transaction may be executed on a combined (“blocked”) basis, because the aggregate volume of the transaction may provide better purchase or sale prices, lower commission expense, or beneficial timing of transactions. However, if an entire block order cannot be filled at one time, the following factors will be considered in order to equitably allocate shares between the respective accounts: the size of each account (a small account’s allocation may be increased to give it a meaningful position, or eliminated if the allocation is too small); or each account’s relative cash position (a relatively large cash position may require more rapid investment of those funds than accounts with relatively smaller cash positions); or transaction fees that will be incurred if multiple trades are executed within a single account (for this reason, pro-rata allocation is preferred over random allocation). All blocked trades are allocated to the clients’ accounts on the day of the trade. HCM personnel may not participate in block trades with clients. Block trades executed at Schwab do not receive commission breaks, as the commission rate applies to the account level. Initial Public Offers Accounts over which HCM has discretionary authority will be eligible to participate in Initial Public Offerings (IPOs). IPOs will be allocated to client accounts according to each client’s investment objective. If the entire order is not filled, HCM may modify the trade allocations with shares distributed on a pro rata basis in client equity accounts, with a minimum allocation of twenty-five (25) shares per account to minimize transaction cost. Acceptable reasons for modification include small accounts do not receive an allocation Page 10  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 because the position’s size results in excess settlement cost; accounts may be over- weight in the industry sector. REVIEW OF ACCOUNTS Mr. Harlow reviews each portfolio at least bi-monthly for asset allocation, cash positions and securities holdings. Client meetings are held at least annually (according to a client’s availability), in which asset allocations, account holdings, performance and the client’s financial profile are reviewed. Additional reviews may be triggered by events such as a client meeting, change in a client’s risk tolerance, financial position or investment objective, change in a company or fund’s management, major market moves, or other unforeseen events. Clients of separately managed accounts receive statements directly from their custodians on at least a quarterly basis. HCM sends quarterly economic and market commentary to investors in the Funds and to clients with separately managed accounts. Additionally, investors in the Funds receive written audited financial statements and performance reports annually. CLIENT REFERRALS AND OTHER COMPENSATION HCM does not pay others for client referrals and does not receive additional compensation beyond that described above. CUSTODY Custody is defined as an investment advisory firm, its related entities, and/or its personnel having direct access to client funds or securities. HCM’s separately managed accounts are held by qualified custodians, which send account statements directly to clients on at least a quarterly basis. (Clients are reminded to review these statements carefully.) Since HCM has the authority to direct the custodian to deduct its management fees directly from these accounts, it has a form of custody for these accounts. However, clients must give prior permission for these deductions and see proof of them on each quarterly statement the client receives from the custodian. Otherwise, HCM does not have physical custody of the assets in these client accounts. The general partner, Arbco, L.L.C., for which Mr. Harlow is managing member, has the authority to withdraw assets from the Funds. Therefore, Arbco, L.L.C. is deemed to have custody of the Funds’ assets. The Funds are audited on an annual basis by a PCAOB- inspected firm as required, with copies of the audited statements going to the investors within 120 days of the Funds’ fiscal year-end. INVESTMENT DISCRETION HCM trades on behalf of its clients through a Limited Power of Attorney, which is included in the Investment Advisor Service Agreement. This limited power grants HCM Page 11  Part 2A of Form ADV: Firm Brochure Harlow Capital Management, LLC March 2026 the authority to place trades with full discretion, not requiring receipt of a client’s permission prior to placing each trade. Clients may notify HCM at any time in the relationship as to restrictions for investments in their portfolio. The Limited Partnership Agreement for each Fund grants HCM investment discretion as well. VOTING CLIENT SECURITIES HCM acknowledges its fiduciary responsibility to vote proxies for securities held in client accounts. The Firm votes in a manner that ensures the exclusive benefit of the underlying participants and beneficiaries, while using care, skill, and due diligence that a prudent person acting in a like capacity and familiar with such matters would use under those circumstances. The firm votes all proxies to, in its opinion; maximize shareholder value, usually voting with management except on matters concerning executive compensation and extraordinary benefits. HCM will provide to clients, upon request, its proxy voting policy as well as its historical records regarding proxy voting. Proxy material for client accounts is sent to HCM rather than to clients, so the likelihood of a client directing HCM how to vote is small. However, should a client direct HCM how to vote on its behalf in writing, and voting has not yet closed, HCM would do so. FINANCIAL INFORMATION There is no financial condition that is reasonably likely to impair HCM’s ability to continue to provide services to its clients. DISCLOSURES Please see the brochure supplement for information regarding the Firm’s owner, Mr. Colby Harlow. No person in the Firm has been involved in any arbitration claim or proceeding involving unethical practices. The Firm does not have any relationships or arrangements with any issuer of securities. Page 12  Colby L. Harlow Harlow Capital Management, LLC PO Box 190136 Dallas TX 75219 214.754.0800 www.harlow-capital.com ITEM 1: COVER PAGE March 2026 This brochure supplement provides information about Colby Harlow that supplements the Harlow Capital Management, LLC brochure. You should have received a copy of that brochure. Please contact Colby Harlow at 214.754.0800 if you did not receive Harlow Capital Management, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Colby Harlow is available on the SEC’s website at www.adviserinfo.sec.gov.  Part 2B of Form ADV: Brochure Supplement Harlow Capital Management, LLC ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Colby Harlow, born 1977 Business Experience: Mr. Harlow is the President and Chief Compliance Officer of Harlow Capital Management, LLC (“HCM” or “the Firm”) and is also the managing member of Arbco, LLC, the general partner for several private funds. Prior to forming HCM in 2005, Mr. Harlow was a portfolio manager for Western Research & Management in Fort Worth, Texas, from September 2000 through January 2005. Mr. Harlow was also an analyst for Salomon Smith Barney in Dallas, Texas, from September 1999 to September 2000. Education: Mr. Harlow received a Bachelor of Arts in Economics and Business Administration from Austin College in Sherman, Texas, in 1998. ITEM 3: DISCIPLINARY INFORMATION Mr. Harlow has had no disciplinary or legal events that would be material to a client or prospective client. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Harlow also holds a life insurance license and periodically offers such products to clients as appropriate. He can receive a portion of the client’s premium if the client chooses to use this service, although clients are free to purchase life insurance elsewhere. Mr. Harlow ensures that compensation from the sale of life insurance products comprises a small portion of his total annual compensation. Mr. Harlow also serves on the Board of a privately held business for which he receives quarterly compensation; he spends approximately 8 hours per quarter in this endeavor during trading hours. ITEM 5: ADDITIONAL COMPENSATION Mr. Harlow receives no compensation beyond that disclosed above under Other Business Activities. ITEM 6: SUPERVISION Mr. Harlow is the senior person at HCM, so does not have a supervisor. ITEM 7: DISCLOSURES Mr. Harlow has not been found liable in an arbitration claim, nor has he been found liable in a civil, self-regulatory organization or administrative proceeding. Mr. Harlow has not been the subject of a bankruptcy petition. Page 1