Firm Description Established in 1976, WCM Investment Management, LLC (“WCM” or “Firm”) is an independent investment advisory firm, registered with the SEC that specializes in providing innovative, equity investment advisory services. Principal Owners The principal owners of the Firm are Kurt Winrich and Paul Black, both of whom joined the organization in the mid-to-late 1980s. Other key owners include Sloane Payne, Michael Trigg, and Sanjay Ayer. Together they control over 75% of the company. These individuals are all employees or former employees, providing them with a stake in the Firm’s success. The Firm’s ownership is held through a holding company, Thalia Street Partners LLC. Types of Advisory Services In accordance with the methods described in the Methods of Analysis, Investment Strategies and Risk of Loss section of this brochure, WCM is an investment adviser that provides discretionary investment advisory services to Separately Managed Accounts (“SMAs”), Mutual Funds, and Private Funds as described in the Types of Clients section of this brochure. The Firm is investment adviser to the “WCM Mutual Funds,” “WCM Private Funds,” and a Collective Investment Trust (CIT). WCM is a Portfolio Manager to a Canadian fund and some Australian funds. WCM is sub-adviser to three UCITS, and the General Partner of the “WCM Private Funds”. This is all described in the Industry Affiliation section of this brochure. WCM also participates as a sub-adviser in various wrap fee programs, as described in the Advisory Business: Wrap Fee Programs section below and provides investment models to other advisers, as described in the Brokerage Practices: UMA Programs section below. Tailored Relationships For SMAs, WCM tailors its standard services to Clients’ investment objectives. Clients may impose reasonable restrictions on investing in certain securities or types of securities. Such restrictions must be submitted to WCM in writing. Client-imposed restrictions may affect WCM’s ability to implement our stated investment strategy, including how trades are executed (as described in the Brokerage Practices section of this brochure). As a result, investment performance may differ from other accounts managed in accordance with the unrestricted strategy. The Private Funds, Mutual Funds, Canadian Fund, Australian Funds, CIT and UCITS are managed only in accordance with each fund’s objectives and are not tailored to any particular fund investor (each a “Fund Investor”). Since WCM does not provide individualized advice to Fund Investors, they should consider whether a particular fund meets their investment objectives and risk tolerance prior to investing. Information about each fund can be found in each fund’s respective Private Placement Memorandum (“PPM”), Prospectus, or Offering Memorandum (“OM”). This disclosure brochure is designed solely to provide information about WCM and should not be considered an offer of interest in the WCM Funds. Wrap Fee Programs WCM provides investment advisory services with respect to accounts in wrap fee programs sponsored by various broker-dealers, investment advisers, consultants or other organizations (“Sponsors”). In these programs, Clients of the Sponsor generally receive a package of services, which includes any or all of the following: discretionary investment management, trade execution, account custody, performance monitoring, and manager evaluation. Sponsors typically: (1) assist Clients in defining their investment objectives based on information provided by the Clients; (2) determine whether the given wrap fee arrangement is suitable for each Client; (3) aid in the selection and monitoring of investment advisers (whether WCM or another adviser) to manage accounts (or a portion of account assets); and (4) periodically contact Clients to ascertain whether there have been any changes in Clients’ financial circumstances or objectives that warrant changes in the arrangement or the manner in which Clients’ assets are managed. Client information is generally channeled to WCM through the program Sponsor, and WCM relies on the Sponsor to forward current and accurate Client information on a timely basis to assist in

the day-to-day management of wrap accounts. Under certain programs, a Client may contact WCM directly concerning their account. WCM offers its discretionary investment advisory services under a number of these programs, which are described in more detail below. Wrap fee programs come in many different forms. In some programs, the Client has a contract with only the Sponsor, and the discretionary manager enters into a sub-advisory contract with the Sponsor to provide discretionary investment advisory services to the Sponsor’s Clients. In these programs, WCM is paid by the Sponsor and receives a portion of the wrap fee collected by the Sponsor. In other programs, the Client has a contract with both the Sponsor and with the discretionary adviser. In these programs, WCM generally uses its standard investment advisory agreement, and Clients usually pay the standard WCM investment advisory fee schedule, although fees and account minimums may be negotiable under certain circumstances. In broker-dealer sponsored wrap programs, the Client’s contract with the Sponsor is charged either as an asset-based fee or a transaction-based fee (i.e., commission). Currently WCM participates in only asset-based wrap fee programs. Typically, account minimums for these programs range between $100,000 and $250,000, and the wrap fee charged by the Sponsor ranges between 1.25% and 3.00%. Wrap fee arrangements are not suitable for all Clients. When evaluating wrap fee arrangements, a Client should consider a number of factors including, but not limited to: the applicable wrap fee; account size; anticipated account trading activity; the Client’s financial needs; circumstances and objectives; and the value of the various services provided. In some instances, these services may be obtained at a lower aggregate cost if purchased separately. As a provider of investment advice under a wrap program, WCM is generally not responsible for determining whether a particular wrap program, WCM’s investment style or a specific strategy is suitable, appropriate, or advisable for any particular wrap program Client. Rather, such determinations are generally the responsibility of the Sponsor and the Client (or the Client’s financial advisor and the Client). WCM is responsible only for managing the account in accordance with the selected investment strategy and any “reasonable restrictions” imposed by the Client. Although WCM is typically responsible for directing trades to brokers or dealers that it believes can provide best execution, trades for asset-based wrap fee accounts are generally executed by the Sponsor so that the Client is not charged commissions on the trades, as would be the case if WCM were to direct trades to other broker-dealers for execution. Even in the event that another broker-dealer quotes a more favorable price than that quoted by the Sponsor in a given trade, the aforementioned lower price, along with the added commission may, on balance, be less favorable to the Client than the Sponsor’s higher quoted price. Broker-dealer Sponsors providing execution services under a wrap fee are responsible for providing best price and execution for Client trades. Also, for asset-based wrap fees which cover trades executed by a broker-dealer Sponsor, Clients are charged both commissions on trades executed by other broker-dealers, as well as “mark-ups” and “mark-downs” on trades affected by the Sponsor or another dealer as principal, as well as: odd-lot differentials; transfer taxes; handling charges; exchange fees; offering concessions and related fees for purchases of unit investment trusts; mutual funds and other public offerings of securities; and other charges imposed by law with regard to transactions in Client accounts. Because Sponsors do not receive commissions from trades affected on an agency basis, Sponsors have an incentive to affect trades as principal in order to obtain “mark-ups” and “mark-downs.” Asset-based fees may be considered by the Internal Revenue Service as an investment expense, rather than a transaction charge, which may result in less favorable tax treatment for certain investors. (Clients should consult with their professional tax advisers concerning the effect of this tax treatment on their individual circumstances.) See the