Merk In v estm en t s LLC
115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 1: Cover Page

MERK INVESTMENTS LLC
PART 2A OF FORM ADV: FIRM BROCHURE
Merk Investments LLC
1150 Chestnut St.
Menlo Park, CA 94025
www.merkinvestments.com

March 28, 2024

This brochure provides information about the qualifications and business practices of Merk
Investments LLC (“Merk Investments” or the “Firm”). If you have any questions about the contentsof this “ Brochure,” please contact us at (650) 323-4341 or info@merkinvestments.com.
This information has not been approved or verified by the United States Securities and Exchange
Commission (the “SEC”) or by any state securities authority.
Any reference to Merk Investments as a “registered investment adviser” does not imply a certain
level of skill or training.
Additional information about Merk Investments is also available on the SEC’s website atwww.adviserinfo.sec.gov.

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115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 2: Material Changes
This is Merk Investments’ Annual Amendment to Form ADV for the fiscal year ending December 31, 2023.
Since Merk Investments’ last Annual Amendment, filed in March 2023, the following changes occurred:•discontinuation of providing investment advisory services to an exchange traded fund;•discontinuation of the Stagflation strategy;•

updated regulatory assets under management;•

included clarifying language including, but not limited to:ofees and compensation;orisk of loss related to investing in securities;oparticipation or interest in client transactions;otrade aggregation and costs that may be incurred when trades are not aggregate;ocontent and frequency of reports provided to Clients andoproxy voting procedures.

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115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 3: Table of Contents
Page

TABLE OF CONTENTS
Item 1: Cover Page ...................................................................................................................... i
Item 2: Material Changes .......................................................................................................... ii
Item 3: Table of Contents .......................................................................................................... iii
Item 4: Advisory Business .......................................................................................................... 4
Item 5: Fees and Compensation ................................................................................................. 5
Item 6: Performance-Based Fees and Side-by-Side Management ............................................. 6
Item 7: Types of Clients .............................................................................................................. 6
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ....................................... 6
Item 9: Disciplinary Information ............................................................................................. 13
Item 10: Other Financial Industry Activities and Affiliations.................................................. 13
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ...................................................................................................................... 14
Item 12: Brokerage Practices .................................................................................................. 15
Item 13: Review of Accounts .................................................................................................... 16
Item 14: Client Referrals and Other Compensation ................................................................ 16
Item 15: Custody ...................................................................................................................... 17
Item 16: Investment Discretion ................................................................................................ 17
Item 17: Voting Client Securities ............................................................................................. 17
Item 18: Financial Information ................................................................................................ 18iii

Merk In v estm en t s LLC
115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 4: Advisory Business
Item 4.A.
Merk Investments LLC (“Merk Investments” or the “Firm”), a Delaware limited liability company, is aninvestment adviser with its principal place of business in Menlo Park, CA. Merk Investments was formedin December 2000 by Alexander “Axel” Merk, Managing Member, who is also the principal owner of
Merk Investments (the “Principal”).
Item 4.B.
Merk Investments is an investment management firm that provides advisory services to an investmentcompany registered under the Investment Company Act of 1940, as amended (the “Investment CompanyAct”), the “Closed-End Fund” and a U.S. listed exchange traded product (“ETP”). Merk Investments has
previously provided (and may in the future) advisory services to sophisticated investors through a privately
offered pooled investment vehicle. Collectively, the Closed-End Fund and ETP are referred to as “Pooled
Vehicles.” Pooled Vehicles, and any private funds Merk Investments may manage, are collectively referred
to as “Clients.”
Merk Investments’ investment objective is to achieve superior risk-adjusted returns by seeking to deliver
uncorrelated returns using alternative strategies that seek optimal profit potential within tailored investment
objectives. Merk Investments provides investment advice on liquid global markets, including domestic andinternational equities, fixed income, commodities and currencies and their respective derivative markets,as described in Item 8. Methods of Analysis, Investment Strategies and Risk of Loss.
Item 4.C.
Merk Investments’ investment management services to the Pooled Vehicles are provided pursuant to theterms of the prospectus of each investment vehicle, and investors in the Pooled Vehicles cannot obtain
services tailored to their individual specific needs.
Item 4.D.
Merk Investments does not participate in a wrap fee program.
Item 4.E.
Merk Investments managed client assets of approximately $1,114,080,628 in regulatory assets undermanagement as of December 31, 2023. This consisted of approximately $339,649,030 of client assets on
a discretionary basis, and approximately $774,431,598 of clients assets on a non-discretionary basis.

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115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 5: Fees and Compensation
Item 5.A.
Management Fees
For the ETP, detailed information on the terms and conditions of fees payable to Merk Investments aredisclosed in the relevant prospectus. Merk Investments is the “Sponsor” of the ETP and the ETP pays a“Sponsor’s Fee” of 0.25% of the net asset value of the ETP. In exchange for the Sponsor’s Fee, Merk
Investments assumes the ordinary administrative and marketing expenses that the ETP is expected to incur.
The Sponsor’s Fee accrues daily based on the prior business day’s net asset value and is payable in sharesof the ETP on a monthly basis in arrears. Merk Investments has discretion to waive all or a portion of theSponsor’s Fee but at this time does not intend to waive any of its fees.
For investment advisory services provided the Closed-End Fund pays “Advisers Fees” to Merk Investments
at an annual rate of 0.70% of the annual average daily net assets of the Closed-End Fund. Adviser Fees are
accrued by the Closed-End Fund daily and shall be payable monthly in arrears on the first business day ofeach calendar month for services performed during the prior calendar month. From time-to-time, Merk
Investments can reimburse expenses of the Closed-End Fund or waive the Adviser Fees to the extent
necessary to maintain the Closed-End Fund’s expense ratio at an agreed-upon amount for a period of time
specified by the parties in a separate letter of agreement. The annual report for the Closed-End Fundelaborates on the details of a voluntary fee waiver for net assets above $300 million and $500 million.
These fees are not negotiable. Item 5.B.
The custodian or administrator to the Pooled Vehicles will deduct fees and compensation from theapplicable Pooled Vehicle assets for advisory services due to Merk Investments as incurred and at the times
described above in Item 5.A. Fees and compensation are deducted on a monthly basis in arrears. For the
ETP, in lieu of paying the Sponsor’s Fee in cash, the Trustee issues shares of the ETP to the Sponsor.
Item 5.C.
Other Fees Earned and Expenses allocated by Merk Investments
The Closed-End Fund bears fees and expenses related to its operations, including, among others, custodial
fees, taxes, foreign investment license fees, administrative fees, legal expenses, audit fees, regulatory fees,transaction costs, brokerage commissions, and other fees and taxes charged by broker-dealers and othercounterparties in connection with effecting portfolio transactions.
Please also see Item 12 for a description of brokerage practices.
Item 5.D.
Generally, fees earned by Merk Investments for advisory and related services are payable by Clientsmonthly in arrears based on the net asset value of Client accounts however, other fee arrangements may benegotiated.

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115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 5.E.
Merk Investments is compensated solely for providing advisory services, and not for the sale of securities
or other investment products, and mutual funds.
The Management Fees described above in Item 5.A (and any performance allocations Merk Investments
may receive) are structured to comply with Rule 205-3 under the Advisers Act and any applicable state
laws.
Item 6: Performance-Based Fees and Side-by-Side Management
Merk Investments has in the past and may in the future be entitled to receive a performance allocation fromcertain Clients. The performance allocation may provide a possible incentive for Merk Investments to makeriskier or more speculative investments on behalf of a Client than those which would be recommended
under a different fee arrangement. In addition, this arrangement may cause Clients to pay a greater expense
than if such fees were not charged. Notwithstanding this potential incentive, Merk Investments will
evaluate investments in a manner that it considers to be in the best interest of Clients.
To the extent that there may be differences in Merk Investments’ compensation arrangements with different
Clients, such circumstances could create an incentive for the Firm to manage Client portfolios so as to favora portfolio that pays performance-based compensation over one that did not. Notwithstanding this conflict,
Merk Investments will allocate transactions and opportunities among the Clients’ accounts in a manner it
believes to be equitable.
Item 7: Types of Clients
Merk Investments provides discretionary investment advice to a registered investment company and a
grantor trust. The Firm has in the past provided (and may in the future) investment management services
to sophisticated investors through privately offered investment funds.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Item 8.A.
Merk Investments provides investment advisory services regarding liquid global markets, including
domestic and international equities, fixed income, commodities, and currencies. Some of Merk
Investments’ strategies focus on a sub-set, such as gold and currencies. General descriptions of Merk
investments’ investment strategies are included below. Certain strategies may be available only in certain
channels or through a purchase of shares of registered investment companies, exchange traded products, or
private investment funds. Investing in securities involves risk of loss that Clients should be prepared tobear. Summarized below are certain important risks for Clients and prospective clients to consider.

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Gold Strategy
The Gold Strategy seeks to track the price of physical gold by providing investors with an opportunity toinvest in gold through shares in an exchange traded product (ETP) organized as a grantor trust, and to beable to take delivery of physical gold in exchange for their shares. The grantor trust does not make use ofderivatives and is not actively managed.
Gold Equities Strategy
The Gold Equities Strategy focuses on companies engaged in the exploration for, development of projects
in, or mining of precious metals and minerals through investments in (i) common shares or securities
convertible into common shares of companies engaged, directly or indirectly, in the exploration, mining orprocessing of gold, silver, platinum, diamonds or other precious minerals, (ii) bullion or other direct formsof gold, silver, platinum or other precious minerals, (iii) instruments representing interests in gold, silver,
platinum or other precious minerals such as certificates of deposit therefor, and/or (iv) securities ofinvestment companies, including exchange traded funds, or other securities that seek to replicate the pricemovement of gold, silver or platinum bullion. Merk Investments employs bottom-up fundamental analysis
and relies on detailed primary research including meetings with company executives, site visits to key
operating assets, and proprietary financial analysis in making its investment decisions for the Gold Equities
Strategy.
Item 8.B and Item 8.C.
As with all investments, there is the risk that an investor in a strategy managed by Merk Investments could
lose money in their investment account. These strategies are not intended to be a complete investment
program but rather one component of a diversified investment portfolio. Many factors affect the net asset
value and performance. The risks associated with the Firm’s’ investment strategies include, but are notnecessarily limited to, those described below. Because each strategy is different, not all risks apply to eachstrategy, and the following is a summary of risks most applicable to the strategies. Investors in the ClosedEnd Fund and ETP should consult the prospectus or offering documents, as applicable, for their investment
for more detailed explanations of the risks associated with their investment.
Risks Applicable to Strategies
Strategy

Principal Investment Risks

Gold

Gold Investment Risks

Precious Metals, Minerals, and Mining Equities Strategy
Common Stock; Concentration of Investments Risk; Convertible Stock;
Currency Exchange Rate; Depository Receipt Risk; Focused Portfolio
Risk; Foreign Instruments Risk; Geographic Focus Risks; Gold
Investment Risk; Gold and Precious Metals/Minerals Risk; Gold-Related
Securities Risk; Junior and Intermediate Mining Companies Risk; Private
Placement Risk; Restricted Stock Risk; and Warrants Risk.

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Commodities Risk. Exposure to investments in physical commodities subjects a strategy to greater volatility
than investments in traditional securities, such as stocks and bonds. Investing in physical commodities,
whether directly or indirectly, is speculative and can be extremely volatile. The commodities markets may
fluctuate rapidly based on a variety of factors, including overall market movements; economic events andpolicies; changes in interest rates or inflation rates; changes in monetary and exchange control programs;
war; acts of terrorism; natural disasters; and technological developments. Variables such as disease,drought, floods, weather, trade, embargoes, tariffs, and other political events, in particular, may have alarger impact on commodity prices than on traditional securities. The prices of commodities can also
fluctuate widely due to supply and demand disruptions in major producing or consuming regions. Because
certain commodities may be produced in a limited number of countries and may be controlled by a small
number of producers; political, economic, and supply-related events in such countries could have adisproportionate impact on the prices of such commodities. These factors may affect the value of aninvestment in varying ways; and different factors may cause the value and the volatility of a strategy tomove in inconsistent directions at inconsistent rates. The current or “spot” prices of physical commodities
may also affect, in a volatile and inconsistent manner, the prices of futures contracts in respect of therelevant commodity.
Common Stock. Common stock represents an equity or ownership interest in an issuer. Common stock
typically entitles the owner to vote on the election of directors and other important matters, as well as toreceive dividends on such stock. In the event an issuer is liquidated or declares bankruptcy, the claims ofowners of bonds, other debt holders, and owners of preferred stock take precedence over the claims of those
who own common stock.
Concentration of Investments Risk. An investment portfolio (on account of size, investment strategy andother considerations) may be confined to the securities of relatively few issuers. The portfolio is not
required to maintain a minimum level of capital. If the portfolio fails to raise substantial initial capital or
incurs losses or withdrawals, it may not have sufficient funds to diversify its investments. There are no
particular limits as to concentration in particular issuers or types of investments. If the portfolio
concentrates its investments in several, relatively large securities positions or industries relative to its
capital, a loss in any one position or downturn in any one industry could reduce the portfolios’ s
performance materially.
Convertible Securities. Convertible securities are hybrid securities that combine the investment
characteristics of bonds and common stocks. Convertible securities typically consist of debt securities orpreferred stock that may be converted (on a voluntary or mandatory basis) within a specified period of time(normally for the entire life of the security) into a certain amount of common stock or other equity securityof the same or a different issuer at a predetermined price. Convertible securities also include debt securities
with warrants or common stock attached and derivatives combining the features of debt securities andequity securities. Other convertible securities with features and risks not specifically referred to herein may
become available in the future. Convertible securities involve risks similar to those of both fixed income
and equity securities. In a corporation’s capital structure, convertible securities are senior to common stock
but are usually subordinated to senior debt obligations of the issuer
Counterparty Risk. A counterparty to a derivative or other financial instrument entered into by Merk
Investments may become bankrupt or otherwise fail to perform its obligations. An investment account may
experience delays in obtaining recovery or obtain limited or no recovery in such circumstances.

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Currency Exchange Rate Risk. Currency exchange rates may fluctuate significantly over short periods oftime and can be unpredictably affected by political developments or government intervention. Changes incurrency exchange rates may affect the U.S. dollar value of investments, including foreign securities,
forward currency contracts, and cross currency forwards.
Cybersecurity Risk. Cybersecurity incidents may allow an unauthorized party to gain access to a strategy’s
assets or proprietary information, or cause a strategy, an adviser, and/or other service providers (including
custodians, counterparties, and financial intermediaries) to suffer data breaches or data corruption.
Additionally, cybersecurity failures or breaches of the electronic systems of a strategy, an adviser, or any
other service providers, market makers, authorized participants, or the issuers of securities in which astrategy invests have the ability to cause disruptions and negatively impact business operations, potentiallyresulting in financial losses to a fund and its shareholders.
Default Risk of Counterparties, Brokers, and Exchanges. The account will be exposed to the credit risk of
the counterparties with which, or the brokers, dealers, and exchanges through which it deals, whether it
engages in exchange-traded or off-exchange transactions. The account may be subject to risk of loss of its
assets on deposit with a broker in the event of the broker’s bankruptcy, the bankruptcy of any clearing
broker through which the broker executes and clears transactions on behalf of the account, or the bankruptcy
of an exchange clearing house. To the extent that the account invests in swaps, derivatives or synthetic
instruments, or other over-the-counter transactions in these markets, the account may take credit risk withregard to parties with which it trades and also may bear the risk of settlement default.
Depositary Receipts Risk. Depositary receipts risks include, but are not limited to, fluctuations in foreign
currencies and foreign investment risks, such as political and financial instability, less liquidity and greater
volatility, lack of uniform accounting auditing and financial reporting standards and increased pricevolatility. In addition, depositary receipts may not track the price of the underlying foreign securities, andtheir value may change materially at times when the U.S. markets are not open for trading. Investments in
unsponsored depositary receipts may be subject to additional risks
Derivatives Risk. The risks of investments in derivatives, including swaps, options, futures contracts, andoptions on futures contracts, include that derivatives may result in losses, which are potentially unlimited,
and that partially or completely offset gains in portfolio positions. Derivative transactions may not beliquid. Many derivatives subject investors to Counterparty Risk.
Equity Market Risk. The equity securities held in a strategy’s investment portfolio may experience sudden,
unpredictable drops in value or long periods of decline in value. This may occur because of factors that
affect securities markets generally or factors affecting specific issuers, industries, sectors, or companies inwhich a fund invests. Common stocks are generally exposed to greater risk than other types of securities,
such as preferred stocks and debt obligations, because common stockholders generally have inferior rights
to receive payment from such issuers.
Exchange-Traded Products Risk. The risks of investing in ETPs typically reflect the risks of the types of
instruments in which such ETPs invest, spanning a wide range of commodities, derivatives, and/or othersecurities designed to track the price, performance and dividend yield of a particular commodity, security,
securities market index or sector of an index. When Merk Investments invests in ETPs, investment accounts
bear their proportionate share of the fees and expenses of the ETP held, as well as their proportionate shareof Merk Investments’ fees and expenses. Shares of ETPs may trade at a premium or discount to their NAV.

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Fixed-Income Securities Risk. Merk Investments invests in fixed-income (debt) securities, which are
generally subject to the following risks:Credit Risk. The financial condition of an issuer of a fixed-income security may cause theissuer to default. The value of an account may change in response to changes in the credit
ratings of securities. Investment risk and price volatility may increase as a security’s credit
rating declines.
Duration Risk. The risk that holding long duration and long maturity investments will magnify
certain other risks, including interest rate risk and credit risk.
Interest Rate Risk. The value of your investment may change in response to changes in interest
rates. An increase in interest rates may cause a fall in the value of the fixed-income securities
in which Merk Investments may invest. Given the historically low interest rate environment,risks associated with rising rates are heightened.
Focused Portfolio Risk. The Firm’s portfolio investments may be more heavily weighted in one or more
sectors or industries. Negative developments affecting those sectors or industries may result in greater
market risk to investors than to a fund that is not weighted in those sectors or industries
Foreign Instrument Risk. Foreign investments are subject to risks that include international trade, currency,
political, regulatory, and diplomatic risks, which may affect their value. Also, foreign instruments are
subject to the risk that their market price may not reflect the issuer’s condition because there is not sufficientpublicly available information about the issuer. Government supervision and regulation of foreign stock
exchanges, currency markets, trading systems and brokers may be less than in the U.S.
Geographic Focus Risk. Some investments may be particularly susceptible to economic, political, or
regulatory events affecting those countries or regions in which Merk Investments focuses its strategies. To
the extent that a portfolio invests a significant portion of its assets in the securities of companies of a single
country or region, it is more likely to be impacted by events or conditions affecting that country or region.
Gold and Precious Metals/Minerals Risk. Investments in gold and other precious metals typically respondto changes in the price of gold and other precious metals, which can be influenced by a variety of global
economic, financial, and political factors; increased environmental and labor costs in mining; and changes
in laws relating to mining or gold production or sales; and the price may fluctuate substantially over shortperiods of time.
Gold Investment Risks. Investments in gold are subject to risks associated with factors that affect price ofgold. The value of an investment in gold will fluctuate based on, and could be materially adversely affectedby, the price of gold. This creates the potential for losses, regardless of the period of time that you hold theshares. Several factors may affect the price of gold and, as a result, the value of the shares, including thefollowing:• Global supply and demand, which is influenced by factors including: (1) forward selling bygold producers; (2) purchases made by gold producers to unwind gold hedge positions; (3)central bank purchases and sales; (4) production and cost levels in major gold-producing
countries; and (5) new production projects;• Global or regional political, economic, or financial events and situations, especially those
unexpected in nature;• Investors’ expectations regarding future inflation rates;• Currency exchange rate volatility;• Investment and trading activities of hedge funds and commodity funds;
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Interest rate volatility andOther economic variables such as income growth, economic output, and monetary policies.

There is no assurance that gold will maintain its long-term value in terms of U.S. dollar value in the future.
In the event that the price of gold declines, Merk Investments expects the value of investments in gold todecline proportionately.
Gold-Related Securities Risk. Investments in gold-related securities may be subject to greater volatility
than investments in traditional securities. The value of gold-related securities may be affected by market
movements and political, regulatory, or other factors affecting the gold industry. Gold-related securities
generate no interest or dividends, and the return from investments in gold-related securities will be derived
solely from the price gains or losses from the commodity. Investments in gold and gold-related securities
may have negative tax consequences for an investor.
Junior and Intermediate Mining Companies Risk. The securities of junior and intermediate explorationand development, gold, and silver mining companies, which are often more speculative in nature, tend to
be less liquid and more volatile in price than securities of larger companies.
Liquidity Risk. Certain securities and derivatives traded by Merk Investments may be difficult to sell at thetime and price Merk Investments would like. As a result, a portfolio may have to hold these investments
longer than it would like and may forego other investment opportunities. There is the possibility that a
portfolio may lose money or be prevented from realizing capital gains if it cannot sell a security at aparticular time and price.
Market Discount from Net Asset Value. Shares of closed-end investment companies frequently trade at a
discount from their net asset value. The Firm cannot predict whether the common shares of any closed-end
funds held in portfolio will trade at, below or above net asset value.
Market Events Risk. The trading prices of securities and other instruments fluctuate in response to a variety
of factors. These factors include events impacting the entire market or specific market segments, such aspolitical, market, and economic developments, as well as events that impact specific issuers. The value ofa strategy’s investment portfolio and market price, like security and commodity prices generally, may
fluctuate significantly in response to these and other factors. As a result, an investor could lose money overshort or long periods of time. U.S. and international markets have experienced significant periods ofvolatility in recent years due to a number of these factors, including the impact of the COVID-19 pandemic
and related public health issues, growth concerns in the U.S. and overseas, uncertainties regarding interest
rates, trade tensions and the threat of tariffs imposed by the U.S. and other countries. These developments
as well as other events could result in further market volatility and negatively affect financial asset prices,
the liquidity of certain securities, and the normal operations of securities exchanges and other markets. It is
unknown how long circumstances related to the pandemic will persist, whether they will reoccur in the
future, whether efforts to support the economy and financial markets will be successful, and what additional
implications may follow from the pandemic. The impact of these events and other epidemics or pandemics,
in the future, could adversely affect the strategy’s performance.
Non-U.S. Investments. Risks include, but are not limited to, less public information available regarding
non-U.S. issuers, limited liquidity of non-U.S. securities and political risks associated with the countries inwhich non-U.S. securities are traded and the countries where non-U.S. issuers are located. These non-U.S.
economies may differ unfavorably from the U.S. economy in gross national product growth, inflation rate,savings rate and capital reinvestment, resource self-sufficiency and balance of payments positions, and inother respects. Merk Investments may invest in securities of non-U.S. governments (or agencies or
subdivisions thereof), and some or all of the foregoing considerations also may apply to those investments.
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Developing Countries. The risks of non-U.S. investments typically are greater in less developed
countries, sometimes referred to as emerging markets. For example, political and economic
structures in these countries may be less established and may change rapidly. These countries also
are more likely to experience high levels of inflation, deflation, or currency devaluation, which canharm their economies and securities markets and increase volatility. Restrictions on currency
trading that may be imposed by developing countries will have an adverse effect on the value ofthe securities of companies that trade or operate in such countries.
Political Risks. Many of the non-U.S. companies in which Merk Investments invests, directly or
indirectly, may be particularly exposed to the risk of political change and governmental action. In
some non-U.S. countries, there is the possibility of expropriation or confiscatory taxation,
limitations on removing funds or other account assets, political or social instability, or diplomaticdevelopments that could materially and adversely affect the value and marketability of a portfolio’s
investments in those countries.
Non-U.S. Investment Limitations. Some of the countries in which Merk Investments invests,
directly or indirectly, may have laws and regulations that currently preclude or severely restrict
direct non-U.S. investment in securities of their companies. Indirect non-U.S. investment may,
however, be permitted through investment funds that have been specifically authorized for that
purpose. Because of the limited number of authorizations granted in such countries, however, units
or shares in most of the investment funds authorized in those countries may at times trade at a
substantial premium over the value of their underlying assets. There can be no certainty that thesepremiums will be maintained and if the restrictions on direct non-U.S. investment in the relevant
country were significantly liberalized, premiums might be reduced, eliminated altogether, or turned
into a discount.
Non-U.S. Securities Regulation. The securities of non-U.S. issuers held by Merk Investments
generally are not registered under, nor are the issuers thereof subject to the reporting requirementsof, U.S. securities laws and regulations. Accordingly, there may be less publicly available
information about these securities and about the non-U.S. company or government issuing them or
the board of trade clearing them than is available about a U.S. company, government entity or boardof trade. Non-U.S. companies and boards of trade generally are not subject to accounting, auditing
and financial reporting standards, practices, and requirements comparable to those applicable to
U.S. companies. Further, government supervision of stock exchanges, boards of trade, securities
brokers and issuers of securities is generally less stringent than supervision in the U.S. The
investments also may be subject to withholding taxes imposed by the applicable country’s taxing
authority.
Limited Liquidity of Non-U.S. securities. Securities of some non-U.S. companies are less liquid,
and their prices are more volatile than securities of comparable U.S. companies. Investing in nonU.S. securities creates a greater risk of securities clearance and settlement problems.
Private Placement Risk. Privately issued securities, including those which may be sold only in accordancewith Rule 144A under the Securities Act of 1933, as amended, are restricted securities that are notregistered with the U.S. Securities and Exchange Commission. The liquidity of the market for specificprivately issued securities may vary. Accordingly, clients may not be able to redeem or resell their interests
in a privately issued security at an advantageous time or at an advantageous price, which may result in a
loss.

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Restricted Security Risk. The Firm may invest client assets in direct equity investments in securities thatare subject to contractual and regulatory restrictions on transfer. These investments may involve a highdegree of business and financial risk. The restrictions on transfer may cause a client to hold a security ata time when it may be beneficial to liquidate the security, and the security could decline significantly invalue before the Firm could liquidate the security.
Warrants Risk. Warrants can provide a greater potential for profit or loss than an equivalent investment in
the underlying security. Prices of warrants do not necessarily move, however, in tandem with prices of theunderlying securities, particularly for shorter periods of time, and, therefore, may be considered
speculative investments. If a warrant held in a portfolio was not exercised by the date of its expiration, theportfolio would incur a loss in the amount of the cost of the warrant.
Item 9: Disciplinary Information
Neither Merk Investments nor its supervised persons have reportable disciplinary events to disclose.
Item 10: Other Financial Industry Activities and Affiliations
Item 10.A.
Neither Merk Investments nor any of its management persons is currently registered or has an application
pending to register as a broker-dealer or registered representative of a broker-dealer.
Item 10.B.
Neither Merk Investments nor any of its management persons is registered or has an application pending toregister as a futures commission merchant, a commodity pool operator, a commodity trading advisor, or an
associated person of the foregoing entities.
Item 10.C.
Merk Investments provides advisory services to Client accounts. Certain Client accounts have in the pastand may in the future invest in the same securities. Should Merk Investments execute a transaction on
behalf of more than one Client account, its policy is to aggregate trades whenever possible to achieve equal
pricing across the Client accounts. Merk Investments may choose not to aggregate trades in avoidance of aperceived or actual conflict of interest, provided that Clients are treated fairly and equitably over time.
Item 10.D.
Merk Investments and its supervised persons do not recommend or select other investment advisers for
Clients or have any business relationships with other investment advisers.

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Merk In v estm en t s LLC
115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 11.A.
Merk Investments has adopted a Code of Ethics (the “Code”) that will obligate Merk Investments andits supervised persons to put the interests of its Clients before their own interests and to act honestly andfairly in all respects in their dealings with Clients.
The Code of Ethics includes the following points:• A statement of the standard of business conduct;• Procedures for handling confidential information;• Treatment of Material, Nonpublic Information;• Personal Trading Policy where all employees are subject to strict reporting requirements regarding
personal holdings and required to pre-clear certain purchases or sales of securities through the Chief
Compliance Officer;• Employees are required to obtain prior approval from the Chief Compliance Officer before entering
into any private securities transaction;• Reporting and prior approval requirements for any Outside Business Activities;• Limits on gifts and entertainment;• Limits on political contributions;• Employees must acknowledge in writing having received and read a copy of the Code; and• Any exceptions to the above need prior approval of the Chief Compliance Officer.
A copy of the Firm’s Code is available to Clients and prospective clients upon request.
Item 11.B
Merk Investments, as a fiduciary, endeavors to always make decisions in the best interest of its Clients if a
conflict of interest arises.
Supervised persons of Merk Investments are permitted to maintain personal brokerage accounts, subject to
the Code of Ethics and its personal trading policy. The Firm’s supervised persons have in the past or may
in the future invest in securities in which Client accounts are invested, which could create a potential conflictin that it could cause Merk Investments to make different investment decisions than if such parties did nothave any such financial ownership interest. Potential conflicts of interest are addressed through preapproval in accordance with the Code of Ethics and its personal trading policy.
Item 11.C
Merk Investments (or a related person) may invest in the same securities (or related securities, e.g.,
warrants, options, or futures) that the Firm (or a related person) recommends to its Clients.
Item 11.D
Merk Investments (or a related person) may recommend securities to Clients, or buys or sells securities for
Client accounts, at or about the same time that the Firm or a related person buys or sells the same securities
for its own (or the related persons own) account.

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Merk In v estm en t s LLC
115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 12: Brokerage Practices
Merk Investments has full discretion to determine which investments to purchase and sell on behalf of the
Clients. When selecting the brokers and/or dealers, or Futures Commission Merchants (FCMs), throughwhom transactions for the Clients are executed, Merk Investments will allocate those transactions to suchbrokers, dealers or FCMs for execution on such markets, at such prices and at such brokerage commission
rates, mark ups or mark downs (which may be in excess of the prices or rates that might have been charged
for execution on other markets or by other brokers, dealers or FCMs) as in Merk Investment’s good faithjudgment are appropriate, subject to Merk Investment’s duty to seek best execution.
When selecting broker-dealers to execute transactions, Merk Investments considers a variety of factors,
including: (i) execution capabilities with respect to the relevant type of order; (ii) commissions charged bya broker, which may be based on the size of the order, the price of the security and whether the receipt of
products or services is involved; (iii) the reputation of the firm being considered; (iv) responsiveness torequests for trade data and other financial information; and (v) other factors suggested by the SEC for
determining best execution and set forth in the Firm’s Compliance Manual.
Item 12.A.1.
Merk Investments does not receive research or other products or services (known as “soft dollar benefits”)
other than execution from a broker-dealer or a third party in connection with Client securities transactions.
Item 12.A.2.
Merk Investments does not participate in selecting or recommending broker-dealers in exchange for clientreferrals.
Item 12.A.3.
Directed brokerage is not applicable to Merk Investments.
Item 12.B.
When Merk Investments must execute a transaction on behalf of more than one Client account, it is the
Firm’s policy to aggregate trades whenever possible to achieve equal pricing across the Client accounts andto reduce transaction costs. Merk Investments may choose not to aggregate trades in avoidance of aperceived or actual conflict of interest. If the Firm elects not to aggregate trades, Clients will not receive
the potential benefits of aggregation, such as lower commission rates and uniform or favorable pricing. As
a result, the Client could pay higher commission rates and receive less favorable prices than if Merk
Investments had aggregated the Client’s trades. The Firm’s policy is to execute trades in a matter where
all Clients are treated fairly and equitably over time.

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Merk In v estm en t s LLC
115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 13: Review of Accounts
Item 13.A. and 13.B.
Merk Investments reviews each portfolio on an ongoing basis for conformity with investment style, asset
allocation and changes to performance of individual securities. Reviews also include monitoring cash
equivalent positions and other position limits, as well as settlement issues regarding transactions.
Additionally, Merk Investments reviews accounts when it is notified of changes in Client objectives,
guidelines, or financial circumstances, among other factors, and also at times of Client addition orwithdrawal of assets.
Various reviews are conducted by members of the Firm’s investment management team (including portfolio
managers and their delegates), operations team, and compliance department. Merk Investments also
executes, in conjunction with the administrator or trustee of Clients’ accounts, as applicable, analysis oftrades for Client accounts for compliance with accounts’ investment guidelines and trading restrictions.
Factors that may trigger a review may include, but are not limited to, (i) unexpected performance ofindividual securities or instruments invested in, and (ii) changes recommended in overall investment policyor strategy by Merk Investments’ portfolio managers.
Item 13.C.
Merk Investments provides quarterly written and oral reports to the Closed-End Fund tailored to comply
with the Firm’s obligations under the Investment Company Act.
From time-to-time Merk Investments makes available, through its websites, information to the generalpublic via webinars, and written reports regarding the strategies and investments it manages, as well as
insights based on the Firm’s research which includes the topics of gold, other precious metals, minerals,
and mining. The Firm also publishes a gold chart book, which is generally made available monthly.
Item 14: Client Referrals and Other Compensation
Item 14.A.
Merk Investments does not receive economic benefits from any non-clients, nor does it provide any
investment advice or other advisory services to non-clients.
Item 14.B.
Merk Investments does not directly or indirectly compensate any person who is not a supervised person forclient referrals, including third-party marketers or solicitors.

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Merk In v estm en t s LLC
115 0 C he stnu t St, Me nl o Pa rk , CA 940 25

Item 15: Custody
Merk Investments does not have custody of any separately managed account, mutual fund, or exchange
traded vehicle assets.
Clients and investors are encouraged to compare account statements from the custodian or administrator,
as may be applicable, to those they may receive from Merk Investments.
Item 16: Investment Discretion
Merk Investments usually receives discretionary authority from the Client at the outset of an advisory
relationship to select the identity and amount of securities to be bought or sold. Clients generally grant
Merk Investments a limited power of attorney to invest through an investment advisory agreement. Merk
Investments manages only the portion of each Client’s assets for which an investment advisory agreement
has been signed and will not provide advice on a Client’s other assets. In all cases, such discretion is to be
exercised in a manner consistent with the stated investment objectives, investment policies, limitations, andrestrictions for the particular Client account. Investment guidelines and restrictions for a Client accountmust be provided to Merk Investments in writing.
For the Closed-End Fund, the Firm’s authority to trade securities is limited by certain federal securities andtax laws that, amongst others, require diversification of investments.
Item 17: Voting Client Securities
Item 17.A.
To the extent that Merk Investments has been delegated proxy voting authority on behalf of its Clients theFirm complies with its proxy voting policies and procedures, the “Proxy Voting Policy.” The Proxy Voting
Policy is designed to ensure that in cases where Merk Investments votes proxies with respect to client
securities, such proxies are voted in the best interests of the Firm’s Clients.
Merk Investments exercises its voting authority with a goal of maintaining or enhancing shareholder valueof the companies in which it has invested Client assets.
Merk Investments is committed to minimizing conflicts of interest when voting proxies on behalf ofClients and strives to verify that proxies are voted in the best interests of Clients, including investors in
Pooled Vehicles. Merk Investments has adopted the following:•••

For routine matters, as the quality and depth of management is a primary factor consideredwhen investing in an issuer, the recommendation of the issuer's management on any issue will
be given substantial weight. The position of the issuer's management will not be supported inany situation where Merk Investments assesses that it is not in the best interests of Clientsand investors.
For non-routine matters, such proposals should be examined on a case-by-case basis.
Merk Investments may abstain from voting a proxy if such vote cannot be cast withcommercially reasonable efforts or if Merk Investments deems it to be in the best interest of the17Merk In v estm en t s LLC
115 0 C he stnu t St, Me nl o Pa rk , CA 940 25•

Clients and investors to abstain from voting a proxy.
Merk Investments may choose to abstain from voting for routine matters when it agrees withthe recommendation of the issuer's management.

As a general rule, conflicts of interest will be resolved by Merk Investments voting in accordance with its
proxy voting policy when: Merk Investments manages the account of a corporation or a pension fundsponsored by a corporation in which Clients of Merk Investments also own stock; an employee or a memberof his/her immediate family is on the Board of Directors or a member of senior management of the company
that is the issuer of securities held in a Client’s account; or Merk Investments has a material relationshipwith a corporation whose securities are the subject of the proxy.
Clients that wish to obtain information on how specific proxies were voted, or a copy of Merk Investments’
Proxy Voting Policy, may contact the Chief Compliance Officer.
Item 17.B.
Not applicable.
Item 18: Financial Information
Item 18.A.
Merk does not solicit prepayment of more than $1,200 in fees per Client, six (6) months or more in advance.
Item 18.B.
There are no conditions that impair Merk Investments’ ability to meet its contractual and fiduciarycommitment to the Client accounts.
Item 18.C.
Merk Investments has not been the subject of a bankruptcy petition at any time during the past ten (10)years.

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