Draper Asset Management has been in business as a registered investment adviser since October 2008. The firm offers its clients investment management services and a range of consulting functions. Draper Asset Management also does business as Union Partners Advisors, LLC (“Union Partners”). Union Partners primarily works with individuals employed by the public sector and who may have access to such accounts as 403(b), 457 or other specific retirement programs. The firm’s primary objective of doing business in this marketplace is to provide investment advice to these clients in an effort to help them achieve their retirement goals. Draper Asset Management’s principal owner is Robert F. Draper and as of January 1, 2024, the firm had $137,299,049 in assets under management, all of which were managed on a discretionary basis. Prior to engaging Draper Asset Management to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Draper Asset Management setting forth the terms and conditions under which Draper Asset Management renders its services (collectively the “Agreement”). This Disclosure Brochure describes the business of Draper Asset Management. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Draper Asset Management’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Draper Asset Management’s behalf and is subject to Draper Asset Management’s supervision or control. Consulting Services Draper Asset Management offers clients a broad range of consulting services, addressing a variety of financial matters. These services include tax and estate planning, as well as a host of other investment and non-investment related functions. In performing these services, Draper Asset Management is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Draper Asset Management may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Draper Asset Management recommends its own services. The client is under no obligation to act upon any of the recommendations made by Draper Asset Management under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Draper Asset Management itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Draper Asset Management’s recommendations. Clients

are advised that it remains their responsibility to promptly notify Draper Asset Management if there is ever any change in their financial situation or investment objectives for the Page 5 © MarketCounsel 2023 purpose of reviewing, evaluating or revising Draper Asset Management’s previous recommendations and/or services. Investment Management Services Draper Asset Management manages clients’ investment portfolios on a discretionary basis and non- discretionary basis. Draper Asset Management allocates clients’ investment management assets primarily among individual debt and equity securities and, to a lesser extent, mutual funds and exchange-traded funds (“ETFs”) in accordance with the objectives of its clients. Clients may engage Draper Asset Management to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Draper Asset Management directs or recommends the allocation of client assets among the various investment options available with the product. These assets are maintained at the underwriting insurance company or the custodian designated by the product’s provider. Clients may also engage Draper Asset Management to assist in the fund menu selection for their participation in programs such as 403(b) and 401k. Client engaged in this service receive an asset allocation recommendation based on the fund menu that they create. Draper Asset Management will monitor the asset allocation recommendation, however, clients are able to freely change their individual investments. Draper Asset Management receives an asset based fee based on each individual account holder’s quarterly assets. Draper Asset Management tailors its advisory services to the individual needs of clients. Draper Asset Management consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that impact the clients’ investment needs. Draper Asset Management ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Draper Asset Management if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Draper Asset Management’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in Draper Asset Management’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Page 6 © MarketCounsel 2023