A. DESCRIPTION OF ADVISORY FIRM Veracity Capital LLC (hereinafter “Veracity”, the “Firm”, “Us”, “Our”, or “We”) is a Limited Liability Company organized in the State of Texas, but headquartered in Atlanta, GA. The Firm was formed in August 2018, and the principal owners are Michael Mess, Kevin Gray, and John Rogers. B. TYPES OF ADVISORY SERVICES Veracity offers investment advisory services to individuals, families, trusts, estates, businesses, and retirement plans (each referred to as a “Client”). Veracity provides comprehensive investment management, planning and consulting services tailored to the individual needs of each Client. These services are primarily focused on high-net-worth Clients. Investment Advisory Services Veracity provides customized investment advisory solutions for its Clients. This is achieved through personal Client contact and interaction while providing discretionary investment management and related advisory services. Veracity works with Clients to identify their investment goals and objectives as well as risk tolerance and financial situation to create an appropriate investment strategy. Veracity will then construct a portfolio strategy that may include the use of our internal investment management and/or outside managers. Internal Investment Management - Veracity customizes its investment management services for its Clients, as outlined in this Disclosure Brochure. Portfolios are primarily constructed using mutual funds, exchange-traded funds (“ETFs”), individual stocks and fixed income securities. The Advisor may also utilize other types of investments, as appropriate, to meet the needs of each Client. The Advisor may retain legacy securities due to portfolio fit and tax considerations. Veracity evaluates and selects investments for inclusion in Client portfolios after applying its internal due diligence process. Veracity’s investment strategy is primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. If it is consistent with the Client’s goals, the Advisor may also engage in an investment strategy that utilizes frequent trading in securities, as outlined in Item 8 below. Veracity will construct, implement, and monitor the Client’s portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. VERACITY CAPITAL LLC | PAGE 5 Clients grant Veracity discretion to purchase and sell securities in their portfolio. Veracity may employ specific positions to increase sector or asset class weightings. Veracity may recommend employing cash positions as a possible hedge against market movement. Veracity may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Veracity will provide investment management and related advisory services. At no time will Veracity accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the investment advisory agreement. Use of Outside Managers – Veracity may recommend to Clients that all or a portion of their investment portfolio be invested by utilizing one or more outside money managers or investment platforms (an “Outside Manager”). Outside Manager may be sourced directly or accessed through an investment management platform or directly engaged by Veracity. The Client may be required to enter into a separate agreement with the Outside Manager. Please see Item 10 for additional information. Generally, with Outside Managers, Veracity serves as the Client’s primary advisor and relationship manager. However, the Outside Manager will assume discretionary authority for the day-to-day investment management of those assets placed in their control. Veracity will assist and advise the Client in establishing investment objectives for their account, the selection of the Outside Manager, and defining any restrictions on the account. Veracity will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these outside parties. The Outside Manager will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties. Financial Planning and Consulting Services Veracity may provide financial planning services to Clients as part of the investment advisory engagement or as a separate engagement, depending on the Client’s financial situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan

or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, education savings and other areas of a Client’s financial situation. VERACITY CAPITAL LLC | PAGE 6 A financial plan developed for a financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence, or alter retirement savings, establish education savings and/or charitable giving programs. Veracity may also refer Clients to an accountant, attorney, or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Ultimately the Client has the discretion to decide whether to implement the plan or recommendations and takes responsibility for this decision. Retirement Plan Advisory Services Veracity serves as an ERISA 3(21) Fiduciary to retirement plans (each a “Plan”) in support of the Plan Sponsor. Veracity may provide the following Plan Fiduciary Services pursuant to the terms of the Advisor’s agreement with each Plan Sponsor:
• Vendor Analysis
• Employee Enrollment and Education Tracking
• Investment Policy Statement
• Investment Monitoring
• Performance Reports
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services The specific services will be outlined in the advisory agreement signed by the Plan Sponsor. Veracity does not provide 3(38) discretionary investment advisory services on behalf of the Plan or Plan Sponsor. Individual Retirement Accounts – Recommended Rollover to Veracity Capital “When providing investment advice to you with respect to funds held in your individual retirement account (IRA) or retirement plan account, including recommendations with respect to the rollover of funds from one account to another and other transactions as may be described below, Veracity Capital, LLC (“Veracity”) is acting as a fiduciary within the meaning of Title I of the Employee VERACITY CAPITAL LLC | PAGE 7 Retirement Income Security Act of 1974 (ERISA) and/or the Internal Revenue Code. The ways in which Veracity makes money can create certain conflicts of interest with respect to our recommendations with respect to IRA and retirement plan account investments. We ensure that your best interests are protected by performing our duties in accordance with professional standards, always putting your financial interests ahead of our own, and providing you with clear information about conflicts of interest (including our investments and compensation).” C. CLIENT ACCOUNT MANAGEMENT Prior to engaging Veracity to provide investment advisory services, each Client is required to enter into one or more advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. Clients should review these agreements in detail prior to executing them. The services provided under these agreements may include:
• Establishing an Investment Strategy – Veracity, in connection with the Client, will develop an investment strategy targeted to achieve the Client’s investment goals and objectives.
• Asset Allocation – Veracity will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – Veracity will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Veracity will provide investment management and ongoing oversight of the Client’s portfolio.
• Financial Planning and Consulting – For Clients engaging for investment advisory services, the Advisor provides ongoing financial planning and related services regarding the Client’s overall financial situation. D. WRAP FEE PROGRAMS A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Veracity does not participate in any wrap fee programs. E. ASSETS UNDER MANAGEMENT Veracity has the following assets under management: VERACITY CAPITAL LLC | PAGE 8 Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 650,811,615 $ 8,717,439 December 2023