Values First Advisors, Inc. (herein “Values First,” “VFA,” the “firm” “we” “us” or “our”) is an independent SEC registered investment adviser founded in July 2009. The firm’s principal owners are L. Alex Ellis and Benjamin P. Nunn. VFA provides portfolio management and financial planning services to individuals, trusts, estates, retirement plans, and charitable organizations. We have no affiliated companies, nor do we participate in any joint ventures. Our home office is located in Gray, Tennessee. VFA strives to implement a Biblically Responsible Investing (“BRI”) overlay into investment strategies whenever feasible. Biblically Responsible Investing (also often referred to as faith-based or values-based investing) works to integrate Scriptural guidelines with an investment portfolio. This method looks for companies to invest in that are making a positive impact on our society, as well as applying screening processes to avoid those that do not. Please see Item 8 for more information about how we choose investments. Portfolios consist primarily of individual stocks, bonds, bond funds, mutual funds, exchange traded funds (“ETFs”) and money market investments. Customarily, we provide investment management services on a discretionary basis, in which case we have the authority to decide which securities to purchase and sell in the client’s account without obtaining the client’s prior approval on a trade-by-trade basis. In certain other arrangements, we manage accounts on a non-discretionary basis, in which case the client retains the responsibility for the final decision on all actions taken with respect to the account. This can result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. Each client is different. We understand that your investment objectives, risk tolerance and certain constraints are unique, and we address them accordingly. Our recommendations or decisions with respect to the allocation and management of your portfolio will be based on information provided to us by you about your investment objectives, risk tolerance, financial circumstances, and if applicable, the strategy you select when executing our investment advisory agreement with you. We collaborate with you, and your other professional advisors when requested to do so, to formulate a personalized investment plan within the context of your long- and short-term investment goals. It remains your responsibility to promptly notify us of any changes in your investment objectives or financial situation for the purpose of re-evaluating your investment plan. While we do not prohibit you from placing reasonable restrictions on a particular security or types of securities held in your account, we discourage this practice. Such restrictions will affect the overall composition and performance of your portfolio. Retirement Plan Rollovers We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. If we recommend that you transfer or roll over your retirement assets into an account to be managed by us, such a recommendation creates a conflict of interest if we will earn a new (or increase our current) advisory fee because of the transfer/rollover. Investing in an IRA with us may be more expensive than an employer-sponsored retirement plan. You are under no obligation to roll over retirement assets to an IRA managed by us or to engage us to monitor and/or manage the account while maintained at your employer. Financial Planning You may elect to retain VFA to prepare a financial plan as a stand-alone service or in conjunction with ongoing portfolio management. Financial planning is the analysis of your current and future financial situation using current assumptions to predict future results in cash flow, retirement options, asset value and distribution planning. Depending on the level of planning desired, VFA’s financial analysis may include, but is not limited to, some of the following areas of service, as applicable:
• Personal / General Information: In creating any sort of financial plan, it is critical to have as much applicable data as possible about you. We gather personal information such as birthdates, social security numbers, contact information for clients, parents, heirs; current contact information for other advisors, such as accountant, attorney, insurance agent; short-term and long-term financial planning goals. Periodically, this area includes cash flow management and budget planning.
• Net-Worth Projection: We believe that monitoring net worth is critical to financial planning, whether it is increasing, decreasing or we are merely monitoring all the assets and liabilities. An unaudited statement of net worth may be prepared annually if requested.
• Retirement Planning: It is our belief that you should have some sense of your retirement roadmap. We endeavor to project expenses including income taxes, capital gains taxes, social security benefits, mortgages, other types of loans, savings and general household maintenance expenses. We project income by including salary, social security, pensions, distributions from trusts, required minimum distributions from qualified plans and any other sources that you may have. Certain assumptions are utilized to project account growth. From this projection, you are able to see year- by-year how your income compares to your expenses.
• Insurance Analysis: Insurance protects what you value. We will help you evaluate your risks and recommend appropriate types and amounts of coverage you need in various areas, including, but not limited to, life, health, property and casualty, disability, long-term care, umbrella, business and identity theft.
• Investment Planning: We believe that thorough investment analysis is most valuable when coupled with financial planning. It is at this point in the financial planning process that we work through your investment analysis.
• Tax Planning: We do

not prepare tax returns or offer tax advice. However, we believe that tax planning is critical to investment success. We work with you and your tax advisor(s) to understand your tax situation and assist you to use tools available to help minimize your current and future taxation.
• Estate Planning : We will educate you about the various tools and techniques available to help you formulate a successful estate plan. We also prepare a summary of beneficiaries, trusts and other estate details based upon what you share with us. We will also work with you to complete the information required in RightCapital, an online financial planning tool we make available to certain clients. We will not be responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the RightCapital platform (or other financial planning platform engaged by VFA) without our oversight. Clients are solely responsible for determining whether to follow any advice or recommendation given by VFA in the financial plan. Clients are also solely responsible for implementing any action upon such advice and for the selection of any service providers. Core Asset Allocation Services The first step in effectively managing the wealth you have worked so hard to accumulate is to determine what types of investments are appropriate for you. In this area, we address fundamental questions like: How much should you keep in cash? When will you need access to this money to help provide for your living expenses? Which asset classes and sectors of the market are appropriate to help you meet your goals? Allocating your investable assets among appropriate asset classes and sectors of the market, including a suitable level of diversification, is a crucial component of your overall financial plan. Direct Portfolio Management and Sub-Advisers Once the asset allocation plan has been determined, it needs to be effectively implemented. This means selecting the specific securities in which to invest your money. At VFA we can manage your entire account directly, creating a unique investment portfolio for you, or we may decide together to manage your accounts utilizing the investment and operational program offered by Folio Investments, Inc. dba Goldman Sachs Custody Solutions, and its successors and/or assigns (“GSCS”). If you choose the GSCS program, VFA has discretion to select from among a variety of sub-advisers to provide one or more model portfolios to manage portions of your account. Each model portfolio is designed to meet a particular investment goal. VFA can also serve as one of the sub-advisers and thus become a component of a stable of sub-advisers that work on your behalf. Once the investments and/or sub-advisers are selected, we strategically rebalance your portfolio as conditions warrant. Non-discretionary, Non-supervisory Advice and Consultations VFA also offers the option of meeting with clients intermittently, whenever the client has a question or would like for us to review the investment portfolio. This allows you to determine just how much involvement you want VFA to have with each financial decision you make. You can consult with us as frequently, or as infrequently, as you like. These services are offered on a non-discretionary and non- supervisory basis. So, while we can place trades in your accounts for you, we do not execute any trades or initiate any activity without your specific direction. Retirement Plan Advisory Services We provide Retirement Plan advisory services to Retirement Plans (“Plans”) and Plan Fiduciaries as described below. Before engaging us to provide services, clients are required to enter into an agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fees that will be incurred (see Item 5 below). Fiduciary Services Discretionary Investment Advisory Services VFA will provide discretionary investment advisory services consistent with the objectives, written guidelines and/or investment objectives set forth in the written investment policy statement (“IPS”) accepted and adopted by the client. VFA will select a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder, if the Plan is a participant-directed defined contribution plan. We are not responsible for placing trades or entering orders for securities transactions with respect to Plan assets or for the execution of any such orders. The placing and execution of trades in Plan assets will be the responsibility of the Recordkeeper or Custodian. VFA is authorized to direct the Custodian or Recordkeeper, as the case may be, to (i) add, replace, or remove an investment option offered under the Plan, (ii) change the target weightings of a strategy offered under the Plan, and (iii) reallocate holdings periodically to align with the target weightings of a strategy. Investment Policy Statement (“IPS”) Services We will gather information regarding the Plan’s investment policies and objectives and provide you with information to be used in developing a written IPS. Alternatively, if the Plan has an existing IPS, we will review the existing IPS and assist you in determining whether the Plan is performing consistent with the IPS and/or whether the IPS needs to be revised, based on an analysis of the Plan's asset class and risk tolerance guidelines, liquidity requirements, and performance goals. The IPS may take into account environmental, social or governance factors (e.g., Values Based Investing) for investment options to the extent consistent with the fiduciary standards of ERISA. You retain sole discretion whether to accept and adopt the IPS. Non-Fiduciary Services Participant Education and Communication For Plans for whom we have been engaged for the discretionary management services described above, we may provide periodic educational support designed for the Plan Participants, if provided for in our agreement with the client. Plan participants may be provided information about the Plan, general financial and investment information and information and materials relating to the Plan’s investment options. The educational support will not provide Plan Participants with individualized, tailored investment advice. Assets Under Management As of December 31, 2023, VFA managed client assets valued at approximately $186,509,341 on a discretionary basis and approximately $3,566,399 on a non-discretionary basis.