Investcorp Credit Management BDC Inc

Evaluation of Disclosure Controls and Procedures

As of March 31, 2024 (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 March 31, 2024, our disclosure controls and procedures were designed at a reasonable assurance level and were effective to provide reasonable assurance that information required to be disclosed in our periodic SEC filings is recorded, processed, summarized and reported within the time periods specified in the SEC's rules and forms, and that such information is accumulated and communicated to our management, including our Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosure.

Changes in Internal Control Over Financial Reporting

For the quarter ended December 31, 2023, our independent auditors issued a material weakness on our internal control over financial reporting related to our disclosure controls and procedures. Our disclosure controls and procedures were not effective in the timely identification of the incorrect accrual of certain expenses in our consolidated financial statements. To address and remediate the ineffective controls, the Company has added or is in the process of adding five accounting personnel and has hired a third-party service provider to provide support for its 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. A member of the third-party service provider’s staff became the Company’s chief financial officer on March 31, 2024, and he will be supported by other finance and accounting members of the third-party service provider’s staff, as well as members of the Company’s finance and accounting staff.

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 March 31, 2024 that has materially affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting.

PART II—OTHER INFORMATION