A. Description of the Advisory Firm Harding Wealth, Inc. (hereinafter “HW”) is a corporation organized in the State of Arizona. The firm was originally formed in January 2016, and the principal owner is Adam Clark Harding. B. Types of Advisory Services Portfolio Management Services HW offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. HW creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. 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 HW evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. HW will request 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. HW seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of HW’s economic, investment or other financial interests. To meet its fiduciary obligations, HW attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, HW’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 HW’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. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation,

and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. Services Limited to Specific Types of Investments HW generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements, although HW primarily recommends diversified fee-conscious portfolios with a focus on liquidity, transparency, and academic research. to a majority of its clients. HW may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions HW 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 HW on behalf of the client. HW may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Investment advisory services will be the tailored as a result of four key items: Risk Tolerance (How well an investor can digest volatility), Risk Capacity (How much risk can be taken given the investor's personal financial situation), Investment Objectives (What rate of return is needed to meet the investment objectives outlined in the investors financial plan), and the Investment Landscape (What are the predominate risks and opportunities in the investable universe). 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 HW from properly servicing the client account, or if the restrictions would require HW to deviate from its standard suite of services, HW 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, transaction costs, fund expenses, and other administrative fees. HW does not participate in any wrap fee programs. E. Assets Under Management HW has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 124,416,689.00 $ 0.00 December 2023