Firm Description Rule Advisors, LLC (‘we,” “us,” “our,” or “Rule Advisors”) a Delaware Limited Liability Company, was formed in October of 2020 and is 100% owned by Arthur Richards “Rick” Rule IV, who is responsible for the overall investment strategy and investment management of client portfolios. Types of Advisory Services Sub-Advisory Services – Separate Account Management Rule Advisors acts as a sub-advisor to both affiliated and unaffiliated investment advisers. The affiliated advisers are affiliates of Sprott Inc., a publicly traded company listed on the New York and Toronto Stock Exchanges. The full legal name of an affiliated entity will be used to make specific disclosures in this document; other references to affiliates generally will use the term “Sprott” or “Sprott-related.” See Item 10 for additional information regarding affiliated entities of Sprott Inc. The third-party advisor (“TPA”) selects Rule Advisors to manage separate accounts overseen by the TPA. Our agreement is with the TPA, not with the end client, and the TPA retains the discretionary authority to hire us, as well as to terminate our services. The TPA is responsible for determining that Rule Advisors’ strategies are appropriate for the TPA’s client and for ongoing monitoring of our management in light of the end-client’s needs. Sub Advisory Services – Pooled Investment Vehicles Rule Advisors also provides sub-advisory investment management services on a discretionary or non- discretionary basis to privately offered pooled investment vehicles exempt from registration under the Investment Company Act of 1940, as amended. Sub-advisory services are provided both directly to the pooled vehicle as well as to other fund sub-advisors. The TPA or the TPA’s sub-advisor selects Rule Advisors to manage the

selected funds, based on the TPA or sub-advisor’s view that Rule Advisors’ strategies are consistent with the fund’s objectives. Both our separate account management and private fund sub-advisory services focus on natural resources, across the investment cycle. We invest primarily in the publicly traded debt and equity securities of companies listed in Australia, Canada, Great Britain and the Unites States, using a bottom-up investment selection process, considering financial, geological, and engineering factors, with a contrarian approach. We primarily invest in micro- and small-cap companies, with strategic investments in mid- and large-cap companies as opportunities arise. Consulting Services Rule Advisors offer strategic advice to issuers, on a flat fee or hourly basis, as negotiated between Rule Advisors and the issuer. The specific services provided will be described in the agreement between us and the issuer, but will generally be focused on company growth. This creates a potential conflict in that these issuers will most likely also be held in the portfolios we advise. Please see Item 10 for additional information and conflicts related to our consulting services. Other information about our Services We manage all assets on a discretionary basis, although the TPA’s that select us may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. However, as noted above, our strategies are focused primarily within the natural resource sector, consequently, any restrictions specific to that sector cannot be accepted. Participation in Wrap Fee Programs We do not offer or participate in a Wrap Fee Program. Assets Under Management As of December 31, 2023, we managed $136,504,873 in assets, all on a discretionary basis.