Description of the Advisory Firm Kennedy Capital Management LLC was established in 1980 by Gerald Kennedy and Richard Sinise as Kennedy Capital Management, Inc. In November 2022 the firm converted from “Kennedy Capital Management, Inc.”, a Missouri S corporation, to “Kennedy Capital Management LLC”, a Delaware limited liability company. The firm is registered with the SEC pursuant to Section 203 of the Investment Advisers Act of 1940, as amended (the “Act”) and is located in St. Louis, Missouri. From 1980 to 1992, we managed accounts for high-net-worth individuals, focusing on small cap stocks. In 1993, a program was initiated to market our philosophy to institutional investors. This program was successful, eventually growing the firm in assets and allowing the company to build the investment team, compliance and operations teams to current levels. Since that time, we have supplemented our small cap strategies to include micro-cap, mid cap, SMID (combination of small and mid-cap), and all cap products. As of December 31, 2023, we employed 46 full-time people. The ownership structure is arranged so that employees own Kennedy Capital Management LLC shares through the entities KCM Holdings, Inc. and KCM Management Holdings LLC. On February 8, 2023, Kennedy Capital Management LLC and Azimut Group (“Azimut”) closed on a transaction in which Azimut, through Azimut US Holdings Inc., purchased 35% of KCM’s equity capital, with the remaining stake continuing to be widely held by existing KCM employees. Azimut will have the option to increase its stake over time. Together, we will work to grow the business in the long term through a mutually agreed 10-year business plan. As used in this Brochure, the words “we”, “our” and “us” or “KCM” refer to Kennedy Capital Management LLC. The words “you”, “your” and “client” refer to you as either a client or prospective client of Kennedy Capital Management LLC. Advisory Services With limited exceptions, we provide investment management services on a discretionary basis for institutions, investment companies, pooled investment vehicles, individual clients and additional clients as described in the section titled Types of Clients. Sub-advisory services are also provided to investment companies, wrap fee programs, model programs, UCITS funds, bank sponsored collective investment trusts and to clients of consultants and other investment advisers as described in further detail later in this section. Discretion means that we have permission to make investment decisions for your account without prior consultation with you, the client. Although most services we provide are discretionary, we also provide non-discretionary services to model programs. Please refer to the section titled Investment Discretion for additional information regarding discretion. We do not consider our services to be “financial planning” or any similar term, and we do not provide advice in the selection of other investment advisers. To determine your specific needs and financial goals, we encourage you to consult with your broker and/or financial consultant. Furthermore, as we are not tax advisers, we recommend that you consult your legal, financial, and/or tax adviser regarding your particular circumstances. SEC File Number: 801-15323 March 27, 2024 5 We primarily invest client funds in domestic equity securities, including common stocks of micro, small, mid, and large capitalization companies. We may also invest client funds in foreign equity securities. These securities may include stocks traded on a U.S. national exchange and over-the- counter such as the New York Stock Exchange and the NASDAQ, foreign non-U.S. exchanges or other applicable venues. Additionally, we may invest client funds in other securities such as preferred stock, real estate investment trusts (“REITS”), American depository receipts, American depository shares, exchange-traded funds, securities convertible to common stock, restricted securities and private placements. When purchasing or selling a security on a foreign exchange, the transaction is generally settled in local currency. Therefore, spot foreign currency transactions will be placed in your account for the purpose of trade settlement. KCM does not make direct investment in currency or in currency forwards. KCM only transacts purchases or sales on a foreign exchange in accounts for which we have been given written permission. Please refer to the section titled Methods of Analysis, Investment Strategies and Risk of Loss for a discussion of these securities and any additional types of securities that may be purchased in your account along with a discussion of the associated risks. Although we retain investment discretion over your account as outlined in the section titled Investment Discretion, you have the opportunity to place reasonable restrictions or constraints regarding specific conditions or limitations on the types of investments to be made for your account. All such restrictions or constraints, and any modifications to existing restrictions or constraints, are to be agreed upon in writing. We reserve the right to reject or to terminate an account if we believe the restrictions or constraints imposed are not reasonable or prohibit effective management of the account. You should understand that the account restrictions or constraints may affect the performance of your account, either positively or negatively. Furthermore, accounts with restrictions may result in performance dispersion due to security holdings and cash levels differing from other accounts in the same investment strategy. The portfolio manager works to maintain minimal dispersion among the accounts; therefore, accounts with restrictions may receive an allocation of a similar non-restricted security and/or may contain higher or lower cash levels than other accounts in the same strategy. Mutual Funds KCM provides discretionary investment management services to affiliated open end mutual funds. Affiliated funds are described below and collectively referred to within this Brochure as “KCM Funds”. KCM provides advisory services to the KCM Funds pursuant to an investment advisory agreement with Investment Managers Series Trust II (“IMST II”), registered under the Investment Company Act of 1940 and includes the following funds: Kennedy Capital ESG SMID Cap Fund, Kennedy Capital Small Cap Value Fund, and Kennedy Capital Small Cap Growth Fund. These funds are available in institutional share classes. KCM continuously manages the assets of the KCM Funds based on the investment objectives outlined in each of the KCM Funds’ prospectus and are generally managed in the same manner as the other accounts in each respective strategy. SEC File Number: 801-15323 March 27, 2024 6 Sub-Advisory Relationships A sub-advisory relationship is defined as one in which another firm hires an outside firm to provide investment advisory services for their clients. We have been retained to serve as sub-adviser to clients of unaffiliated registered investment advisers. Clients should understand that the unaffiliated registered investment adviser is responsible for analyzing the financial needs of its clients and for also determining the suitability of our services for their client. Clients should understand that when we have been retained to serve as sub-adviser, KCM relies solely on the unaffiliated registered investment adviser to make such determination, as we are generally not provided sufficient information by the investment adviser to perform an assessment of client suitability. Absent specific client guidelines, directed brokerage arrangements, and cash flows, we will manage these accounts similarly to other separately managed client accounts within the same strategy based on the strategy’s characteristics and the availability of cash in the individual accounts. In these sub-advisory relationships, KCM enters into a sub-advisory agreement with the unaffiliated registered investment adviser to provide portfolio management services to the adviser’s clients. As part of our sub-advisory agreements with such investment advisers, we do not pay them a fee for referring clients to us. We receive an agreed upon percentage of the fees charged by the investment adviser for the sub-advisory services. The sub-advisory agreement between us and the investment adviser states the manner and amount that we will be paid and also describes the services we will provide to the investment adviser’s clients. Clients of these investment advisers

compensate their investment adviser directly and the investment adviser in turn pays us a fee as specified in our sub- advisory agreement with the investment adviser. If our services are terminated, the fees will be pro- rated through the date of termination. With respect to the assets we manage for clients of these investment advisers that are employee benefit plans covered under Rule 408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), KCM provides services as an ERISA “fiduciary” (as defined in Section 3(21) of ERISA) and is a registered investment adviser under the Investment Advisers Act of 1940. Wrap Fee Programs Although we are a sub-adviser to wrap fee programs through wirehouse consultants, we do not sponsor any wrap account arrangements. A wrap account is where one fee (generally determined as a percentage of assets under management) is charged for investment advisory, trade execution and other services provided to a client. Wrap account arrangements, are commonly referred to as separately managed accounts, directly managed accounts, unified managed accounts, wrap accounts or similarly named arrangements (collectively, “wrap account”). These managed wrap accounts have been created by unaffiliated financial institutions (each a “Sponsor”). Wrap account clients typically enter into an agreement with a Sponsor and the Sponsor enters into a sub-advisory agreement with KCM to provide portfolio management services to the wrap account. Each Sponsor has retained us through a separate advisory agreement. “Wirehouse consulting accounts” are those referred to us by an investment consultant, financial adviser or broker (“wirehouse consultant”) affiliated with a wirehouse brokerage firm (e.g., Morgan Stanley Smith Barney, LLC). Wirehouse consulting accounts may either be: SEC File Number: 801-15323 March 27, 2024 7 A. arranged such that all fees are bundled under a wrap arrangement (where the client pays one all-inclusive asset-based fee covering custody, transaction costs, the services of the consultant or adviser and our services – “wrap wirehouse accounts”); or B. unbundled where these fees are paid separately by the client (“unbundled wirehouse accounts”). Each Sponsor is responsible for preparing and providing a brochure which contains information about its wrap fee program. Copies of each brochure are available from the Sponsor. Wrap fee program clients are encouraged to review the relevant Sponsor’s brochure for further details. Clients should understand that the Sponsor is responsible for analyzing the financial needs of each particular wrap account client and for also determining the suitability of our services for their clients. KCM relies solely on the Sponsor to make such determinations, as we are generally not provided with sufficient information by the Sponsor to perform an assessment as to the client’s suitability. Absent specific client guidelines, directed brokerage arrangements, and cash flows, we manage these accounts similarly to other separately managed client accounts within the same strategy based on the strategy’s characteristics and the availability of cash in the individual accounts. As part of our sub-advisory agreements with the Sponsors, we do not pay them a fee for referring clients to us. We receive an agreed upon percentage of the fees charged by the Sponsor for the sub- advisory services. The sub-advisory agreement between us and the Sponsor states the manner and amount that we will be paid and also describes the services we will provide to the Sponsor’s clients. Clients compensate the Sponsor directly and the Sponsor in turn pays us a fee as specified in our sub- advisory agreement with the Sponsor. Model Programs Model programs are defined as professionally managed private investment accounts that are rebalanced regularly by a Sponsor generally in accordance with instructions from an outside portfolio manager. KCM has entered into arrangements to provide models to investment advisers, broker- dealers, or other financial services companies who are Sponsors. KCM supplies the Sponsor with a model portfolio and notifies the Sponsor when changes to the model are to be made. The Sponsor offers the model to their respective clients and may choose whether or not to implement the changes provided by KCM. The placement and execution of security transactions are not made by KCM, nor does KCM assume any fiduciary duties associated with these tasks. Each Sponsor is responsible for preparing and providing a brochure which contains information about its model program. Copies of each brochure are available from the Sponsor. Clients are encouraged to review the relevant Sponsor’s brochure for further details. KCM is generally not provided with any individual client information by the Sponsor in order to perform an assessment as to the client’s suitability with the model; therefore, the Sponsor has the actual relationship with the client and the fiduciary duty to the client, including the discretion to make and implement changes in client accounts. The Sponsor has the sole responsibility for obtaining information from each client regarding the client’s investment objectives, financial information, risk tolerance and any reasonable restrictions for determining that the investment portfolio, investment model and investment strategy, provided by KCM to the Sponsor as part of the model program, is SEC File Number: 801-15323 March 27, 2024 8 initially suitable and continues to be suitable for the client. Additionally, the Sponsor is solely responsible for taking all appropriate steps to comply with anti-money laundering requirements. KCM is generally not responsible for voting securities held in the client’s portfolio. KCM is not responsible for overseeing the provision of services by a model-based program sponsor. Clients invested in a model program, typically enter into an agreement with a Sponsor and the Sponsor enters in a sub-advisory agreement with KCM to provide a model to the Sponsor. Each Sponsor has retained us through a separate investment sub-advisory agreement. The sub-advisory agreement between KCM and the Sponsor states the manner and amount that we will be paid. We do not pay the Sponsor a fee for referring clients to us although we may pay a fee to a Sponsor to be included on their platform. In the model-based program, the Sponsor pays KCM a fee for the amount of assets managed within the program. Clients compensate the Sponsor directly and the Sponsor in turn pays us a fee as specified in our sub-advisory agreement with the Sponsor. KCM has entered into an Investment Advisory Agreement with Azimut Investments S.A., (“AI SA”) a registered Luxembourg adviser and an affiliate of KCM. KCM shall provide AI SA with one or more model portfolios but will not make any investment decisions nor manage the investments of the model portfolio(s) for AI SA. AI SA is an asset management affiliate of Azimut. KCM does not assume any fiduciary duties associated with the management of accounts by AI SA. AI SA shall pay KCM, on a quarterly basis, a percentage of the net quarterly management fees charged to clients per model portfolio. On an annual basis, KCM shall also receive a percentage of the variable management fees that AI SA earns annually with respect to each model portfolio. Clients should understand that the variable management fee is akin to a performance-based fee. KCM has an incentive to prioritize offering AI SA model portfolios over Sponsors who may not be paying KCM a performance-based fee. We believe this conflict is mitigated by ensuring that the model portfolios are consistently and appropriately subject to the same pro-rata allocation between AI SA and other Sponsors or investment advisors. Please refer to the section titled Brokerage Practices for further information. Investment Manager Services We serve as investment manager to the Kennedy Capital Small Cap Value Collective Investment Trust (“CIT”) sponsored by SEI Trust Company. We serve as the investment manager pursuant to an investment sub-adviser and administrative services agreement and receive a fee for managing the investment portfolio. The CIT has not been registered under federal or state securities laws and is subject to an exemption provided by Rule 3(c)(11) of the Investment Company Act of 1940. The CIT is only available for investment by qualified retirement plans and are not for sale to the general public. Assets Under Management We have the following assets under management as of 12/31/2023: Non-Discretionary Assets: Discretionary Assets: Total Firm Assets: $22,765,959 $4,747,042,933 $4,769,808,892 SEC File Number: 801-15323 March 27, 2024 9