Investcorp Credit Management BDC, Inc.

Evaluation of Disclosure Controls and Procedures

Our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of the design and operation of our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the Exchange Act)) as of June 30, 2026. Based on that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures were not effective as of June 30, 2026 because of the material weakness in internal control over financial reporting described below.

Material Weakness in Internal Control Over Financial Reporting

The Company did not design and maintain effective risk assessment processes to identify and evaluate risks associated with compliance with the qualifying income requirements of section 851(b)(2). This deficiency resulted from the Company not having a formal policy in place to ensure non-qualifying income from portfolio investments treated as pass-through entities and other arrangements that could generate non-qualifying income for purposes of Subchapter M of the Internal Revenue Code are correctly evaluated or forecasted for compliance. As a result, the Company did not design and maintain effective related process-level control activities over such income.

The control deficiencies resulted in immaterial misstatements in our consolidated financial statements as of and for the six months ended December 31, 2024, as of and for the year ended December 31, 2025 and the interim periods within that year. Prior period amounts have been adjusted to reflect the immaterial corrections. The control deficiencies described above created a reasonable possibility that a material misstatement of the consolidated financial statements would not be prevented or detected on a timely basis. Accordingly, management concluded that the deficiencies represent a material weakness in the Company’s internal control over financial reporting.

Management’s Remediation Plan

Subsequent to the end of the second quarter, Management has taken initial steps to address the material weakness by enhancing risk assessment processes and related process-level controls over compliance with the RIC qualifying income requirements. As of July 2026, Management has formed ICMB Blocker LLC, a domestic taxable subsidiary, to hold investments in existing equity investments that may have adverse tax attributes. Additionally, in August, Management presented to the Board of Directors a written accounting policy to establish procedures for the use of blockers and required tax analysis for future equity positions. Management will continue to evaluate these actions and implement additional measures as necessary until the material weakness has been remediated.

Changes in Internal Control Over Financial Reporting

There were no changes in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) during the quarter ended June 30, 2026 that materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

PART II—OTHER INFORMATION