Description of our Firm. Our firm is a limited liability company organized and operated in New York state. We commenced operations as an SEC registered investment adviser in 2009 pursuant to the Investment Advisers Act of 1940 (the “Act”) and offer fee- based investment advisory services (hereafter “Service”). The Firm is wholly owned by Quaestus Holdings, LLC and is operated by Joseph Arena, Chief Investment Officer, and Kyle Webber, Chief Operating Officer and Portfolio Manager, and Joseph Leo, Chief Executive Officer. Quaestus Holdings, LLC is owned by Mr. Arena, Mr. Webber, Mr. Leo, and Scott Weisman, Chairman through Pterodactyl Holdings, LLC. Advisory Services Offered. The following are descriptions of the discretionary and non-discretionary advisory services we offer and made available primarily through financial professionals affiliated with our firm as an investment advisor representatives (hereafter “Financial Professional”). “ Non- discretionary” services require clients to initiate or pre-approve investment transactions in their accounts before they can occur, whereas ” discretionary” services authorize the Financial Professional or other designated third party investment advisor to buy, sell or hold investment positions without obtaining pre-approval from clients for each transaction. Financial Professionals are required by applicable rules and policies to obtain licenses and complete certain training in order to recommend certain investment products and services. You should be aware that your Financial Professional, depending on the licenses and training obtain, may or may not be able to recommend certain investments, models, programs, or services. Please ask your Financial Professional whether any limitations apply. Please understand that a written agreement, which details the exact terms of the Service and advisory fee schedule, must be signed by the client and, in most cases, accepted by our firm before we can provide the client with the Services described below. Our Financial Professional’s provide investment management and account monitoring on an ongoing and continuous basis. In addition to the programs described in this Brochure, clients may receive a separate Brochure from a third-party manager or sub-advisor if they are selected by you or your Financial Professional to aid in the investment management of your account. If your account is invested in mutual funds and exchange traded funds, the fund company provides important disclosures in the fund's prospectus. If you would like more information on such services please contact the firm, your Financial Professional, or you can go to https://adviserinfo.sec.gov. In addition to accounts held at traditional brokerages, we also provide discretionary investment management to clients who have a variable annuity or held-away Account, like an individual 401(k) account. Due to the often-limited investment options, investment performance may differ significantly from a traditional brokerage Account. Clients are allowed to impose reasonable restrictions in accordance with their values, beliefs, or unique situation on the Services we provide and the investment management of their Account. If a proposed restriction is determined to be unreasonable, or we believe is not in the client’s best interest, we will request the client to modify or withdraw the restriction. At our sole discretion, we reserve the right to end an advisory relationship if we believe a client’s-imposed restriction is detrimental. We are not obligated to buy, sell, or recommend to our clients any security or other investment that we may buy, sell, or recommend for any other clients or for our own accounts. If we obtain material, non-public information about a Security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client and will not use it for our or any client’s benefit. The simultaneous management of the different investment advisory services offered below creates certain conflicts of interest, as the fees for the management of certain types of Services are higher than others. Nevertheless, we seek to treat all such Accounts fairly and equitably over time, model-based Strategies aid in mitigating this conflict of interest. Description of Private client Services. We offer the following investment advisory services through our Financial Professionals directly to individuals, which we refer to as Private clients: A. Rep as Portfolio Manager Program: This an open architecture Program your Financial Professional has discretion to build custom portfolios for you. Your Financial Professional will provide discretionary Services based on personal discussions, guided questionnaire, and your collective collaboration. At the direction of your Financial Professional and congruent with your goals, time horizon and risk tolerance, your Account will be invested into a portfolio of Securities that your Financial Professional has vetted and selected. Unless otherwise stated, this Program requires that clients grant our firm and the Financial Professional full investment discretion. Under this Program, client Accounts will be held at a qualified custodian that we have or will establish a relationship with. When the investment adviser representative selects individual Securities, they have an ongoing responsibility for investment decisions, security selection, day-to-day portfolio management of the assets, and/or the specific timing in which to effectuate securities transactions, along with helping to continuously monitor and manage the client Account congruent with their objectives and suitability. Etico Wealth Management | Form ADV Part 2A: Firm Brochure 3 B. Third-Party Asset Management (TAMP) Program: Under this program, through our Financial Professionals, we provide access to asset management programs offered by institutional third-party investment advisors (referred to as “ Platform Sponsors” ) with which our firm has entered an agreement to make their services available as a co-investment adviser or sub-advisor. These Platform sponsors are subject to review by our firm’s Investment Committee for inclusion as a TAMP and are subject to future change from time to time. As of the date of this Brochure, these firms include Morningstar Investment Services, Orion Portfolio Solutions, our affiliate Quartz Partners Investment Management (“Quartz”) TAMP Services, and in limited cases, other Platform sponsors accommodated through our firm. Quartz is affiliated with Etico WM through common ownership and control. Please understand this is a conflict of interest. Our recommendation to use Quartz investment management Services is based, almost entirely, on the fact that Quartz and Etico WM are affiliated and Etico WM has a financial and economic interest to recommend Quartz over other TAMP Sponsors that provide similar services because Etico WM will receive compensation that would otherwise be paid to another TAMP Sponsor. You are not mandated to utilize the Quartz TAMP Services and our firm will always act in your best interest. Please consult your Financial Professional for information regarding available advisory model Platform Sponsors. TAMP services begin with the Financial Professional obtaining the necessary financial data from the client to assist with setting an appropriate investment objective based on their unique circumstances and needs, determining the suitability of the program and aiding the client in completing the necessary paperwork to open an account with the Platform Sponsor. Depending on the particular program, the Financial Professional may also assist the client with selecting a model portfolio of securities designed and managed by either the Platform Sponsor or a selected portfolio management firm available through the Platform Sponsor responsible for providing discretionary asset management services. The Platform Sponsor or other third party investment advisor is typically granted discretionary authority in its client agreement to purchase and sell securities on a basis pursuant to investment objective chosen by the client. In doing so, the Platform Sponsor or other third party investment advisors typically construct various model investment portfolios that are managed according to specific investment strategies associated with the respective models, and that are not generally customized for individual clients (subject to the client’s ability to request reasonable investment restrictions on investing in Securities or other special accommodations that may be made). In addition to portfolio management services, the Platform sponsor will also generally arrange for custody of client assets, performance reporting, advisory fee calculation, trade execution, cashiering services, and such other services as outlined in their separate client agreement and disclosure brochure. The Platform sponsor may also offer the Financial Professional a greater degree of influence and/or discretion in connection with portfolio selection and composition, as may be applicable pursuant to the terms of the TAMP’s program agreement with clients. Since the TAMP services provided by each Platform Sponsor or other third party investment advisor in the TAMP program are unique, clients should request and carefully review the applicable disclosure brochure, client agreement and other account paperwork for each TAMP for more detailed information about the services provided by the Platform Sponsor, including without limitation, a description of the Platform sponsor’s background, investment strategies, fees, custody arrangements, conflicts of interest, and other relevant information regarding the Platform Sponsor’s services and business practices. Clients may request a copy of their disclosure brochure from the Financial Professional or by visiting https:/ /adviserinfo.sec.gov/ . Clients may also request the advisor’s Form ADV 2B Supplemental Brochure from their Financial Professional for detailed information about the management personnel responsible for managing client investment portfolios. C. Financial Planning Program: Our Financial Planning Program has your Financial Professional preparing a written or digital financial plan covering specific or multiple topics as it relates to understanding a client’s financial planning needs, setting financial goals, and monitoring progress. As an alternative to a written plan, your Financial Professional is also available to provide financial planning on a strictly consultative basis through meetings and written or digital communications. In this Program, your Financial Professional will typically serve as a liaison and work with other professionals such as attorneys, Certified Public Accountants, trust officers, etc., to provide a holistic financial plan which may include:
• Estate Planning • Charitable Giving • Retirement Planning • Business Planning This Service does not involve implementing any transaction on a client’s behalf or the active and ongoing monitoring or management of their investments. Client typically remains solely responsible for determining whether or not to implement program recommendations and taking all necessary steps to do so. A conflict of interest exists because investment advice may involve investment advisory services for which we will charge an advisory fee in addition to the Financial Planning fee. Additional conflicts of interest arise if the recommended financial plan involves the purchase of insurance products for which a Financial Professional receives compensation. Clients are under no obligation to follow the Financial Professional’s recommendation. In addition to the Financial Planning Program, Financial Professionals may, in their sole discretion and as agreed from time to time with clients, Etico Wealth Management | Form ADV Part 2A: Firm Brochure

4 provide financial planning or financial consulting services to clients in connection with the program at no additional cost. Financial Professionals will require clients to enter into a separate agreement with an agreed upon fee for financial planning or financial consulting services. Description of Employer Retirement Plan Services. We provide investment advice, certain administrative oversight, and consulting services to employer sponsored retirement plans (hereafter “Retirement Plan”). We offer the following Retirement Plan Services as either a turn-key comprehensive solution or a la carte: Non-Fiduciary Services. Monitoring and Reporting Key Metrics: Performance monitoring and reporting to assist Plan Sponsor in making sure investment decision making adheres to the plan’s investment policy statement and identify areas of concern. Plan Design: Aiding the Plan Sponsor in determining the unique needs, requirements, and goals of the Retirement Plan. Provider Search and Selection: Assisting the Plan Sponsor in the fiduciary obligation of evaluating, selecting, and implementing provider services. We can oversee, negotiate, and maintain relationships with plan providers. Education: We provide educational support to both Plan Sponsors and participants which includes advising them on the Retirement Plan’s investment options, features, benefits, online account access, regulatory updates, enrollment, and servicing paperwork. Any investment recommendations so provided will be based on information relating to age, time horizons (e.g., life expectancy, retirement age), risk tolerance, current investments in designated investment options, other assets or sources of income, and investment preferences of the participant or beneficiary. Investment advice will not include monitoring or rebalancing of a participant’s portfolio unless the participant is invested in one of our Strategies. Fiduciary Services. Investment Policy Statement: A customized written Investment Policy Statement (hereafter “IPS”) will be drafted that roadmaps the investment methodologies, objectives, asset class guidelines, performance monitoring, duties and responsibilities, implementation of investment options, and expense monitoring of the Retirement Plan. Designated Investment Alternatives (“DIAs”) Investment Menu: Prudent investment recommendations and ongoing monitoring of Retirement Plan investment options, including a qualified default investment alternative (hereafter “QDIA”). Investments shall be monitored and replaced when appropriate using a repeatable process. Model Asset Allocation Portfolios: Our Strategies and/or Portfolios will be made available to Participants as a means of more efficiently delivering investment advice to Participants. When a Participant selects one of our Strategies and/or Portfolios, we have an ongoing responsibility for investment decisions, security selection, day-to-day portfolio management of the assets, and/or the general timing in which to effectuate securities transactions. Disclosures Specific to Retirement Plan Accounts and IRAs. Retirement Plan Consulting Limited Scope of Advice and Discretion: We do not provide nor have any responsibility to provide any Services with respect to the following: employer securities, real estate, non-publicly traded securities or assets, illiquid investments, legal or tax advice. Further, unless we agree in writing to be appointed as a discretionary ERISA 3(38) investment manager, our recommendations are non-discretionary and will only be implemented at the Plan Sponsor’s sole discretion. ERISA Disclosure: We will disclose any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(iv) as soon practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable). Further, in accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or plan administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Retirement Plan agreement and any compensation or fees received in connection with the agreement that is required for the Retirement Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section2550.408b-2(c)(1)(iv) or (vi), we will disclose to the Retirement Plan the correct information as soon as practicable, but no later than thirty (30) days from the date on which we identify such error or omission. Retirement Plan Rollover and IRA Recommendations. A recommendation to take a distribution from an employer sponsored retirement plan or to transfer (or withdraw from) an IRA are fiduciary acts. Providing education regarding distribution options is an important consideration for selecting among those options. To the extent a rollover is recommended from a client’s employer sponsored retirement plan or existing IRA to an IRA, managed by our firm please know that this presents a conflict of interest. As with any Account Etico Wealth Management | Form ADV Part 2A: Firm Brochure 5 we have an economic incentive due to increased advisory fees. You are under no obligation, contractually, or otherwise to rollover or transfer your retirement account. To mitigate this conflict of interest we have adopted an impartial conduct standard whereby our we will provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, i. Not recommend investments which result in our firm receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA; ii. Fully disclose compensation received by our firm and any material conflicts of interest; iii. Follow policies and procedures designed to ensure that we give advice in our client’s best interest and avoid putting our financial interests ahead of our clients when making recommendations; iv. Charge no more than is reasonable for our Services; v. Refrain from making any materially misleading statements about conflicts of interest, fees, and investments; and vi. Meet a professional standard of care when making investment advice by acting with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of our firm or our affiliated personnel. A decision to move and invest assets from an IRA or former employer’s qualified retirement plan (e.g., 401(k), 403(b), 457(b), etc.) is an important one. If you retire or otherwise leave your employer there are several factors to when determining what option best fits your individual needs and objectives. Factors include among others, tax implications, changes in account features and consider differences in fees and expenses. Generally, the following three options are available, and each option has advantages and disadvantages: 1. Cash Out: Take a full lump sum distribution directly from the qualified employer plan to have immediate access to your money. We strongly encourage you to consult with a qualified tax professional regarding this option. a. Advantage: Immediate access to your money. b. Disadvantage: Lose protection from creditors. Potential adverse tax consequences. Lose tax deferred growth compounding potential. If you are under the age of 59.5 you may incur a 10% IRS early withdrawal penalty. 2. Leave It or Roll to New Employer Plan: If allowed you may leave assets in your former employer plan. Additionally, if you changed employers and your new employer offers a retirement plan you may be able to roll your assets into your new employer’s retirement plan. a. Advantage: Potentially lower fees based on the plan size and the fees the employer elects to pay on your behalf. If offered, you may have access to a loan feature or to potentially delay your required minimum distributions beyond age 70.5. b. Disadvantage: Limited investment options, distribution stipulations and restrictions on having our firm or other Financial Professional allocating your assets to a unique strategy or actively managing your investments on a discretionary basis. If you leave your account in your former employer’s plan you will lose the ability to make new contributions. 3. Roll to IRA: Rollover assets into an Individual Retirement Account (IRA) and/or Roth IRA (account type depends on whether monies invested were contributed as pre-tax or after-tax). This option will provide more personal control along with a wide assortment of investment options and active investment management by our firm. With this option, the expenses and account fees may be higher than an employer’s qualified plan and while you’ll maintain bankruptcy protections, the protection from creditors may be limited. a. Advantage: More investment options and control over your investment options whether you self-direct the investment of your assets or chose to hire our firm or another financial professional to direct the investments in your account. b. Disadvantage: Investment expenses and fees may be higher and protection from creditors may not be as robust as an employer’s qualified plan. Please Note: The advantages and disadvantages listed above are not all inclusive and are generalized and do not address your unique situation. We strongly encourage you to speak with both your Financial Professional and a tax professional regarding your options. Wrap Fee Programs. Wrap Programs are investment management programs in which a client pays a single stated monthly or quarterly Wrap Program fee based upon a percentage of the value of the assets under management in which the expenses arising from investment advice, investment management, trade execution (regardless of the frequency of trading), and custodial service are "bundled” with no breakdown or separate disclosure as to the individual fees associated with each service provider on the clients Account statement. While we do not sponsor a wrap fee program (hereafter “Wrap Program”), certain TAMP Programs our Financial Professionals recommend may be a Wrap Program. Clients participating in a Wrap Program will sign a separate agreement and receive a Wrap Fee Program Brochure from the Platform Sponsor. Clients should carefully evaluate the fees for the services provided under a Wrap Program, including the identification of infrequent trading activity or transaction-based expenses not covered by the Wrap Program fee. Etico Wealth Management | Form ADV Part 2A: Firm Brochure 6 Assets Under Management. As of December 31, 2022, we receive fees on a total of $90,552,526 of client assets. Of this, we managed $68,723,551 in discretionary assets under management. The remaining $21,828,975 are non-discretionary assets under management in which we do not have full investment trading discretion. These non-discretionary assets under management are typically employer sponsored retirement plans where our firm only serves as a 3(21) fiduciary or for accounts utilizing the services of a third-party manager or sub-advisor.