Description of Advisory Firm EAM Investors, LLC, (“EAM,” “we,” “our” or “us”) is a majority-employee-owned investment firm headquartered in Solana Beach, California. EAM is an investment adviser registered with the U.S. Securities and Exchange Commission under the Investment Advisers Act of 1940. Our focus is managing public equity growth investment strategies. We employ the firm’s Informed Momentum™ process across all our investment products. The firm was founded in August 2007 by Travis T. Prentice, Montie L. Weisenberger, and Joshua M. Moss. EAM employees own 56% of EAM. Byron C. Roth, through majority ownership of CR Financial Holdings, Inc. and its wholly owned subsidiary WACO Limited, LLC, indirectly owns a 44% interest in the firm. Advisory Services Offered Investment Management Services EAM offers investment management and supervisory services on a discretionary basis. We provide investment management services to managed accounts. Client assets are invested and continuously managed based on a “model” account of securities that pertains to the investment style(s) selected by the client and the client’s investment objectives and restrictions. EAM offers the following investment styles: US Small Cap --seeks capital appreciation by investing in companies that correspond to the market values within the range of the Russell 2000 Growth Index. US Micro Cap --seeks capital appreciation by investing in companies that correspond to the market values within the range of the Russell Micro Cap Growth Index. US Ultra Micro Cap --seeks capital appreciation by investing in companies whose market values correspond to the bottom half of the Russell Micro Cap Growth Index. The following are definitions for each index listed above: Russell 2000 Growth Index measures the performance of those Russell 2000 Index companies with higher price-to-book ratios and higher forecasted growth values. Russell Micro Cap Growth Index measures the performance of those Russell Micro Cap Index companies with higher price-to-book ratios and higher forecasted growth values. EAM may offer investment advice on any investment held by the client at the start of the advisory relationship. New investments purchased for clients will typically include: EAM Investors, LLC Brochure Revised March 28, 2024 6
• Equity securities, including common stocks, exchange traded funds (ETFs), index funds, and real estate investment trusts (REITs)
• Investments in foreign issuers of equity securities
• Master limited partnerships (MLPs), which may trade on a public exchange or in the over-the- counter market. We describe our investment strategies and the material investment risks for many of the securities that we recommend under Item 8 – Methods of Analysis, Investment

Strategies and Risk of Loss, below. EAM may also occasionally offer advice regarding additional types of investments or strategies if they are appropriate to address the individual needs, goals, and objectives of the client or in response to client inquiry. We discuss our discretionary authority below under Item 16 - Investment Discretion. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below. We describe the fees charged for investment management services below under Item 5 - Fees and Compensation. Services to Registered Investment Companies EAM provides investment advisory services to registered investment companies (mutual funds). EAM will enter into a written agreement which outlines the services we will perform for each mutual fund. EAM currently acts as a sub-adviser to the BNY Select Managers Small Cap Growth Fund, the SEI Institutional Investments Trust Small Cap Fund, the SEI Institutional Investments Trust Small Cap II Fund, the SEI Institutional Managed Trust Small Cap Fund, and the SEI Institutional Managed Trust Small Cap Growth Fund. EAM does not purchase or recommend these funds for other investment management clients. Tailored Services and Client Imposed Restrictions EAM manages client accounts based on the investment strategy the client chooses, as discussed below under Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss. EAM applies the strategy for each client, based on the client’s individual circumstances and financial situation. We make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. Our recommendations may be limited if the client does not provide us with accurate and complete information. It is the client’s responsibility to keep EAM informed of any changes to their investment objectives or restrictions. Clients may also request other restrictions on the account, such as when a client does not want to own greater than a specific percentage of the outstanding securities of any one company, needs to keep a EAM Investors, LLC Brochure Revised March 28, 2024 7 minimum level of cash in the account or does not want EAM to buy or sell certain specific securities or security types in the account. EAM reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Assets Under Management EAM manages client assets in discretionary accounts on a continuous and regular basis. As of 12/31/2023, the total amount of assets under our management was $932,639,270.