Description of Advisory Firm Euro Pacific Asset Management, LLC (“EPAM,” “we,” “our,” “the firm,” or “us”) is a privately-owned limited liability company headquartered in Dorado, Puerto Rico. EPAM is registered as an investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Peter Schiff, a member of EPAM, and James Nelson, EPAM’s Managing Member, are the principal owners of the firm. Founded in 2009, EPAM was formed in order to provide a platform of actively managed investment products reflecting Mr. Schiff’s investment philosophy. EPAM primarily invests in international 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. 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 include 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 (“Sub- Advisory 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 advisory 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. Echelon Wealth Partners, Inc. EPAM has entered into an agreement with Echelon Wealth Partners, Inc. (“Echelon Wealth Partners”), a full- service Canadian brokerage and advisory firm registered with the Investment Industry Regulatory Organization of Canada. EPAM provides investment management services to the advisory clients of Echelon Wealth Partners on a discretionary basis for all or a portion of the client’s assets as directed

by Echelon Wealth Partners. Schiff Gold, Inc. Peter Schiff is an equity holder, exerting no majority control, in Schiff Gold, Inc., a precious metals dealer. Schiff Gold, Inc. has signed a letter of agreement to enter into a consulting services agreement with EPAM, through which the firm will provide strategic development, product development, branding and marketing services to Schiff Gold, Inc. As part of the contemplated services agreement, EPAM will receive a consulting payment from Schiff Gold, Inc. 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 in Item 5 – Fees and Compensation and in 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 in detail under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. Clients may request restrictions on their account. Restrictions must be communicated to the client’s investment advisor representative and provided to EPAM in writing. EPAM reserves the right to not 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 Specific Security 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. 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 advisory fees charged by investment advisors. 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. Assets Under Management EPAM manages client assets on a continuous and regular basis. As of February 29, 2024, our total assets under management was: Discretionary Assets $ 1,231,750,134 Non-Discretionary Assets $ 0 Total Assets $ 1,231,750,134