INTRODUCTION As an investment adviser, we are subject to a fiduciary duty requiring that we act and provide investment advice in our clients’ best interest. We also are required to provide full and fair disclosure of material facts associated with our services and investment advice. We must act to avoid conflicts of interest or disclose these conflicts to our clients. This brochure is designed to explain our services and how we provide investment advice and to disclose conflicts of interest associated with our services and advice. We provide investment advice through investment adviser representatives registered with our firm. We refer to these financial advisors as “Advisors” in this brochure. Our primary methods of providing investment advisory services are: 1) Advisor managed accounts; 2) third-party recommendations; 3) financial planning; 4) wrap-fee programs; 5) individual retirement planning services; and 6) qualified and non-qualified retirement plan services. We describe these services in more detail below. If you are a retirement plan client, please refer to our Retirement Plan Brochure. Generally, prior to opening an advisory account with us, your Advisor will meet with you to understand your investment experience, investment objectives, risk tolerance and current financial circumstances in order to create an investment profile for you. This investment profile helps your Advisor determine appropriate investment products and services for you. Should you engage our firm, you will enter into an agreement with us setting forth terms and conditions of the advisory services relationship, including fees to be charged and authorization for the Advisor to purchase and sell securities on your behalf consistent with your defined investment objectives. Generally, your Advisor will recommend, purchase, or sell mutual funds, variable insurance products and investments in their sub-accounts, exchange-traded funds, equities (stocks) and fixed income securities (bonds). Your Advisor may also recommend various alternative investments, typically designed to diversify your portfolio, and a portion of your account may also remain in cash, a cash product, or a money market fund. Our firm supports independent Advisors, and while we oversee their advice and asset management, subject to our fiduciary duty and rules of suitability, we do not dictate the products, platforms, or services your Advisor recommends to you within the scope of available options we make available to your Advisor. We offer a variety of investment advisory platforms, custodians, and brokers, including our own affiliated broker-dealer. Most of our Advisors are also registered representatives of our affiliated broker-dealer, Kestra Investment Services, LLC (Kestra IS). Please refer to the Brokerage Practices section for additional information regarding our broker-dealer affiliate. In addition, many of our Advisors also act as insurance agents independent from our firm. To the extent your Advisor provides fixed insurance products or services to you (other than fixed indexed annuities), he or she does so outside of our firm and supervision. Some of our Advisors are also involved in other business activities, such as accounting, legal, tax, and other non-investment services for which we are not responsible. Unless otherwise provided by applicable law and the particular circumstances, services provided by our Advisors outside of our company will not be subject to a fiduciary standard. Our firm does not provide legal or tax advice and you should consult your own attorney or tax advisor for guidance relative to your specific circumstances. ADVISOR MANAGED ACCOUNTS With an Advisor Managed Account, your Advisor will be responsible for managing your account consistent with your defined objectives and risk tolerance and may assist you to develop a personalized asset allocation program and custom-tailored portfolio. The recommended portfolio will typically include investments such as mutual funds, exchange-traded funds, variable annuities, stocks, bonds, direct participation programs or a combination of these products. A portion of your account may also remain in cash or a money market fund. In an Advisor Managed Account, your Advisor typically will diversify your holdings across various asset classes unless your objective is to invest in specific assets. The percentage weightings within the asset classes will be based on your risk profile, investment objectives, individual preferences and availability. You will have the opportunity to meet with your Advisor to periodically review the assets in your Advisor Managed Account. We recommend you and your Advisor meet on a regular basis to review your financial situation, investment objectives and current holdings, and you should let your Advisor know about any changes to your circumstances in the meantime. You will maintain full and complete ownership of all assets held in your Advisor Managed Account. This means you retain the right to add or withdraw securities or cash, pledge securities, and vote securities. We will not pool your Advisor Managed Account assets with assets in other accounts. You will receive periodic statements from the account custodian. We offer both discretionary and non-discretionary portfolio management services. If you want your Advisor to have discretion over the timing and amount of securities purchased or sold in your account, you will be asked to sign an addendum authorizing your Advisor to place orders for your account without contacting you in advance. We place most transactions in Advisor Managed Accounts through our affiliated broker-dealer, Kestra IS, and its unaffiliated clearing broker-dealer and custodian, National Financial Services, LLC (NFS), but also use other broker-dealers and custodians. Please refer to the Brokerage Practices section for additional information. ADVISORY PLATFORMS Through our relationships with NFS and other custodial and clearing firms, we make available platforms (Advisory Platforms) to assist our Advisors to provide you an Advisor Managed Account. Examples of our Advisory Platforms include the AdvisorEnterpriseSM Platform, Horizon, and AdvisorChoice Platforms described in more detail below. Through these Advisory Platforms, our Advisors provide investment advice to you combined with portfolio administration and reporting services, advisory fee processing, and account reconciliation. AdvisorEnterprise Platform Our relationship with Envestnet Asset Management, Inc. (Envestnet), an unaffiliated company, allows our Advisors to provide you with an Advisor as Portfolio Manager (APM) Account using tools, resources, and technology provided by Envestnet as part of the AdvisorEnterprise Platform. This includes the ability to produce an investment proposal, model building, trading and rebalancing, research tools, and performance reporting. Through an AdvisorEnterprise APM account, your Advisor generally invests your assets in individual equity or fixed income securities, as well as pooled investment vehicles such as mutual funds and/or ETFs available through the AdvisorEnterprise Platform. You will pay more for this platform than you will for our other advisory platforms, which do not offer our Advisors the same resources and technology as the AdvisorEnterprise Platform. We earn more on assets managed on the AdvisorEnterprise Platform than through other available platforms which serves as an incentive to place your assets on this platform and is therefore a conflict of interest. On the AdvisorEnterprise Platform, we offer two APM programs; APM-Tickets and APM-Wrap. They differ based on whether transaction charges are assessed separately (APM-Tickets) or are included in the total client fee (APM-Wrap). We assess a Program Fee for accounts on the AdvisorEnterprise Platform. The Program Fee includes fees for Kestra AS and its affiliates’ maintenance of the advisory platform. The cost Kestra and its affiliates pay Envestnet is based on the number of accounts and the amount of client assets we have on the AdvisorEnterprise Platform. Our costs will decrease as our advisors put more client assets on the AdvisorEnterprise Platform. When our costs decrease, the savings are not shared with you or our Advisors. As a result, we have an incentive to recommend the AdvisorEnterprise Platform, creating a conflict of interest. Horizon and AdvisorChoice Platforms Both the Horizon and AdvisorChoice Platforms offer Advisor as Portfolio Manager (APM) programs. The Horizon Platform is provided through NFS. The AdvisorChoice Platform is provided through NFS and other custodians such as Charles Schwab & Co. (Schwab) and Fidelity IWS. Through these platforms, our Advisors recommend and invest in individual equity or fixed income securities as well as pooled investment vehicles such as mutual funds and ETFs. The minimum account size for Horizon is $5000 and the minimum account size for AdvisorChoice is $10,000. We may waive the account minimum at our discretion. The trading charges and administrative costs as well as the tools, technology, and services available to you and your Advisor will vary by custodian and platform, which means that your costs will vary for similar services. THIRD PARTY PROVIDER ADVISORY PLATFORMS Our Advisors can delegate investment advisory responsibilities or discretionary authority to a third-party investment adviser through external advisory platforms that are offered at Kestra. Typically, you will enter into an agreement directly with that third party, which will outline, among other things, the fees and trading of your account by that investment adviser. Depending on the Advisory Program, you either pay us directly or pay one fee to the third-party investment adviser, who will then remit a portion of the fee to us. You will receive a copy of both the third- party investment adviser’s brochure as well as this document if we and the third party are acting as co-investment advisers. If investment advisory services are delegated to a third-party investment adviser, your Advisor will monitor your assets and will provide services such as, but not limited to, helping you choose the third-party investment adviser, reviewing your accounts, and assisting you with administrative functions related to your portfolio. Our Advisor will conduct periodic reviews of your account(s) in the Advisory Program, monitor performance of the account, and be available to meet with you upon reasonable request. You and your Advisor should meet on a regular basis to review your financial situation, investment objectives and current holdings, and you should let your Advisor know about any changes to your financial goals or circumstances. We make available certain Advisory Platforms offered through third-party advisors to assist our Advisors in providing you additional options for a Managed Account. Examples of Advisory Platforms offered at Kestra AS include, but are not limited to, the following: Buckingham Strategic Partners, Symmetry Partners, SEI and AssetMark. SEI and AssetMark are described below. SEI We have entered into a co-advisory relationship with SEI Investments Management Corporation (SEI). In conjunction with SEI, we provide portfolio management services, selection of other investment advisers, mutual fund wrap services, access to separate account managers and alternative investments. SEI is both an investment adviser and broker-dealer. From the services and products SEI provides, our Advisor can customize the asset allocation and level of diversification, and determine the preferred investment vehicle or structure to create your account portfolio. There generally is no minimum investment for an account in the SEI Program. Prior to opening an account with SEI, your Advisor will gather information through the use of SEI-developed questionnaires, software and other materials or through a personal interview. Your Advisor will also assist you in completing all necessary paperwork, including an agreement between you and SEI that grants SEI discretionary trading authority in your account. SEI has created asset allocation programs using mutual funds invested in stocks, bonds and cash to meet varying client objectives and needs for growth, income and capital preservation. Our Advisors will rely on the model investment portfolio designations and allocation recommendations provided by SEI. You may impose conditions in your investment guidelines or in written instructions to us that limit the discretionary authority implemented through the rebalancing program. In a select few instances, certain Advisors qualify for SEI’s Enhanced Advisory Services. In these instances, your account will be managed as generally described under the Advisor Managed Account section above. SEI Private Trust Company, an affiliate of SEI, acts as a custodian of all assets in the SEI Program and you will enter into a separate custodial agreement with the SEI Private Trust Company. SEI will execute transactions for your account pursuant to your agreement with them. Your Advisor will conduct periodic reviews of your account in the SEI Program and monitor the performance of the account. AssetMark We have entered into a co-advisory relationship with AssetMark, Inc. (AssetMark). AssetMark is a registered investment adviser

with the Securities and Exchange Commission (SEC), and provides consulting services and AssetMark Platform access to your Advisor. AssetMark makes a number of different Solution Types available to clients through the Platform. Account minimums range from $10,000 to $1,000,000. We or AssetMark may waive the account minimum at our discretion. The Solution Types consist of: 1. Guided Portfolios 2. Single Strategy Portfolios 3. Separately Managed Accounts 4. Unified Managed Accounts 5. Multiple Strategy Accounts Your investments made through the Platform are held in your name by a custodian you select, pursuant to a custody agreement directly between you and the custodian. Your account will be held in custody at one of the following firms: Schwab Institutional, Pershing Advisor Solutions, TD Ameritrade, AssetMark Trust or Fidelity Brokerage Services. AssetMark makes available periodic reports to your Advisor for use should your Advisor opt to do so. Your Advisor will conduct periodic reviews of your accounts on the AssetMark Program and monitor performance of those accounts. We also have the ability to act in a referral capacity and refer clients to AssetMark. Please see the THIRD-PARTY REFERRALS section below for more details regarding the services we provide and how we are compensated in such an arrangement. LEGACY OFFERINGS We may enter, or previously have entered, into advisory relationships, programs and platforms offered through third-party investment advisers either as legacy offerings for our firm or as an accommodation to an Advisor who joins our company. These relationships are usually limited to certain Advisors and their existing clients. Details and descriptions of these programs have been or will be given to you by us, your Advisor and/or the Advisor’s prior firm. THIRD-PARTY REFERRALS We have entered into agreements with various third-party investment advisers that participate in, manage, or sponsor different types of money management services and investment advisory programs. Depending on our relationship with the third party, our Advisors may refer clients to such third parties, in which case we will not provide investment advice or have discretionary authority over your assets. These referral arrangements are structured in accordance with the marketing rule 206(4)-1 under the Advisers Act which requires, among other things, that we disclose to you the compensation we will receive for referring you to a third-party adviser. Where we act solely as a referrer, you will not enter into an agreement directly with us and we are not responsible for the services provided by the third-party investment adviser. In such an arrangement, you establish a direct relationship with the third-party investment adviser, and we will receive a referral fee from the adviser based on a percentage of the advisory fee they charge you. The amount of the fee varies by the referral arrangement with a maximum fee of 2.5%. The referral disclosure you receive when you establish an account with the third-party adviser will specify the total fee you will be charged, and what portion of that fee is payable to Kestra AS. You should read the third-party adviser’s brochure and any compensation disclosure statements provided in connection with these referral arrangements for information regarding the services of the third-party adviser and applicable fees and charges. Private Fund Advisers Our affiliated broker-dealer, Kestra IS, has entered into agreements with various private funds (“Private Funds”) and acts as placement agent in connection with the offering and sale of securities of such funds to current and prospective clients. While we and Kestra IS are not current clients and are not investors of the Private Funds, it is possible that we or one or more of our affiliates or our or their employees or agents may be, or may subsequently become, a client of or investors in the Private Funds. Kestra IS and our Advisors receive cash compensation from the sponsors of the Private Funds for activities as placement agent. We and our affiliates may have additional relationships with the Private Fund sponsor or other investment vehicles managed by the Private Fund sponsor. The payment of cash compensation to our affiliate and Advisor, and any additional relationships that the placement agent or its affiliates may have with the Private Fund or its sponsor or other investment vehicles managed by the fund’s sponsor creates a conflict of interest for Kestra AS and its Advisor since we may receive compensation in addition to advisory fees in connection with the recommendation of a Private Fund. Affiliated funds of Warburg Pincus, LLC (“Warburg Pincus”) own a majority interest of the ultimate parent company of Kestra Advisory Services, LLC (“KAS”), Kestra Private Wealth Services, LLC (“KPWS”) and Kestra Investment Services, LLC (together with KAS and KPWS, “Kestra”). Kestra makes available investment funds affiliated with Warburg Pincus. The recommendation of such a fund creates a conflict of interest since the holder of a majority interest in Kestra’s ultimate parent company would directly or indirectly benefit from an investment in the fund. In addition, an affiliate of Warburg Pincus owns a financial interest in the investment adviser to certain funds available through the alternative investment platform, iCapital, that Kestra uses to make such investments available. The recommendation of such a fund creates a conflict of interest since the holder of a majority interest in Kestra’s ultimate parent company, Warburg Pincus, would directly or indirectly benefit from an investment in the fund. FINANCIAL PLANNING & FINANCIAL CONSULTING Many of our Advisors perform financial planning, business consulting, estate planning, and similar securities investment consulting services for you. In performing financial planning or consulting services, the Advisor typically reviews your overall financial circumstances, such as your tax status, insurance needs, overall debt, business ventures, retirement savings and current investments. An Advisor’s services may also focus on only one or several of these areas, depending on your specific engagement. You will enter into an agreement with us setting forth the services our Advisor will provide and other terms and conditions of the relationship, such as fees for our services. You are under no obligation to accept any of the recommendations from an Advisor pursuant to a financial planning or consulting engagement, and you retain discretion and responsibility for implementing the recommendations in the absence of a contract for such additional services. WRAP FEE PROGRAMS Through our relationship with Envestnet, we sponsor a privately labeled wrap fee program on the AdvisorEnterprise Platform. Our Advisors have access to an Advisor as Portfolio Manager Wrap (APM-Wrap) program and third party managed wrap programs. We assess a Program Fee for accounts participating in the wrap program. Except where otherwise indicated, the Program Fee includes fees for Kestra AS and its affiliates’ maintenance of the advisory platform, custody and trading services. Depending on the Advisor Fee determined by your Advisor, the size of the account, the number of trades placed in your account and the transaction costs associated with those trades, the APM-Tickets program may cost more or less than the APM-Wrap program. When your Advisor chooses to pay your transaction charges or where the trades have no associated transaction charges, the APM-Tickets program is the lowest cost, providing your Advisor does not adjust their advisory fee to account for their additional expense. While there is no cap on the number of trades in your account, the APM-Wrap program is priced to accommodate approximately 60 trades per account annually. We reserve the right to assess your Advisor the cost of trades that exceed this amount which creates an incentive for the Advisor to limit trading in your account to avoid this cost. In wrap program accounts, you will not be responsible for paying transaction charges to our affiliated broker-dealer but will be responsible for paying any account maintenance charges as detailed in the fee schedule of our affiliated broker-dealer. You are also responsible for paying any charges imposed by the issuers of investments in your account or their affiliates. Please see our Wrap Fee Program Brochure for details and corresponding fee schedules regarding this wrap-fee program. INDIVIDUAL RETIREMENT PLANNING SERVICES Our Advisors also provide services in connection with clients’ retirement accounts, such as individual retirement accounts (IRAs). Our services to IRA clients include those described above. If you are participating in an employer sponsored retirement plan (such as 401(k) plan) and are no longer with that employer, you typically have four options (and may engage in a combination of these options): i) leave the money in the former employer’s plan, if permitted, ii) roll over the assets to a new employer’s plan, if one is available and rollovers are permitted, iii) rollover to an IRA, or iv) cash out the account value (which could, depending on your age, result in adverse tax consequences). To the extent you are a retirement plan client, please refer to our Retirement Plan Brochure. Our Advisors may recommend that you roll over plan assets to an IRA under our management. As a result, we generally earn an asset-based fee. NFS assesses IRA accounts an annual charge of $35, which is shared with Kestra IS in an increasing proportion as the number of total accounts custodied at NFS increases. This payment arrangement NFS has with Kestra IS serves as an incentive to open IRA accounts with NFS. However, no portion of this fee is shared with our Advisors. If you leave plan assets with your old employer’s plan, or roll the assets to a plan sponsored by a new employer, we cannot manage the assets and will earn no compensation unless we are engaged to monitor or consult on your assets in the retirement plan. We have a financial incentive to encourage you to roll plan assets into an IRA that we will manage. There are various factors you should consider before rolling over assets from a retirement plan to an IRA. These factors include: 1) the investment options available in the plan versus the investment options available in an IRA; 2) fees and expenses in the plan versus the fees and expenses in an IRA; 3) the services and responsiveness of the plan’s investment professionals versus ours; 4) strategies for the protection of assets from creditors and legal judgments; 5) required minimum distributions and age considerations; and 6) employer stock tax consequences, if any. No client is under any obligation to roll over plan assets to an IRA managed by us or to engage our Advisors to monitor and/or consult on an account maintained in an existing retirement plan. A recommendation to roll assets out of an employer-sponsored plan into an IRA will most likely result in more expenses and charges than if the assets were to remain in the plan. QUALIFIED AND NON-QUALIFED RETIREMENT PLAN SERVICES Please see our Retirement Plan Brochure for more information on retirement plan services. OTHER INFORMATION ABOUT OUR ADVISORY SERVICES In some instances, we and our Advisors may independently consider a security a client is trying to sell appropriate for another one of our clients. We and our Advisors advise numerous clients with similar or identical investment objectives or advise clients with different objectives that may trade in the same securities. Despite such similarities, portfolio recommendations relating to your investments and the performance resulting from such recommendations will differ from client to client. We will not necessarily recommend, purchase, or sell the same securities at the same time or in the same amounts for all eligible clients. In some cases, such as the recommendations of private placements or oversubscribed public offerings, due to the availability of, or qualifications necessary to buy the investment, it may not be possible or feasible for you to buy a certain security. Therefore, you will not necessarily be able to participate in the same investment opportunities or participate on the same basis with our other clients. To the extent our Advisors have investment discretion over your account, it is our policy that the Advisor allocate, to the extent practicable, investment opportunities on a basis that the Advisor in good faith believes is fair and equitable to each client over time. We utilize BTS, an unaffiliated third party strategist, to provide investment subadvisory services as a model signal provider to a limited number of Advisors who utilize that data to inform their own asset allocation models. You should promptly notify us if there is a change in your financial circumstances or investment objectives so we may confirm any prior recommendations remain appropriate going forward, or advise you as to any proposed changes. As of December 31, 2023, we managed approximately $48,324,319,629 in assets for approximately 140,425 clients. Approximately $35,495,163,831 is managed on a discretionary basis, and approximately $12,829,155,798 is managed on a non-discretionary basis.