LEGAL NOTICES AND TERMS OF USE

Please read carefully before proceeding.

Individuals who access the information made available on Great Elm Capital Corp.’s web site agree to the following:

Scope of Use/ No Warranties

Great Elm Capital Corp. invites you to view, use and download a single copy of this web site for your informational, non-commercial use to evaluate whether to enter into a business relationship with Great Elm Capital Corp. Such use shall not constitute a commercial use for the purposes hereof. Except as otherwise provided in these Terms of Use, no part of any content, information or software on or comprising this web site may be copied, downloaded or stored in a retrieval system for any other purpose or redistributed in any form or manner for any purpose without the express prior written permission of Great Elm Capital Corp. You understand that Great Elm Capital Corp. may discontinue, change or restrict your use of this web site for any reason without notice.

By using this web site, you represent that you are at least 18 years old and are a United States resident or an entity incorporated and headquartered in the United States. If not, do not use this web site.

Great Elm Capital Corp. takes care to ensure that the information provided on the Great Elm Capital Corp. web site is accurate at the date of publication. However the Great Elm Capital Corp. web site is provided without warranties of any kind, either expressed or implied, including but not limited to warranties of title or implied warranties of merchantability or fitness for a particular purpose. Opinions expressed herein are subject to change without notice. All information and content on this web site is furnished "AS IS," without warranty of any kind, express or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, or non-infringement. Great Elm Capital Corp. will not assume any liability for any loss or damage of any kind, arising or caused by, whether direct or indirect, the use of any part of the information provided or the use of or download of any materials from this web site. While Great Elm Capital Corp. makes reasonable efforts to avoid technological problems, at any time this web site may have and may cause technological problems such as viruses and other damaging computer programming routines or engines. Great Elm Capital Corp. also takes reasonable security precautions when using the Internet, telephone or other means to transport data or other communications, but disclaims liability for any interception of data or communications. Great Elm Capital Corp. makes reasonable efforts to ensure that this web site is secure but does not guarantee the security of this web site, and is not liable for any damage or injury caused by the performance or failure of performance of all or any portion of this web site and is not liable for any defects, delays, or errors in or resulting from use of this web site.

NOTICE: Great Elm Capital Corp. accepts applications for commercial loans only. The proceeds of any loan received from Great Elm Capital Corp. shall not be used for consumer purposes. If you are seeking a consumer loan, please do not use this web site.

Privacy Policy

Great Elm Capital Corp. will exercise reasonable precautions to maintain the confidentiality of all information provided in connection with accessing this site. Because such information can be accessed through the Internet, no assurance can be given that this information will remain secure. Great Elm Capital Corp. may, at anytime, disclose such information to its employees, representatives, officers, agents or affiliates, as well as any government entity, in the conduct of its business, to comply with applicable rules, orders, subpoenas or other legal processes, or in order to provide information to any government agency or official requesting such information, or for any other legitimate business purpose.

This site does not collect personally identifying information about individuals except when specifically and knowingly provided by such individuals.

Proprietary Rights

Great Elm Capital Corp. and FCF are registered trademarks in the US and other countries throughout the world. No permission is granted to copy, distribute, modify, post or frame any text, graphics, video, audio, software code, or user interface design or logos. The entire Great Elm Capital Corp. web site is subject to copyright with all rights reserved.

The information contained on this web site shall not be published, rewritten for broadcast or publication, or redistributed in any medium without prior written permission from Fairfield Greenwich Limited.

Passwords

Great Elm Capital Corp. may provide users with a password to access certain areas of this web site.

Users are solely responsible for maintaining the confidentiality and security of such password and may not disclose such password to any third party. Users accept full responsibility for any use of their passwords and, as a condition to its issuance, must notify Great Elm Capital Corp. immediately of any actual or suspected loss, theft, or unauthorized use of their password.

Great Elm Capital Corp. is not obligated to inquire as to the authority or propriety of any use of or action taken under a user's password. Great Elm Capital Corp. will not be responsible for any loss to user that arises from such use or action or from a user's failure to comply with these provisions.

Users also understand that being provided a password does not in and of itself allow a user to invest in a Great Elm Capital Corp. fund, as investors in Great Elm Capital Corp. funds must meet certain technical suitability requirements, and must enjoy a “pre-existing, substantive relationship” with Great Elm Capital Corp. prior to investment. As a result, users should be on notice that at least 30 days may transpire between the issuance of a password and such time that they may be allowed to invest in an Great Elm Capital Corp. fund.

Users further understand that in order for Great Elm Capital Corp. to exercise proper control of its web site, it may terminate the password of any user without notice for any (e.g., letting more than 90 days transpire between uses) or no reason.

Use of Links

The Great Elm Capital Corp. web site may contain hyperlinks to web sites operated by other parties. Great Elm Capital Corp. does not control the content or accuracy of information on such web sites and does not otherwise endorse the material placed on such sites. Further, the warranties and Great Elm Capital Corp. privacy policy as described herein would no longer apply with respect to your use of any hyperlinked or third-party web site. The hyperlinks are provided for your reference only.

Investment Performance

Investors should seek financial advice regarding the appropriateness of investing in any securities or investment strategies discussed or recommended in this web site and should understand that statements regarding future prospects may not be realized. Investors should note that income from such securities may fluctuate and that each security's price or value may rise or fall. Accordingly, investors may experience a total loss of an investment or may receive back less than originally invested. Past performance is not necessarily a guide to future performance.

For Information Only

Not all securities, products, or services described in the Great Elm Capital Corp.’s web site are available everywhere. The information contained herein does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction in which such distribution or offer is not authorized. In particular, the information herein is not for distribution and does not constitute an offer to sell or the solicitation of any offer to buy any securities in the United States ("US") to or for the benefit of any US person (being residents of the US or partnerships or corporations organized under the laws of the US). Great Elm Capital Corp.’s funds have not been and will not be registered in the US according to the US Investment Company Act of 1940 and units or shares of Great Elm Capital Corp.’s funds will not be registered in the US according to the US Securities Act of 1933.

Great Elm Capital Corp.’s funds referred to in this web site are not recognized collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the "Act"). The promotion of such investment funds and the distribution of offering materials in relation to such funds in the United Kingdom is accordingly restricted by law. The information contained on the restricted part of this site (the "Restricted Area") is directed only at persons to whom such investment funds may lawfully be promoted by a person authorized under the Act (an "authorized person") by virtue of Section 238(5) of the Act and Annex 5 to Chapter 3 of the FSA Conduct of Business Sourcebook. Shares in the investment funds referred to in the Restricted Area are only available to such persons and information on this site must not be relied or acted upon by any other persons. Investors in the investment funds referred to in the Restricted Area will not benefit from the rules and regulations made under the Act for the protection of investors, nor from the Financial Services Compensation Scheme. Shares in the investment funds referred to in this web site are not dealt in or on a recognized or designated investment exchange for the purposes of the Act, nor is there a market maker in such shares, and it may therefore be difficult for an investor to dispose of his shares otherwise than by way of redemption. Further, FCC fund shares will not be marketed in Ireland without the approval in writing of the Central Bank of Ireland.

Nothing in the Great Elm Capital Corp. web site constitutes investment, legal, tax or other advice nor is it to be relied upon in making an investment decision. Subscriptions for share or units in any of Great Elm Capital Corp.’s funds will only be made to existing clients or known properties of Great Elm Capital Corp. which Great Elm Capital Corp. deems suitable, on the basis of the current offering memorandum (or other offering document) for the relevant fund.

LOCATION, GOVERNING LAW AND MISCELLANEOUS

These terms and conditions shall be governed and construed in accordance with the laws of the State of New York, without regard to conflict-of-laws provisions. To the maximum extent possible, the parties agree that the body of law known as the Uniform Computer Information Act will apply to these Terms of Use and your use of the web site. Great Elm Capital Corp. makes no representation or warranty that the information in this web site is appropriate or available for use in other locations, and access to this web site from territories where the content of this web site may be illegal or prohibited. If you access this web site from other locations, you do so on your own initiative and you are responsible for compliance with applicable local laws. Great Elm Capital Corp. disclaims any responsibility for compliance with any such laws in such circumstances. These Terms of Use and all documents incorporated herein by reference constitute the entire agreement between Great Elm Capital Corp. and you with respect to this web site. In the event any portion of these Terms of Use or any other provision of this web site is determined to be unenforceable, invalid or void by a court of competent jurisdiction, the remaining provisions shall remain valid and enforceable without any effect on their validity and enforceability.

Violations and Additional Policies

Great Elm Capital Corp. reserves the right to seek all remedies available at law and in equity for violations of the rules and regulations set forth in these Terms of Use or elsewhere in this web site, including the right to block access from a particular Internet address to this web site. You acknowledge that any violation of the rules and regulations set forth in these Terms of Use or elsewhere in this web site will cause irreparable injury to Great Elm Capital Corp. and remedies at law may be inadequate to protect Great Elm Capital Corp. against any such actual or threatened breach. You agree to the granting of equitable relief, including injunctive relief and specific performance, in Great Elm Capital Corp.'s favor without posting bond or the need to prove actual damages. Any such equitable remedy shall not be deemed to be the sole and exclusive remedy of Great Elm Capital Corp. hereunder but shall be in addition to all other remedies available to Great Elm Capital Corp. at law or in equity.

No failure or delay by Great Elm Capital Corp. in exercising any right, power or privilege under these Terms of Use will operate as a waiver thereof, nor shall any single or partial exercise thereof preclude any other or further exercise of any right, power or privilege hereunder. No provision of these Terms of Use can be waived or amended except by the written consent of Great Elm Capital Corp.

These Terms of Use are binding on any and all users of this web site.