Description of Advisory Firm Steward Inc. is registered as an Investment Adviser with the United States Security Commission (SEC). We were founded in April 2021. Ami Nash Shah, is the principal owner of the firm. The major decisions of a strategic and administrative nature for the firm are undertaken by Ms. Shah. This narrative brochure provides clients with information regarding Steward and the qualifications, business practices, and nature of advisory services that should be considered before becoming an advisory client of Steward. Prior to engaging Steward to provide services, clients are required to enter into an agreement with Steward setting the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Steward beginning services. It remains the client’s responsibility to promptly notify Steward if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing/evaluating/revising Steward’s previous recommendations and/or services. Types of Advisory Services Steward offers wealth advisory services (investment management, ongoing financial consulting), and financial wellness software. A) Investment Management Services (Steward manages accounts) We manage individually tailored investment portfolios. Steward provides continuous advice to clients regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Subject to any written guidelines, which the client may provide, Steward will be granted discretion and authority to manage the client’s investment account(s). Accordingly, Steward is authorized to perform various functions, at the client’s expense, without further approval from the client. Such functions include making all investment decisions on the (a) securities purchased/sold and (b) the amount of securities to be purchased/sold. Once the portfolio is constructed, Steward provides ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Steward primarily allocates investment management assets of its client accounts among various asset classes using mutual fund and exchange-traded funds (“ETFs”) (and to a much lesser extent, among various individual debt and equity securities), on a discretionary basis, in accordance with the investment objectives of the client as set forth in an Investment Policy Statement prepared by Steward for review and acceptance by the client. Investment management accounts are managed on a discretionary basis. Account supervision is guided by the client’s stated objectives. Each client has a responsibility to inform Steward of any changes to financial circumstances or investment objectives. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors, if, in Steward’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Clients can engage Steward to manage all or a portion of their assets on a discretionary basis. Steward also may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, Steward either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Fees pertaining to this service are outlined in Item 5 of this brochure. B) Ongoing Financial Consulting Steward offers advanced financial planning services. Such advice will typically involve providing a variety of services, principally advisory in nature, to clients regarding the management of the client’s financial resources based upon an analysis of each client’s individual needs. The process typically begins with an initial complementary consultation. Once such information has been studied and analyzed, a financial plan – designed to achieve the client’s expressed financial goals and objectives – will be produced and presented to the client. To the extent requested by the client, financial planning advice may be rendered in the areas of business planning, cash flow and debt management, retirement planning, personal tax planning strategies, estate planning, insurance planning, college planning, and employee benefits optimization, among others. Financial plans are based on the client’s financial situation at the time the plan is presented and are based on financial information disclosed by the client to Steward. Clients are advised that certain assumptions will be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. Steward cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As the client’s financial situation, goals, objectives, or needs change, the client must notify Steward promptly. Retirement Rollovers-No Obligation/Conflict of Interest: A client leaving an employer typically has four options (and may engage in a combination of these options): 1) leave the money in his former employer’s plan, if permitted, 2) roll over the assets to his/her new employer’s plan, if one is available and rollovers are permitted, 3) rollover to an Individual Retirement Account (IRA), or 4) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Steward may recommend an investor roll over plan assets to an IRA managed by Steward. As a result, Steward may earn an asset-based fee; however, a recommendation that a client or prospective client leave their plan assets with their old employer will result in no compensation. Steward has an economic incentive to encourage an investor to roll plan assets into an IRA that Steward will manage. There are various factors that Steward may consider before recommending a rollover, including but not limited to: i) the investment options available in the plan versus the investment options

available in an IRA, ii) fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan’s investment professionals versus those of Steward, iv) required minimum distributions and age considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to roll over plan assets to an IRA managed by Steward. C. Financial Wellness Software Steward offers a software-only service to clients through providing and Initial Financial Plan and Ongoing Service. Initial Financial Plan – Steward’s goal is to address all aspects of a client’s financial need, providing a roadmap to achieve their goals. The financial plan is a comprehensive evaluation focusing on the three core areas of personal finance. This may include assisting clients with their savings, ensuring they allocate funds in a priority order. For example, maxing out their 401(k) employer match, creating an emergency fund, paying down expensive debt, max out IRAs, investing for short term goals, investing for long term wealth accumulation. We recommend specific accounts and investment products for each. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The three core areas we focus on: ● Prioritizing goals : We will conduct a review of your income and expenses to determine your current surplus or deficit. We collect basic information on financial assets (cash and investments) already available. We also collect your aspirational financial goals during discovery. We recommend an initial prioritization of your goals based on your timeline and advise you which of the goals you told us during discovery you can fund. Then we allow you to calibrate these goals in light of your overall ability to fund them. As part of defining your goals, we guide you towards best practices by recommending what we believe to be an appropriate cash reserve that should be considered for emergencies and we ensure you put aside enough of your income to pay taxes and expenses. ● Tax Optimization : We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits and other tax optimization strategies (like IRA and 529 accounts). We accomplish this by identifying the most tax efficient account for each of your prioritized goals, calculating the optimal contributions you can make to those considering the complex eligibility criteria and your financial situation and then comparing these optimal contributions to your current approach to make tailored recommendations on what to change. ● Investment strategy : For each goal you prioritized and can fund, we will recommend a specific investment strategy. These are tailored to the time horizon of the goal to maximize returns while minimizing losses on your chosen time horizon. The final product is a detailed digital plan that provides in-depth analysis and specific recommendations in each of the three topic areas of personal finance. Additional information on our fees is provided under Section 5 of this document. Typically, the Financial Wellness Plan will be presented to the client as soon as they share the required data in the form of a discovery questionnaire. The client always has the right to decide whether or not to act upon our recommendations. If the client elects to act on any of the recommendations, the client always has the right to affect the transactions through anyone of their choosing. Ongoing Service Steward provides financial wellness software clients with an ongoing planning service. Clients can at any time update their data to receive a new plan. Trade Error Policy Should they occur, losses resulting from Steward’s trade errors shall be reimbursed by either Steward or the custodian depending on the dollar amount. Any gains will be donated by the custodian to a charity designated by Steward. Client Obligations In performing its services, Steward is not required to verify any information received from the client or from the client’s other professionals. Moreover, each client is advised that it remains his or her responsibility to promptly notify Steward if there is ever any change in the client’s financial situation or investment objectives during the client engagement. Disclosure Statement A copy of Steward’s written brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or at the same time as, the execution of the Financial Planning and Consulting Agreement and/or Investment Advisory Agreement. Any client who has not received a copy of Steward’s written brochure at least 48 hours prior to executing the Financial Planning and Consulting Agreement and/or Investment Advisory Agreement shall have five business days subsequent to executing the agreement to terminate Steward’s services without penalty. Client Tailored Services and Client Imposed Restrictions We offer the same suite of services to all of our clients. However, specific client financial plans are dependent upon a client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Wrap Fee Program Steward, as a matter of policy and practice, does not sponsor any wrap fee program. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment supervisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. We do not participate in wrap fee programs. Amount of Assets Under Management As of February 1, 2023 2, Steward manages $7,981,752 on a discretionary basis and $0 on a non-discretionary basis. Our Policy on Class Action Lawsuits From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Steward has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. It also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Steward has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where Steward receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials, to the client. Electronic mail is acceptable where appropriate if the client has authorized contact in this manner.