Company Overview AthenaInvest Advisors LLC (“AthenaInvest”) is an industry leader in Behavioral Portfolio Management with a patented research process built on a deep academic foundation. Led by C. Thomas Howard, PhD, CEO and Chief Investment Officer, the Firm’s unique investment approach is based on proprietary research developed over 40 years of interaction with leading academics and institutional managers. AthenaInvest pioneered a formalized framework to apply behavioral finance principles, known as Behavioral Portfolio Management (“BPM”) to create what we believe is a unique and systematic way to view asset allocation, investment selection, and tactical management. AthenaInvest has been registered as an investment adviser with the Securities and Exchange Commission (“SEC”) since June 16, 2008. Company Ownership Structure AthenaInvest is wholly owned by AthenaInvest Inc. (“Athena Parent Company”), which is, in turn, largely owned by members of the AthenaInvest Inc. team. C. Thomas Howard is the only shareholder in excess of 25% and acts as our Chief Executive Officer. Services We Offer AthenaInvest offers a range of services including:
• Investment management services for investment advisers and broker dealers, including the management of separate accounts (“Separate Account Management”) and the creation of model or target portfolios.
• Advisory and sub-advisory services for registered investment companies and institutions.
• To a limited degree, Separate Account Management for individual investors. The following paragraphs describe our services. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your needs. Investment Management Services AthenaInvest offers investment management services to: (1) financial professionals to use with their clients, both directly and via model provider platforms, (2) investment companies and institutions and (3) individual investors. In connection with our services to financial professionals, the client and client’s advisor may grant AthenaInvest trading discretion for the client’s account. In this arrangement, AthenaInvest is only responsible for ongoing investment management of the client’s account by placing trades subject to the investment model election and restrictions the client and/or client’s advisor have provided to AthenaInvest. Financial professionals may also access AthenaInvest’s investment management services through model provider platforms. In this arrangement, AthenaInvest is responsible for maintaining its investment model on the model provider’s platform. The model provider remains responsible for trading according to the provided model and servicing the client accounts. AthenaInvest does not have trading discretion in such cases. In connection with its advisory services to clients in general, AthenaInvest builds investment portfolios for its various AthenaInvest Advisors LLC | ADV Brochure | 20240331 Page 5 of 19 clients using a variety of financial instruments, including, but not limited to, mutual funds, stocks, exchange traded products (“ETPs”), such as exchange traded funds (“ETFs”) and exchange traded notes (“ETNs”) (collectively

referred to herein as ETPs, unless otherwise indicated), as well as combinations of U.S. equity, international equity, U.S. fixed income, cash and cash equivalents, and other asset classes. The number of funds, specific funds, specific securities and allocations to these asset classes will vary depending on the client and strategy implemented. Clients and/or client advisors may impose restrictions on trading in specific securities or types of securities. Currently Offered Investment Strategies Athena Global Tactical The portfolio utilizes patented behavioral market indicators to gauge and select broad market-exposure ETFs among various equity markets, market capitalization or cash each month. The portfolio invests in long or leveraged positions within U.S. small, U.S. large or international equities when market indicators are strong. In certain circumstances, the position may be leveraged up to twice the market to enhance returns. During weak conditions, a portfolio can hold up to 100% in cash or cash equivalents. The portfolio normally holds a concentrated position of one broad equity market ETF or 200% leveraged broad market ETF when Athena’s market indicators are strong. Athena Market Rotation The portfolio utilizes patented behavioral market indicators to gauge and select broad market-exposure ETFs among various equity markets, market capitalization or cash each month. The portfolio invests in long positions within US small, US large or international equities when market indicators are strong. During weak conditions, the portfolio can hold up to 100% in cash. The portfolio normally holds a concentrated position of one broad equity market ETF. Athena Pure Valuation The portfolio manager invests in stocks that pay dividends and have attractive valuation ratios along with leveraged balance sheets. Such stocks tend to be overlooked by investors and often can be purchased at attractive valuations. Each month, stocks are screened based on balance sheet, projected earnings, revenues, dividends, price ratios, and trading volume. The portfolio prefers stocks which are strategy categorized as either valuation or profitability and sector diversification is used to decrease industry concentration risk. Advisory and Sub-Advisory Services for Registered Investment Companies AthenaInvest provides investment management services in an advisory and sub-advisory role for registered investment companies such as mutual funds and ETFs. Separate Account Management for Individual Investors In limited circumstances, AthenaInvest will directly manage a client’s account as the client’s advisor through an investment management agreement with the client. Client Assets As of December 31, 2023, Athena managed $375 million in client assets, of which $84 million was managed on a discretionary basis and $291 million was managed on a non-discretionary basis. Non-discretionary assets include AthenaInvest Advisors LLC | ADV Brochure | 20240331 Page 6 of 19 client assets which AthenaInvest does not have direct trading discretion, but are traded according to AthenaInvest’s investment strategies, such as for its model portfolio platform business and/or target portfolio service.