A. Description of the Advisory Firm B. Types of Advisory Services clients to avoid favoring one client over another over time. It is AXIA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. As fiduciaries we are obligated to do the following:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Services Limited to Specific Types of Investments AXIA generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. AXIA may use other securities as well to help diversify a portfolio when applicable. AXIA will tailor a program for each individual client. This will include an interview session to get to know the client’s

specific needs and requirements as well as a plan that will be executed by AXIA on behalf of the client. AXIA may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. 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 AXIA from properly servicing the client account, or if the restrictions would require AXIA to deviate from its standard suite of services, AXIA reserves the right to end the relationship. C. Client Tailored Services and Client Imposed Restrictions A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. AXIA does not participate in any wrap fee programs. AXIA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $49,650,189 $0 December 2024 Asset-Based Fees for Portfolio Management Total Assets Under Management Annual Fee All assets 1.00% These fees are generally negotiable and the final fee schedule is provided for in the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of AXIA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 1 days' written notice. AXIA uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Payment of Asset-Based Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client’s accounts with client’s written authorization on a quarterly basis, or may be invoiced and billed D. Wrap Fee Programs E. Assets Under Management