GECC · Great Elm Capital Corp. · Insider Trading

Reflects shares of common stock of Great Elm Capital Corp. ("GECC") owned by Great Elm Group, Inc. ("GEG") that (i) GEG granted as compensation to certain employees in exchange for no consideration and (ii) which were delivered by GEG (together with any accumulated stock dividends thereon) to such employees in connection with the vesting of such awards (or an applicable portion thereof).

Prior to the vesting and delivery of any such compensation awards (or any portion thereof), GEG retains beneficial ownership rights over the GECC shares underlying such awards, the number of which are included in GEG's direct holdings.

Represents the exempt acquisition of shares of common stock of GECC as a result of a stock dividend associated with the portion of the equity compensation awarded to Mr. Kleinman in previous years that vested on the anniversary of those grant dates.

Reflects the net share settlement of awards of restricted stock in connection with vesting thereof that is exempt pursuant to Rule 16b-3.

Ms. Davis is the CFO of Great Elm Capital Management, Inc. ("GECM"), the external investment manager of Great Elm Capital Corp. ("GECC"). Ms. Davis received an award of 7,646 shares of common stock of GECC as equity compensation for her position at GECM, 1,911 of which vested on the grant date, September 21, 2026, and the remainder of which will vest in equal annual installments on September 20th of each year until September 20, 2029, subject to continued service with GECM.

Represents shares of common stock of GECC acquired as a result of a stock dividend associated with the portion of the equity compensation awarded to Ms. Davis in previous years that vested on the anniversary of those grant dates.

Mr. Kleinman is the Chief Compliance Officer and Secretary of Great Elm Capital Corp. ("GECC"). Mr. Kleinman received the exempt grant of an award of 15,292 shares of common stock of GECC as equity compensation for his position at GECC, 3,823 of which vested on the grant date, September 21, 2026, and the remainder of which will vest in equal annual installments on September 20th of each year until September 20, 2029, subject to continued service with GECM.

Reflects the net share settlement of awards of restricted stock in connection with vesting thereof that is exempt pursuant to Rule 16b-3.

The reported transaction reflects a private sale of shares of Common Stock of the Issuer not effectuated on the open market.

The price reported in Column 4 is a weighted average price. These shares were purchased in multiple transactions at prices ranging from $7.55 to $7.74, inclusive. The Reporting Person undertakes to provide to Great Elm Capital Corp. ("GECC"), any security holder of GECC, or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares purchased in each transaction at each separate price within the ranges set forth herein.

Reflects the net share settlement of awards of restricted stock in connection with vesting thereof that is exempt pursuant to Rule 16b-3.

Reflects the net share settlement of awards of restricted stock in connection with vesting thereof that is exempt pursuant to Rule 16b-3.

Reflects the net share settlement of awards of restricted stock in connection with vesting thereof that is exempt pursuant to Rule 16b-3.

Reflects shares of common stock of Great Elm Capital Corp. ("GECC") owned by Great Elm Group, Inc. ("GEG") that (i) GEG granted as compensation to certain employees in exchange for no consideration and (ii) which were delivered by GEG (together with any accumulated stock dividends thereon) to such employees in connection with the vesting of such awards (or an applicable portion thereof).

Prior to the vesting and delivery of any such compensation awards (or any portion thereof), GEG retains beneficial ownership rights over the GECC shares underlying such awards, the number of which are included in GEG's direct holdings.

Mr. Kaplan is the President and Chief Executive Officer of Great Elm Capital Corp. ("GECC"). Mr. Kaplan received an award of 37,117 shares of common stock of GECC as equity compensation for his position at GECC, 9,280 of which vested on the grant date, September 19, 2025, and the remainder of which will vest in equal annual installments on September 20th of each year until September 20, 2028, subject to continued service with GECC.

Represents the exempt acquisition of shares of common stock of GECC as a result of a stock dividend associated with the portion of the equity compensation awarded to Mr. Kleinman in previous years that vested on the anniversary of those grant dates.

Reflects shares of common stock of Great Elm Capital Corp. ("GECC") owned by Great Elm Group, Inc. ("GEG") that (i) GEG granted as compensation to certain employees in exchange for no consideration and (ii) which were delivered by GEG (together with any accumulated stock dividends thereon) to such employees in connection with the vesting of such awards (or an applicable portion thereof).

Prior to the vesting and delivery of any such compensation awards (or any portion thereof), GEG retains beneficial ownership rights over the GECC shares underlying such awards, the number of which are included in GEG's direct holdings.

Ms. Davis is the CFO of Great Elm Capital Management, Inc. ("GECM"), the external investment manager of Great Elm Capital Corp. ("GECC"). Ms. Davis received an award of 3,820 shares of common stock of GECC as equity compensation for her position at GECM, 955 of which vested on the grant date, September 19, 2025, and the remainder of which will vest in equal annual installments on September 20th of each year until September 20, 2028, subject to continued service with GECM.

Represents the exempt acquisition of shares of common stock of GECC as a result of a stock dividend associated with the portion of the equity compensation awarded to Mr. Kaplan in previous years that vested on the anniversary of those grant dates.

Represents shares of common stock of GECC acquired as a result of a stock dividend associated with the portion of the equity compensation awarded to Ms. Davis in previous years that vested on the anniversary of those grant dates.

Mr. Kleinman is the Chief Compliance Officer and Secretary of Great Elm Capital Corp. ("GECC"). Mr. Kleinman received the exempt grant of an award of 5,458 shares of common stock of GECC as equity compensation for his position at GECC, 1,365 of which vested on the grant date, September 19, 2025, and the remainder of which will vest in equal annual installments on September 20th of each year until September 20, 2028, subject to continued service with GECM.

The price reported in Column 4 is a weighted average price. These shares were sold in multiple transactions at prices ranging from $11.00 to $11.19, inclusive. The reporting person undertakes to provide to the Issuer, any security holder of the Issuer or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price within the range set forth in this footnote.

The price reported in Column 4 is a weighted average price. These shares were sold in multiple transactions at prices ranging from $10.95 to $11.13, inclusive. The reporting person undertakes to provide to the Issuer, any security holder of the Issuer or the staff of the Securities and Exchange Commission (the "SEC"), upon request, full information regarding the number of shares purchased at each separate price within the range set forth in this footnote.

The price reported in Column 4 is a weighted average price. These shares were purchased in multiple transactions at prices ranging from $11.1150 to $11.2000, inclusive. The Reporting Person undertakes to provide to the Issuer, any security holder of the Issuer or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares purchased at each separate price within the range set forth in this footnote.

The price reported in Column 4 is a weighted average price. These shares were purchased in multiple transactions at prices ranging from $11.1150 to $11.2000, inclusive. The Reporting Person undertakes to provide to the Issuer, any security holder of the Issuer or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price within the range set forth in this footnote.

The price reported in Column 4 is a weighted average price. These shares were purchased in multiple transactions at prices ranging from $11.0500 to $11.1700, inclusive. The Reporting Person undertakes to provide to the Issuer, any security holder of the Issuer or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price within the range set forth in this footnote.

The price reported in Column 4 is a weighted average price. These shares were purchased in multiple transactions at prices ranging from $10.7950 to $10.8400, inclusive. The Reporting Person undertakes to provide to the Issuer, any security holder of the Issuer or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price within the range set forth in this footnote.

The price reported in Column 4 is a weighted average price. These shares were purchased in multiple transactions at prices ranging from $10.7050 to $10.7500, inclusive. The Reporting Person undertakes to provide to the Issuer, any security holder of the Issuer or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price within the range set forth in this footnote.