Adopted June 30, 2022

Previously amended March 28, 2024

Amended June 25, 2025

IEDC Board approved 6.25.2025

PURPOSE

This Investment Policy specifically applies to IANF III, which has been established to invest, hold, and account for funds received by the State of Indiana through the State Small Business Credit Initiative administered by the United States Treasury as it has been reauthorized by the American Rescue Plan Act of 2021 (“SSBCI Program”). Because SSBCI Program is the sole source of funds for IANF III, compliance with laws, regulations, and guidance related to that program as well as the state statutory provisions of the Indiana Twenty-First Century Research and Technology Fund (“21 Fund”), which serves as Indiana’s statutory authority for the creation and operations of this IANF III, are required to make investments.

The purpose of IANF III, currently managed through the Indiana Angel Network Fund, LLC, by Elevate Ventures, Inc. (“Elevate Ventures”) through its subsidiary Elevate Advisors, LLC (“Elevate Advisors”), and pursuant to Elevate Ventures’ professional services contract with the State of Indiana and the Indiana Economic Development Corporation (the “IEDC”), is to foster and promote the development of entrepreneurs and emerging Indiana companies within the State of Indiana in support of the Indiana economy and its creation and retention of jobs. Elevate Ventures is an Indiana-based nonprofit venture development organization.

In conjunction with other State-supported funds and programs, IANF III aims to stimulate statewide technology-based economic development by actively inducing participation of angel and institutional investors through sharing of deal flow, due diligence, and co-investment.

TYPE OF INVESTMENT

Upon completion of its review and approval process and with the ultimate approval in compliance with State and Federal law by IEDC staff, Elevate Advisors may make an investment through IANF III into an Investee (as defined below) at substantially the same time, pursuant to substantially the same structure, and on substantially the same terms as the qualified private co-investment capital. Funding made available to Elevate Ventures through IANF III shall only be used for investment capital and ultimately for purposes of repaying outstanding loans due to the State in accordance with each loan agreement made and entered into by and between the IEDC and Indiana Angel Network Fund, LLC, and may not be assessed or allocated against any management fees or expenses, including but not limited to administration costs of Elevate Ventures or any of its subsidiaries. Any interest earned while such funds are held in an account managed by Elevate Ventures or any of its subsidiaries may only be used for purposes of repaying the debt obligations owed to the State.

DEFINITIONS

Commercial Domicile – has the meaning set forth in 45 IAC 3.1-1-32.

C-Suite Position – means a top-level executive, usually denoted as a Chief Officer, who oversees the decision-making and operations of a portion of or all of the company. Whether a position is C-Suite necessarily includes a review of job functions to ensure that duties align with position titles and must include ownership of at least five percent (5%) non-diluted interest in the company.

Headquarters – means the company: (1) has its North American Principal Office Address located in Indiana per the Indiana Secretary of State Business Registration Filing and, in the context of all information required to the satisfaction of the State, that the named Indiana Principal Office Address serves as the Commercial Domicile of the company; and (2) has at least one full-time C-Suite Position who is a Resident in Indiana.

Resident – has the meaning set forth in 45 IAC 3.1-1-21, 21.5, 22, and 22.5.