General Information Beanstox Inc. (“Beanstox”), a corporation organized in 2018 under the laws of Delaware, is a provider of automated internet-based investment advisory services. Beanstox is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser and maintains its principal office at 1010 Sherbrooke Street West, Suite 2105, Montreal, Quebec H3A 2R7 Canada. Program Description Beanstox provides automated internet-based investment advisory services (the “Program”) available online through mobile applications (the “App”). Additional information regarding the Program is also available via the Beanstox website (the “Website” and, collectively with the App, the “Platform”). The Program provides individual investors with simple and cost-effective ways to invest in United States (the “U.S.”) and international equity and bond markets through Exchange Traded Funds (an “ETF” or “ETFs”). Beanstox does not provide overall financial or tax planning. The information that Beanstox provides in the App and on the Website regarding investing, personal finance and other topics of general interest is designed to be educational and is not personalized advice. In order to provide the Program to Clients, Beanstox collects information from each Client, including specific information about each Client’s financial profile and investment goals and risk tolerance (the “Client Information”). In providing the Program, Beanstox relies on the accuracy of the Client Information received from Clients. As part of the Program, Beanstox currently offers two investment plans (each a “Plan”), Beanstox Simple and Beanstox Plus, and three different investment accounts (each an “Account”) and two subscriptions levels: Plan Accounts Fees Beanstox Simple • Stocks 500 (non-discretionary Account/self directed)
• Power Savings (non-discretionary Account/self directed) No Fee Beanstox Plus • Wealth Builder (discretionary Account)
• Stocks 500 (non-discretionary Account/self directed)
• Power Savings (non-discretionary Account/self directed) $5/month Beanstox Wealth Builder Wealth Builder is available to Clients for a $5 monthly Subscription Fee (defined below) and includes the Stocks 500 and Power Savings Accounts. Please refer to the Fees section below for additional information regarding the applicable Subscription Fee. For Wealth Builder Clients, Beanstox provides investment advice via the Program (the “Advice”) specifically based on a Client’s investment goals and risk tolerance levels (the “Client Profile”). The Advice derived from the Client Profile is based on Beanstox’s investment methodology and asset allocation strategies. More information about Beanstox’s Advice and methodologies is available on the Platform. Wealth Builder Investment Strategy and Portfolios Beanstox develops model portfolios (the “Model Portfolios”) which are designed to address the investment goals and risk tolerance levels set out in the Client Information. In developing and updating the Model Portfolios, Beanstox identifies what it believes to be appropriate (i) asset classes, (ii) securities to represent these asset classes, and (iii) allocations within each asset class for each identified risk level to provide Clients with access to a Client targeted simple and cost-effective Model Portfolio. Beanstox selects ETFs for each asset class comprising the Model Portfolios, using selection criteria for each Model Portfolio, including the ETF portfolio definition, diversification, trading liquidity, and cost. The asset classes considered for a Model Portfolio include U.S. equities (e.g. large cap, technology, value and growth), international equities, emerging markets equities and fixed income (e.g. treasury and municipal bonds and corporate bonds). Based on the Client Information, using its proprietary method, Beanstox will propose to a Wealth Builder Client for review and approval a proposed portfolio (the “Proposed Portfolio”) derived from the various Model Portfolios. Generally, Clients with a lower risk tolerance will be offered a Proposed Portfolio from the various Model Portfolios with lower risk profiles and lower expected returns and lower expected volatility. Clients with a higher risk tolerance will be offered a Proposed Portfolio from the various Model Portfolios with higher risk profiles and higher potential returns and higher expected volatility. Beanstox recommendations for a Proposed Portfolio will not be based on any assets or liabilities outside the Portfolios (defined below). Beanstox does not take a Client’s other assets, including assets a Client may invest in Stocks 500 or Power Savings, into consideration for its assessment of diversification of a Client’s assets. Client should be aware and also acknowledges that a self-directed investment in Stocks 500, as an addition to a Client’s Proposed Portfolio, would likely result in an allocation to large cap equity securities. To the extent that a Client’s Portfolio is less diversified because of an overallocation to large cap equity securities, a Client may experience more market volatility in the Portfolio than in a portfolio that is more diversified among different asset classes. Clients can also decline the Proposed Portfolio and select another portfolio offered by Beanstox (a “Selected Portfolio”) within the Wealth Builder Product. By declining the Proposed Portfolio, (i) Clients have determined that the Selected Portfolio is appropriate for their investment goals, risk tolerance and other personal conditions, and (ii) they assume the risk that the Selected Portfolio may perform worse than the Proposed Portfolio and are responsible for such outcome. In order to begin the investment process, Client must approve the Proposed Portfolio or the Selected Portfolio (the “Approved Portfolio” and, collectively with the Model Portfolios, the Proposed Portfolios, and the Selected Portfolio, the “Portfolios”). The Approved Portfolio establishes the target investment allocations. Beanstox will not accept Client’s legacy investments from another investment account. Clients are not obligated to approve the Approved Portfolio in its entirety to be the Approved Portfolio. However, except as noted below, Client can approve or refuse a Proposed Portfolio or chose a Selected Portfolio and can only make one modification to an Approved Portfolio. To make other adjustments to a Proposed Portfolio, using the App, Client can revise the Client Information, including responses regarding financial profile and investment goals and risk tolerance. Beanstox shall not have authority or discretion to approve any Approved Portfolio for Clients. It is Clients’ responsibility to review and carefully consider the information available on the App about an Approved Portfolio, and the constituent ETFs, before approving an Approved Portfolio. Notwithstanding the foregoing, a Client may exclude from an Approved Portfolio any one of the ETFs that otherwise comprise an Approved Portfolio if, after carefully reviewing and analyzing all pertinent information available on the App about an Approved Portfolio, the Client concludes that they do not want to own any one of the ETFs in the Approved Portfolio. A Client may request to exclude from an Approved Portfolio an ETF at any time by emailing support@beanstox.com. A Client shall have the ability to exclude only one ETF from an Approved Portfolio at any time. If a Client excludes an ETF from an Approved Portfolio, the remaining ETFs in the Approved Portfolio will be allocated relative to each other in the same proportions that they are allocated relative to each other in the Approved Portfolio. A Client may not exclude more than one ETF in an Approved Portfolio. By excluding an ETF, Clients must understand that:
• Clients assume the risk that the resulting Approved Portfolio may perform worse for you over any time period than the original Proposed or Selected Portfolio, or any of the other Model Portfolios on which the original or resulting Proposed or Selected Portfolio is based, or any other investment;
• the resulting Approved Portfolio may not be suitable with respect to Clients’ investment goals, risk tolerance, age, financial condition, or other facts or circumstances that apply to Clients;
• Beanstox shall not be liable for any losses or other damages resulting from Clients’ exclusion of any ETF from a resulting Approved Portfolio; and
• there is no guarantee, representation, warranty, or covenant that the resulting Approved Portfolio will perform better over any time period than any other Portfolio or any other investment. The Approved Portfolio will be implemented almost entirely using ETFs. From time to time, some or all of the Wealth Builder Account’s portfolio can be in cash under certain circumstances, including when cash distributions or additional deposits are credited to the Wealth Builder Account pending investment, or when a Wealth Builder Account is liquidated and cash is deposited in the Wealth Builder Account. The Approved Portfolio’s allocations will be adjusted periodically using cash inflows from dividends and additional Client funding, and may also be adjusted if the Approved Portfolio’s underlying asset allocations deviate by more than 20% from target allocations. As a result, Beanstox may sell over concentrated ETFs or buy under concentrated ETFs to bring Approved Portfolios in line with the target allocations. Beanstox does so on a best efforts basis and does not take into account individual tax, market or legal circumstances. Clients must consult with a tax or legal professional for such information. Beanstox utilizes its best efforts to seek to maintain the Client’s Approved Portfolio allocations through market fluctuations, withdrawals, deposits, and other events that may cause deviations. Stocks 500 Stocks 500 is available to Clients at no fee. Please refer to the Fees section

in this Agreement for additional information relating to Subscription Fees. Stocks 500 is a non-discretionary Product which allows Clients to invest in one or more ETFs available on the App which aim to track the S&P 500 Index’s performance. Results may vary due to expenses and other factors. Clients appoint Beanstox to manage their Stocks 500 Account on a non-discretionary basis and may direct Beanstox to place non-discretionary orders (a “Self- Directed Order”) for the Stocks 500 ETF(s) available on the App with the Carrying Broker (defined below). Beanstox does not act as a broker. Clients grant Beanstox limited discretion, with Beanstox exercising discretion over the specifics of the transaction, including the time, price, number of shares, and units or dollar amounts in the transaction. Clients retain general investment discretion over other matters, including the ultimate decision to invest in a Stocks 500 ETF. Beanstox reserves the right to decline any requested Self-Directed Order in its sole discretion. Clients are solely responsible for any Self-Directed Orders placed through their Stocks 500 Account, and all Self-Directed Orders submitted by Clients using their Stocks 500 Account are based on their investment decisions. The resulting investment is referred to as an Approved Portfolio. Clients are responsible for the suitability of any investments or investment decisions they make in their Stocks 500 Account, and Beanstox’s placement of Self-Directed Orders at Clients’ direction does not signify any view or judgment on the part of Beanstox that the investments or investment decisions are suitable for Clients or consistent with how Beanstox manages Beanstox discretionary Accounts. Beanstox will not be liable for any losses or other damages resulting from Clients’ choice of investments in their Stocks 500 Account. Federal and state securities laws impose liabilities under certain circumstances on persons who act in good faith and therefore nothing herein shall in any way constitute a waiver or limitation of any rights which Client may have under federal or state securities laws. Power Savings Power Savings is available to Clients at no fee. Please refer to the Fees section in this Agreement for additional information relating to Subscription Fees. Power Savings is a non-discretionary Product which allows you to invest in T-Bills through one or more ETFs available on the App which aim to generate a higher return than most traditional savings accounts. There are no assurances that higher returns will be sustainable in the future. Investing in T-Bills ETFs is different from having cash in a traditional bank savings account. There is no FDIC Insurance, no Bank Guarantee, and the investment may lose value (please refer to the Risk Considerations section). Clients appoint Beanstox to manage their Power Savings Account on a non-discretionary basis and may direct Beanstox to place non-discretionary orders (a “Self-Directed Order”) for the Power Savings ETF(s) available on the App with the Carrying Broker (defined below). Beanstox does not act as a broker. Clients grant Beanstox limited discretion, with Beanstox exercising discretion over the specifics of the transaction, including the time, price, number of shares, and units or dollar amounts in the transaction. Clients retain general investment discretion over other matters, including the ultimate decision to invest in a Power Savings ETF. Beanstox reserves the right to decline any requested Self-Directed Order in its sole discretion. Clients are solely responsible for any Self-Directed Orders placed through their Power Savings Account, and all Self-Directed Orders submitted by Clients using their Power Savings Account are based on their investment decisions. The resulting investment is referred to as an Approved Portfolio. Clients are responsible for the suitability of any investments or investment decisions they make in their Power Savings Account, and Beanstox’s placement of Self- Directed Orders at Clients’ direction does not signify any view or judgment on the part of Beanstox that the investments or investment decisions are suitable for Clients or consistent with how Beanstox manages Beanstox discretionary Accounts. Beanstox will not be liable for any losses or other damages resulting from Clients’ choice of investments in their Power Savings Account. Federal and state securities laws impose liabilities under certain circumstances on persons who act in good faith and therefore nothing herein shall in any way constitute a waiver or limitation of any rights which Client may have under federal or state securities laws. An investment in any financial instrument involves risks. While short-term U.S. Treasury securities such as T-Bills are considered safer than many other financial instruments, Clients could, as with any investment, lose all or part of their investment in their Account. Clients’ investments are subject to certain risks, any one or more of which may adversely affect the value of their portfolio, yield, or the total performance of their portfolio. T-Bills may underperform in comparison to the general financial markets, a particular financial market, or other asset classes. The T-Bills ETFs held in Clients’ portfolio may be susceptible to an increased risk of loss, including losses due to adverse events that affect the investments more than the market as a whole, as the investments are not diversified and are concentrated wholly in T-Bills. Fees Beanstox currently offers two investment Plans and charges the following subscription fees (the “Subscription Fee”) Plan Accounts Fees Beanstox Simple • Stocks 500 (non-discreionary Account/self directed)
• Power Savings (non-discreionary Account/self directed) No Fee Beanstox Plus • Wealth Builder (discreionary Account)
• Stocks 500 (non-discreionary Account/self directed)
• Power Savings (non-discreionary Account/self directed) $5/month Included in the Plus Plan monthly Subscription Fee is a $0.10 fee for Advisory Services (the “Advisory Fee”) and $4.90 for additional educational content and additional non-advisory services provided by Beanstox (“Beanstox Plus Fee”). The first monthly Subscription Fee payment covers additional on-boarding expenses incurred by Beanstox for new and current Clients and is not refundable. This is waived for Simple Plan Clients. The Subscription Fees are subject to change upon notice to Clients. Beanstox may apply reduced Subscription Fees, including in connection with promotional programs, in its sole discretion. Advisory Fees are not charged for accounts with a $0.00 balance and the $0.10 Subscription Fee for Advisory Services will be deemed to be part of the Beanstox Plus Fee. Subscripion Fees may change from ime to ime and updated informaion on the Subscripion Fee will be available on the Plajorm. Depending on numerous factors, including the volume and type of trading in a Client’s Account and the aggregate cost of custodial, trade execuion, advisory, and other services that are provided to Clients, the Subscripion Fee may cost more or less money than if the Client were to purchase such services separately away from Beanstox. The Subscription Fee will be charged monthly in advance commencing on the date of the related Account opening and thereafter upon each monthly anniversary of the Account opening. Beanstox will arrange for the automatic debit of applicable fees from the Client’s linked bank account for the Subscription Fee. Clients will not be charged additional fees by Beanstox for costs associated with Advisory Services, including custody, account maintenance and trade execution commissions (except for those fees related to foreign exchange or third-party asset fees). For all Beanstox Plans and Accounts, Clients who request non transactional special or additional services may be charged for such services, including, without limitation, a $0.25 processing charge when they withdraw funds from their Account, which will be subtracted from the total withdrawal amount. Client may also be charged additional fees for reimbursement of non advisory expenses such as insufficient funds charges. Although the fees are not negotiable, Beanstox may, at its sole discretion, waive a portion of its fees or offer fees to some Accounts that differ from the standard fee schedules referenced above. The ETFs in which a Client’s assets are invested charge their own separate management fees and bear other expenses, as described in each ETF’s prospectus. These fees are not part of Beanstox’s wrap fee program. Beanstox receives no portion of these fees, and these fees are separate from, and in addition to, Beanstox’s Subscription Fees. Brokerage If Clients choose to participate in the Program, they will be required to delegate to Beanstox the selection of service providers for brokerage and custody services. Beanstox has entered into an agreement with DriveWealth, LLC (the “Carrying Broker”) to provide and/or arrange broker-dealer and custodial services for Beanstox Accounts. As part of the account opening process, Clients enter into a separate brokerage agreement with the Carrying Broker (the “Brokerage Agreement”). A detailed description of fees of, and services provided and/or arranged by, the Carrying Broker are set out in the Brokerage Agreement. Additionally, the Beanstox Advisory Agreement authorizes and directs Beanstox to place all trades for a Beanstox Account through the Carrying Broker. Beanstox does not receive payment for order flow related to these trade orders. The Carrying Broker is ultimately responsible for trade confirmations and Client statements. Beanstox will generally aim to initiate all trade orders in a timely manner, however Clients should be aware that at times order execution may be delayed, including due to market conditions or to permit bundling of trades in order to achieve scale and cost efficiencies. Under these instances, Beanstox reserves the right to delay trade executions at its discretion. Trades are usually processed once a day, around 10 am ET. This timing may change from time to time.