Description of the Advisory Firm This firm has been in business since May of 2007, and the principal owner is Financial Gravity Companies, Inc. (“FGC”) (OTCQB: FGCO). Types of Advisory Services Financial Gravity Asset Management, Inc. (hereinafter “FG Asset Management”) offers the following services to advisory clients: Investment Supervisory Services FG Asset Management offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Investment Supervisory Services include, but are not limited to, the following: ● Investment strategy ● Asset allocation ● Asset selection ● Regular portfolio monitoring ● Asset location optimization when applicable ● Tax lot harvesting when requested FG Asset Management endeavors to provide clients with risk appropriate investment management but using our Real Risk System. Real Risk is defined as the percentage decline of an investment from peak to trough. Each investor has a Real Risk Tolerance, and each portfolio of investments has a Real Risk Score. The client’s Real Risk Tolerance, meaning maximum amount of Real Risk a client is willing to take with the investments to be managed, is measured using the Risk Meter, a proprietary software designed to help clients understand and consider the relationship between expected risk and expected return. The highest level of Real Risk available is 50% and the lowest is zero. FG Asset Management recommends portfolios whose Real Risk Score is equal to or less than the client’s Real Risk Tolerance. FG Asset Management will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Real Risk Tolerance is documented in the Investment Policy Statement, which is given to each client. Selection of Other Advisors FG Asset Management may direct clients to appropriate third-party money manager(s). FG Asset Management will be compensated via a fee share from these advisors to which it directs clients. This relationship will be disclosed in each contract between FG Asset Management and the third-party money manager, and each client will receive full disclosure of the relationship. The fees shared will 6 Financial Gravity Asset Management, Inc. not exceed any limit imposed by any regulatory agency. Before selecting other advisors for clients, FG Asset Management will always ensure those other advisors are properly licensed or registered as investment advisor(s). FG Asset Management Strategies All strategies are managed by FG Asset Management’s Investment Committee chaired by Chief Investment Officer William R. Nelson, PhD. We feel 4 Alpha invests in individual equities and focuses on dominant companies, loved brands, and great products that are understandable, inspire confidence, and are on the right side of long-term trends. The long term trends include, but are not limited to, the electrification of vehicles, renewable energy (as opposed to fossil fuel dependence), autonomous vehicles, biotech, genetic engineering, the growing global middle class, the move from a purchase to a service model, the reduction in the importance of location versus other amenities, the increase in e-commerce accompanied by reduction in conventional retail, proliferation of online platforms, increased economies of scale, aging of developed nation populations, healthier eating including veganism, direct contact between micro- producers and clients, and the reduced influence of traditional push marketing. The 4 Alpha model invests solely in individual stocks that, while actively monitored and managed, are chosen based on the long-term growth prospects. While many of the stocks pay dividends, income is the program’s secondary objective. The three 4 Beta strategies invest in-cost Exchange-Traded Funds (“ETFs”). 4 Beta Taxable Fixed Income diversifies across corporate and sovereign; USA and foreign; short, medium, and long duration; and investment grade to high yield with the objective of earning an efficient risk adjusted return. The 4 strategies are typically blended, often along with insurance products, to accommodate the client’s Real Risk Tolerance. FG Asset Management strives to manage the different models in a low turnover, tax-efficient manner. Additional tax-efficiencies may be gained through location optimization which places securities from the same household in different account types taxed, tax-deferred, and after tax based upon security type (like equity or fixed income) and yield. This strategy only applies to households whose accounts have more than one tax treatment governed by the same investment policy statement. 7 Financial

Gravity Asset Management, Inc. Depending on the size of the account(s) and/or the model or blend chosen, there may be instances where certain higher-priced securities are not purchased. In these cases, the Advisor may replace the security not purchased with a substitute security to maximize the percentage of assets invested. FG Asset Management is a proprietary investment advisory program and the Advisor may benefit financially by recommending these programs over other programs that are not managed by the advisor but any recommendation made by the Advisor should be in the client’s best interest and not based on the interests of the Advisor. Additionally, the Representative acting as a solicitor for the proprietary programs may own stock in or may be a participant in a stock option or stock appreciation plan sponsored by FGC (“Stock Ownership”). Representatives may benefit from placing assets with the Manager in that the value of the FGC stock may be enhanced by such placement. In approving the investment of funds in a Manager Portfolio, Clients should consider whether Representative’s recommendation is influenced by the Stock Ownership. The full extent of the relationship between FCG and Financial Professional is described in Financial Professional’s ADV. Transition Services From time to time, FG Asset Management may provide transition services for the management of a client’s current portfolio and transition it to a FG Asset Management Strategies over time. Transition times will vary and could take several years to complete based on various client specific reasons for example as taxation. Financial Planning FG Asset Management will allow Investment Advisor Representatives to offer financial planning for a fee if the client is given a detailed contract outlining the services from the Advisor. The Investment Advisor Representative is responsible for completing this document which will outline the fees that can be charged along with a detailed list of the services. This client will need to be recorded in the CRM as a client and complete the required documents just like any other wealth client. Private Placements Our affiliated Representatives may refer to private placement products. Private placements can carry a substantial risk and should adhere to the overall philosophies of FG Asset Management. Tax Advice Policy Representatives may reference common tax features associated with specific accounts or products offered by or through FG Asset Management (e.g., tax deferral associated with IRAs or tax-free benefits of insurance products, ie death benefits), but may not provide individualized tax advice in connection with the recommendation of such accounts or products. In connection with services being provided by or through FG Asset Management, representatives may not recommend any tax strategy or engage in any conduct that would cause the representative or FG Asset Management to be a 8 Financial Gravity Asset Management, Inc. “material advisor” as defined by the IRS. Representatives may not recommend or participate in any way in the formation or execution of an IRS “transaction of interest,” IRS “listed transaction,” or potentially abusive tax structure. Services Limited to Specific Types of Investments FG Asset Management limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, hedge funds, third party money managers, REITs, private placements, government securities. FG Asset Management may use other securities as well to help diversify a portfolio when applicable. Client Tailored Services and Client Imposed Restrictions FG Asset Management offers the same suite of services to all its clients. However, specific investment allocations and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current Real Risk Tolerance and provides a risk appropriate portfolio. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FG Asset Management from properly servicing the client account, or if the restrictions would require FG Asset Management to deviate from its standard suite of services, FG Asset Management reserves the right to end the relationship. Wrap Fee Programs FG Asset Management does not participate in a wrap fee program and no transaction costs are wrapped in the program fees. Amounts Under Management FG Asset Management has the following assets under management as calculated in the last ADV filing: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $290,599,160 $0 09/31/2023