Euro Pacific Asset Management, LLC: investment adviser

Advisory Services Offered EPAM provides investment advisory services through the following arrangements: Euro Pacific Funds EPAM is the investment advisor to a series of funds in Investment Managers Series Trust (the “Trust”), each a registered investment company under the Investment Company Act of 1940. The series of funds includes the EuroPac International Value Fund (“EPIVX”), EuroPac International Bond Fund (“EPIBX”), EP Emerging Markets Fund (“EPASX”), EuroPac Gold Fund (“EPGFX”), and EuroPac International Dividend Income Fund (“EPDPX”) (collectively, the “Euro Pacific Funds”). EPAM is responsible for making all investment decisions concerning the investment and reinvestment of the assets of the Euro Pacific Funds in accordance with each Fund’s investment objectives and policies, as outlined in the Prospectus and Statement of Additional Information. Additional services include, but are not limited to, placing transactions for the purchase and/or sale of securities with a broker-dealer selected by EPAM and providing the Trust with certain information and documents to help prepare and maintain its books and records. Additional information about the Euro Pacific Funds, including the Fund Prospectus and Statement of Additional Information, is available online at: www.europacificfunds.com. Prospective investors should review these documents carefully before making any investment in Euro Pacific Funds. Sub-Advisory Services EPAM has entered into sub-advisory agreements with certain unrelated investment advisory firms (“Advisors”) to provide discretionary investment advisory services to the Advisor’s clients (“SubAdvisory Clients”). Our sub-advisory agreements are described below. EPAM’s investment strategies are implemented in Sub-Advisory Client accounts primarily utilizing foreign equities. Occasionally, EPAM may also utilize additional types of securities if they are appropriate to address the individual needs, goals, and objectives of the Sub-Advisory Client or to respond to a specific client inquiry. For example, we may incorporate foreign fixed-income securities in a client’s portfolio. If appropriate for the client’s overall situation, we may recommend that clients invest in other types of securities such as mutual funds, exchange-traded funds (“ETFs”), or different types of limited offerings, such as private placements and initial public offerings (“IPOs”). Typically, mutual funds and limited offerings are maintained in a separate brokerage account of the client and are not part of

the client’s managed advisory account. EPAM may offer investment advice on any investment held by the client at the start of the advisory relationship. A.G.P. / Alliance Global Partners Corp EPAM has an agreement with A.G.P. / Alliance Global Partners Corp (“A.G.P.”), a dually registered investment adviser and full-service broker-dealer with the SEC and with the Financial Industry Regulatory Authority (“FINRA”). A.G.P. was previously known as Euro Pacific Capital, Inc., which served as an affiliated entity of EPAM. A.G.P. acquired Euro Pacific Capital, Inc., which subsequently became a division of A.G.P. Under the agreement, EPAM provides investment management and supervisory services to the advisory clients of A.G.P. on a discretionary basis for all or a portion of the client’s assets as directed by A.G.P. EPAM also acts as sub-advisor to A.G.P.’s Wrap Fee Program, as discussed in greater detail under Wrap Fee Program. EPAM manages the accounts in accordance with each Sub-Advisory Client’s investment policy statement (“IPS”), which is obtained by A.G.P. and provided to EPAM. The IPS reflects the Sub-Advisory Client’s investment objectives for the assets to be managed by EPAM, and also includes their risk profile, liquidity needs, general time horizon, tax considerations, legal considerations, and any special investment circumstances. A.G.P. remains the primary investment manager of the Sub-Advisory Client’s account and is responsible for ongoing suitability review of EPAM’s services for each client. If determined appropriate for the Sub-Advisory Client and consistent with the client’s IPS, EPAM may invest a portion or all of the Sub-Advisory Client’s account in one or more of its Euro Pacific Funds. The accounts of clients participating in A.G.P.’s Wrap Fee Program will be allocated solely among the Euro Pacific Funds. EPAM has an incentive to recommend Euro Pacific Funds because we receive internal management fees from the Funds based on the level of assets invested in the Funds. A.G.P. addresses the conflict of multiple fees by rebating the fee the client pays by the amount of the fee EPAM receives for the management of the Euro Pacific Funds. Ventum Financial Inc. (Formerly Echelon Wealth Partners) EPAM has entered into an agreement with Ventum Financial, Inc. (“Ventum”), a full-service Canadian brokerage and advisory firm registered with the Investment Industry Regulatory Organization of Canada. EPAM provides investment management services to Ventum's advisory clients on a discretionary basis for all or a portion of the client’s assets, as directed by Ventum. Further information on how any conflicts of interest are mitigated in this relationship is outlined below under Item 10 - Other Financial Industry Activities and Affiliations. Schiff Gold, LLC PDS Trust, an affiliate of Peter Schiff, is the sole owner of Schiff Gold, LLC, a precious metals dealer. Under a written consulting agreement, EPAM provides marketing and consulting services to Schiff Gold, LLC. Further information on how any conflicts of interest are mitigated in this relationship is outlined below under Item 10 - Other Financial Industry Activities and Affiliations.

Schiff Sovereign Peter Schiff is the co-founder of Schiff Sovereign, an investment newsletter service focused on the economy, investing, and other topics. Further information on how any conflicts of interest are mitigated in this relationship is outlined below under Item 10 - Other Financial Industry Activities and Affiliations. Other Services Adrian Day Asset Management EPAM and Global Strategic Management Inc., d/b/a Adrian Day Asset Management (“ADAM”) have a services agreement (“Services Agreement”), whereby, under the Services Agreement, EPAM provides operational and compliance support to ADAM. This arrangement has been further outlined under Item 5 – Fees and Compensation and Item 10 – Other Financial Activities and Affiliations. Tailored Services and Client Imposed Restrictions EPAM manages client accounts based on the investment strategy selected for the client. The selected strategy is applied based on the client’s individual circumstances and financial situation. We make investment decisions for Sub-Advisory Clients based on the investment objectives and suitability information provided by the client’s investment advisor representative. EPAM’s investment strategies are discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. Clients may request restrictions on their accounts. Restrictions must be communicated to the client’s investment advisor representative and provided to EPAM in writing. EPAM reserves the right not to accept and/or terminate management of an account if we determine that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Additional Information about Services EPAM’s investment strategies are discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. We describe the material investment risks for the primary securities that we utilize under the heading Investing Involves Risks in Item 8. We discuss our discretionary authority below under Item 16 - Investment Discretion. We describe the fees charged for investment management services below under Item 5 - Fees and Compensation. Wrap Fee Programs EPAM acts as sub-advisor to a Wrap Fee Program sponsored by A.G.P. As part of the Wrap Fee Program, the client pays a single bundled fee to A.G.P., instead of paying separately for advisory services, commissions on transactions, custodian fees, and other transaction-related fees. A.G.P. then pays EPAM a portion of the wrap fee for our sub-advisory services. Sub-Advisory Clients may participate in the Wrap Fee Program, which typically requires a minimum account value of $50,000 or more. Under the Wrap Fee Program, the client’s account will be invested

according to one of five Portfolio Wrap strategies designed by EPAM. Each Portfolio Wrap strategy is allocated among various Euro Pacific Funds. Client accounts under A.G.P.’s traditional Separately Managed Account (“SMA”) service will typically be invested in individual stocks and bonds and do not participate in the Wrap Fee Program. The SMA Portfolios are discussed in greater detail under Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss: Euro Pacific International Separately Managed Account. This Brochure does not provide a full description of the Wrap Fee Program. A.G.P.’s Wrap Fee Program, including the fees charged to clients and investment strategy utilized in the program, is described in its Form ADV Part 2A Appendix 1 Wrap Fee Program brochure, which is provided to all clients participating in the program and available from A.G.P. upon request. In addition, EPAM acts as the manager to a Wrap Fee Program at Interactive Brokers LLC on behalf of separately managed accounts at the firm. Under the Wrap Fee Program, the client’s account will be invested according to one of five Portfolio Wrap strategies designed by EPAM. Each Portfolio Wrap strategy is allocated among various Euro Pacific Funds. EPAM Wrap Fee Program and Proprietary Funds This Brochure does not provide a full description of the Wrap Fee Program. EPAM’s Wrap Fee Program, including the fees charged to clients and investment strategy utilized in the program, is described in our Form ADV Part 2A Appendix 1 Wrap Fee Program Brochure, which is provided to all clients participating in the program and available upon request. The overall cost you will incur if you participate in our Wrap Fee Program may be higher or lower than you might incur by paying transaction costs separately. To compare the cost of our Wrap Fee Program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies, the brokerage commissions charged by other broker/dealers, and the management fees charged by investment advisors. EPAM invests Wrap Fee program accounts in proprietary Euro Pacific mutual funds for which EPAM serves as investment adviser and receives management fees from the funds. Because EPAM also receives compensation at the fund level on proprietary funds held in wrap accounts, EPAM has a financial incentive to recommend or retain investments in those funds, 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 charged by the proprietary fund so that EPAM does not receive two management fees on the same assets. Clients, however, continue to bear their proportionate share of each fund's management fees and operating expenses through the fund's expense ratio, as described in the applicable prospectus. EPAM addresses this conflict through full and fair disclosure, the wrap fee offset described above, its fiduciary obligations, and supervisory policies and procedures designed to help ensure recommendations remain in each client's best interest. EPAM also periodically evaluates whether continued participation in the Wrap Fee Program remains appropriate for each client based on the client's investment objectives, financial circumstances, risk tolerance, anticipated trading activity, and other relevant factors. Where appropriate, EPAM may recommend changes to the client's advisory program or investment strategy. Separately Managed Accounts EPAM offers investment advisory accounts for individuals, high net worth individuals, individual retirement accounts, trusts and estates, and businesses. EPAM will typically exercise investment discretion, including, but not limited to, the type and amount of securities and other financial instruments purchased and sold, subject to investment guidelines in the applicable client’s investment management agreement

(“IMA”), which may be periodically updated by the client. These guidelines would generally vary among clients with respect to investment objectives, strategies, policies, and limitations. EPAM periodically reviews client accounts and advisory services to help ensure that investment recommendations and the advisory program selected continue to be appropriate in light of each client's objectives and best interests. Clients should promptly notify EPAM of any material changes in 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 advisory services or investment strategy are appropriate. Assets Under Management EPAM manages client assets on a continuous and regular basis. As of February 28, 2026, our total assets under management was: Discretionary Assets $ 2,180,629,620 Non-Discretionary Assets $ 0 Total Assets $ 2,180,629,620

Further information on how any conflicts of interest are mitigated when investing in Euro Pacific Funds is outlined below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. Mutual Fund Share Classes When recommending or purchasing proprietary Euro Pac mutual funds for client accounts, EPAM seeks to utilize the lowest-cost share class for which the client is eligible, taking into consideration investment minimums, custodial availability, account type, and other relevant factors. In certain circumstances, a client may initially be invested in a higher-cost share class because a lower-cost share class is not available or the client does not satisfy the applicable eligibility requirements.

Because client eligibility for lower-cost share classes may change over time, EPAM periodically reviews client accounts to determine whether a lower-cost share class has become available and, where appropriate, will recommend or implement a conversion consistent with the client's best interests. Additional information concerning the management fees, and other expenses, is contained in the prospectus and statement of additional information. Investors are advised to review the prospectus and statement of information prior to investing in any Euro Pacific Funds. Termination of Agreement The written agreement between EPAM and the Trust for any Euro Pacific Fund may be terminated by either party at any time. EPAM may terminate the agreement by providing prior written notice to the Trust. The Trust may terminate the agreement upon prior written notice to EPAM following a majority vote of the Board of Trustees of the Trust or the outstanding voting securities of the Fund. The written agreement will also terminate automatically in the event of any transfer or assignment of the agreement, as defined by the Investment Company Act of 1940. Sub-Advisory Services Sub-Advisory Clients do not pay fees directly to EPAM. The fees paid by Sub-Advisory Clients to their Advisor are outlined in a written agreement, to which EPAM is not a party. Sub-Advisory Clients should review their agreement with the Advisor for more information. A.G.P. Under the sub-advisory agreement EPAM has with A.G.P. (see also Item 4 – Advisory Business above), A.G.P. pays EPAM an annual management fee of 0.80% for management of Separately Managed Account clients and 0.80% for Wrap Account clients. Either party may terminate the agreement upon prior written notice to the other party. Ventum Under the sub-advisory agreement EPAM has with Ventum, Ventum pays EPAM an annual management fee of 0.30% or a minimum of CAD 75,000 per quarter for Separately Managed Accounts. EPAM may terminate this agreement upon prior written notice to Ventum. While Ventum may remove any sub-advised clients under the agreement, Ventum remains obligated to pay the minimum quarterly fee. Other Services Adrian Day Asset Management (ADAM) EPAM receives compensation from ADAM for providing operational and compliance services. The value that EPAM receives is based on an estimate of costs incurred to provide the services, accrued over the 10-year life of the Services Agreement. This arrangement has been further outlined under Item 10 – Other Financial Activities and Affiliations.

Schiff Gold, LLC PDS Trust, an affiliate of Peter Schiff, is the sole owner of Schiff Gold, LLC, a precious metals dealer. Under a written consulting agreement, EPAM provides marketing and consulting services to Schiff Gold, LLC. Further information on how any conflicts of interest are mitigated in this relationship is outlined below under Item 10 - Other Financial Industry Activities and Affiliations. Separately Managed Accounts EPAM offers a separately managed account program directly to investors outside of the United States, as well as certain investors inside of the United States. The program is focused on offering International Value, International Dividend Income and Gold separately managed accounts, but we also do offer custom portfolio models for clients on a case-by-case basis. EPAM charges annual management fees to its clients which may differ on a case-by-case basis and generally range from between 1.00% - 2.00%; however, EPAM’s management fee is negotiable at EPAM’s discretion. Billing Method Fees for separately managed accounts will be calculated daily and billed monthly, in arrears based upon the value of the account as of the close of business on each business day of the calendar month. There are no fees or penalties for terminating an account at any time. EPAM bills A.G.P. and Ventum in arrears based on the assets under management as of the last day of the previous calendar month and quarter, respectively. With client authorization, the client’s custodian will automatically withdraw the management fee from the client’s account at the time it is billed. All clients will receive brokerage statements from their custodian at least on a quarterly basis. The custodian statement will show the deduction of the management fee. Termination of Agreement Either party may terminate the IMA upon ten (10) days prior written notice to the other party. The client may terminate the agreement by writing to EPAM at our office. EPAM does not charge any termination fees. Upon termination of the agreement of a separately managed account, as fees are billed in advance, EPAM will refund any unearned fees. Terminations will not affect liabilities or obligations from transactions initiated in the client’s account prior to termination. In the event that a client terminates the IMA, EPAM will not liquidate any securities in the account unless instructed in writing to do so by the client. Clients should understand that in the event that a client requests that his or her account(s) be fully liquidated, it may take EPAM a number of days to sell all the securities in the account(s). This timing is dependent on the types of securities in a client’s account. In the event of a client’s death or disability, EPAM will continue management of the account until we are notified of the death or disability and given alternative instructions by an authorized party. Other Fees and Expenses Unrelated to Euro Pacific Funds EPAM’s investment management fees for the services described above do not include custodian fees. Clients pay all brokerage commissions, margin charges and/or other charges incurred in connection with transactions in accounts, from the assets in the account. Transaction fees for securities traded on foreign exchanges may be higher than fees for securities traded through domestic exchanges and may

include such additional charges as foreign settlement costs, account movement charges, and foreign exchange fees. Fees for each trade will vary. For transactions executed through A.G.P. and Ventum as a broker-dealer, these fees will be passed through to clients without markup. For aggregated trades, these fees will be allocated on a pro-rata basis based on each client’s participation and the principal amount of the total transaction. See Item 12 - Brokerage Practices below for more information. While the following fees are waived within the A.G.P. wrap fee program, any mutual fund shares held in a client’s account may also be subject to deferred sales charges, 12b-1 fees and other fund-related expenses. The fund’s prospectus fully describes the fees and expenses. All fees paid to EPAM for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds. Mutual funds pay management fees to their managers, which are indirectly charged to all holders of the mutual fund shares. Consequently, clients with mutual funds in their portfolios are effectively paying both EPAM and the mutual fund manager for the management of their assets. For our policies regarding an EPAM-managed Euro Pacific Fund recommended for a Sub-Advisory Client’s account, see Item 4 – Advisory Business above. For clients participating in EPAM's Wrap Fee Program, additional information regarding wrap fee compensation, including the treatment of proprietary Euro Pacific mutual funds and related conflicts of interest, is described under Item 4 – Advisory Business. Other Compensation EPAM does not purchase for managed accounts securities that are obtained through the investment banking division of A.G.P.

Euro Pacific Separately Managed Account (SMA) Strategy Overview EPAM manages Advisory and Sub-Advisory Client accounts according to each specific investment policy statement (IPS). Typically, the portfolios attempt to provide capital appreciation outside of the U.S., using a top-down analysis to select countries and industries and a bottom-up analysis to select securities. The strategy seeks to diversify currency risk and takes a long-term investment view with low portfolio turnover. International Dividend Payers SMA The International Dividend Payers strategy is designed to maximize dividend income by selectively investing in foreign companies that the portfolio management team believes have the capacity to consistently pay high dividends and grow them over time. International Value SMA The International Value strategy is designed to provide exposure to international equity with a with a focus on high quality businesses that the portfolio manager believes are trading at a discount to fundamental value. Gold SMA The Gold strategy is designed to provide exposure to precious metal producers. The portfolio manager will invest in exploration companies, mid-tier, and large-tier producers, as well as royalty companies. The manager will also, from time to time, buy or sell call or put options. Emerging Markets SMA The Emerging Markets strategy is designed to provide exposure to countries classified as Emerging Markets. The primary objective is capital appreciation, and the strategy attempts to add the highest quality companies trading at a discount to their intrinsic value. Natural Resources SMA The Natural Resources strategy is designed to achieve long-term capital appreciation by investing in companies directly involved in natural resources businesses such as precious metals, industrial metals, agriculture, water, and other resources. In general, the strategy is expected to provide a hedge against future bouts of unexpected inflation. Other Model Portfolio Investment Styles In addition to the styles above, EPAM also offers an allocation to a core of stocks under the Value strategy or Dividend Payers strategy, with various Euro Pacific Funds included in the portfolio to achieve our client’s overall asset allocation strategy. For example, EPAM offers a blended investment style that allocates 50% of the portfolio to the International Dividend Payers SMA and 50% to the EuroPac International Bond Fund. The various styles available to clients in addition to those listed above can be found at www.europac.com. Certain clients may also be invested according to investment strategies that are no longer actively offered by the firm. Investment Process EPAM uses fundamental analysis in the ongoing management of client accounts. The fundamental approach emphasizes bottom-up analysis with a focus on the quality of each business and purchasing them at attractive values.

The investment committee typically meets on a weekly basis to review the fundamentals of the portfolio. Decisions regarding country, sector and stock allocation are presented to the committee for approval following the screening of fundamentals by the Portfolio Manager. Approximately 20 to 40 recommendations will be provided to the investment committee for inclusion in the portfolio. Sample Country Criteria: • Expected 1-2 year trade surplus • Real interest rates exceed those of the U.S. • Low debt-GDP ratio • Favorable GDP growth estimates Sample Industry Criteria: • Favorable growth rate • Well-positioned against anticipated secular shifts in supply/demand • Resource availability • Favorable political and regulatory environment Sample Security Criteria: • Favorable dividend yield • Attractive valuation • Strong balance sheet • Superior management Model Portfolio Composition The model portfolios are balanced across Asia, Europe, Latin America, North America, and Australasia, to diversify currency risk, while remaining appropriately balanced between non-cyclical and cyclical industries. Please reference the style descriptions above for more information. Portfolio Rebalancing Portfolios are rebalanced on a calendar quarter basis or as necessary. Individual positions may be rebalanced if the Portfolio Manager determines the benefits of rebalancing exceed the additional cost of the transaction(s). Euro Pacific Wrap Fee Accounts Wrap fee client accounts invest in proprietary Euro Pacific mutual funds. As discussed in Item 4, EPAM receives management fees from these funds, creating a conflict of interest. EPAM mitigates this conflict by reducing the wrap management fee by the proprietary fund management fee and through its fiduciary obligations and supervisory procedures.

Investing in Euro Pacific Funds EPAM may invest client accounts, including accounts participating in EPAM's Wrap Fee Program, in proprietary Euro Pacific mutual funds when EPAM determines that doing so is consistent with the client's investment objectives, risk tolerance, and overall best interests. EPAM believes these funds may provide clients with efficient access to professionally managed, diversified investment strategies. Because EPAM serves as investment adviser to the Euro Pacific Funds, EPAM receives management fees from those funds. This creates a financial incentive to recommend or retain investments in proprietary funds, which presents a conflict of interest. For Wrap Fee Program accounts invested in proprietary Euro Pacific Funds, EPAM reduces the client's wrap management fee by an amount equal to the management fee attributable to those assets 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 the fund's expense ratio. EPAM addresses this conflict through full and fair disclosure, its fiduciary obligations, supervisory policies and procedures, and periodic reviews designed to help ensure that investment recommendations remain in clients' best interests. See also Item 4 – Advisory Business and Item 5 – Fees and Compensation. Investing Involves Risk Prior to entering into an agreement with EPAM, the client should carefully consider the following:

1. Investing in securities involves risk of loss which clients should be prepared to bear; 2. Securities markets experience varying degrees of volatility; 3. Over time the value of the client’s assets may fluctuate and at any time may be worth more or less than the original amount invested; and 4. Clients should only commit assets that they feel are available for investment on a long-term basis. This is typically a minimum of five to seven years. EPAM primarily invests in foreign securities and certain domestic securities with exposure to international markets. Our strategies may not be appropriate for clients seeking exposure to the U.S. domestic securities markets. Investing in foreign securities involves risks, including but not limited to currency controls and fluctuation, political risk, economic changes, and market risks, as well as different legal standards governing accounting, auditing, financial reporting, disclosure, and regulatory practices. Various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends, can also lead to additional risk. Investments in developing countries can further heighten these risks. The prices of securities and the income they generate (such as dividends) may fluctuate based on events specific to the company that issued the shares, conditions affecting the general economy and overall market changes, changes or weakness in the company’s relevant business sector, and other factors. Further, prices of these securities can be affected by financial contracts held by the issuer or third parties (such as derivatives) relating to the security or other assets or indices. There may be little trading in the secondary market for particular equity securities, which may adversely affect the ability to value accurately or dispose of those equity securities. Adverse publicity and investor perceptions, whether or not based on fundamental analysis, may decrease the value and/or liquidity of equity securities. As with all investments, an investor should carefully consider his investment objectives

and risk tolerance as well as any fees and/or expenses associated with such an investment before investing. International investing may not be suitable for all investors. In addition to the risks of investing in foreign securities in general, the risks of investing in the securities of companies domiciled in emerging market countries include increased political and/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, lack of investor protection against parties who fail to complete transactions, and the potential for government seizure of assets or nationalization of companies. 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 if measured in U.S. dollars. As a result of our buy-and-hold strategy, during those time periods when the U.S. dollar is rising in value, or when global stock markets are in decline, our portfolios may lose value, priced in U.S. dollars. Though such declines may be partially offset by dividends, investors unwilling to assume short-term volatility as a trade-off for potential absolute long-term performance should not implement this strategy. Risks of using margin include “margin calls.” Margin calls occur when account values decrease below minimum maintenance levels established by the broker-dealer that holds the securities in the client’s account, requiring the investor to sell securities and/or deposit additional money or securities into the account. While the use of margin borrowing can increase returns, it can also magnify losses. Exposure to gold and other precious metals may subject a portfolio to greater volatility than investments in traditional securities. Client accounts may be invested in physical gold and the securities of companies in the gold and other precious metals mining sectors. Prices of gold and other precious metals are susceptible to changes to U.S. and non-U.S. taxes, currency, mining laws, inflation, and various other market conditions. The purchaser of a put or call option runs the risk of losing the entire investment in a relatively short period of time. The writer of an uncovered call option is subject to a risk of loss should the price of the underlying security increase, and the writer of an uncovered put option is subject to a risk of loss should the price of the underlying security decrease. Markets may be volatile, and values of individual securities and other investments, including those of a particular type, may decline significantly in response to adverse issuer, political, regulatory, market, economic, or other developments that may cause broad changes in market value, public perceptions concerning these developments, and adverse investor sentiment or publicity. Events like hurricanes, floods, earthquakes, forest fires and similar natural disturbances, war, terrorism or threats of terrorism, civil disorder, public health crises, and similar “Act of God” events have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term and wide-spread effects on the world economies and markets generally. Clients may have exposure to countries and markets impacted by such events, which could result in material losses. 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 nonEuro Pacific Asset Management Brochure

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 offline (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 we do not directly control the cybersecurity systems of issuers or third-party service providers. Artificial Intelligence EPAM may rely on programs and systems that use Artificial Intelligence, machine learning, probabilistic modeling, and other data science technologies ("AI Tools"). EPAM is committed to the responsible and ethical use of AI Tools in its operations. All employees must ensure that any AI Tools deployed are compliant with applicable laws, regulations, and company policies governing privacy, data protection, and security. AI Tools may be used for the following purposes with appropriate safeguards: (1) Research and Analysis – Market research, data analysis, and information synthesis to support investment decisionmaking, provided that outputs are verified and reviewed by qualified personnel; (2) Administrative Tasks – Drafting routine correspondence, meeting summaries, internal communications, and document organization and creation, and other purposes including completion of middle-office or back-office tasks; (3) Coding and Technical Work – Software development assistance, code review, debugging, and technical documentation; (4) Educational Purposes – Training, learning new concepts, and professional development; and (5) Content Creation – Creating draft marketing materials, presentations, and educational content, subject to human review and approval before distribution. AI Tools may be flawed, and underlying datasets may be insufficient, of poor quality, or biased. In addition, AI Tools generally use machine learning and/or predictive analytics, which may lead to flawed, biased, and inaccurate results. AI Tools often use data feeds from multiple sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool will be unable to properly function, or its operation may be adversely impacted. The tool’s ability to use the data may also be adversely impacted by any change in the format of data delivered or acquired by the tool. The timeliness and quality of a third party’s data may be compromised for a variety of reasons, some of which are outside of the control of the Adviser and the third-party data provider. A tool’s ability to process data may also be adversely affected if the Adviser experiences any disruptions to its computing resources or network connections, including disruption of cloud-based computing resources.

Past performance does not guarantee future returns; investments may increase or decrease in value, and you may lose money. Investors should carefully consider these facts before implementing our strategies.

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 creates a financial incentive that could influence...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 may benefit indirectly through the consulting compensation 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 Inc. (Formerly Echelon Wealth Partners Mr. Schiff also owns a minority interest (currently less than 10 percent) in Ventum, which EPAM serves as sub-advisor 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. EPAM currently does not advise any clients of Ventum, and does not expect to do so in the future. 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 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 dayto-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, on a part-time basis. 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. Mr. Ishkanian is under the same compensation structure at both firms, minimizing incentive to promote one over the other.

ADAM and EPAM share office space, 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.

EPAM’s personnel are required to follow guidelines from the Code of Ethics in areas such as quarterly and annual reporting obligations, gifts, and entertainment, outside business activities, prohibitions of insider trading, and adherence to applicable federal and state 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 this 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 (i.e., where A.G.P., acting as broker-dealer, purchases a security from one advisory client into its inventory but then at the same time sells the security out of its inventory to another advisory or brokerage client). We only consider principal transactions when a clear benefit exists to the client and never for the sole benefit of EPAM or A.G.P. 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 each principal transaction, we 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 cross transactions (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 interests between the interests of EPAM and A.G.P. 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 repurchased. 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.

Factors Considered in Selecting Broker-Dealers for Client Transactions In exercising our discretionary authority, EPAM will normally determine (without consultation with the client on a transaction-by-transaction basis):

1. 2. 3. 4.

Which securities to buy and sell for the account; The total amount of such purchases and sales; The broker-dealers through which transactions will be executed; and The commission rates paid to affect the transactions.

In the case of accounts where EPAM has the discretion to choose the broker for the execution of client transactions, EPAM considers several factors in evaluating broker-dealers. EPAM’s primary objective in selecting a broker-dealer for any transaction or series of transactions is obtaining the best combination of execution price and efficiency of execution. EPAM may consider, among other factors, the net price received, reputation of the broker-dealer, financial strength and stability of the broker-dealer, efficiency of execution and error resolution, block trading capabilities, willingness to execute related or unrelated difficult transactions in the future, order of call, availability of research and other matters involved in the receipt of brokerage services generally. We currently do not use any soft-dollar arrangements. Although we sometimes receive research from brokerage firms, we consider the additional cost of execution against the value of such research consistent with our best execution guidelines. Directed Brokerage Transactions Clients who direct EPAM to use a particular broker-dealer for all trading should understand that they may pay higher commission charges. Under these circumstances, EPAM may not have authority to negotiate commissions or obtain volume discounts, and best execution may not be achieved. Clients should further understand that when they direct EPAM to use a specific broker, disparity in transaction charges might exist between the transaction costs charged to other clients. EPAM will not be able to aggregate orders with other clients to reduce transaction costs, and clients who direct EPAM to use a particular broker-dealer may receive less favorable prices. Aggregation and Allocation of Transactions Trade Aggregation On some occasions, EPAM will execute client transactions on a block or aggregate basis. That is, we enter one large trade and allocate the shares among various Sub-Advisory Client accounts. We do not currently aggregate transactions for Euro Pacific Funds with those for Sub-Advisory Clients or Separately Managed Accounts. Trade aggregation may allow us to execute transactions in a more timely, equitable and efficient manner in an attempt to achieve a better overall price execution for a group of clients. EPAM’s policy is to engage in this technique when it is deemed to be in the best interest of clients. Clients participating in any aggregated transactions will receive an average share price on a pro-rata basis. When placing trades for the same security for different clients and EPAM is unable to aggregate the trade for all participating clients, EPAM has implemented procedures, to the extent practicable, to allocate investment opportunities among our various clients, on a basis that over time is fair and equitable to all clients. Trade Allocation EPAM’s trade allocation policies and procedures call for a fair and equitable method of allocating trades among accounts with no particular client(s) or groups of clients being favored or disfavored. Generally, EPAM must identify a given block trade allocation before that trade is entered. If the trade is filled as entered, EPAM must allocate according to the pre-determined block. If issues arise relating to successfully filling such allocation pursuant to the pre-determined block, EPAM will allocate the shares

in a fair and equitable manner. See Code of Ethics under Item 11 above. Allocation of Initial Public Offerings and Private Offerings EPAM may, from time to time, when consistent with a client’s investment objectives and restrictions, purchase a security in an initial or secondary public or private offering (“IPO” or “PIPE”) for certain client accounts. When this occurs, it is EPAM’s intention to allocate shares among participating accounts in an equitable manner as not to give one client preference over another. EPAM will generally allocate shares based on the amount deemed appropriate for each client. In most cases, for each client, this will be the number of shares pertaining to a dollar value derived by applying a consistent percentage over each client’s account value. If EPAM does not receive a full allocation, then the shares will be allocated to accounts on a pro-rata basis. EPAM reserves the right to make exceptions to this policy if we believe it is in the best interest of clients to do so.

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. The accounts of A.G.P.’s Sub-Advisory Clients are also reviewed and monitored by the A.G.P. investment advisor representative assigned to the account. EPAM does not provide written reports to Sub-Advisory Clients. A.G.P.’s Sub-Advisory Clients receive quarterly written account statements from A.G.P. showing the client’s account balance, activity during the quarter and the amount of management fees paid to A.G.P. Clients also will receive monthly and/or quarterly written account statements from their custodian. Separately Managed Account 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.

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.

cover of this brochure. Clients who do not receive a statement from their qualified custodian at least quarterly should also notify us.

In addition, EPAM may subscribe to the services of an unrelated third-party proxy vendor to provide us with in-depth analysis of shareholder meeting agendas, vote recommendations and/or administrative assistance with regards to proxy voting. If the person(s) responsible for voting proxies becomes aware of any type of potential or actual conflict of interest relating to a proxy proposal, they will promptly report such conflict to the CCO. The CCO will forward all necessary proxy voting materials to the Trust’s Board of Trustees for direction on how to vote such proxy, in accordance with the Trust’s written Proxy Voting Policies and Procedures. EPAM may also choose not to vote proxies in certain situations, such as where EPAM deems the cost of voting exceeds any anticipated benefit to the Fund. A complete copy of EPAM’s current Proxy Voting Policies & Procedures is available upon request. The Trust may obtain information on how proxies were voted by contacting EPAM at our principal office and place of business indicated on the cover page of this brochure.

Managed Accounts EPAM does not accept or have the authority to vote proxies for individual securities held in SubAdvisory Client or Separately Managed Accounts. These clients retain the authority to vote proxies. However, clients may call us if they have questions about a particular solicitation. EPAM will not be deemed to have proxy voting authority solely as a result of providing advice or information about a particular proxy vote to a client. Clients will receive their proxies or other solicitations directly from their custodian or a transfer agent. Where clients own the Euro Pacific Funds in their accounts, EPAM will vote the proxies of the underlying securities within the Euro Pacific Funds, as described above, but will not vote the proxies of the Fund shares held by the client. Class Actions EPAM does not instruct or give advice to clients on whether or not to participate as a member of class action lawsuits and will not automatically file claims on the client’s behalf. However, if a client notifies us that they wish to participate in a class action, we will provide the client with any transaction information pertaining to the client’s account needed for the client to file a proof of claim in a class action.