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 1980’s. Other key owners include Sloane Payne, Peter Hunkel, Michael Trigg, Sanjay Ayer, David Brewer, Matt MacArthur, Duff Daniels, Bill Orke, and Andrew Wiechert. Together they control about 93% of the company. These individuals are all employees. This provides employees 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
WCM is an investment adviser that provides investment advisory services on a discretionary basis in accordance with the methods described in the Methods of Analysis, Investment Strategies and Risk of Loss section of this brochure. WCM provides discretionary investment advisory services to Separately Managed Accounts, 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”, a Collective Investment Trust (CIT), a Canadian fund and some Australian funds. WCM is sub-adviser for two 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 our investment models to a few advisers, as described in the Brokerage Practices: UMA Programs section below.
Tailored Relationships
For Separately Managed Accounts, WCM’s standard services are tailored to our Client’s 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); therefore, 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 so called “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 please register to get more info

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 his or her 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, the Client has a contract only with 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), but WCM currently participates only in asset-based wrap fee programs. Typical 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%. In evaluating wrap fee arrangements, a Client should consider a number of factors. Wrap fee arrangements are not be suitable for all Clients. Suitability depends on 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. Although WCM is typically responsible for directing trades to brokers or dealers that it believes are capable of providing 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 receive no 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 Brokerage Practices: Wrap Fee Programs section of this brochure for additional information.
UMA Programs
WCM provides model portfolio recommendations for UMA (“Unified Managed Account”) Programs offered by broker-dealers, advisers and other Sponsors (“Sponsors”). WCM delivers the model portfolio recommendations to Sponsors on a rotational basis for trading by the Sponsor. See the Brokerage Practices: UMA Programs section for more details.
Back Office Support
In connection with certain directed trading accounts, WCM has engaged SEI Global Services, Inc. (“SEI”), to provide certain back-office support services on our behalf. SEI’s services to us include, but are not limited to, trading, settlements, reconciliation, and account maintenance. We continue to monitor accounts serviced by SEI, and we supervise all functions performed on behalf of our firm and our clients.
Client Assets
As of December 31, 2019, WCM managed $42,672 million assets on a discretionary basis. WCM also provides model portfolio recommendations for $6,228 million in UMA Programs. Fees and Compensation WCM charges advisory fees based on the value of Client assets managed. Unless otherwise specifically provided for, valuation of securities follows WCM’s Valuation Policy.
Separately Managed Account Fees
The specific manner in which WCM charges advisory fees for separately managed account fees for the client’s portfolio is set out in the investment management agreement. Generally, Separately Managed Account fees are payable quarterly in advance and are calculated based on the value of an account’s assets on the last business day of each calendar quarter. If an account commences or terminates on a date other than the first or last business day of a billing period, the fee is prorated based upon the portion of the billing period in which WCM provided services. All unearned, pre-paid fees will be refunded upon account termination. At WCM’s discretion, assets of related accounts, such as family or business relationship, may be aggregated for purposes of calculating the applicable advisory fee. Separately Managed Account agreements may be terminated at any time by either party, for any reason upon written notice. When fees are paid in advance and a significant Client deposit or withdrawal occurs, fees may be adjusted, as specified in a Client Investment Management Agreement. A significant deposit or withdrawal is typically defined as a capital flow in excess of 25%. An adjustment is calculated based on the amount of the deposit or withdrawal applied to the fee schedule and prorated for the portion of the calendar quarter in which WCM provided services. Such adjustments are generally applied in the subsequent billing period. WCM’s standard fee schedule is 1% of assets under management for Separately Managed Accounts, and the minimum account size is $10 million. Management fees and minimums are negotiable. To the extent that fees are negotiable, some Clients may pay more or less than other Clients for the same management services, depending, for example, on account inception date, number of related investment accounts or total assets under management. WCM will also, in its sole discretion, charge lower management fees or waive account minimums based on certain criteria (e.g., historical relationship, related accounts, account composition, anticipated future earning capacity, anticipated future additional assets, accounts referred to adviser by another professional, etc.). We charge lower fees for accounts managed through wrap-fee programs, or pursuant to other consulting or referral arrangements in which broker-dealers, investment advisers, trust companies and other providers of financial services typically provide Clients with services that complement or supplement our services. Fees for such accounts vary depending on the nature of the arrangement and other circumstances. Additionally, fee reductions or waivers are available to WCM personnel and their family members. Clients may either choose to pay management fees themselves or, with Client authorization, management fees may be automatically deducted quarterly from Client accounts by billing their custodians. In either case, Clients receive an invoice detailing the management fee calculation. Typically, Clients are charged fees in addition to the advisory fee paid WCM, which can include brokerage commissions and other custodian fees. Please refer to the section entitled Brokerage Practices for more information. To the extent that Client assets may be invested in shares of non-WCM-related investment companies (e.g., mutual funds, ETFs), these assets are included in calculating the value of an account for purposes of computing WCM’s fees, and are also subject to additional advisory and other fees and expenses as set forth in the prospectuses or offering memoranda of those investment companies, which are paid by the investment companies, but ultimately borne by investors. For Client assets invested in the WCM Mutual Funds for reasons other than tax-loss selling, and for which WCM serves as the adviser or sub-adviser, these assets are excluded in calculating the value of an account for purposes of computing WCM’s fees.
WCM Private Fund Fees
Fees for WCM Private Funds are described in each private fund’s respective Private Placement Memorandum (“PPM”). Investors are generally charged an advisory fee, payable quarterly, based upon the net asset value of the capital account of each investor on the first day of each calendar quarter. The WCM Focused Global Growth Long-Short Fund L.P. is entitled to an additional fee based on any net profit allocation. The private funds also pay brokerage commissions, as well as other transaction and fund-related expenses. As General Partner to the WCM Private Funds, WCM will not pay an advisory fee on its capital account, and advisory fees may be altered, reduced or waived with respect to investors who are related parties or persons of the General Partner, or those deemed to involve a significant or strategic relationship. Thus, different investors will pay different advisory fees. As General Partner, WCM directly accesses the assets of the WCM Private Funds for payment of Fund expenses as described in the Fund’s PPM. WCM complies with the requirements of the Custody Rule with regard to the WCM Private Funds. Specific procedures and restrictions apply to redemptions, as described in each private fund’s respective PPM. The General Partner, in its sole discretion, may impose minimum redemption amounts and require the maintenance of a minimum capital account size in the event of a partial redemption. The General Partner may also, in its sole discretion, require an investor to redeem all or part of its interest in a private fund to ensure that the private fund remains in compliance with applicable law, or for any or no reason at all.
WCM Mutual Fund Fees
Information on the fees and expenses paid directly from each WCM Mutual Fund and the funds’ service providers are described in each funds’ Prospectus. Such fees include management fees (paid to WCM) and other expenses (paid to fund service providers). The WCM Mutual Funds are no-load funds and have multiple class structures. The class structures represent the same underlying investments. Only the Investor Share Class pays a 12b-1 fee, which is primarily used to pay for distribution expenses on non- transaction fee platforms. A portion of the 12b-1 fees could be paid to WCM by the Funds’ distributor for reimbursement of marketing and distribution services. This conflict of interest is mitigated by the fact that WCM does not recommend one class share over another, rather the class share is chosen by the client based on eligibility. See Account Minimum section below. Additionally, each fund pays brokerage commissions, as well as other transaction or fund-related expenses out of each respective fund. The higher expenses associated with the Investor Share Class will reduce an investor’s return over time. As discussed above, the value of the WCM Mutual Funds is excluded from the value of the assets for the calculation of the management fees when a client account holds WCM Mutual Funds for reasons other than tax-loss selling.
Other Fund Fees
Fees for the Canadian Fund, Australian Funds, CIT and UCITS are described in each fund’s respective disclosure documents.
Compensation for the Sales of Investment Products
WCM’s Investment Adviser Representatives ("IARs") are licensed as agents with a broker-dealer. In such capacity, the IARs will discuss and offer WCM Funds to institutional clients and investment consultants. This presents no conflict of interest as there is no incentive for IARs to recommend one investment vehicle over another based on the compensation received, because the fee sharing arrangements are the same for all vehicles. In addition, there is no incentive for the IARs to recommend one Share Class over another as no portion of the 12b-1 fee is passed on to the IAR. Clients have the option to purchase investment products that are recommended through other brokers or agents that are not affiliated with us. Performance-Based Fees and Side-By- Side Management
Performance-Based Fees
Performance-based fees are based on a percentage of the capital appreciation of the assets in a fund or account. In limited circumstances, WCM accepts client requests to charge a performance-based fee. Because WCM manages accounts that are charged an asset-based fee and accounts that are charged a performance-based fee, there is an incentive for WCM to favor accounts for which we receive a performance-based fee and/or to make investments that are riskier or more speculative than would be the case in the absence of such a compensation framework. Please refer to the Brokerage Practices section for additional information on how WCM mitigates such presented conflicts by aggregating orders.
Side-By-Side Management
Management of multiple portfolios gives rise to conflicts of interest. The conflicts of interest that arise in managing multiple accounts include, for example, conflicts among investment strategies or conflicts in the allocation of investment opportunities. WCM mitigates these conflicts of interest through our Order Aggregation and Trade Rotation policies and procedures, designed so that all client accounts are treated fairly and equitably and that no one client account receives, over time, preferential treatment over another, as described in the Brokerage Practices section below. In addition, WCM uses a model portfolio as the basis of portfolio construction for separate accounts in the same strategy so those accounts are treated the same, subject to each client’s investment mandate. WCM performs a periodic review of each investment strategy’s model portfolio versus each client account. In this review, every position size for each client account is compared to our model weights. In addition, portfolios are monitored by our compliance department for consistency with client objectives and restrictions. WCM has another potential conflict of interest, as an adviser to both long-only accounts and accounts that execute short sales. WCM could sell short securities in a long-short account in one strategy while holding the same security long in a long-only account in another strategy. In this case, we could harm the performance of the long-only accounts for the benefit of accounts that execute short sales, which may include performance-based fee accounts. For example, continually selling a position short may depress the stock price, potentially harming a long-only account if it holds the same security. To mitigate this conflict of interest WCM has a specific policy that requires pre-approval of a short position, in the event the same security is held as a long position by another managed account. Compliance periodically performs side-by-side testing of the trades in these accounts to ensure all clients are being treated fairly.

Types of Clients
Description
WCM generally provides discretionary investment advisory services to institutional clients, such as pension and profit sharing plans, business entities, charitable organizations, foundations, endowments, trusts and public funds; individuals (collectively, “Separately Managed Accounts”); mutual funds (“Mutual Funds”), privately placed pooled investment vehicles organized as limited partnerships (“Private Funds”); CITs, Canadian Fund, Australian Funds and UCITS; (collectively, “Clients”.)
Account Minimums
WCM’s minimum account size for a Separately Managed Account is $10 million as noted under Separately Managed Account Fees section. Minimums are sometimes waived depending on the circumstances. It is not required that a minimum be maintained as a condition of continued management. Initial minimum investment requirements for the WCM Private Funds is $5 million. Initial minimum investment requirements for the WCM Mutual Funds is $100 thousand for the Institutional Share Class and $1 thousand for the Investor Share Class. Additional details regarding the minimum investment requirements are set forth in each fund’s respective Private Placement Memorandum, Prospectus or Offering Memorandum. This disclosure brochure is designed solely to provide information about WCM and should not be considered to be an offer of interest in the WCM Funds. Methods of Analysis, Investment Strategies and Risk of Loss
Types of Investments
At the highest level, our investment philosophy rests on four timeless principles in support of our overall goal of providing significant, long-term excess return (“alpha”) over appropriate benchmarks: 1. Differentiation: we believe that to outperform a benchmark, a portfolio has to be meaningfully different than the benchmark; 2. Simplicity: regardless of approach, we think that unnecessary complication ultimately detracts from returns; 3. Culture: we believe that successful investing includes an element of gifted ability, so we strive to foster a firm culture that attracts and keeps gifted investors, including a commitment to keep the firm simple, and thus relatively small; and 4. Temperament: we think that temperament—which includes discipline, patience, the ability to look through the short term to the long term—is a necessary ingredient in the recipe for long-term excess return. Our firm’s overall vision embraces multiple strategies, each run by gifted, passionate investors within an atmosphere of inquiry and intellectual rigor. We believe this ensures that investment results are not constrained by the arbitrary orthodoxy that defines traditional methodologies.
Methods of Analysis & Investment Philosophy
WCM employs a bottom-up, fundamental method of analysis that emphasizes long-horizon growth prospects, competitive advantages, and company cultures conducive to attracting great people. Valuation also plays an important factor in our analysis method, predominantly impacting the timing of decisions and portfolio position sizing.
Investment Philosophy
The philosophical underpinnings for our strategies are comprised of several key elements:
1) Structural Differentiation
It should be clear that to outperform the benchmark, the portfolio has to be meaningfully different from the benchmark. Unconstrained from the benchmark, we are free to seek those companies we believe will benefit from their competitive positioning and/or favorable long term trends developing throughout the world. This provides us with a significant structural advantage as we strive towards the goal of providing significant, long-term excess return (“alpha”).
2) Company Culture
We believe that successful investing includes an element of gifted ability, so we strive to foster a firm culture that attracts and keeps gifted investors, including a commitment to keep the firm simple, and thus relatively small. In a similar way, we view corporate culture as important to the long-term success of any enterprise. So, when selecting companies, we work on understanding the “DNA” of the enterprise. As but one example, we view as extremely important the strength, quality and trustworthiness of management. We think a primary goal of any company should be to attract and retain quality people. In our view, the culture is what foundationally enables the success or failure of a business, and what separates the great businesses from the mere good ones.
3) Focused Portfolio
Since our objective is to significantly outperform the indices over an extended period of time, we employ a focused approach to investing. We believe exceptional returns can only be achieved by structuring a portfolio distinct from the indices, so we concentrate on our best ideas. Said positively, we would rather own a lot of a good company than a little bit of an average one. Said negatively, we refuse to dilute the portfolio with inferior ideas.
4) Temperament
The longer we are in this investment business, the more convinced we become that temperament is what sets the great investors apart from the pack. Temperament is that attitude or approach to investing that includes discipline, patience, the ability to look through the short term to the long term, the ability to “buy when others are despondently selling and sell when others are greedily buying,” as Templeton used to say, and the ability to stay rational when all your emotions are screaming at you to be otherwise. We think temperament is an oft- overlooked yet important “edge” an investor can have.
Investment Strategies
Our strategies utilize different capitalization ranges (e.g., large-cap, small-cap, all-cap,) different geographical scopes (e.g., international, global, emerging markets, U.S. domestic) and different security types (e.g., foreign ordinary shares, American Depository Receipts “ADR”.)
Global Growth Equity Strategies:
Focused Growth International Seeks non-US, quality growth businesses with strengthening competitive advantages (“economic moats”), supported by moat-aligned corporate cultures and durable global tailwinds. These companies tend to have high or rising returns on invested capital, superior growth prospects, and low (or no) debt. Vehicles: Separately Managed Accounts, Private Fund, Mutual Fund, CIT, Wrap Programs, UMA Program Material Risks: Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Frontier Market, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuers

Quality Global Growth Seeks global, quality growth businesses with strengthening competitive advantages (“economic moats”), supported by moat-aligned corporate cultures and durable global tailwinds. These companies tend to have high or rising returns on invested capital, superior growth prospects, and low (or no) debt. Vehicles: Separately Managed Accounts, Private Fund, Mutual Fund, UCITS, Canadian Fund, Australian Fund, Wrap Program, UMA Program Material Risks: Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Frontier Market, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuers

Emerging Markets Seeks emerging markets, quality growth businesses in with strengthening competitive advantages (“economic moats”), supported by moat-aligned corporate cultures and durable global tailwinds. These companies tend to have high or rising returns on invested capital, superior growth prospects, and low (or no) debt. Vehicles: Separately Managed Accounts, Private Fund, Mutual Fund, SICAV Material Risks: Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Frontier Market, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuers International Small Cap Growth Seeks small-cap, non-US, quality growth businesses with strengthening competitive advantages (“economic moats”), supported by moat-aligned corporate cultures and durable global tailwinds. These companies tend to have high or rising returns on invested capital, superior growth prospects, and low (or no) debt. Vehicles: Separately Managed Accounts, Private Fund, Mutual Fund Material Risks: Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Frontier Market, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuers China Quality Growth Seeks Chinese, quality growth businesses with strengthening competitive advantages (“economic moats”), supported by moat-aligned corporate cultures and durable global tailwinds. These companies tend to have high or rising returns on invested capital, superior growth prospects, and low (or no) debt. Vehicles: Separately Managed Accounts, Mutual Fund Material Risks: Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuer

Quality Global Growth Long-Short Seeks a long position in global, quality growth businesses with strengthening competitive advantages (“economic moats”), supported by moat-aligned corporate cultures and durable global tailwinds. These companies tend to have high or rising returns on invested capital, superior growth prospects, and low (or no) debt.

Seeks to short global businesses with low or falling returns on invested capital, high potential for negative operating leverage, decreasing margins, macro sensitivity, and/or a history of low to no-or decreasing-growth Vehicles: Private Fund Material Risks: Counterparty, Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Frontier Market, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuer, Short Sale
U.S. Value Strategies:
Focused Small Cap Seeks U.S. small cap businesses with durable competitive advantages and shareholder-friendly management teams, trading at discounts to their intrinsic values. Characteristics of these businesses include sustained, high returns on invested capital, consistent free cash flow generation, and impressive compounding of net book value over time. Vehicles: Separately Managed Accounts, Mutual Fund Material Risks: Equity, Focused Portfolio, Interest-rate, Management and Strategy, Market and Focused SMID Cap Seeks U.S. smid-cap businesses with durable competitive advantages and shareholder-friendly management teams, trading at discounts to their intrinsic values. Characteristics of these businesses include sustained, high returns on invested capital, consistent free cash flow generation, and impressive compounding of net book value over time. Vehicles: Separately Managed Accounts Material Risks: Equity, Focused Portfolio, Interest-rate, Management and Strategy, Market and Focused Mid Cap Seeks U.S. mid-cap businesses with durable competitive advantages and shareholder-friendly management teams, trading at discounts to their intrinsic values. Characteristics of these businesses include sustained, high returns on invested capital, consistent free cash flow generation, and impressive compounding of net book value over time. Vehicles: Separately Managed Accounts Material Risks: Equity, Focused Portfolio, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuers
U.S. Growth Strategies:

Small Cap Growth Seeks U.S. small cap growth businesses with increasing cash flow returns on invested capital, growing asset bases, and the ability to reinvest cash flows into additional assets to generate recursive business models. Vehicles: Separately Managed Accounts, Mutual Fund, Wrap Program Material Risks: Equity, Focused Portfolio, Interest-rate, Management and Strategy, Market and Focused US Growth Opportunities Seeks U.S. smid-cap growth businesses with increasing cash flow returns on invested capital, growing asset bases, and the ability to reinvest cash flows into additional assets to generate recursive business models. Vehicles: Separately Managed Accounts, Mutual Fund, Wrap Program Material Risks: Equity, Focused Portfolio, Interest-rate, Management and Strategy, Market and Select US Growth Seeks U.S. small cap growth businesses with increasing cash flow returns on invested capital, growing asset bases, and the ability to reinvest cash flows into additional assets to generate recursive business models. Vehicles: Separately Managed Accounts, Mutual Fund, Wrap Program Material Risks: Equity, Focused Portfolio, Interest-rate, Management and Strategy, Market and
ESG Equity Strategies:
Focused ESG International Seeks international businesses that exhibit strong or strengthening competitive advantages (“economic moats”), wide runways for growth within their core competencies, and strong or strengthening ESG characteristics (“ESG trajectory”). Vehicles: Separately Managed Accounts, Mutual Fund Material Risks: Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Frontier Market, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuer

Focused ESG Global Seeks global businesses that exhibit strong or strengthening competitive advantages (“economic moats”), wide runways for growth within their core competencies, and strong or strengthening ESG characteristics (“ESG trajectory”). Vehicles: Separately Managed Accounts Material Risks: Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Frontier Market, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuer Focused ESG Emerging Markets Seeks emerging markets businesses that exhibit strong or strengthening competitive advantages (“economic moats”), wide runways for growth within their core competencies, and strong or strengthening ESG characteristics (“ESG trajectory”). Vehicles: Separately Managed Accounts, Mutual Fund Material Risks: Currency, Emerging Market, Equity, Focused Portfolio, Foreign Equity, Frontier Market, Interest-rate, Management and Strategy, Market and Economic, Market Capitalization, Risks Affecting Specific Issuer
Risk of Loss
Although WCM makes every effort to preserve each Client’s capital and achieve real growth of wealth, investing involves risk of loss that each Client should be prepared to bear. The following is a brief description of the material risks associated with an investment in the investment strategies described above, as well as other general risks with WCM. Counterparty Risk: The risk that counterparties may encounter financial difficulties, fail, or otherwise become unable to meet their obligations. The long-short strategy may invest in securities and derivatives that have institutional counterparties, including brokerage firms and banks; client assets may also be entrusted for custodial and prime brokerage purposes to such counterparties. Any such development could cause damaging losses, or even complete loss, of investors’ capital. In the event that the counterparty to such a derivative instrument becomes insolvent, a strategy potentially could lose all or a large portion of its investment in the derivative instrument. Currency Risk: Non-U.S. securities that trade in, and receive revenues in, foreign currencies are subject to the risk that those currencies will fluctuate in value relative to the U.S. dollar. Cybersecurity and Disaster Recovery Risk: With the increased use of technologies such as the Internet and the dependence on computer systems to perform necessary business functions, WCM and its service providers may be prone to operational and information security risks resulting from cyber-attacks and/or other technological malfunctions and also those risks associated with power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. In general, cyber-attacks are deliberate, but unintentional events may have similar effects. Cyber-attacks include, among other things, stealing or corrupting data maintained online or digitally, preventing legitimate users from accessing information or services on a website, releasing confidential information without authorization, and causing operational disruption. Successful cyber- attacks against, or security breakdowns of WCM or other third-party service provider may adversely affect the clients. For instance, cyber-attacks and/or certain disasters may affect WCM’s cause the release of private client information or confidential firm information, impede trading, cause WCM’s information and technology systems to become inoperable for extended periods of time or to cease to function properly, expose WCM to theft or embezzlement, cause reputational damage, and subject WCM to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, and additional compliance costs. While WCM and its service providers have established business continuity plans, disaster recovery plans, and systems designed to prevent or reduce the impact of cyber-attacks, such plans and systems have inherent limitations due in part to the ever-changing nature of technology and cyber security attack tactics, and there is a possibility that certain risks have not been adequately identified or prepared for. There is also a risk that cybersecurity breaches may not be detected. Please refer to the section in this document titled Additional Disclosures: Summary of Business Continuity and Disaster Recovery Plan, below. Emerging Markets Risk: Investments in emerging market countries involve exposure to changes in economic and political factors. The economies of most emerging market countries are in the infancy stage of capital market development. As a result, their economic systems are still evolving and their political systems are typically less stable than those in developed economies. For example, emerging market countries can suffer from currency devaluation and higher rates of inflation. Equity Risk: Investment in equity securities involves risks and may be subject to wide and sudden fluctuations in market value, with a resulting fluctuation in the amount of profits and losses. The market value of a stock may fluctuate for any number of reasons that directly relate to the company, such as management performance, financial leverage, and reduced demand for the company’s goods or services. Focused Portfolio Risk: By definition, concentrated portfolios hold larger position sizes. In principle, a large loss in any one holding has a greater impact on portfolio return for a concentrated portfolio than it would for a broadly diversified portfolio. Foreign Equity Risk: This is the risk that prices of non-U.S. securities may be more volatile than those of U.S. securities because of reduced liquidity, economic conditions abroad, political developments, and changes in the regulatory environment of foreign countries. Non-U.S. companies are generally subject to different legal and accounting standards than U.S. companies, and foreign financial intermediaries may be subject to less supervision and regulation than U.S. financial firms. In some countries there are restrictions on investments or investors such that the only practicable way to invest in such markets is by entering into swaps or other derivative transactions. Such transactions involve counterparty risks which are not present in the case of direct investments. Frontier Market Risk: Frontier market countries generally have smaller economies and even less developed capital markets than traditional emerging markets, and as a result, the risks of investing in emerging market countries are magnified in frontier market countries. The magnification of risks are the result of potential for extreme price volatility and illiquidity in frontier markets; government ownership or control of parts of private sector and of certain companies; trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which frontier market countries trade; and the relatively new and unsettled securities laws in many frontier market countries. Interest-rate Risk: Fluctuations in interest rates may cause stock prices to fluctuate. For example, companies with higher rates of earnings growth, selling at higher price/earnings ratios, may be more susceptible to price declines if interest rates rise. Management and Strategy Risk: The value of your investment depends on the judgment of WCM about the quality, relative yield, value or market trends affecting a particular security, industry, sector or region, which may prove to be incorrect. Investment strategies employed by WCM in selecting investments for a strategy may not result in an increase in the value of your investment or in overall performance equal to other investments. Market and Economic Risk: This is the risk that portfolio value may be affected by a sudden overall price decline in the financial markets. The prices of equities may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a stock’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. Market Capitalization Risk: Larger, more established companies may be unable to attain the high growth rates of successful, smaller companies during periods of economic expansion. In addition, large-capitalization companies may be unable to respond quickly to new competitive challenges, such as changes in technology and consumer tastes and may be more prone to global economic risks. Investing in small-capitalization and mid- capitalization companies generally involves greater risks than investing in large- capitalization companies. Small- or mid-cap companies may have limited product lines, markets or financial resources or may depend on the expertise of a few people and may be subject to more abrupt or erratic market movements than securities of larger, more established companies or market averages in general. Many small capitalization companies may be in the early stages of development. Since equity securities of smaller companies may lack sufficient market liquidity and may not be regularly traded, it may be difficult or impossible to sell securities at an advantageous time or a desirable price. Risks Affecting Specific Issuers: The value of an equity security or debt obligation may decline in response to developments affecting the specific issuer of the security or obligation, even if the overall industry or economy is unaffected. These developments may include a variety of factors, including but not limited to management issues or other corporate disruption, political factors adversely affecting governmental issuers, a decline in revenues or profitability, an increase in costs, or an adverse effect on the issuer’s competitive position. Short Sale Risk: A short sale involves the sale of a borrowed security, in anticipation of purchasing that same security at a lower price in the future in order to close the short position. If the value of the borrowed security increases between the date the account enters into the short sale and the date that the account buys that security to cover its short position, the account may experience a loss. Disciplinary Information Neither WCM nor any of its management personnel have been involved in a disciplinary proceeding. In addition, they have not been involved in any legal proceeding that might reasonably be considered material to a Client’s evaluation of WCM’s advisory business or the integrity of its management. Other Financial Industry Activities and Affiliations
Industry Activities
Some of WCM’s Investment Adviser Representatives ("IARs") are licensed as agents with a broker- dealer. In such capacity, the IARs will discuss and offer WCM Funds to institutional clients and investment consultants. For further information, see the Fees and Compensation and Code of Ethics sections.
Industry Affiliations
Mutual Fund As noted earlier in Types of Advisory Services section, WCM serves as the adviser to the following WCM Mutual Funds.:
• WCM Focused International Growth Fund
• WCM Focused Global Growth Fund
• WCM Focused Emerging Markets Fund
• WCM International Small Cap Growth Fund
• WCM Focused Small Cap Fund
• WCM Small Cap Growth Fund
• WCM Focused ESG International Fund
• WCM Focused ESG Emerging Markets Fund
• WCM China Quality Growth Fund If deemed by WCM to be in the Client’s best interest, WCM invests Clients in such mutual funds. The WCM Mutual Funds are advised by WCM following WCM’s investment philosophy and management strategies. Fees paid to WCM with respect to the WCM Mutual Funds are described in the Fees and Compensation section. Private Fund As noted earlier in Types of Advisory Services section, WCM serves as adviser and General Partner to the following WCM Private Funds:
• WCM Focused International Growth Fund LP
• WCM Focused Global Growth Fund LP
• WCM Focused Emerging Markets Fund LP
• WCM International Small Cap Growth Fund LP
• WCM Focused Global Growth Long-Short Fund (master-feeder structure with one onshore and one offshore fund: The WCM Focused Global Growth Long-Short Offshore Fund Ltd. is a Cayman Islands exempted company and invests all of its assets in limited partnership interests of the Master Fund, the WCM Focused Global Growth Long-Short Fund L.P., a Delaware limited partnership]

WCM IARs will offer the private funds to eligible Clients as a possible vehicle for investing in one of WCM’s strategies. The WCM Private Funds are advised by WCM following WCM’s respective investment philosophy and management strategy. Fees paid to WCM with respect to the WCM Private Funds are described in the Fees and Compensation section. Canadian Fund As noted earlier in Types of Advisory Services section, WCM serves as the adviser to the WCM (Canada) Focused Global Growth Fund. This fund is available for eligible (Canadian) clients, who are interested in our Quality Global Growth strategy. Australian Funds As described earlier in Types of Advisory Services section, WCM serves as the adviser to the WCM Global Growth LIC, WCM Quality Global Growth ETMF, WCM Quality Global Growth Managed Fund, and WCM International Small Cap Growth Fund. These funds are available for eligible (Australian) clients who are interested in our Quality Global Growth and International Small Cap Growth strategies. CIT As noted earlier in Types of Advisory Services section, WCM serves as the adviser to a Collective Investment Trust, the WCM Focused Growth International CIT. This fund is offered to eligible U.S. 401k and other retirement and employee benefit plans that are interested in our Focused Growth International strategy. UCITS As noted earlier in Types of Advisory Services section, WCM serves as the sub-adviser to the following UCITS, which are investment companies operating pursuant to the European Union’s UCITS (Undertakings for Collective Investment in Transferable Securities) Regulations:
• WCM Global Equity Fund of Heptagon Fund plc
• WCM Global Emerging Markets Equity Fund The funds are offered to eligible non-U.S. clients, who are interested in our Quality Global Growth strategy.
Material Industry Business Relationships
Natixis Natixis IM holds a minority equity interest in WCM Investment Management, LLC. As described below, WCM and Natixis IM and its affiliates have also entered into a global distribution relationship. Natixis IM is not an advisory affiliate or related person of WCM, and the operations and management of WCM are completely separate and independent of Natixis IM and all of its affiliates. To avoid the appearance of any conflicts of interest, WCM has implemented a policy of not entering into transactions (e.g. trade execution, participation in underwritings, cross trades, etc.) with Natixis IM or any Natixis affiliates on behalf of WCM’s clients. However, WCM does engage in business activities with some of these entities, subject to its policies and procedures governing conflicts of interest. These activities are generally limited to UMA model recommendation, marketing and referral arrangements. WCM has been engaged by Natixis Global Asset Management (“NGAM”) Advisors to provide investment recommendations (UMA Program model recommendations) to assist NGAM Advisors in providing non- discretionary model portfolio provider services. These recommendations are subject to WCM’s trade aggregation, allocation and rotation procedures that require equitable allocation of trades among accounts. See the Brokerage Practices section below. Natixis Distribution, L.P., Natixis Advisors, L.P., Natixis Investment Managers S.A. and WCM have also entered into certain referral agreements. These agreements provide that Natixis IM and Natixis IM affiliates, generally on a global basis, will (or will enter into distribution arrangements with third parties for such third parties to) provide consulting, sales and other distribution-related services with respect to investment products advised or sub-advised by WCM (other than the WCM Mutual Funds, which are discussed below) in exchange for certain fees. These agreements are subject to Rule 206(4)-3 under the Investment Advisers Act of 1940 (Cash Solicitation Rule). For information about referral arrangements, see the Client Referrals and Other Compensation section. In addition, Natixis Distribution, L.P. acts as the principal underwriter to the WCM Mutual Funds. In connection therewith, WCM and Natixis Distribution, L.P., a subsidiary of Natixis IM., entered into a Mutual Fund Support Services Agreement. Under this agreement, Natixis Distribution, L.P. is responsible for providing investor support services and other marketing, sales, and distribution-related activities relating to the WCM Mutual Funds. For more details about this relationship, see the Client Referrals and Placement Arrangements section. Clifford Capital WCM maintains a passive 24.9% investment in Clifford Capital Partners, LLC (“Clifford”). Clifford is not an advisory affiliate or related person of WCM, the operations of WCM and Clifford are completely separate and independent and WCM does not conduct business with Clifford. WCM supervised persons are permitted to invest in mutual funds where Clifford Capital is adviser. Such transactions are subject to the firm’s policies and procedures for Personal Trading, as described below. Wanzenberg WCM maintains a passive 12.5% investment in Wanzenberg Partners, LLC (“Wanzenberg”). Wanzenberg is not an advisory affiliate or related person of WCM and the operations of the two companies are completely separate and independent. WCM provides investment recommendations (UMA Program model recommendations) to Wanzenberg Partners, LLC. and WCM has a small corporate account that participates in this UMA program. WCM has adopted trade aggregation, allocation and rotation procedures that require equitable allocation of trades among accounts. See the Brokerage Practices section below.

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
WCM has adopted a Code of Ethics (“Code”) pursuant to Rule 204A-1 that sets forth the standards of business conduct required of WCM’s personnel, and requires an affirmative commitment that we will comply with federal securities laws. As a matter of Firm policy, WCM’s Code of Ethics states: “WCM is committed to maintaining the highest legal and ethical standards in the conduct of our business. We have built our reputation on Client trust and confidence in our professional abilities and our integrity. As fiduciaries, we place our Clients’ interests above our own. Meeting this commitment is the responsibility of WCM and each and every one of our employees.” All WCM personnel are subject to the Code’s restrictions and procedures on personal securities transactions. Among other things, the Code addresses:
• WCM’s fiduciary obligations to Clients.
• WCM’s obligation to provide all personnel with a copy of the current Code and any subsequent amendments, and obtain a written acknowledgement of their receipt of the Code and any amendments.
• WCM’s restrictions on purchases and sales for personal accounts of securities purchased or sold for Clients and reporting requirements.
• WCM’s requirement of all Supervised Persons to report Outside Business Activities. The Code is based upon the following principle: “The personal investing activities of all WCM personnel and family members must be conducted in a manner to avoid actual or potential conflicts of interest with WCM’s Clients and WCM itself. No employee of WCM may use his or her position with WCM or any investment opportunities they learn of because of his or her position with WCM to the detriment of WCM’s Clients or WCM.” The Code generally requires pre-clearance by the Chief Compliance Officer of all personal securities transactions in any Covered Security as defined in the rule and the Code. Pre-clearance requests will be approved or based on: the general policies set forth in this Code; the requirements of applicable law; the timing of the proposed transaction in relation to transactions made or contemplated for Clients of WCM; the nature of the security and transaction involved; and the potential for conflicts with the interests of Clients or WCM, or the appearance of such conflicts. Pre-clearance is only good for the day the pre-clearance was approved. All WCM personnel must provide to the Chief Compliance Officer personal securities’ holdings reports and quarterly transaction reports within 30 days of the end of each calendar quarter, which may consist of monthly brokerage statements for all accounts in which they have a beneficial interest. Typically, this requirement is satisfied when WCM personnel electronically link their brokerage accounts relating to all personal securities transactions in which they have a beneficial ownership interest to the Firm’s compliance portal for real-time monitoring of personal securities transactions and holdings by the Chief Compliance Officer. All WCM personnel are also required to comply with ethical restraints relating to Clients and their accounts, including restrictions on giving gifts or political contributions to, and receiving gifts from, Clients in violation of WCM’s general standards of conduct. All WCM personnel must comply fully with the Code and related procedures. Failure to do so may result in disciplinary action, up to and including termination of employment. An existing or prospective Client may obtain a copy of the Code upon request.
Recommend Securities with Material Financial Interest
WCM receives a fee for its role as adviser to the WCM Mutual Funds. In certain situations, WCM may place this fund in a Client’s account when the Client’s investment objectives seek such an investment opportunity. Yet, direct ownership of the individual securities may not be cost effective due to the size of the Client’s account. If the fund is held in a Client’s account for reasons other than tax-loss selling, its value is not included in the account value when computing WCM’s management fee. Under special circumstances, if eligible, WCM IARs will solicit Clients to invest in the WCM Private Funds in which WCM has a financial interest. As General Partner to the WCM Private Funds, WCM participates in the private funds’ investments, pro rata, in accordance with its capital accounts (as described in the Brokerage Practices section of this brochure). Principal executive officers and other personnel of WCM receive annual compensation and bonuses based, in part, on the performance of the private funds, and are also be permitted to invest in the private funds as “knowledgeable employees.”
Invest in Same Securities Recommended to Clients
WCM acts as investment adviser to numerous accounts. WCM gives advice and takes action with respect to any Client account or for its own account, or the account of its officers, directors, employee, or agents, that may differ from actions taken by WCM on behalf of other accounts. WCM is not obligated to recommend, buy or sell — or to refrain from recommending, buying or selling— any security that WCM, its officers, directors, employees or agents, may buy or sell, directly or indirectly, for its or their own accounts, or for any other account WCM manages. WCM is not obligated to refrain from investing in securities held in the accounts it manages, except to the extent that such investments violate the Code adopted by WCM. From time to time, access persons of WCM will have interests in securities owned by or recommended to Clients. On occasion, WCM purchases or sells for its advisory accounts securities of an issuer in which WCM or its access persons also have a position or interest. To mitigate this conflict of interest, WCM aggregates transactions for its proprietary accounts and accounts of its personnel, and averages prices across all accounts participating in the transaction to the extent that such aggregated transactions do not violate the securities laws or regulations or the Code. Additionally, “knowledgeable employees” of WCM may invest in private funds which, in turn, may invest in securities in which WCM invests on behalf of other managed accounts. As these situations represent a potential conflict of interest, WCM has implemented procedures, relating to personal securities transactions and insider trading, that are designed to prevent actual conflicts of interest.
Insider Trading Policy
Access persons may, from time to time, come into possession of material nonpublic and other confidential information which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, access persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is an advisory Client. Accordingly, should access persons come into possession of material nonpublic or other confidential information with respect to any company, they are prohibited from communicating such information to, or using such information for the benefit of, WCM Clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, Clients when following policies and procedures designed to comply with law. The Code contains a policy on Protection of Material, Nonpublic and Other Confidential Information and Prevention of Insider Trading and Tipping, adopted in accordance with Advisers Act Section 204A, which establishes procedures to prevent the misuse of material nonpublic information by access persons. Any WCM officer, director, employee or other access person who fails to observe the above-described policies risks serious sanctions, including dismissal and personal liability. Brokerage Practices
Selecting Brokerage Firms
In determining the ability of a broker-dealer to obtain best execution of securities transactions, WCM considers a number of factors, including: size; access to various markets; history in effectively completing transactions in certain types of securities (e.g., bonds, over-the-counter securities, listed stocks); ability, based on our own experience with them, to execute transactions quickly and effectively; execution capabilities required by the transactions; the importance to the account of speed, efficiency and confidentiality; the broker-dealer’s apparent familiarity with sources from or to whom particular securities might be purchased or sold; the reputation and perceived soundness of the broker-dealer; research services received from the broker-dealer; as well as other matters relevant to the selection of a broker-dealer for portfolio transactions. In evaluating the reasonableness of brokerage commissions, we consider the size of the transaction, the difficulty of the transaction (e.g., liquidity), and the degree of effort put forth by the broker to achieve the best possible price. Except in connection with Clients who are treated as Directed Brokerage Clients (see Directed Brokerage and Consultant Accounts, Wrap Fee Programs and UMA Programs below), wherever possible, we negotiate commissions at the lowest commission level based on the previously mentioned factors. We do require that the commission discounts be competitive with those offered by other firms for like transactions. Occasionally, we perform a trade with a broker and pay a higher commission than another might charge; however, if this is done, it will be because of our need for specific expertise a firm has in a particular type of transaction (due to factors such as size or difficulty), or for speed/efficiency in execution, or for research services provided (see Research and Soft Dollars below). In all cases though, the transaction costs will still remain competitive. When a Client does not have a brokerage arrangement, or is not using a bank or trust company as custodian for the Client's assets, WCM will sometimes suggest the services of a broker-dealer or bank trust department. Our suggestion is generally based on our past experience with a custodian and a confidence in their abilities to service our Clients.
Commission Rates or Equivalent Policy
WCM has no duty or obligation to seek in advance competitive bidding for the most favorable commission rate applicable to any particular portfolio transaction or to select any broker-dealer on the basis of its purported or “posted” commission rate, but will endeavor to be aware of the current level of the charges of eligible brokers and to minimize the expenses incurred for effecting portfolio transactions to the extent consistent with the interests and policies of the accounts. Although WCM generally seeks competitive commission rates, it will not necessarily pay the lowest commission or commission equivalent. Transactions may involve specialized services on the part of the broker-dealer involved and thereby entail higher commissions (or their equivalents) than would be the case with other transactions requiring more routine services.
Research and Soft Dollars
Under Section 28(e) of the Securities Exchange Act of 1934, WCM pays commissions to broker-dealers for Client portfolio transactions that exceed the amount of commissions that would be charged by another broker-dealer for the same transaction, provided that WCM determines in good faith that the amount of commissions paid are reasonable in relation to the value of the brokerage and research services provided by such broker-dealer, either in terms of a particular transaction or WCM's overall responsibilities with respect to accounts for which it exercises investment discretion. Pursuant to Section 28(e), WCM has entered into soft dollar arrangements with third parties and broker-dealers for eligible "brokerage" and "research" products and services (as defined under Section 28(e)) used by WCM in connection with its investment process, including, without limitation, general economic and security market analyses and reports, industry and company analyses and reports, third party and proprietary analyses and reports concerning securities, and market data. WCM uses these eligible research and brokerage products and services in providing investment advisory services to all of its Clients, rather than just those portfolios for which soft dollar transactions are executed. WCM believes that its soft dollar arrangements comply with the requirements of Section 28(e). A potential conflict of interest exists because WCM receives these products and services from broker-dealers in exchange for directing commissions from Client portfolio transactions, rather than paying for these products and services with its own assets. WCM has an incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on our Clients’ interest in receiving most favorable execution. To mitigate this conflict, WCM conducts quarterly reviews of our best execution efforts, as described in the Brokerage Reviews section below.
Brokerage Reviews
All the topics discussed in this Brokerage Reviews section are reviewed quarterly by WCM’s Best- Execution Committee. The committee reviews the approved broker list, all trade activity, commissions paid, commission allocation, execution quality, qualitative performance of brokers, directed broker relationships, and soft dollar commissions, research and execution services. This committee is comprised of representatives from the Investment Strategy Group (ISG) and Portfolio Management Team, the Leadership Team, the Trade Team, the Ops Team, and the Chief Compliance Officer.
Order Aggregation
Except as disclosed in Directed Brokerage and Consultant Accounts, Wrap Fee Programs and UMA Programs, WCM generally aggregates or “blocks” orders being placed for execution at the same time for the accounts of two or more Clients where it believes such aggregation is appropriate and in the best interest of Clients. WCM believes this practice enables WCM to seek more favorable executions and net prices for the combined order. All block orders are subject to WCM’s order aggregation and allocation policy and procedures (“Procedures”). The Procedures are designed to meet applicable legal standards. They have been designed to ensure that Clients whose orders are eligible for aggregation are treated fairly vis-à-vis one another. WCM makes decisions to recommend, purchase, sell or hold securities for all of its Client accounts, including affiliated Client accounts, based on the specific investment objectives, guideline please register to get more info

Discretionary Authority for Trading
WCM renders advice primarily on a discretionary basis. By signing the investment management agreement, the Client generally gives WCM full discretion on all investment decisions regarding their account. Depending on the terms of the agreement that WCM has entered into with each Client for whom it provides discretionary management, WCM is generally given authority to make the following determinations without obtaining the consent of the Client before a transaction is effected:
• Which securities to buy or sell;
• The total amount of securities to buy or sell;
• The broker or dealer through whom securities are bought or sold;
• The commission rates at which securities transactions for Client accounts are effected;
• The prices at which securities are to be bought or sold, which may include dealer spreads or mark-ups and transaction costs. WCM’s authority is, however, subject to conditions imposed pursuant to its agreement with the Client. Examples might include (a) restrictions on ownership of securities in a specific industry, or (b) directions that transactions be accomplished using particular brokers. Clients retaining WCM for discretionary or non-discretionary services are free to select their own custodians and brokers. When WCM is retained as a sub-adviser, it may be either a discretionary or non-discretionary sub- adviser. Additionally, WCM provides model portfolio recommendations to UMA Programs, which are implemented by the UMA Sponsor (see Brokerage Practices: UMA Programs.)
Limited Power of Attorney
By signing the investment management agreement the Client gives WCM Power of Attorney on all investment decisions regarding their account. Unless WCM otherwise agrees in writing, WCM does not advise or take any action on behalf of Clients in any legal proceedings, including bankruptcies or class actions, involving securities held or formerly held in Client accounts or the issuers of those securities. please register to get more info

Proxy Voting
WCM has written proxy voting policies and procedures as required by Advisers Act Rule 206(4)-6. Under these policies and procedures, WCM votes proxies relating to equity portfolio securities in the best economic interests of Clients, unless the Client contract specifies that WCM will not vote. WCM believes that its Clients’ best economic interest with regards to proxy voting is best served by engaging an independent firm that specializes in researching companies and their management for the purpose of increasing Investors potential financial gain through voting proxies. WCM has therefore engaged and adopted the proxy voting recommendations of Glass Lewis (our “Proxy Adviser”). Generally, the voting recommendations of the Proxy Adviser are accepted. However, in some cases, a vote recommendation is flagged by either the company’s management during discussions with WCM’s analysts, or when the Proxy Adviser’s recommendation is contrary to management’s recommendation. Such cases are escalated to WCM’s Investment Strategy Group (“ISG”) who makes the determination for voting in the best economic interest of the clients. When a vote is contrary to the recommendation of the Proxy Adviser, documentation is maintained to support the decision. In the event WCM does not have the authority to vote proxies on a Client’s behalf, Clients should instruct their custodian to send proxies directly to them. Any proxies erroneously received by WCM for the Client will be forwarded to the Client. Clients are welcome to contact WCM with questions regarding proxy ballots or other solicitations. WCM acknowledges its responsibility for identifying material conflicts of interest relating to voting proxies. When a material conflict of interest between WCM’s interests and its Clients’ interests appears to exist, WCM will either (1) obtain a Client’s consent to how the ISG will vote the proxy; or (2) vote in accordance with Glass Lewis’ recommendation. In the event that a conflict of interest arises between Glass Lewis or the proxy issuer and a Client of WCM, WCM will evaluate the circumstances and either (1) elevate the decision to the ISG who will make a determination as to what would be in the Client’s best interest; (2) if practical, notify affected Clients of the conflict of interest and seek a waiver of the conflict; or (3) if agreed upon in writing with the Clients, forward the proxies to affected Clients allowing them to vote their own proxies. For each proxy, WCM maintains all related records as required by applicable law. Clients may obtain copies of WCM’s written proxy voting policies and procedures, as well as information on how proxies were voted for their accounts by requesting such information from WCM at the address and phone listed on the cover of this brochure. WCM will not disclose proxy votes for a Client to other Clients or third parties unless specifically requested in writing by the Client; however, to the extent that WCM serves as a sub-adviser to another adviser to a Client, WCM will be deemed to be authorized to provide proxy voting records on such Client accounts to such other adviser. please register to get more info

WCM has never been the subject of a bankruptcy petition, and it is not aware of any financial condition that is reasonably likely to impair its ability to meet any contractual commitments to Clients.

Additional Disclosures
Investor Privacy Notice
Last updated: March 20, 2020 WCM Investment Management, LLC (“We”, “Our”, “Us”) respects your privacy rights. In offering or providing investment management services to you, WCM Investment Management obtains certain non- public personal information. We recognize the sensitive nature of this information and take appropriate precautions to protect your privacy. Our policy is to keep this information strictly safeguarded and confidential, and to use or disclose it only as necessary to provide services to you or as otherwise permitted or required by law. We do not sell, rent or trade your information with other companies. We are sharing this Notice with you so you can understand how we use, store, and share your data. We also want you to know your rights with regards to this information and the data we collect about you. For privacy disclosures concerning your visits to our website or general marketing of our services, please refer to our online https://www.wcminvest.com/disclosures. This privacy disclosure applies to our funds, and includes the funds listed below: Private Funds
• WCM Focused International Growth Fund LP
• WCM Focused Global Growth Fund LP
• WCM Focused Emerging Markets Fund LP
• WCM International Small Cap Growth Fund LP
• WCM Focused Global Growth Long-Short Offshore Funds

Mutual Funds
• WCM Focused International Growth Fund
• WCM Focused Global Growth Fund
• WCM Focused Emerging Markets Fund
• WCM International Small Cap Growth Fund
• WCM Focused ESG International Fund
• WCM Focused ESG Emerging Markets Fund
• WCM China Quality Growth Fund

Collective Investment Trust
• WCM Focused Growth International CIT

Foreign Funds
• Canadian Unit Trust: WCM (Canada) Focused Global Growth Fund
• Four Australian Funds: WCM Global Growth LIC, WCM Quality Global Growth ETMF, WCM Quality Global Growth Managed Fund, and WCM International Small Cap Growth Fund.
• UCITS: WCM Global Equity Fund of Heptagon Fund plc, WCM Global Emerging Markets Equity Fund
1. What Types of Personal Information Do We Collect?
Information You Give Us. You may give us information in subscription agreements, investor questionnaires, applications or other forms. You may also provide us information in your correspondence and transactions with us in person, by phone, mail, e-mail or other electronic means. In most cases, you give us this information yourself or through a person you have authorized to share it. The categories of information include:
• Contact information, such as name, address, email, telephone number
• Identification information, such as signature, date of birth, social security number, taxpayer identification number, driver’s license, passport, or other government identification
• Background information, such as information revealed in know-your- customer (KYC) and anti- money laundering (AML) due diligence transaction information, tax information, brokerage, custodial arrangements, and family relationships (for family trusts)
• Employment information, such as your employer and employment history Information We Collect From Third Parties. We may collect your information from third party service providers, such as broker-dealers, screening companies, investor placement entities, or public databases, who perform services on our behalf or at your request to verify or supplement our information.
2. Retention of Information We Collect and Process
We will only retain your personal information and data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
3. How Do We Use Personal Information?
We use your personal information as follows:
• To fulfill your requests for financial and investment products and services offered and subscribed or accepted by you, through any medium of communication
• To deliver to you any administrative notices, advice and communications relevant to your use of the products and/or services
• To market our advisory or investment services to you
• For market research, project planning, troubleshooting problems
• For detecting and protecting against error, fraud or other criminal activity
4. How Do We Share Personal Information?
We may disclose non-public personal information about you that we have collected, only to those persons that provide necessary services to your account or as permitted or required by law or specifically authorized by you. The following discussion identifies categories of persons who may have access to this information. Within WCM WCM employees are permitted access to the information they need to perform their jobs on your behalf. We maintain strict internal policies against unauthorized disclosure or use of client information by employees. Companies That You Ask Us to Share With From time to time, you may request that we provide information to third parties such as financial planners, portfolio consultants, tax advisors or legal counsel. In these cases, WCM will obtain your permission prior to sharing your information with the outside firm. WCM may get your written, online, or verbal permission to share your information. Your consent will apply only to the specific parties you request. If you have previously requested that we block the sharing of your information, that request will remain in place for all other situations, except where required by law. Outside Service Providers We have arrangements with companies whose experience is essential for our advisory services to operate properly. For example, we work with firms that execute securities transactions for us or our clients, custody client assets, provide systems or write software for accounting, compliance and other critical operational functions. These companies work at WCM's direction and only the client information necessary for them to perform these functions is shared. They are required to safeguard your information and only use it for authorized purposes, and within the guidelines established by WCM for the protection of client information. Courts and Government Bodies Certain federal and state laws may require us to share information about you. For example, if you are involved in a legal matter with a third party, we may be ordered to provide information to a court or other party. In these circumstances, only the specific information required by law, subpoena, or court order will be shared. The Fair Credit Reporting Act and other laws allow us to share specific details about your transactions and experience with us. The use of this information is limited by federal law to specific permissible purposes, such as applications for credit, insurance or employment.
5. Your Privacy Choices
Right to Access/ Rectification: Please contact us if you would like to request a copy of your information or to make any changes to your personal information. Marketing Opt-Out: We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).
EEA/ UK Disclosures
Right to Object to Processing. You have the right to object to the processing or place restrictions on the processing and sharing of your personal information and data, if permitted by law. This, however, could impact whether and to what extent we may provide investment management services to you. Automated Processing/Profiling. WCM does not use automated processing/ profiling of an individual in order to make investment decisions on their behalf, e.g. automated scoring based on background checks. Complaints. You have the right to lodge a complaint against WCM with a local supervisory authority.
6. Legal Bases for Processing (EEA and UK)
If you are from the European Economic Area or the United Kingdom, our legal bases for collecting and using your Personal Information is as follows: ● The processing is necessary for the performance of a contract for investment or advisory services to which you are a party or in order to take steps at your request prior to entering into a contract. ● Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improvement of our services. ● Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatary retention periods. We may also collect your Personal Information to record your requests to exercise your rights and to verify your identity for such requests. ● Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time. ● In some limited cases, we may also have a legal obligation to collect Personal Information from you, in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in “How Do We Share Personal Information?” If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Contact Information" section below.
7. International Transfers of Data
Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract). This may entail a transfer of your personal information across international borders. The data protections standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally, and as required by applicable law, will seek your consent prior to such transfers.
8. Safeguarding Your Data
To protect the personal information of individuals, we permit access only by authorized employees who need access to that information to provide services to us and to you. To guard investors' personal information, we maintain physical, electronic and procedural safeguards that comply with applicable federal and state standards. Your right to privacy extends to all forms of contact with us, including telephone, written correspondence and electronic media, such as the internet.
9. Change of Control
Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your personal information.
10. Policy Changes
For current investors, we will provide you with a copy of this Privacy Notice annually. For prospective investors, we encourage you to periodically review this Privacy Notice to ensure you are familiar with the most current version.
11. Contact Information
If you wish to contact us or have any questions about or complaints in relation to this Investor Privacy Notice, please contact us at:
• privacy@wcminvest.com
• 949-380-0200
Summary of Business Continuity and Disaster Recovery Plan
WCM maintains a document that outlines its immediate and long-term business continuity and disaster recovery plan (the “Plan”). The purpose of the Plan is to provide specific guidelines WCM and its employees will follow in the event of a disruption or failure of any critical business capability whether due to an emergency, disaster or otherwise. Key Concept Distributed Workspace Environment (“DWE”): This is WCM’s architecture of systems that gives personnel the ability to perform all business functions from anywhere and at any time. With access to the Internet, personnel are able to perform all portfolio management functions (e.g., portfolio monitoring, trade allocation, trading, trade settlement, reconciling, reporting); access client files; maintain electronic communications; retrieve company research; process client billing; conduct HR functions; and process company payables. A secured connection provides personnel access to the company network, which is maintained at redundant data centers. Areas Addressed by the Plan
• The Emergency Response Team
• The safety and mobility of employees
• Lack of access to office facilities
• Disruption to office communications
• The disaster recovery plans of key third-party vendors
• The stability and security of WCM’s computer network
• The protection, preservation, and recovery of critical data
• Key personnel
• Cash reserves & Insurance protection
• Maintenance and testing of the Plan
Notice to Canadian Clients
WCM Investment Management, LLC (“WCM”) provides advice to persons and companies located in Canada in reliance upon the international adviser exemption that is available to persons or companies registered, or exempt from registration, in a foreign jurisdiction pursuant to section 8.26 of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (“NI 31- 103”) and for purposes of such exemption we are required to advise you of the following: 1. WCM is not registered in any province or territory of Canada to engage in the advisory activity that is contemplated by section 8.26(3). 2. The foreign jurisdiction in which WCM’s head office or principal place of business is located is California, USA. 3. All or substantially all of WCM’s assets may be situated outside of Canada. 4. Consequently, there may be difficulty enforcing legal rights against WCM. WCM is limited to advising clients in Canada who are “Permitted Clients” as defined under NI 31-103. WCM has appointed the following agents for service of process in the Canadian provinces listed below: Alberta McCarthy Tétrault LLP Suite 4000 421 – 7th Avenue SW Calgary, AL T2P 4K9 Attention: John Osler, Q.C.

Nova Scotia Stewart McKelvey LLP Purdy's Wharf Tower One 1959 Upper Water St. Halifax NS B3J 3N2 Attention: Richard Hirsch
Ontario
Cartan Limited Suite 5300 Toronto Dominion Bank Tower Toronto, Ontario M5K 1E6 Attention: Sean D. Sadler

Quebec
McCarthy Tétrault LLP Bureau 2500 1000, De La Gauchetière Street West Montréal QC H3B 0A2 Attention: Sonia J. Struthers
Manitoba
MLT Aikins LLP 30th Floor Commodity Exchange Tower 360 Main Street Winnipeg, MB R3C 4G1 Attention: Richard L. Yaffe
Notice to Australian Clients
WCM Investment Management, LLC (“WCM”) is exempt from the requirement to hold an Australian financial services licence under the Corporations Act 2001 (Cth) in respect of its financial services. WCM is regulated by the SEC under US laws, which differ from Australian laws. please register to get more info