Investcorp Credit Management BDC Inc

Evaluation of Disclosure Controls and Procedures

As of December 31, 2023 (the end of the period covered by this report), our management, with the participation of our Chief Executive Officer and Chief Financial Officer, has evaluated the effectiveness of our disclosure controls and procedures (as defined in Rule 13a-15(e) under the Exchange Act). Our management recognizes that any controls and procedures, no matter how well designed and operated, can provide only reasonable assurance of achieving their objectives, and our management necessarily applies its judgment in evaluating the cost-benefit relationship of possible controls and procedures. The design of disclosure controls and procedures and internal control over financial reporting must reflect the fact that there are resource constraints and that management is required to apply judgment in evaluating the benefits of possible controls and procedures relative to their costs.

Based on such evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that, as of December 31, 2023, our disclosure controls and procedures were not effective in timely identifying the incorrect accrual of certain expenses in our consolidated financial statements. In connection with the preparation of our consolidated financial statements for the fiscal quarter ended December 31, 2023, approximately $388,000, or approximately $0.02 per share, of adjustments relating to the incorrect accrual of certain expenses were identified, of which approximately $356,000 of adjustments related to the fiscal year ended June 30, 2023. The Company believes these errors were immaterial in nature and has corrected such errors in the consolidated financial statements contained in this Form 10-Q for the quarter ended December 31, 2023.

Notwithstanding the foregoing, our independent registered public accounting firm advised us that such delayed detection of the errors resulted in a material weakness in our internal control over financial reporting. Management has taken, and will continue to take, significant and comprehensive action to remediate the internal control weakness. In this regard, we have added or are in the process of adding five accounting personnel and are hiring a third-party service provider to provide support for our day-to-day finance and accounting activities to, among other things, create additional redundancies in duties surrounding the Company’s accrual of expenses and the frequency of the review thereof.

Changes in Internal Control Over Financial Reporting

Other than as noted above, management did not identify any change in the Company’s internal control over financial reporting that occurred during the quarter ended December 31, 2023 that has materially affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting.

PART II—OTHER INFORMATION