Grandeur Peak Global Advisors, LLC

Our Firm: Grandeur Peak Global Advisors, LLC (“Grandeur Peak Global”) was founded on July 1, 2011 by Robert Gardiner, Blake Walker, and Eric Huefner. The firm is headquartered in Salt Lake City, Utah. It is a privately held limited liability company, and is a wholly-owned subsidiary of Grandeur Peak Global Holdings, LLC (“GPGH”). Grandeur Peak Global is registered as an investment adviser with the SEC. Our Advisory Services: Grandeur Peak Global provides discretionary investment management services to the Grandeur Peak Funds, a family of no-load mutual funds that are part of the Grandeur Peak Global Trust (“GPGT”), a series trust. There are currently ten mutual funds in the Grandeur Peak fund family (together the “Grandeur Peak Funds”): • • • • • • • • • •

Grandeur Peak Emerging Markets Opportunities Fund Grandeur Peak Global Contrarian Fund Grandeur Peak Global Explorer Fund Grandeur Peak Global Micro Cap Fund Grandeur Peak Global Opportunities Fund Grandeur Peak Global Reach Fund Grandeur Peak Global Stalwarts Fund Grandeur Peak International Opportunities Fund Grandeur Peak International Stalwarts Fund Grandeur Peak US Stalwarts Fund

Each fund is more fully described in the Grandeur Peak Funds Prospectus available online at www.grandeurpeakglobal.com or www.sec.gov. Grandeur Peak Global currently provides investment management services in the Global Opportunities and International Stalwarts strategies to accredited investors through private investment funds. There may be other private funds in the future (together the “Grandeur Peak LPs”). Each private investment fund is more fully described in the offering documents provided to investors. Grandeur Peak Global also offers similar investment management services in the Global Stalwarts, International Stalwarts, International Opportunities, and Global Reach strategies to certain accredited investors through separately managed accounts (together the “Grandeur Peak SMAs”). Each of the Grandeur Peak SMAs is governed by an investment management agreement between Grandeur Peak Global and the client. The Grandeur Peak Funds, the Grandeur Peak LPs, and the Grandeur Peak SMAs are together referred to each as a “Portfolio” and together as the “Portfolios.” Item 8 provides more information about our investment strategy.

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Grandeur Peak Global offers advisory services from time-to-time, including general market advice and its analysis of companies, to certain unaffiliated private fund advisers. Grandeur Peak Global does not provide financial planning services, nor does Grandeur Peak Global advise clients in the selection of other investments that it does not manage. Tailoring Our Services: Grandeur Peak Global does not tailor its services to the individual needs of shareholders or investors in the Grandeur Peak Funds or Grandeur Peak LPs. All shareholders in the Grandeur Peak Funds are shareholders in a common mutual fund and as such cannot impose restrictions on investing in certain securities. All investors in the Grandeur Peak LPs are limited partners in a pooled investment vehicle and as such are not able to individually impose restrictions on investing in certain securities. The Grandeur Peak SMAs are managed in a similar style to their respective Grandeur Peak Fund strategy, although variations exist. The principal variations result from specific guidelines and restrictions placed on separate account portfolios by clients. Restrictions on the management of the account must be mutually agreed upon by Grandeur Peak Global and the client. Clients who place restrictions, including restrictions as to types of securities, concentrations, countries, cash balances, brokers to be used or not used, etc. should recognize that the performance of their account(s) may not be consistent with the performance of other accounts managed in the same or similar strategy. Assets Under Management: As of December 31, 2025, Grandeur Peak Global had $3.802 billion in assets under management. All of these assets were discretionary assets. Services Grandeur Peak Global Does Not Typically Provide: When Grandeur Peak Global takes significant positions in an issuer, Grandeur Peak Global is required to file reports with issuers and regulators around the globe regarding its clients’ holdings of the issuer. Those reports are often made available to the public and at times require disclosure to the public of a client’s identity and holdings. While Grandeur Peak Global monitors holdings of its clients on an aggregate basis, and makes regulatory filings (around the globe) as required based on the aggregate holdings of the Portfolios, Grandeur Peak Global does not monitor or advise its Grandeur Peak SMA clients on individual reporting requirements they may have. Grandeur Peak Global does not file class action claims for Grandeur Peak SMA clients. If Grandeur Peak Global receives class action information, we will make a good faith effort to share such information with the applicable Grandeur Peak SMA clients or client custodians based on the client’s management agreement.

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Mutual Funds: Grandeur Peak Global receives fees from the Grandeur Peak Funds based on the average daily net assets under management in each Fund as follows: Fund Name Emerging Markets Opportunities Fund Global Contrarian Fund Global Explorer Fund Global Micro Cap Fund Global Opportunities Fund Global Reach Fund Global Stalwarts Fund International Opportunities Fund International Stalwarts Funds US Stalwarts Fund

Annual Fee Rate 1.35%* 1.00% 0.80% 1.50% 1.25%* 1.10% 0.80% 1.25%* 0.80% 0.75%

*Through at least September 1, 2026, thirty-five basis points (0.35%) of the fees are waived on assets in excess of $400 million for the Emerging Markets Opportunities Fund and twenty-five basis points (0.25%) of the fees are waived on assets in excess of $500 million for the Global Opportunities and International Opportunities Funds.

The fees received by Grandeur Peak Global as a service provider to the Grandeur Peak Funds, as well as fees paid to other service providers by the Grandeur Peak Funds (e.g. custody, administration, transfer agent, accounting, legal, etc.), are described in detail in the registration statement and/or financial filings of those funds. The fees are accrued on a daily basis and deducted directly from the Grandeur Peak Funds. They are paid to the advisor on a monthly basis. Extraordinary expenses, if any, are also borne by Grandeur Peak Funds shareholders. Some of the Grandeur Peak Funds have two share classes, an Investor class and an Institutional class. Shareholders in the Investor share class pay a 12b-1 fee at an annual rate of 0.25% of average daily net assets. Such fee is paid to the Grandeur Peak Funds’ distributor, Northern Lights Distributors, LLC (“NLD”). NLD is not affiliated with Grandeur Peak Global. NLD uses these fees to pay for distribution and shareholder services, such as compensation to broker-dealers selling Fund shares. There is no 12b1 fee on the Institutional class of shares. The Grandeur Peak Funds incur brokerage, foreign exchange, custodial, and administrative expenses separate from the fees described above. Item 12 provides additional detail of our brokerage practices. Individual shareholders may also be charged wire fees, returned check fees, short-term redemption fees, and other shareholder fees.

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Private Investment Funds (“LPs”): The Grandeur Peak LPs are private investment funds managed by Grandeur Peak Global in the Global Opportunities and International Stalwarts investment strategies. The management fee is paid monthly by the limited partners based on assets under management of each limited partner. The fee is deducted from each limited partner’s capital account at the rates shown below: • •

Global Opportunities: an annual rate of 1.25% on the first $200 million in collective assets, and 1.05% on collective assets above $200 million. International Stalwarts: an annual rate of 0.85%.

This fee covers the Grandeur Peak Global investment advisory fee as well as normal custody, administration, legal, tax, and audit expenses for each Grandeur Peak LP. There is no negotiation of fees, or side letters. Seed investors in the Grandeur Peak LP in the International Stalwarts strategy were given a five basis point (0.05%) reduction in fee. The Grandeur Peak LPs incur brokerage and foreign exchange costs separate from these fees. Item 12 provides additional detail of our brokerage practices. Extraordinary expenses are borne by the limited partners as an additional expense. Separately Managed Accounts (“SMAs”): Grandeur Peak Global advises SMAs based on the Global Stalwarts, International Stalwarts, International Opportunities, and Global Reach strategies. The management fee is paid quarterly in arrears by each SMA client based on assets under management, and is pro-rated for partial quarters. Depending on the agreement between Grandeur Peak Global and its client, the fee may be paid independently by the client or deducted directly from the client’s account. The management fee for the International Opportunities offering is at an annual rate of 1.15% on the first $60M and 0.90% on assets above $60M. The management fee for the Global Stalwarts and International Stalwarts offerings is at an annual rate of 0.70%. Fee discounts on each of those strategies are available to clients who meet either, or both, of the following requirements: a) five basis points (0.05%) fee reduction for being the initial SMA client in a specific strategy, or investing within six months of the initial SMA client in a specific strategy, and b) five basis points (0.05%) fee reduction for accounts with a net capital contribution above $150M. The management fee for the Global Reach offering is at an annual rate of 0.90%, with a five basis points (0.05%) fee reduction for being an initial SMA client in the strategy. The management fees described above are Grandeur Peak Global’s standard fees; however, Grandeur Peak Global has agreed to performance fee structures with certain SMA clients. These clients are large institutions who have invested significant assets (generally more than $150mm each) in their SMA accounts. The performance fees are unique to each client and negotiated individually. In general, these arrangements consist of a below‑market base management fee and a performance‑based fee that is Page | 7

payable only if the account’s performance exceeds an agreed‑upon benchmark over a defined performance period. While these arrangements share similar structural features, the base management fee, performance period, benchmark, and the use of any hurdle rate are individually negotiated and vary by client. The specific details of each client’s performance fee arrangement are set forth in the applicable client’s investment management agreement. The management fees described above only cover the Grandeur Peak Global investment advisory services. The Grandeur Peak SMAs incur brokerage, foreign exchange, custodial, and other expenses separate from the fees described. Item 12 provides additional detail of our brokerage practices. Clients who direct their custodian to use a sweep or other interest-bearing account for cash in their Grandeur Peak Global account, including a money market fund or other such fund, likely pay two management fees on that cash, one to the manager of the cash fund and one to Grandeur Peak Global. Other Services: Grandeur Peak Global may consult with certain unaffiliated private fund advisers from time-to-time on topics that may include general market views and analysis of certain companies. While Grandeur Peak Global does not charge or receive any fees in exchange for such consultations, Grandeur Peak Global receives a reduced carried interest rate with respect to its investment for its own account in at least one private fund advised by a private fund adviser. Affiliated Broker-Dealer: Grandeur Peak Global does not have an affiliated brokerdealer and does not receive a commission attributable to the sale of a security or other investment product, including shares of the Grandeur Peak Funds and the Grandeur Peak LPs.

Investing in securities involves risk of loss that clients should understand and be prepared to bear. Please read offering documents carefully before investing. We use a process of quantitative screening followed by fundamental analysis to identify individual companies domiciled throughout the world which we believe have above average return potential over the next 5+ years. Our team talks with management and travels extensively to visit companies globally (as deemed appropriate by the firm based on health and safety considerations). We do not use allocation models to restrict Page | 9

investments to certain regions, countries, or industries. We may significantly shift assets between asset classes, sectors, and geographic regions based on where we believe the best opportunities and valuations currently exist. Our primary focus is on publicly traded micro to mid-cap companies ($50M - $10B in market capitalization), but we purchase securities of smaller and larger cap companies as well. Our favorite companies are best-in-class growth companies. We also look for “fallen angel” companies. These are growth companies that have hit a bump in the road, but which we believe can regain their footing and return to growth. Our Global Contrarian strategy also purchases companies that we believe are currently out of favor due to their industry, geography, or for other reasons, and therefore selling at particularly interesting value relative to their long-term potential. The Portfolios are invested in companies domiciled in developed, emerging, and frontier markets. The Portfolios may also invest in early stage companies, initial public offerings (IPOs), private investments in public equities (PIPEs), 144A offerings, and other forms of securities relevant to the investment objectives of each strategy. The Portfolios do not currently use leverage. At times we have, and may again in the future, purchase securities of companies for the Portfolios which are also owned by private funds which we advise and/or invest in for our own account. We may also purchase securities issued in connection with a company’s initial public offering (“IPO”) where private funds in which we invest for our own account may be selling shareholders in such IPOs. These situations present a conflict of interest for Grandeur Peak Global since the decision to purchase those securities for the Portfolios could also affect the performance of our own investments in such private funds. However, we do not have the contractual ability to exercise any control or influence over the investment decisions of the private funds in which we invest for our own account, and we further mitigate the potential conflict by evaluating each potential investment by the Portfolios on its own merit, by adherence to our Trade Allocation Policy, and by oversight of our Trade Compliance Committee. The investment strategies summarized above represent our current intentions, are general in nature and are not exhaustive. We have broad flexibility in the types of securities we may purchase on behalf of the Portfolios, the size of positions that we may take, the concentration of the Portfolios’ investments and/or the amount of leverage that they may use. We may use other trading or investment techniques, whether or not contemplated by the expected investment strategies described above. In addition, there are limitations in describing any investment strategy due to its complexity, confidentiality and indefinite nature. Depending on conditions and trends in securities and commodities markets and the economy generally, we may pursue other objectives or use other techniques that we consider appropriate and in the clients’ interest.

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Risks: Investing in securities involves risk of loss that clients should be prepared to bear. Below are some of the risks (in alphabetical order) that investors should consider before investing in any Portfolio that we manage. Any or all such risks could materially and adversely affect investment performance, the value of any Portfolio or any security held in any Portfolio, and could cause investors to lose substantial amounts of money. Below is only a brief summary of some of the risks that an investor could encounter. Potential investors should review offering materials and management agreements carefully and in their entirety, and consult with their professional advisers, before deciding whether to invest. ADR Risk. ADRs involve risks similar to those associated with investments in foreign securities. ADRs listed on U.S. exchanges are issued by banks or trust companies, and entitle the holder to all dividends and capital gains that are paid out on the underlying foreign shares. Investments in ADRs that provide exposure to non-U.S. securities involve certain risks that may not be present with investments in U.S. securities. Investments in ADRs also may be subject to withholding or other taxes and may be indirectly subject to additional trading, settlement, custodial, and operational risks. These and other factors can make investments in the Fund more volatile and potentially less liquid than other types of investments. Artificial Intelligence Risk. Grandeur Peak Global may utilize artificial intelligence, machine learning, or similar technologies provided by third parties in connection with research or operational processes, which may rely on imperfect data, models, or assumptions. Although investment decisions are made by Portfolio Managers exercising independent judgment and oversight, the use of such technologies involves risks. The risks include errors, biases, cybersecurity vulnerabilities, regulatory uncertainty, or unintended outcomes, which could adversely affect investment decisions or operational processes. Business Continuity and Operational Resilience Risk. Grandeur Peak Global’s business operations depend on the effective functioning of its personnel, systems, facility, and third‑party service providers, all of which may be disrupted by natural disasters, public health emergencies, geopolitical events, technology failures, or other unforeseen circumstances. Although Grandeur Peak Global maintains business continuity and disaster recovery plans, disruptions (particularly those affecting third‑party service providers) could impair investment activities, client communications, or transaction processing and may result in delays, losses, or other adverse effects on client accounts. Currency Risk. The U.S. dollar value of a Portfolio’s assets will be affected by foreign currency exchange rates and may be affected by exchange control regulations. A change in the value of any foreign currency will change the U.S. dollar value of a Portfolio’s assets that are denominated or traded in that country. In addition, a Portfolio may incur costs in connection with conversions between various currencies. Currency exchange rates can be volatile and are affected by factors such as general economic Page | 11

conditions, the actions of the U.S. and foreign governments or central banks, or the imposition of currency controls and speculation. A risk of not hedging currencies is that if the U.S. dollar strengthens, returns from foreign markets will be less when converted into U.S. dollars. Cybersecurity Risk. As the use of technology has become more prevalent in the ordinary course of business, companies have generally become potentially more susceptible to operational and other risks through breaches in cybersecurity. Cybersecurity attacks or incidents can result from intentional and unintentional acts or events that cause misappropriation of assets or sensitive information, corruption of data, or operational disruption. Such acts or events could cause a client, the Portfolios and/or Grandeur Peak Global to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss or other damages. Cybersecurity breaches may involve unauthorized access to digital information systems or inadvertent or intentional release of confidential or proprietary information stored on our systems. In addition, cybersecurity breaches of third-party service providers (such as administrators, transfer agents, and custodians) can also subject Grandeur Peak Global and/or the Portfolios to many of the same risks associated with direct cybersecurity breaches. There is no guarantee that cybersecurity acts or events can be fully avoided or prevented, especially because Grandeur Peak Global does not directly control the cybersecurity systems of any third party, or that the Portfolios will not be harmed as a result of cyber-attacks or similar issues. Derivatives Risk. Some of the Portfolios may invest in derivatives, which involves risks different from, or greater than, the risks associated with investing in more traditional investments. Derivatives may not perform as anticipated, may not be closed out at a favorable time or price, may increase volatility in the Portfolio, may create investment leverage, may be difficult to value, may be highly illiquid, and there may be risk that the other party in the derivative contract will fail to make required payments or comply with the terms. Early-Stage Companies Risk. Early-stage companies may never obtain necessary financing, may rely on untested business plans, may not be successful in developing markets for their products or services, and may remain an insignificant part of their industry, and as such may never be profitable. Stocks of early-stage companies may be less liquid, privately traded, and more volatile and speculative than the securities of larger companies. Emerging and Frontier Markets Risk. In addition to the risks of investing in foreign securities in general, the risks of investing in the securities of companies located in or with exposure to emerging and frontier market countries include increased political or social instability, economies based on only a few industries, unstable currencies, runaway inflation, highly volatile securities markets, unpredictable shifts in policies relating to foreign investments, less developed legal, regulatory, tax, and accounting systems, lack of protection for investors against parties who fail to complete transactions, and the potential for government seizure of assets or nationalization of Page | 12

companies. Securities of issuers actually located in emerging or frontier markets may be susceptible to greater custodial and operational risks and may be substantially less liquid. Epidemic Risks. The impact of epidemics and pandemics that may arise in the future could negatively impact the economies of nations, individual companies, their securities (including equity and debt), and the market in general in ways that cannot necessarily be foreseen or predicted. In addition, the impact of infectious diseases in developing or emerging market countries may be greater due to less established health care systems. Health crises may exacerbate other preexisting political, social and economic risks in certain countries. The impact of an outbreak may be short term or may last for an extended period of time. ESG Considerations Risk. The consideration of environmental, social and governance (ESG) factors in evaluating and making investments by the Portfolios could result in selling or avoiding investments that subsequently perform well or purchasing investments that subsequently underperform. In addition, while we do intend to vote proxies based on the fundamental premise of attempting to maximize the value of our investments for the benefit of our clients with a bias towards long-term value over shortterm value, to the extent Grandeur Peak Global takes ESG factors into account when voting proxies, doing so may not always be consistent with maximizing performance of the issuer or the Portfolio holding such issuer’s securities over any particular period of time. Financial System Risk. Regional, national and global financial and capital systems are interrelated, and a disruption or failure of one or more banks or financial service providers, even on a local or regional basis, may lead to systemic pressures on the availability of capital as well as consumer and commercial confidence. This could materially and adversely impact markets and the performance and valuation of individual companies and their securities, and consequently the Portfolios (or any of them). These risks are amplified by the decentralized nature of the financial and banking system, which is largely subject to local or national regulation and oversight. Foreign Country Exposure Risk. A Portfolio may have exposure to foreign countries as a result of investments in domestic companies with foreign exposure. This includes possible exposure to emerging and frontier countries. To the extent a Portfolio invests in securities of companies with exposure to foreign markets, including in emerging and frontier countries, such investments would be subject to the same risks as a direct investment in such markets and countries. Such risks may impact the stock valuation of companies with foreign exposure. Foreign Securities and Foreign Markets Risk. Foreign securities are generally more volatile and less liquid than U.S. securities. Further, foreign securities may be subject to additional risks not associated with investment in U.S. securities due to differences in the economic and political environment, the amount of available public information, the degree of market regulation, and financial reporting, accounting and auditing standards, Page | 13

Read the rest in the brochure

Grandeur Peak Global provides investment management services to registered investment companies (the Grandeur Peak Funds), private pooled investment vehicles (the Grandeur Peak LPs), and accredited investors (the Grandeur Peak SMAs). Investors within these investment vehicles may now, or in the future, include individuals, trusts, financial advisers, corporations, charitable institutions, foundations, endowments, municipalities, registered investment companies, private investment funds, and other entities. Grandeur Peak Global offers certain non-investment advisory services from time-totime, including consultation regarding general market views and analysis of companies, to certain unaffiliated private fund advisers. Some of the Grandeur Peak Funds have two share classes, an Investor Class and an Institutional Class. Both share classes have a minimum investment of $1,000 ($100 for UTMA accounts). The Grandeur Peak LPs have a minimum investment of $10 million. The Grandeur Peak SMAs have a minimum investment of $50 million. The minimums can be waived by Grandeur Peak Global under certain circumstances.

Grandeur Peak Global manages side-by-side accounts in the Global Stalwarts strategy, the International Opportunities strategy, the International Stalwarts strategy, the Global Reach strategy, and may do so in other strategies similar to other Grandeur Peak Funds in the future. The net fee received by Grandeur Peak Global from the mutual funds, the LPs, and SMAs in a common strategy are generally intended to be similar to each other, but vary based on expenses, assets under management, and other factors. There is a conflict of interest when Grandeur Peak Global receives a higher fee from one of the clients in the same strategy, in which case Grandeur Peak Global could be incentivized to direct better investments to the client with the higher fee. As noted in Item 5, Grandeur Peak Global has entered into performance-based fee arrangements with two separate account clients. Such performance-based fee arrangements create a conflict of interest for Grandeur Peak Global because we would Page | 8

have an incentive to prefer a performance-fee SMA over a flat-fee SMA for better investments due to the additional fees that might be earned. Clients with higher fees or performance-based fees create an incentive for Grandeur Peak Global to recommend investments to the accounts which may be riskier or more speculative than those we might recommend under a different fee arrangement. To mitigate these potential conflicts, Grandeur Peak Global manages Portfolios within the same general strategy by reference to a model portfolio and allocates partially filled trades consistent with the Grandeur Peak Global Trade Allocation Policy, which has been specifically designed to be unbiased across Portfolios. These policies are described in more detail in Item 12. However, despite our best efforts, it is possible that in certain transactions you may be advantaged or disadvantaged as we attempt to manage conflicts and treat all clients fairly.

Grandeur Peak Global is not registered as a broker-dealer, nor is it affiliated with a broker-dealer. As noted in Item 5 above, the Grandeur Peak Funds are distributed by NLD, which is a registered broker-dealer. Certain employees of Grandeur Peak Global are registered representatives of NLD, which holds the securities licenses of such Page | 17

employees. One of these individuals, Eric Huefner, is the President of Grandeur Peak Global. Grandeur Peak Global serves as investment adviser to Grandeur Peak Global Trust, an unaffiliated statutory trust that houses the Grandeur Peak Funds. A significant portion of Grandeur Peak Global’s revenues each year comes from the Grandeur Peak Funds and so a potential conflict could arise if Grandeur Peak Global preferred the Grandeur Peak Funds over other Grandeur Peak Global clients. Grandeur Peak Global serves as the General Partner of the Grandeur Peak LPs. Grandeur Peak Global conducts business in Canada but avails itself of various exemptions from registration as a foreign investment adviser in the provinces where its clients are located. Grandeur Peak Global has invested for its own account in unaffiliated private funds that acquire securities of private companies and may invest in other such funds in the future. Grandeur Peak Global’s holding company, GPGH, has a separate subsidiary, Grandeur Partnership Capital (“GPC”), which was formed with the intent of investing the assets of GPGH for its own account in primarily small, private investment opportunities. Prior to any such investment by GPC or GPGH, the opportunities are reviewed by the directors and Chief Compliance Officer (“CCO”) of Grandeur Peak Global and determined not to be suitable for the Grandeur Peak Portfolios or Grandeur Peak clients for one or more of the following reasons: (1) the investment opportunity is considered too small for the Grandeur Peak Portfolios, (2) the investment opportunity is illiquid or significantly less liquid than is appropriate and/or required by the Grandeur Peak Portfolios, (3) the nature of the investment is not suitable for a Grandeur Peak Portfolio (for example, an investment in a local real estate asset), (4) the entity into which the investment will be made is offering the investment only to certain types of investors that does not include the Grandeur Peak Portfolios, or (5) other reasonable considerations that render the investment opportunity unsuitable for a Grandeur Peak Portfolio as determined in good faith by the directors and CCO of Grandeur Peak Global. Grandeur Peak Global’s affiliation with GPC may present a conflict of interest as Grandeur Peak Global and its owners may be motivated to direct an investment opportunity to GPC or GPGH rather than making that investment opportunity available to the Grandeur Peak Portfolios. Grandeur Peak Global mitigates this conflict by requiring that (a) each investment opportunity that may be referred to GPC or GPGH by Grandeur Peak Global or any of its Employees is reviewed and pre-approved by Grandeur Peak Global’s directors, as well as the firm’s CCO, with reference to the considerations listed above, (b) documentation is retained by the firm’s CCO explaining the specific considerations and rationale for unsuitability for the Grandeur Peak Portfolios, and (c) that all such investments are disclosed to the Grandeur Peak Global Trade Compliance Committee.

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Transactions and Personal Trading Code of Ethics: Grandeur Peak Global expects its managers and employees (together “Employees”) to act in the best interest of our clients, and to place the interests of our clients ahead of our own. Grandeur Peak Global has adopted a Code of Ethics (the “Code”) which sets forth the standard of business conduct expected from each member of our team. The Code treats every manager and Employee as an “Access Person.” The Code restricts trading in any security for which we believe we may be privy to material non-public information. It also restricts personal trading activities to prevent immediate conflicts of interest between personal trading and client trading. The Code limits gifts and entertainment, be they received or given, to avoid material conflicts of interest. The Code requires all outside business activities of our Employees (and members of their immediate households) be disclosed so that potential conflicts can be recognized and addressed. The Code restricts political contributions of our Employees and their immediate household members to avoid potential conflicts. Finally, the Code includes a Whistleblower Policy for all Employees. All Grandeur Peak Employees are trained and must accept in writing the terms of the Code upon employment and at least annually thereafter. Grandeur Peak Global will provide a copy of the Code to any client or prospective investor upon request to ahone@grandeurpeakglobal.com. Grandeur Peak Global may invest client assets in companies whose officers, directors, or employees have investments in a Grandeur Peak Portfolio. This could create a conflict of interest where Grandeur Peak Global might be motivated to make a decision relative to the Grandeur Peak Portfolio’s investment in such a company with the intent of benefiting the company’s officers, directors or employees in a manner that may not be in the best interest of a Grandeur Peak Global client. Grandeur Peak Global, its directors, officers, Employees, as well as GPGH or GPC (for purposes of this paragraph, “Own Account Investors”), or any of them, have invested or may invest for their own account in (a) the Grandeur Peak Portfolios, or (b) publiclytraded securities, private securities, or private funds that may hold securities of companies that are or could in the future be owned in the Grandeur Peak Portfolios. If an Own Account Investor holds a security which is or becomes available and suitable for a Grandeur Peak Global client, then a conflict of interest would arise for the Own Account Investor to favor one strategy or product over another or to make decisions to benefit its own account over the interests of a Grandeur Peak Global client. Grandeur Peak Global has adopted policies designed to mitigate and prevent such conflicts, including a Trade Allocation Policy that is specifically designed to be unbiased across all Grandeur Peak Portfolios, a Code requirement that all Access Persons obtain preapproval from Grandeur Peak Global’s Approvals Committee (comprising crossPage | 19

functional representation from compliance, research and trading functions) of any investment covered by item (b) above, trade procedures that require multi-functional disclosure among the Grandeur Peak Global team of all investment recommendations and trade decisions on behalf of any Grandeur Peak Portfolio, and approval by the CCO of any trade of securities recommended for a Grandeur Peak Portfolio by an Own Account Investor who holds the same securities in their own account. Notwithstanding the foregoing, it is possible that an Own Account Investor who holds securities of a company may benefit from market activity in those securities by a client. Personal Trades: Grandeur Peak Global Employees are required to obtain preapproval for all personal trades. Employees are not allowed to purchase public equities in their personal accounts, although in limited circumstances an Employee can seek an exception from the Approval Committee (which includes the CCO). The Code is designed to prevent any personal account transaction from taking place when it might advantage an Employee and disadvantage a client. Nonetheless, since the Code does allow Employees and clients to potentially hold the same security, there is a possibility that an Employee might benefit from market activity by a client in such a security. To help reduce the likelihood of inappropriate benefit to an Employee from personal trades, the Code requires equity trades to be pre-approved and executed in a manner to mitigate client conflict. The Code also requires that Grandeur Peak Employees obtain approval before investing in a limited offering, including private funds. The Code prohibits Employees from investing in IPOs. The Code requires periodic reporting of personal securities transactions and holdings to Compliance. Participation in Client Transactions: Grandeur Peak Global does not buy or sell securities directly to or from its clients. Grandeur Peak Global solicits investors to invest in the Grandeur Peak Funds and Grandeur Peak SMAs, which we manage and for which we receive a fee. Grandeur Peak Global also solicits investors to invest in the Grandeur Peak LPs, for which Grandeur Peak Global acts as the general partner and receives a fee for managing. Grandeur Peak Global does not have discretion over client accounts to make the decision to invest in Grandeur Peak Portfolios, but once a client has decided to invest in a Grandeur Peak Portfolio, then Grandeur Peak Global has investment discretion over the client assets invested in that Grandeur Peak Portfolio.

Brokerage Selection & Best Execution: SMA clients have the ability to grant Grandeur Peak Global brokerage discretion or direct Grandeur Peak Global to execute transactions for the client with a specific broker. Currently, Grandeur Peak Global has discretion to select the brokers to execute transactions for all Grandeur Peak Portfolios, and to negotiate and determine the commissions to be paid for such transactions. Grandeur Peak Global considers a number of factors when selecting a broker or dealer (collectively, a “broker”) for a transaction, including the broker’s execution capability, the broker’s responsiveness to Grandeur Peak Global, the broker’s reputation and access Page | 20

to the global market for the security being traded, the efficiency with which the trade will be executed, the broker’s integrity (ability to maintain confidentiality), the broker’s knowledge of global regulatory practices, commission rates and the value of the research products and services that a broker lawfully may provide to assist Grandeur Peak Global in the exercise of its investment decision-making responsibilities, the availability of soft dollar accrual, the broker’s technology infrastructure and operations capabilities, and the expected market impact of the trade. The determining factor is not solely the lowest possible commission cost, but whether the transaction represents the best qualitative execution for our clients. Grandeur Peak Global has no affiliated brokerdealer. Research & Other Soft Dollar Benefits: As an adviser, Grandeur Peak Global has a fiduciary obligation to seek best execution for client trades and not to use client assets for its own benefit at the expense of its clients. Congress, recognizing the value of research in managing client accounts, enacted Section 28(e) of the Securities Exchange Act of 1934 to allow advisers to use client commissions to acquire research and brokerage services in good faith that the amount of commission was reasonable in relation to the value of the research and brokerage services received. On most executed trades, the Portfolios pay brokerage commissions that are competitive, though they may be higher than the lowest available rate available from an “execution only” broker; in such cases, Grandeur Peak Global receives research products and services in return. The “additional” commission paid for this research is commonly referred to as “soft dollars.” There are two types of soft dollars, a) those used to acquire proprietary research products and services from the broker executing the trade (“bundled”), and b) those used to acquire research products and services from third parties (“unbundled”). Grandeur Peak Global utilizes both types of soft dollars. Grandeur Peak Global benefits from the use of client commissions to purchase research products and services because Grandeur Peak Global does not have to produce or pay for these research products or services. This creates a conflict of interest for Grandeur Peak Global because: A. Grandeur Peak Global has an incentive to trade with brokers providing research products or services, which may or may not be the broker providing the best price. B. Grandeur Peak Global has an incentive to trade more frequently in order to accrue additional soft dollars. Grandeur Peak Global client accounts generate soft dollars in varying forms and amounts. Soft dollars are aggregated together and collectively used to pay for research products and services benefiting all accounts. Soft dollar benefits may not be received in proportion to the soft dollars generated by each account. The types of research services acquired with soft dollars typically benefit the Grandeur Peak Global research process on a broad basis, and as such it is difficult to separately measure the benefit received by each individual account. In addition, the volume and nature of trading Page | 21

activities by account are not uniform, and so the amount of soft dollars generated by each account varies. Certain clients (e.g. clients using directed brokerage, not allowing unbundled soft dollar accrual on trades, or restricting brokerage practices in other ways) are likely to generate significantly fewer soft dollars. These clients benefit from the research services provided to Grandeur Peak Global through soft dollars generated by other Grandeur Peak Global clients. Grandeur Peak Global has a Trade Compliance Committee (TCC) that oversees the firm’s best execution responsibilities and the accrual and use of soft dollars, among other things. The TCC reports to the Managing Partners and also includes the Grandeur Peak Global CCO as a member, thus enabling additional oversight of the firm’s trading practices and use of soft dollars independent of the trading and research functions, which is an additional safeguard and mitigation against the related potential conflicts of interest described above. Proprietary Research Products and Services: Grandeur Peak Global uses “bundled” soft dollars to obtain proprietary research products and services from most of the brokers we utilize. These brokers bundle trade execution and research services into the total trade commission cost. The types of proprietary products and services that Grandeur Peak Global receives directly from these brokers includes: 1) coordinating meetings or calls with management teams of companies of interest to Grandeur Peak Global, 2) coordinating trips for Grandeur Peak Global research analysts to visit companies and talk with management (though Grandeur Peak Global is careful to pay for the travel expenses of its team members), 3) providing opportunities to attend broker-sponsored conferences where Grandeur Peak Global research analysts hear company presentations and meet with company management, 4) access to allocations in limited offerings, such as IPOs, and 5) access to research analysts at the broker, and reports generated by such analysts. These products and services are not generally available for sale otherwise and can typically only be obtained by paying the broker via trade commissions. Third Party Research: Grandeur Peak Global uses “unbundled” soft dollars accrued through trade commissions to obtain third party research products and services. On many of our trades, the trade commission paid includes both a commission paid to the broker for their services as well as an additional commission that is used to pay for “unbundled” research products and services offered by third parties. These “unbundled” soft dollar commissions may be accrued on trades executed through execution-only brokers as well as through brokers also receiving “bundled” soft dollars. “Unbundled” soft dollars allow Grandeur Peak Global to select research products and services it feels are the most valuable to its research process and in turn most beneficial to its clients. Third party research products and services include, among other things, data services, translation services, publications, databases, reports, and software. To date, the largest expense for third-party research services used by Grandeur Peak Global and paid for with “unbundled” soft dollars is Bloomberg Professional Service. Bloomberg is an interactive financial information network that integrates data, news, Page | 22

analytics, multimedia reports, and Portfolio holdings on a single platform. Bloomberg analytics provide real-time tools that can retrieve company, financial, and economic data. Our research process relies on Bloomberg as an important research tool. Other third party research products and services are also purchased using “unbundled” soft dollars. On occasion, a product or service furnished to Grandeur Peak Global will have both research and non-research functionality (for example, Bloomberg is used both by the research team and the trading team). Under such circumstances, Grandeur Peak Global will make a reasonable allocation as to the portion of the product or service that provides assistance in the research process and can appropriately be paid for with soft dollars. The non-research portion of the product or service will be paid for by Grandeur Peak Global. Brokerage for Client Referral: Client referral is not a consideration in selecting brokerdealers to execute securities transactions for the Portfolios. We do not compensate broker-dealers for distributing the Grandeur Peak Funds or any of the Portfolios or products by directing brokerage transactions to them. Directed Brokerage: Grandeur Peak Global has discretion to select the brokers used for trades in the Portfolios. SMA clients may, at their discretion, direct trades to a particular broker-dealer or type of broker-dealer. Clients who request or require directed trades may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, and the client may also receive less favorable prices and trade execution. Directed brokerage account trades will typically be executed after all discretionary trades in the same security have been completed. As a result, the price of a particular security may move away from the desired execution price prior to completing all directed brokerage account trades, which may cause directed brokerage accounts to not receive the same Portfolio weighting or price in a security as other client accounts where Grandeur Peak Global has full discretion to execute trades. Trade Aggregation & Allocation: If Grandeur Peak Global believes the purchase or sale of a security is in the best interest of more than one of the Portfolios it manages, we will typically aggregate the securities to be purchased or sold into a single order (a “block trade”). Grandeur Peak Global will allocate securities purchased or sold in a block trade, as well as the expenses incurred in the transaction, generally on a pro-rata basis or in another manner that it considers equitable and consistent with its fiduciary obligation to clients. Each Portfolio may not receive a pro-rata allocation of a block trade in instances where the trade is only partially filled. Grandeur Peak Global has a Trade Allocation Policy for such instances in order to maintain economically sound and equitable treatment of the Portfolios. For example, one Portfolio may randomly receive the entire executed trade if the pro-rata division of the trade would make the trades for each Portfolio uneconomical. Grandeur Peak Global will seek to be fair and equitable in its allocation of trades, but there can be no assurance that the net result will be equal

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across Portfolios. We will follow the same Trade Allocation Policy when allocating IPOs among its suitable and eligible Portfolios within the relevant investment style/product. Cross Trades: In the course of providing advisory services, Grandeur Peak Global may simultaneously recommend the sale of a particular security for one account and the purchase of the same security for another account if such recommendations are consistent with each client’s investment objectives and guidelines. Therefore, opportunities may arise for Grandeur Peak Global to effect “cross” transactions between client accounts. If we determine that it is more cost effective and in the best interests of clients to cross securities between client accounts, Grandeur Peak Global, acting as investment advisor and fiduciary to both buyer(s) and seller(s), may affect cross trades between client accounts consistent with its policies and procedures. Grandeur Peak Global receives no compensation from cross-trades. ERISA accounts are not permitted to participate in cross trades. Trades for ERISA accounts may be placed after cross trades for a particular security have been made on behalf of non-ERISA accounts. Accordingly, trades for accounts that do not participate in cross transactions may be subject to price movements, particularly in volatile markets, and may receive a price that is less favorable than the price obtained in a cross transaction. Foreign Currency Transactions: Grandeur Peak Global engages in foreign currency transactions to facilitate trading in or settlement of trades in foreign securities. It is Grandeur Peak Global’s policy to seek best execution on behalf of our clients. In situations where it is market convention or operationally efficient, or where a client limits Grandeur Peak Global to trading foreign exchange with certain counterparties or requires Grandeur Peak Global to trade solely with the client’s custodian bank, such limitations may impact our ability to obtain best execution for the client. Other Brokerage Practices: In the event a trade error occurs, Grandeur Peak Global will seek to identify and correct the error as promptly as possible consistent with its Trade Error Policy and Procedures. Grandeur Peak Global may invest the Portfolios’ assets in companies that provide research products or services to Grandeur Peak Global, including those paid for with soft dollars. Grandeur Peak Global may also invest the Portfolios’ assets in brokerdealers, including those used to execute client transactions or that underwrite securities offerings in which the Portfolios may participate. The brokerage practices above apply generally to the Portfolios, but investors should review carefully the offering materials and management agreement for the specific brokerage practices applicable to their investment, and consult with their professional advisers, before deciding whether to invest.

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Grandeur Peak Global receives no economic benefit for providing investment advice to clients other than as outlined in Item 5.

As a registered investment adviser, we are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Grandeur Peak Global or the integrity of Grandeur Peak Global’s management. Grandeur Peak Global has no such events to report.

The portfolio managers generally review the Portfolios on a daily basis and/or as trades are considered. Similarly, the Portfolios are reviewed in real time if there are significant inflows or outflows of assets. The Portfolios are monitored on a pre-trade and post-trade basis to ensure the Portfolios are adhering to their quantifiable investment strategies. The Portfolios are monitored for compliance with investment guidelines and regulations using a software program, Bloomberg Compliance Manager. When the software rejects a proposed order due to a restriction, the Portfolio is reviewed promptly by Compliance, Trading and/or the Portfolio Manager to determine if alternate instructions are appropriate. Grandeur Peak Fund shareholders receive account statements on a quarterly basis and generally have access to account information daily. The Grandeur Peak LPs partners have access to account statements monthly. Grandeur Peak SMAs have daily access to their account through their custodian and typically receive a monthly performance report from Grandeur Peak Global.

Grandeur Peak Global does not directly provide qualified custodial services to its clients. Client assets are held with banks, registered broker-dealers or other “qualified custodians.” As the General Partner of the Grandeur Peak LPs, we are deemed to have custody of assets, as per the custody rules in 206(4)-(2)(b) under the Investment Advisers Act. Audited financial statements of the Grandeur Peak LPs are provided to each limited partner annually. Clients do not receive account statements from Grandeur Peak Global. Clients should receive account statements directly from the qualified custodian at least quarterly which identifies the amount of assets in the account, each security in the account, and all transactions in the account during the period. The Administrator of the Grandeur Peak LPs provides monthly account statements to the limited partners. Clients and Investors should review their statements carefully. Grandeur Peak Global generally takes steps to avoid having custody of client assets and does not have custody over Grandeur Peak Portfolios. However, we may be deemed to have custody of a limited number of portfolios due to our ability to make Page | 25

certain payments from those portfolios without independent verification. As such, we follow the custody rules in 206(4)-(2)(a) under the Investment Advisers Act.

Grandeur Peak Global has discretionary authority to manage the assets in the Portfolios. We observe investment limitations and restrictions that are outlined in each Portfolio’s investment management agreement or offering materials.

Clients may choose to direct Grandeur Peak Global to vote proxies on their behalf or retain the authority to vote such proxies themselves. We have a Proxy Voting Committee to oversee the firm’s proxy voting activities. Our policy is to vote proxies in the manner we believe will best maximize long-term shareholder value. Grandeur Peak Global has adopted and implemented a Proxy Voting Policy, including guidelines and procedures to assist research analysts in making voting decisions that we believe are in the best interest of our clients. Grandeur Peak Global invests in companies that we believe have high quality management teams, and consequently Grandeur Peak Global generally supports the recommendations of the company’s management when voting proxies. However, we ultimately vote for or against recommendations based on what we believe is in our clients’ best interest. Grandeur Peak Global has retained an independent service provider to assist in reconciling and processing proxy ballots and providing record-keeping and vote disclosure services, as well as research on proxy issues. In the event that we identify a material conflict of interest in any proposal that is subject of a proxy to be voted for a client account, we will not vote on that proposal. Clients or potential investors may obtain a copy of Grandeur Peak’s Proxy Voting Policy and Procedures upon request by sending a request to ahone@grandeurpeakglobal.com. Clients may also obtain information about how we voted any proxies on behalf of the Portfolio(s) in which they are invested. The Grandeur Peak Funds proxy voting record is publicly available on the SEC’s website at www.sec.gov no later than August 31st for the prior twelve months ending June 30th.

In certain circumstances, registered investment advisers are required to provide you with financial information or disclosures about their financial condition. Grandeur Peak Global has no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients. Grandeur Peak Global has also never been the subject of a bankruptcy proceeding. Page | 26