Social Media Policy

Needham Investment Management, LLC. (“NIM”) is an investment adviser with the U.S. Securities and Exchange Commission (“SEC”). The following disclosure applies to NIM’s use of social media and is intended to inform clients, prospective clients, and other visitors to NIM’s website about the nature and limitations of NIM’s social media presence.

NIM maintains an official presence solely on LinkedIn. Social media networks are independent organizations and are not affiliated with NIM and their affiliates. All content we post is for informational purposes only, and not intended as personal advice or an offer, solicitation, or an offer to buy or sell any security or investment product and is not provided in a fiduciary capacity. The Firm’s comments, opinions and analyses are rendered as of the date of the posting and may change without notice. Reliance upon information in the posting is at the sole discretion of the viewer. Investors should consult a financial professional/financial consultant before making any investment decisions. The information provided should not be considered tax advice. Investors should always consult their own legal or tax professional for information concerning their individual situation.

NIM’s social media activity, including content posted on LinkedIn and interactions conducted through LinkedIn, is subject to review by NIM’s compliance department and is monitored, archived, and retained in accordance with applicable federal securities laws and NIM’s policies and procedures, including NIM’s recordkeeping obligation under Rule 204-2 under the Investment Advisory Act of 1940.

Mutual fund investing involves risk, including the possible loss of principal. Current performance may be higher or lower than the performance data quoted. To manage for market volatility, the SEC and FINRA require long-term performance horizons to contextualize short-term returns. For the fund’s most recent month-end performance metrics, gross/net asset values, and a copy of the prospectus containing investment objectives, risks, charges, and expenses, please visit https://www.needhamfunds.com/ or call 1-800-625-7071. Please read the prospectus carefully before investing.