GAM USA Inc

Item 5 Fees and Compensation

 Institutional (Separately Managed ) Accounts
  The fees for GAM USA’s services are typically based on a percentage of a client’s net assets under
  management. GAM USA’s basic fee schedule for institutional separately managed accounts are negotiated and
  can vary based upon a variety of factors, including the type of client, strategic mandate, investment amount,
  particular circumstances of the client, additional or differing levels of servicing, or as otherwise agreed between
  GAM USA and the client. The specific manner in which fees are charged by GAM USA for a managed account
  is established in a written agreement between the client and GAM USA.

 GAM USA generally bills its fees either on a monthly or quarterly basis. Fees are either deducted directly from
 client accounts or billed separately. Accounts initiated or terminated prior to the last day of the month or quarter,
 as applicable, will be charged a pro-rated fee. Fees are not typically paid in advance.

 The basic fee schedule may also be modified if the client and GAM USA agree to a performance-based
 compensation arrangement. GAM USA’s performance-based compensation arrangements are structured to
 comply with Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).

 In addition to being subject to the fees charged by GAM USA, a portion of each client account that is invested in
 a fund will also bear a proportionate share of the advisory fees and other expenses of that fund.

 GAM Funds
 GAM USA receives investment management fees from certain GAM Funds. GAM USA’s fee schedule
 applicable to each such GAM Fund is generally set forth in the relevant GAM Fund’s Governing Materials. The
 investor, the GAM Fund and/or GAM USA, in certain circumstances, may negotiate the terms. Prospective
 investors should review the relevant GAM Fund’s Governing Materials.

 GAM USA, an affiliate, or a GAM Fund managed, advised or sponsored by GAM USA or an affiliate, have
 entered, and may in the future enter, into side agreements with specific investors in a GAM Fund providing for
 different fees, withdrawal rights, access to information about the respective GAM Fund’s investments, or other
 matters relating to an investment in the GAM Fund. Appropriate disclosures will be made to other clients and
 GAM Fund investors of any terms of any such side letter that could potentially adversely affect other clients or
 investors in a GAM Fund. Certain investors, including “seed” investors and persons associated or formerly
 associated with GAM USA or an affiliate (and members of their families), as well as certain friends of such
 persons, receive preferential fee arrangements. These separate agreements, commonly referred to as “side
 letters”, or other similar agreements with a particular investor in connection with its admission to the Fund
 without the approval of any other investor, which would have the effect of establishing rights under, or
 supplementing, the terms of the applicable Fund’s governance documents with respect to such investor in a

GAM USA Inc.
Part 2A of Form ADV –Brochure
March 31, 2026

 manner more favorable to such investor than those applicable to other investors in the respective fund. Such
 rights or terms in any such side letter or other similar agreement may include, without limitation: (i) reporting
 obligations, (ii) waiver of certain confidentiality obligations, (iii) “most favored nation” provisions or (iv) rights or
 terms requested or necessary in light of particular investment, legal, regulatory or public policy characteristics
 of an investor.

 Each GAM Fund is managed in accordance with the mandate established in the relevant Governing Materials.
 Certain GAM Funds that are advised by GAM USA are or may in the future be either co-managed or sub-
 advised by GLL or other affiliates. I n t h o s e c i r c u m s t a n c e s , GAM USA will be responsible for any
 investment management fees payable to an affiliate to whom it contracts for sub-advisory services.

 GAM USA’s advisory and management fees are exclusive of all investment costs incurred by client accounts,
 including brokerage commissions, transaction fees, custodian fees and other administration fees.

 Investments in GAM Funds and other funds will also be subject to the investment and operating expenses
 incurred by those funds which may include management fees, administrative fees, directors fees, and legal, tax
 and audit fees, transfer taxes, wire transfer and electronic fund transfer fees, borrowing costs and other fees and
 taxes on brokerage accounts and securities transactions, sales and marketing expenses including placement
 agent fees, insurance premiums, regulatory expenses to include filing fees and licenses, depositary fees and
 other bank and custodial fees, investment research costs and third party valuation costs and expenses as set
 out in the relevant fund Governing Materials. Investors considering investing in a particular fund should request
 and review the Governing Materials of the relevant fund for more detailed information about the fees and
 expenses to be incurred by the applicable fund. Expenses incurred on behalf of more than one client account are
 allocated among participating client accounts in proportion to their participation in specific investments, in
 proportion to their respective net asset values, or in such other manner as GAM USA determines to be equitable.

 Item 12 below describes the factors that GAM USA considers in selecting or recommending broker-dealers to
 execute client transactions.

Item 7 Types of Clients

 As noted above, GAM USA provides investment advisory/management services to pooled investment vehicles
 (including advisory services to European regulated commingled funds referred to as “UCITS” and publicly traded
 open- end investment fund structures offered in Europe referred to as “SICAVs”), as well as to separately
 managed accounts for corporate and public pension plans, trusts, estates, charitable organizations,
 foundations, endowments, corporations and other business entities.

 In general, U.S. investors in GAM Funds must qualify as both “accredited investors” as defined in Regulation D
 under the Securities Act, and “qualified purchasers” as defined in Section 2(a)(51) under the Investment
 Company Act, and they must meet other applicable suitability requirements. Generally, investors must invest
 a minimum dollar amount (which may be waived or modified at the sole discretion of GAM USA and/or the
 applicable GAM Fund).