A. Description of the Advisory Firm Maxwell Wealth Strategies Inc. (hereinafter “Maxwell Wealth”) is a Corporation organized in the State of California. The firm was formed in July 2015, and the principal owner is James Eric Maxwell. B. Types of Advisory Services Portfolio Management Services Maxwell Wealth offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Maxwell Wealth creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Maxwell Wealth evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Maxwell Wealth will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Maxwell Wealth seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Maxwell Wealth’s economic, investment or other financial interests. To meet its fiduciary obligations, Maxwell Wealth attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Maxwell Wealth’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Maxwell Wealth’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. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments Maxwell Wealth 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 and non-U.S. securities, although Maxwell Wealth primarily recommends large cap. domestic stocks. Maxwell Wealth may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Maxwell Wealth offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). 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 Maxwell Wealth from properly servicing the client account, or if the restrictions would require Maxwell Wealth to deviate from its standard suite of services, Maxwell Wealth reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. Maxwell Wealth does not participate in wrap fee programs. E. Assets Under Management Maxwell Wealth has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 191,704,523 $ 11,058,928 October 2023