Great Elm Capital Corp

March 31, 2024

(1)

Great Elm Capital Corp.’s (the “Company”) investments are generally acquired in private transactions exempt from registration under the Securities Act of 1933, as amended (the “Securities Act”) and, therefore, are generally subject to limitations on resale, and may be deemed to be “restricted securities” under the Securities Act.

(2)

Certain of the Company’s variable rate debt investments bear interest at a rate that is determined by reference to Secured Overnight Financing Rate (“SOFR”) or prime rate (“Prime”) which are reset periodically. For each debt investment, the Company has provided the interest rate in effect as of period end. A floor is the minimum rate that will be applied in calculating an interest rate. A cap is the maximum rate that will be applied in calculating an interest rate. The SOFR as of period end was 5.34%. The one-month (“1M”) SOFR as of period end was 5.33%. The three-month (“3M”) SOFR as of period end was 5.30%. The six-month (“6M”) SOFR as of period end was 5.22%. The Prime as of period end was 8.50%.

(3)

Percentage of class held refers only to equity held, if any, calculated on a fully diluted basis.

(4)

“Controlled Investments” are investments in those companies that are “Controlled Investments” of the Company, as defined in the Investment Company Act of 1940, as amended (the “Investment Company Act”). A company is deemed to be a “Controlled Investment” of the Company if the Company owns more than 25% of the voting securities of such company.

(5)

“Affiliate Investments” are investments in those companies that are “Affiliated Companies” of the Company, as defined in the Investment Company Act, which are not “Controlled Investments.” A company is deemed to be an “Affiliate” of the Company if the Company owns 5% or more, but less than 25%, of the voting securities of such company.

(6)

Investments classified as Level 3 whereby fair value was determined by the Company’s board of directors (the “Board”).

(7)

Security pays, or has the option to pay, some or all of its interest in kind. As of March 31, 2024, the Avation Capital SA secured bond, New Wilkie Energy Pty Limited secured loan and working capital facility, Nice-Pak Products, Inc. secured loan B, Ruby Tuesday Operations, LLC secured loans, each of the Universal Fiber Systems term loans, and Vi-Jon secured loan pay all or a portion of their interest in-kind and the rates above reflect the payment-in-kind (“PIK”) interest rates.

(8)

Non-income producing security.

(9)

Investment was on non-accrual status as of period end.

(10)

Indicates assets that the Company believes do not represent “qualifying assets” under Section 55(a) of the Investment Company Act. Qualifying assets must represent at least 70% of the Company’s total assets at the time of acquisition of any additional non-qualifying assets. Of the Company’s total assets,20.49% were non-qualifying assets as of period end.

(11)

Security exempt from registration pursuant to Rule 144A under the Securities Act. Such security may be sold in certain transactions (normally to qualified institutional buyers) and remain exempt from registration.

(12)

As a practical expedient, the Company uses net asset value to determine the fair value of this investment.

(13)

The investment in Collateralized Loan Obligation (“CLO”) equity is entitled to recurring distributions which are generally equal to the remaining cash flow of payments made by underlying investments after payment of the contractual payments to debt holders and fund expenses. The effective yield is based on the current projection of the amount and timing of these recurring distributions in addition to the estimated amount of terminal principal payment. These assumptions are periodically reviewed and adjusted. The effective yield and investment cost may ultimately not be realized.

(14)

As of period end, the aggregate gross unrealized appreciation for all securities in which there was an excess of value over tax cost was$13,746; the aggregate gross unrealized depreciation for all securities in which there was an excess of tax cost over value was$28,488; the net unrealized depreciation was$14,742; the aggregate cost of securities for Federal income tax purposes was$285,937.

• Represents less than 1%.

As of March 31, 2024, the Company’s investments consisted of the following:

As of March 31, 2024, the geographic composition of the Company’s portfolio at fair value was as follows:

As of March 31, 2024, the industry composition of the Company’s portfolio at fair value was as follows:

CONSOLIDATED SCHEDULE OF INVESTMENTS

December 31, 2023

(1)

The Company’s investments are generally acquired in private transactions exempt from registration under the Securities Act of 1933 and, therefore, are generally subject to limitations on resale, and may be deemed to be “restricted securities” under the Securities Act of 1933.

(2)

Certain of the Company’s variable rate debt investments bear interest at a rate that is determined by reference to Secured Overnight Financing Rate (“SOFR”) or prime rate (“Prime”) which are reset periodically. For each debt investment, the Company has provided the interest rate in effect as of period end. A floor is the minimum rate that will be applied in calculating an interest rate. A cap is the maximum rate that will be applied in calculating an interest rate. The SOFR as of period end was 5.38%. The one-month (“1M”) SOFR as of period end was 5.35%. The three-month (“3M”) SOFR as of period end was 5.33%. The six-month (“6M”) SOFR as of period end was 5.16%. The prime rate as of period end was 8.50%.

(3)

Percentage of class held refers only to equity held, if any, calculated on a fully diluted basis.

(4)

“Controlled Investments” are investments in those companies that are “Controlled Investments" of the Company, as defined in the Investment Company Act. A company is deemed to be a “Controlled Investment” of the Company if the Company owns more than 25% of the voting securities of such company.

(5)

“Affiliate Investments” are investments in those companies that are “Affiliated Companies” of the Company, as defined in the Investment Company Act, which are not “Controlled Investments.” A company is deemed to be an “Affiliate” of the Company if the Company owns 5% or more, but less than 25%, of the voting securities of such company.

(6)

Investments classified as Level 3 whereby fair value was determined by the Company’s board of directors (the “Board”).

(7)

Security pays, or has the option to pay, some or all of its interest in kind. As of December 31, 2023, the Avation Capital SA secured bond, Nice-Pak Products, Inc. secured loan B, Ruby Tuesday Operations, LLC secured loan and each of the Universal Fiber Systems term loans pay a portion of their interest in-kind and the rates above reflect the payment-in-kind (“PIK”) interest rates.

(8)

Non-income producing security.

(9)

Indicates assets that the Company believes do not represent “qualifying assets” under Section 55(a) of the Investment Company Act. Qualifying assets must represent at least 70% of the Company’s total assets at the time of acquisition of any additional non-qualifying assets. Of the Company’s total assets,16.97% were non-qualifying assets as of period end.

(10)

Security exempt from registration pursuant to Rule 144A under the Securities Act. Such security may be sold in certain transactions (normally to qualified institutional buyers) and remain exempt from registration.

(11)

As a practical expedient, the Company uses net asset value to determine the fair value of this investment.

(12)

As of period end, the aggregate gross unrealized appreciation for all securities in which there was an excess of value over tax cost was $13,715; the aggregate gross unrealized depreciation for all securities in which there was an excess of tax cost over value was $11,273; the net unrealized depreciation was $2,441; the aggregate cost of securities for Federal income tax purposes was $238,978.

• Represents less than 1%.

As of December 31, 2023 the Company’s investments consisted of the following:

As of December 31, 2023 the geographic composition of the Company’s portfolio at fair value was as follows:

As of December 31, 2023 the industry composition of the Company’s portfolio at fair value was as follows: