Euro Pacific Asset Management, LLC

Description of the Advisory Firm Euro Pacific Asset Management, LLC (also referred to as “EPAM,” “we,” “our,” “us” or the “firm” throughout this brochure) is an SEC-registered investment adviser with its principal place of business located in Dorado, Puerto Rico. EPAM is a privately held Puerto Rico limited liability company and is principally owned and controlled by Peter Schiff and Jim Nelson, CFA. We are an independent investment advisor focused on providing high-quality and sustainable investment strategies to our clients globally. With our in-house advisory and asset management team, we offer money management services to our clients, from planning and asset allocation to security selection and portfolio construction. Please visit this link to https://europac.com/about/.

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Wrap Fee Services Offered EPAM offers discretionary account management to clients through a Wrap Fee Program, as described in this brochure. We are the sponsor of the Wrap Fee Program and do not utilize sub advisors. The Wrap Fee Program invests in EPAM’s proprietary mutual funds which focus solely on international equities, commodities, and fixed income. Each portfolio is designed to provide varying levels of overall risk and volatility based on each of our client’s needs. While we do not actively trade the funds held inside the account, we do make changes from time to time in the funds themselves. We believe that our Wrap Fee Program provides clients diversified exposure to investments outside of the US Dollar. The Wrap Fee Program is not suitable for investors seeking exposure to US domestic securities markets. As of February 28, 2026, EPAM has total assets under management broken down as follows: Discretionary

Non-Discretionary

Date Calculated

$ 2,180,629,620

$0.00

December 31, 2025

Wrap Fee Program As part of the Wrap Fee Program, the client pays a single bundled fee to EPAM, instead of paying separately for EPAM’s advisory services and commissions on transactions. Typically, clients with account values of fifty thousand dollars ($50,000) or more will be eligible to participate in the Wrap Fee Program. Under the Wrap Fee Program, the client’s account will be invested according to one of five Portfolio Wrap strategies designed by EPAM. Investment in Proprietary Euro Pacific Funds Each Portfolio Wrap strategy is allocated among various proprietary mutual funds (“Euro Pacific Funds” or “the Fund(s)”) to which EPAM is the investment advisor. The five wrap strategies are designed to be suitable for clients with risk tolerance levels ranging from low to high, pertaining to their international exposure only. EPAM achieves varying levels of risk in each wrap strategy by changing the allocations to our primary asset classes of bonds, equity, and alternative investments (precious metals). Because EPAM serves as investment adviser to the Euro Pacific Funds, EPAM receives management fees

from those funds. As a result, EPAM has a financial incentive to recommend and retain investments in the proprietary funds utilized in the Wrap Fee Program, creating a conflict of interest. To mitigate this conflict, EPAM reduces the client's wrap management fee by an amount equal to the management fee attributable to the proprietary Euro Pacific Funds held in the client's wrap account so that EPAM does not receive two management fees on the same assets. Clients nevertheless indirectly bear their proportionate share of each fund's management fees and operating expenses through each fund's expense ratio, as described in the applicable fund prospectus. EPAM addresses this conflict through full and fair disclosure, its fiduciary obligations, supervisory policies and procedures, and periodic reviews designed to help ensure that the Wrap Fee Program and the proprietary funds utilized within the Program remain appropriate and in each client's best interest. These reviews include consideration of whether continued participation in the Wrap Fee Program remains appropriate for the client in light of the client's investment objectives, financial circumstances, risk tolerance, and overall best interest. Fees for the Wrap Fee Program Clients participating in our Wrap Fee Program pay a single bundled fee for our advisory services and commissions on transactions instead of paying these fees separately. The wrap fee does not include: (0) margin interest; or (ii) certain miscellaneous account fees or other administrative fees charged by the custodian, such as wire fees, or transfer fees; and (iii) management fees and expenses of mutual funds (including money market funds), closed-end investment companies or other managed investments, if any are held in the client’s account. A miscellaneous fee schedule is available upon request. Participants in the Wrap Fee Program are obligated to pay a wrap fee based on a percentage of the client’s assets under management, per the following schedule: Assets Under Management First $250,000 $250,001 to $500,000 $500,001 to $750,000 $750,001 to $1,000,000 Any additional amount over $1 million

Basic Annual Wrap Fee Schedule 0.92% 0.67% 0.42% 0.17% 0.00%

The fees outlined above consider our normal separately managed account (SMA). Management fee, minus the maximum management fee that EPAM could possibly earn on its Euro Pacific Funds. This ensures that EPAM does not earn two fees, one on the Wrap Fee Program and one on the Euro Pacific Funds. For example, the maximum fee percentage EPAM charges on its SMAs is 2% for the first $250,000 in assets under management and the maximum management fee on its Euro Pacific Funds is 1.08%. Therefore, the fee that EPAM charges on its first tier of the Wrap Fee Program is 0.92% (2.00% minus 1.08%). The client will see this 2.00% fee in the form of 1) a 0.92% fee on assets under management in their wrap account and 2) the underlying management fee in the mutual fund they own of 1.08%. The underlying management fee of 1.08% will not be broken out on the custodial statement, as with all open-ended mutual funds the fee is accrued daily and reflected in the net asset value (NAV) of the Fund. However, the client may review each Funds expenses in each Fund’s current prospectus located at www.europacificfunds.com. EPAM does not aggregate related client accounts for purposes of calculating the wrap fee applicable to the client. The actual fee charged to a client will be outlined in the Wrap Account Investment Management Agreement (“WAIMA”). EPAM reserves the right to negotiate fees with clients and may waive fees or charge higher or lower fees than those described above, at our discretion. The fees are subject to change with prior written notice to the client.

Participating in the Wrap Fee Program may cost a client more or less than purchasing investment management and trading services separately. Factors that may affect the cost of Wrap Fee Program relative to other compensation arrangements include the management fees the client would pay for EPAM’s investment management services if the fees were unbundled; the transaction and execution fees the custodian would charge to the client under a non-wrap fee arrangement; and the frequency and volume of trading activity in the client’s account. Under the terms of this Wrap Fee Program, EPAM will pay trading and execution costs imposed by the custodian for transactions in client accounts. This arrangement presents a potential conflict of interest for EPAM, as EPAM has a financial disincentive to engage in active trading. However, transaction fees are not a material consideration for EPAM in deciding whether to engage in any trading or the level of trading activity for client accounts. The Wrap Fee Program is intended to be a low-turnover account, with a focus on achieving the appropriate asset allocation overall, not on trading in and out of the Funds based on short-term opportunities. Most changes in holdings within the Wrap Fee Account will be accomplished by trading the Funds themselves, rather than the holdings in the Wrap Fee Account. The client’s Investment Advisor Representative (IAR) receives compensation when clients participate in this Wrap Fee Program. This compensation may be more than what the IAR would receive if clients participated in other programs at EPAM or paid separately for investment advice, brokerage, and other services, and the IAR may therefore have a financial incentive to recommend the Wrap Fee Program over other programs or services. Billing Method EPAM’s wrap fees are payable monthly in arrears, based on a daily accrual of fees calculated on assets under management at the end of each day of the month. Thus, fees are adjusted for contributions or withdrawals made during the month. The fair market value of the assets in the account is determined by the custodian in accordance with its standard policies and practices. In the event the custodian does not provide a value for any asset(s) in the account, those asset(s) will be valued at a market value as determined in good faith by EPAM. From time to time, due to mergers, consolidations, corporate actions, or other circumstances which require a fair value determination, EPAM does provide a fair value determination on individual securities within the Funds. While the impact to the NAV of the Fund would generally be minimal, and EPAM maintains practices and committees for managing the fair value determination process, this may nonetheless result in a potential conflict of interest. However, all recommended fair value determinations provided for the Funds are reviewed by the Fund administrator and independent board of trustees. Initial deposit or subsequent additions may be in cash or securities, provided that EPAM reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Transfers of assets into the wrap account will be liquidated by us in order to rebalance the portfolio to the intended allocation. Transferred securities may be liquidated without regard to any transaction fees, fees assessed at the mutual fund level, (i.e., contingent deferred sales charge) and/or tax ramifications. However, in most cases, any liquidation costs are absorbed by EPAM, and the Fund’s portfolio manager will pay extra attention to minimizing overall costs and transaction quality. The client should note that by signing the IMA, they have directed to have the custodian directly debit the wrap fee without any prior notice. All clients will receive account statements from the custodian no less frequently than quarterly. The custodian statement will include the deduction of the wrap fee. At our discretion, EPAM may make alternative billing arrangements for clients upon request. Cash Balances in Program Accounts In consultation with your IAR, a portion of your portfolio will be held in cash, cash equivalents, or money

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Generally, EPAM requires a minimum account size of $50,000 for accounts in our Wrap Fee Program. Accounts below this minimum may be negotiable and accepted on an individual basis at EPAM’s discretion. Clients in the Wrap Fee Program include individuals, high net worth individuals, trusts and estates, and corporations or business entities. EPAM's internal policies and procedures include documented supervisory reviews designed to evaluate both the initial and ongoing suitability of client participation in the Wrap Fee Program.

EPAM maintains an open-door policy in terms of the client’s ability to ask questions concerning their account(s) or their current investment strategy. There are no restrictions on a client’s ability to contact and consult with EPAM; however, any changes in the client’s investment objectives or financial circumstances should be communicated directly to the client’s IAR with EPAM. Our clients who receive ongoing investment management services are contacted at least annually to determine whether there have been any changes to their financial situation or investment objectives and whether they wish to impose any reasonable restrictions on the management of their account or reasonably modify any existing restrictions.

EPAM acts as the sole portfolio manager of the Wrap Fee Program and currently does not utilize any other subadvisors or portfolio managers, whereby account information for participating clients in the Wrap Fee Program would need to be communicated.

Portfolio Management EPAM functions not only as the Wrap Fee Program sponsor, but also as the portfolio manager. No outside portfolio managers are used. Since EPAM functions as the portfolio manager for the Wrap Fee Program, a conflict of interest exists because EPAM pays certain client trading costs from its fee. EPAM upholds our fiduciary duty to provide investment advice that is in our clients’ best interest, and it is the firm’s policy to always act in the best interests of our clients. Advisory Business Advisory Services Offered EPAM offers investment management and supervisory services to clients on a discretionary basis in SMAs and the Wrap Fee Program. This Wrap Fee Program brochure describes the services we provide to clients of the Wrap Fee Program and our investment and trading policies as they relate to Wrap Fee Program clients. The other services EPAM offers are described in more detail in our Form ADV Part 2A brochure, which is available upon request. When an advisory account is opened, EPAM will perform an assessment of the client’s financial information, which may include the client’s overall investment objectives, tax considerations, risk tolerance, and any investment restrictions the client may have. From there, EPAM will develop a written Investment Policy Statement (“IPS”) that reflects the client’s investment objective and performance goals for the assets to be managed, and also includes the client’s risk profile, liquidity needs, general time horizon, tax considerations, legal considerations, and any special investment circumstances (Please note: EPAM does not provide specific legal or tax related advice and clients should consult their independent tax and/or legal practitioners for such advice). The IPS is then used to implement and monitor the investments in a client’s account. Generally, EPAM believes we can best meet the financial needs of our clients by building a portfolio of investments that we believe are best suited for the economic climate and in line with each IPS. Tailored Services and Client Imposed Restrictions EPAM manages client accounts based on the investment strategy selected for the client, as discussed below under Methods of Analysis, Investment Strategies, and Risk of Loss. EPAM assists the client in selecting an investment strategy suitable for the client’s individual circumstances and financial situation. EPAM then manages the client’s account according to the selected strategy for the client. EPAM makes investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. It is important for clients to keep EPAM informed of any

changes to their investment objectives or restrictions. Our investment decisions may not be suitable if the client does not provide us with accurate and complete information. Client accounts will be invested in the Portfolio Wrap strategy we believe is most suitable for the account. Because client accounts are invested in mutual funds which own underlying securities collectively for all shareholders, clients participating in the Wrap Fee Program cannot direct us to avoid specific securities. However, clients may request other restrictions on the account such as when a client needs to keep a minimum level of cash in the account. EPAM reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Wrap Fee Program EPAM may participate in other wrap fee programs sponsored by a third-party firm. Currently, we serve as a sub-advisor to an unaffiliated sponsored wrap fee program. Client accounts under the Wrap Fee Program will generally be invested in a diversified portfolio of Euro Pacific Funds. In some circumstances, client accounts in the Wrap Fee Program may also be invested in other non-Euro Pacific Funds if the management team believes it would be in the best interests of the underlying wrap strategy. Performance-Based Fees and Side-by-Side Management EPAM does not charge performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Methods of Analysis, Investment Strategies and Risk of Loss EPAM is responsible for determining the allocation of each Portfolio Wrap strategy among various Euro Pacific Funds which represent asset classes including equity, fixed income, and alternative assets. The Portfolio Wrap strategies are designed to reflect a range of investment objectives with risk tolerance levels from Low (Portfolio 1) to High (Portfolio 5). Each client completes an investment questionnaire designed to collect information about the client’s investment objectives and risk tolerance. Based on this questionnaire, the client’s IAR will recommend a Portfolio Wrap strategy consistent with the client’s investment objectives, financial circumstances and risk tolerance. EPAM remains the primary investment manager of the client's account and is responsible for determining both the initial and ongoing suitability of the client's participation in the Wrap Fee Program and the selected Portfolio Wrap strategy. Client accounts are periodically reviewed to determine whether continued participation in the Wrap Fee Program and the selected strategy remain appropriate in light of the client's investment objectives, financial circumstances, risk tolerance, anticipated trading activity, and other relevant factors. Where appropriate, EPAM may recommend changes to a client's Portfolio Wrap strategy or, if the Wrap Fee Program is no longer appropriate, recommend another advisory program offered by EPAM. Clients should promptly notify EPAM of any material changes to their financial circumstances, investment objectives, or other information relevant to the management of their accounts so that EPAM can evaluate whether any changes to the client's investment strategy or advisory program are appropriate. EPAM is responsible for making all investment decisions concerning the investment and reinvestment of the assets in the Euro Pacific Funds in accordance with each Fund’s investment objectives and policies outlined in the Prospectus and Statement of Additional Information. Day-to-day management of the Fund is the responsibility of the Fund’s portfolio manager. For additional information about Euro Pacific Funds, the Fund Prospectus and Statement of Additional

Information are available online at www.europacificfunds.com. Investing Involves Risk The potential risks of the Wrap Fee Program are indicated in the forthcoming paragraphs in this section and in the Form ADV Part 2A Brochure of EPAM. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Investing in Foreign Securities Investing in foreign securities involves risk and deserves special considerations because of economic and social conditions abroad, political developments, and changes in the regulatory environment of foreign countries. Prices may be more volatile compared to domestic equities due to the complex landscape of international investing. In addition to macroeconomic and geopolitical factors, divergent standards governing accounting, auditing, financial reporting, disclosures, regulatory practices, restrictions on foreign ownership due to protectionism and inconsistent corporate governance rules across countries, further increase the risk for investors. However, despite the risks, we believe a diversified portfolio of domestic and foreign investments decreases overall volatility and improves risk adjusted returns over the long run. Dividend yields change as stock prices change, and companies may change or cancel dividend payments in the future. The fluctuation of foreign currency exchange rates will impact your investment returns. Past performance does not guarantee future returns; investments may increase or decrease in value, and you may gain or lose money. As a result of our buy-and-hold strategy, during those time periods when the US dollar is rising in value or when global stock markets are in decline, our portfolios may lose value priced in US dollars. Though such declines may be partially offset by dividends, investors unwilling to assume short-term volatility as a tradeoff for potential absolute long-term performance should not implement this strategy. Operational Systems/Information Security Risks Cybersecurity There are various operational systems, information security and related risks involved in investing including, but not limited to, cybersecurity’ risk. Cybersecurity attacks include electronic and non-electronic attacks that include but are not limited to gaining unauthorized access to digital systems to obtain client and financial information, compromising the integrity of systems and client data (e.g., misappropriation of assets or sensitive information), or causing operational disruption through taking systems off-line (e.g., denial of service attacks). As the use of technology has become more prevalent, we and the client accounts we manage have become potentially more susceptible to operational risks through cybersecurity attacks. These attacks in turn could cause us and client accounts (including funds) we manage to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. Similar adverse consequences could result from cybersecurity incidents affecting issuers of securities in which we invest, counterparties with which we engage in transactions, third-party service providers (e.g., a client account’s custodian), governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers and other financial institutions and parties. While cybersecurity risk management systems and business continuity plans have been developed and are designed to reduce the risks associated with these attacks, there are inherent limitations in any cybersecurity risk management system or business continuity plan, including the possibility that certain risks have not been identified. Accordingly, there is no guarantee that such efforts will succeed, especially since

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Personal Trading Code of Ethics EPAM believes that we owe clients the highest level of trust and fair dealing. As part of our fiduciary duty, we place the interests of our clients ahead of the interests of the firm and our personnel. We have adopted a Code of Ethics (the “Code”) that outlines the high standards of conduct that EPAM seeks to observe. EPAM’s personnel are required to conduct themselves with integrity at all times and follow the principles and policies detailed in our Code of Ethics. EPAM’s Code of Ethics attempts to address specific conflicts of interest that either we have identified or that could likely arise. EPAM’s personnel are required to follow guidelines from the Code in areas such as gifts and entertainment, other business activities, prohibitions of insider trading and adherence to applicable federal securities laws. EPAM will provide a copy of the Code of Ethics to any client or prospective client upon request by contacting the Chief Compliance Officer at email address mquain@europacificfunds.com. Personal Trading Practices EPAM’s advisory associates are subject to personal trading policies governed by the Code of Ethics. EPAM or our personnel may trade in securities for our/their own accounts. The securities we trade in may be the same securities we recommend to clients, or they may be securities that do not meet the criteria of our investment process, or we do not feel are appropriate for clients. We may also trade in related securities (i.e., warrants, options, or futures). Our personal trading practices present potential conflicts of interests as we may have an incentive to take investment opportunities from clients for our own benefit, favor our personal accounts over client accounts when allocating trades or use the information about the transactions we intend to make for clients for our personal benefit by trading ahead of clients (also known as “front running”). Our policies to address these conflicts include the following: 1. We seek to always put the best interests of our clients first and to never place our interests ahead of clients; 2. EPAM prohibits trading in a manner that takes personal advantage of our knowledge of client transactions;

3. EPAM personnel must request pre-clearance from our CCO if they wish to purchase or sell a security already owned by clients or that the individual is aware it is being considered for purchase or sale by EPAM on behalf of clients. Direct obligations of the US government, some short-term debt securities and CDs, money market funds and certain mutual funds do not need to be pre-cleared; 4. Conflicts of interest also may arise when EPAM personnel have access to limited offerings or IPOs, including private placements or public or private offerings of interests in limited partnerships or any thinly traded securities, as a result of their position with EPAM. Given the inherent potential for conflict in connection with limited offerings and IPOs, EPAM personnel are required to obtain pre-approval from our CCO before trading in these types of securities; and 5. Because these policies are intended to protect the interests of clients, we may make exceptions where we feel clients would not be harmed.

Aggregation with Client Orders EPAM may aggregate orders for clients in the same securities in an effort to seek best execution, negotiate more favorable commission rates and/or allocate differences in prices, commissions, and other transaction costs equitably among our clients. When aggregating such orders, EPAM will observe the following procedures: 1. We disclose our aggregation policies in our Form ADV Part 2A brochure; 2. We will not aggregate transactions unless we believe that aggregation is consistent with our duty to seek best execution for our clients; 3. No client account will be favored over any other client account within a trading block; 4. Each account in the aggregated transaction will participate at the average share price for all of the transactions included in the block; 5. Accounts will share in the transaction costs on a pro-rata basis; 6. At the time a trade is modelled an allocation key is created in EPAM’s trade order management system, recording how the trade is allocated; 7. If aggregated order is filled in its entirety, then it will be allocated in accordance with original allocation trade model; 8. If we determine that a pro-rata allocation is not appropriate under the particular circumstances, we may allocate the order on a different basis if all client accounts receive fair and equitable treatment. For example, if the ticket charges are too high to allocate pro-rata, we may allocate on a least-tickets basis; 9. Our books and records will separately reflect each aggregated order and the securities held by, bought and sold for each client account; 10. We do not receive additional compensation or remuneration of any kind as a result of aggregating orders; and 11. We will provide individual investment advice and treatment to each client’s account.

Participation or Interest in Client Transactions The following items represent situations where a conflict of interests may exist between the client and EPAM and our personnel. Principal Transactions There may be times when EPAM feels it is in the best interest of certain clients to execute a riskless principal transaction. We only consider principal transactions when a clear benefit exists to the client and never for the sole benefit of EPAM. One advantage of principal transactions is the ability to narrow spreads on thinly traded positions, potentially receiving more favorable pricing on both sides than the market currently offers. In addition, principal transactions can provide greater liquidity for clients than may have existed otherwise.

Potential conflicts that can exist when conducting principal transactions include the incentive to favor proprietary accounts when establishing pricing or to dispose of underperforming assets from proprietary portfolios and other abuses in the absence of full market disclosure. In advance of any principal transaction, we would provide participating clients with important details of the proposed trade and obtain the client’s consent. Cross Transactions There may be times when EPAM feels it is in the best interest of clients to perform internal crosstransactions (i.e., where EPAM, acting as advisor, sells a security from one advisory account to another advisory account, but does not receive any type of commission or other fee, other than our regular management fee). Agency cross transactions pose a conflict of interest between the interests of EPAM and our clients. Our practice is to engage in these types of transactions in very limited circumstances, and we will only perform cross-transactions when the proposed transaction is in the best interests of both clients and cross trade is appropriate based on each client’s investment objectives and guidelines. Internal cross transactions prevent market impact (potentially lower price) on a sale transaction and allow potential price improvement on a purchase. In effect, the price sold, and the price paid as part of the “cross” is at a better price (bid/ask) than would be achievable if the security is sold to the market and then re-purchased. We will provide details pertaining to all cross trades to participating clients prior to or promptly following each crossed transaction. We will request client consent and provide applicable disclosures any time we engage in agency cross transactions. Where a cross trade involves a Euro Pacific Fund, EPAM will follow the procedures adopted pursuant to Rule 17a-7 under the Investment Company Act of 1940, as amended. Review of Accounts Client Accounts are reviewed on an ongoing basis to ensure their conformity with each client’s IPS. The review process is based on a variety of factors, which include but are not limited to: the client’s investment objectives, the economic environment, outlook for the securities markets and the merits of the securities in which the accounts are invested. Reviews of client accounts are performed by EPAM’s Portfolio Manager. These reviews include consideration of whether each client's selected Portfolio Wrap strategy continues to be appropriate based on the client's investment objectives, financial circumstances, risk tolerance and any material changes communicated by the client. Clients are provided quarterly reports showing the assets held and the value of the account as of the end of each quarter. In addition, these clients receive statements from their custodian, at least quarterly, showing all transactions effected in the account during the quarter, the amount of funds, and each security held in the account at the end of each quarter. Client Referrals and Other Compensation Support Products and Services We receive an economic benefit from the client’s custodian in the form of the support products and services they make available to us and other independent investment advisors whose clients maintain their accounts at the custodian. The custodian may provide EPAM with access to their institutional trading and custody services, which are typically not available to retail investors. These services are generally available to independent investment advisors on an unsolicited basis at no charge to them, so long as the advisor maintains a minimum amount of its clients’ assets in accounts with the custodian. Services provided by the custodian also include but are not limited to brokerage, custody, research and access to certain mutual funds and other investments that may not otherwise be available to non-institutional investors or would require a significantly higher minimum initial investment. Generally, the custodian either does not charge separately

for custody or provides a discount on custodial services, because it is compensated by account holders through commissions or other transaction-related fees for security trades that are executed through the custodian. The custodian may also make available to EPAM other products and services that benefit EPAM but may not directly benefit our clients’ accounts. Some of these other products and services may assist EPAM in managing and administering client accounts. These may include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitation of trade execution (and allocation of aggregated trade orders for multiple client accounts), providing research pricing information and other market data and assisting with back-office functions, recordkeeping, and client reporting. Many of these services may be used to service all or a substantial number of EPAM’s accounts, including accounts not maintained by the custodian providing the services. The custodian may also make available to EPAM other services intended to help EPAM manage and further develop our business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. In addition, the custodian may make available, arrange and/or pay for these types of services rendered to EPAM by other independent third parties. Due to the fact that EPAM does not directly pay for these services, including any research received, it may be construed as receipt of an economic benefit by EPAM, and therefore, a conflict of interest between EPAM and the client. We do not base particular investment advice, such as buying particular securities for our clients, on the availability of the custodian’s products and services to us. Referral Arrangements EPAM may pay a share of its management fees for client referrals to authorized persons or entities as permitted under the Investment Advisers Act of 1940, and applicable marketing requirements. Fees will not be paid to referrers where not allowed by relevant state regulations. The referral fee will be paid pursuant to a written agreement between EPAM and the referral agent. A statement of the arrangement will be provided to such clients prior to or at the time of entering into any investment management agreement, and their written authorization is required to pay the referral fee. Such fee splits would not increase the fee amount a client would pay to EPAM. EPAM does not currently have any paid referral arrangements.

Registered investment advisors are required to provide clients with certain financial information or disclosures about the firm’s financial condition. EPAM does not require the prepayment of more than $1,200 in fees per client six months or more in advance. Further, EPAM does not have or foresee any financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients and has not been the subject of a bankruptcy proceeding.

Disciplinary Information Peter Schiff, a control person of EPAM, has been named as a defendant in a civil action filed in September 2025 in the United States District Court for the District of Puerto Rico. The complaint alleges that he participated in a scheme to misappropriate approximately $50 million in assets associated with an international bank. The alleged conduct is unrelated to EPAM’s business or its clients. Mr. Schiff denies the allegations and has filed a motion to dismiss the complaint. The matter is currently pending, and no findings have been made by the court." Any other disclosures regarding our advisory associates or related investment advisory firms not required under this Item would be contained in the Form ADV Part 2B supplement for the individual, or the Form ADV Part 2A brochure of the related firm. These documents are provided separately to clients where required. Other Financial Industry Activities and Affiliations Adrian Day Asset Management EPAM and Global Strategic Management Inc., d/b/a Adrian Day Asset Management (“ADAM”) have a Services Agreement. Under the Services Agreement, EPAM provides operational and compliance services to ADAM. For additional information about ADAM, please see Section 7.A. “Financial Industry Affiliations” of Schedule D in ADV Part 1. Other Related Businesses Peter Schiff Schiff Gold, LLC PDS Trust, an affiliate of Peter Schiff (EPAM’s majority owner), is the sole owner of Schiff Gold, LLC (“Schiff Gold”), a precious metals dealer. Under a written consulting agreement, EPAM provides marketing and consulting services to Schiff Gold — principally through Mr. Schiff’s public media activities, such as his podcasts and social-media commentary, in which he promotes Schiff Gold to the general public. For these services, EPAM receives a consulting fee calculated as 50% of Schiff Gold’s distributable income, subject to a transfer-pricing adjustment. Because EPAM’s compensation increases with Schiff Gold’s income, EPAM and its principals — including Mr. Schiff — benefit financially when anyone, including an EPAM advisory client, purchases precious metals from Schiff Gold. This is a conflict of interest: it could create a financial incentive. For EPAM or its personnel, consciously or unconsciously, to favor commentary or recommendations concerning gold and other precious metals. EPAM’s advisory practice operates separately from Schiff Gold. In providing investment advice, EPAM does not recommend that clients purchase precious metals from Schiff Gold, does not direct or execute client transactions through Schiff Gold, and does not share client information with Schiff Gold or market Schiff Gold through communications directed to EPAM’s advisory clients. Neither firm pays the other for client referrals, and EPAM receives no compensation, referral fees, or other economic benefit in connection with any client’s decision to transact with Schiff Gold. Clients are under no obligation to do business with Schiff Gold; any purchase a client chooses to make from Schiff Gold is solely between the client and Schiff Gold and is not

reviewed or supervised by EPAM, although EPAM benefits indirectly as described above. EPAM addresses this conflict of interest by: disclosing it in this brochure and in separate written disclosures provided to clients; not marketing or promoting Schiff Gold through channels directed to EPAM’s advisory clients; requiring, under the consulting agreement, that materials prepared by or on behalf of EPAM in connection with the agreement that reference EPAM or its advisory services be submitted to EPAM’s Chief Compliance Officer for review prior to use; and conducting documented periodic compliance review of public media content that references EPAM’s advisory services or the Schiff Gold relationship under EPAM’s compliance policies. Ventum Financial (Formerly Echelon Wealth Partners) Mr. Schiff owns a minority interest (currently less than 10 percent) in Ventum, which EPAM serves as subadvisor to its Separately Managed Accounts. This relationship creates a potential conflict of interest because EPAM has a financial incentive in its relationship with an entity in which a control person has an ownership interest. EPAM addresses this conflict by conducting the relationship on an arm’s-length basis and through its overall compliance framework, which is designed to ensure that the relationship does not influence EPAM’s provision of services. Schiff Sovereign Mr. Schiff is a co-founder of Schiff Sovereign, an investment newsletter service focused on the economy, investing, and other topics. This activity is conducted independently of the EPAM. The newsletter does not provide personalized investment advice to EPAM’s clients, and EPAM does not rely on or incorporate the newsletter’s content in providing advisory services. This arrangement creates a potential conflict of interest to the extent that the control person’s external activities could give rise to perceived or actual differences between publicly available commentary and EPAM’s investment approach. EPAM addresses this potential conflict through its overall compliance framework, including controls designed to prevent the misuse of information and to ensure that client portfolios are managed independently of such external activities. Dual Employee Adrian Day, Portfolio Manager of EPGFX and gold separately managed accounts at EPAM, is also an employee of ADAM, serving as Chairman and Chief Executive Officer and is responsible for the day-to-day management of ADAM client portfolios. Because Mr. Day is serving as portfolio manager for two separate firms, he may have an incentive to favor one group of clients over another. EPAM has identified this potential conflict of interest and has implemented internal controls to monitor and mitigate this potential risk. Mr. Day, as an employee of both firms, allocates his time as needed for each entity. Mark Ishkanian serves as an Investment Advisor Representative for EPAM. He also serves as an Investment Advisor Representative for ADAM, a Registered Investment Adviser, as a part-time employee. Because Mr. Ishkanian is serving two separate firms, he may have an incentive to favor one group of clients over another. EPAM has identified this potential conflict of interest and has implemented internal controls to monitor and mitigate this potential risk. In addition, EPAM shares office space with ADAM, which is subject to an agreement of confidentiality setting forth restrictions on the use, dissemination, and disclosure of any confidential information exchanged between the firms, whether directly or indirectly. Dual Chief Compliance Officer Michael Quain, EPAM’s Chief Compliance Officer (“CCO”), is also the CCO of ADAM, as well as an unrelated registered investment company. Mr. Quain allocates time as needed for each entity.

Other Related Businesses to this Adviser and Possible Conflicts of Interests The fact that EPAM serves as an advisor to its own SMAs and the Wrap Fee Program, and as a sub-advisor to AGP’s separately managed accounts and its Wrap Fee Program, causes an inherent conflict of interest in that EPAM could favor one group of clients over another. For example, EPAM could trade or make changes to one group of portfolios and not to the other. However, as mentioned above, EPAM has developed a Compliance Program designed to monitor our adherence to our fiduciary duties as your advisor. The two wrap programs are diligently managed according to the strategy laid out in the investment documents; however, clients should understand that EPAM accounts are custodied with Interactive Brokers, Inc., and AGP accounts are custodied with National Financial Services, LLC. Due to the differing custodians, fees, and market access, trading in one wrap fee program will not closely mirror trading of another wrap fee program. Other than what is previously discussed in Item 9 above, EPAM does not have any other related businesses.