Firm Description Gradient Investments, LLC, (“GI”) is an independent, SEC registered investment advisor. The Charles E. Lucius Arizona Separate Property Revocable Trust is a 80% owner, the Nathan Lucius Revocable Trust is a 10% owner and Luson Capital, LLC is 10% owner. GI provides investment management services to institutional accounts, individuals, pension and profit sharing plans, trusts, estates, corporations, charitable organizations, and small businesses. The clients to whom GI provides discretionary management services are often introduced to GI through other registered investment advisor firms operating as independent referring party for GI. GI is strictly a fee-only investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other products for a commission. GI does not act as a custodian of client assets. The client always maintains ownership of their assets. GI places trades for clients under a limited power of attorney and withdraws management fees per the Investment Proposal and Contract signed by the client. Clients that work with an independent investment advisor as the referring party should work with that investment advisor to determine the appropriate GI portfolio based on investment objectives, risk tolerance, and time horizon; however, GI is available throughout the consultation process. GI is only responsible for money allocated to and managed by GI. It is the client’s obligation to notify their advisor immediately if circumstances have changed with respect to the goals of the money being managed by GI. Types of Advisory Services GI provides investment supervisory services, also known as asset management services, and upon request, GI furnishes investment advice about securities through consultations directly with clients. Advisory Service Agreement GI offers ongoing portfolio management services based on the individual goals, objectives, time horizon and risk tolerance of each client. This information is obtained through GI's Risk Tolerance Analysis from which an Investment Proposal and Investment Contract is prepared and presented to the client. GI practices management of portfolios on a discretionary basis unless directed otherwise by the client. Investment services include but are not limited to:
• Investment Strategy
• Asset Allocation
• Asset Selection
• Regular and/or continuous portfolio monitoring Managed Portfolios All client portfolios are managed on a discretionary basis unless otherwise noted. GI offers a variety of managed portfolios primarily utilizing no-load mutual funds, exchange traded funds (ETF), individual equities, and money market funds. GI may also manage subaccounts within a variable annuity. Based on client circumstances, GI may create, recommend, and manage custom portfolios that fall outside the scope of the GI-managed model portfolios. GI offers the following types of managed portfolios: Strategic Portfolios: Strategic portfolios are designed to achieve a specific objective. Objectives can range from long term capital appreciation, income, or a blend of income and growth. The primary vehicles for investment in strategic portfolios include individual equities and equity, bond, or alternative exchange traded funds (ETFs). Tactical Portfolios: Tactical portfolios utilize proprietary quantitative methods to achieve a stated objective. These quantitative strategies use bond and equity exchange traded funds (ETFs) as the primary method of investment. Allocation Portfolios: Allocation portfolios are designed to achieve a diversified approach that can incorporate a wide variety of investor objectives and risk tolerance. These portfolios incorporate individual equities or equity, bond, or alternative exchange traded funds (ETFs). Defined Outcome Portfolios: Defined outcome portfolios comprise assets that are bult to achieve a defined outcome solution based on a set of pre-defined parameters. These portfolios typically include structured notes as the primary vehicle of investment. Preservation Portfolios: Preservation portfolios are designed for lower degrees of volatility with a conservative risk profile. These portfolios typically incorporate money market mutual funds and bond exchange traded funds (ETFs) as the vehicles of investment. Managed Portfolios Acknowledgement All portfolios managed by GI involve risk including the potential loss of principal. It is important that you work closely with your investment advisor in selecting the proper allocation and investment strategy for the portion you are allocating to GI. GI will actively manage your account to help ensure your investments are in line with your risk tolerance, time horizon and overall financial objectives. GI is not responsible for investments or other products recommended or purchased outside of the GI managed portfolios. Past performance is not an indication of future results. Client Directed Accounts GI will assist in the opening, closing and transferring of accounts. GI will not have discretion at any time on these accounts. Client is solely responsible for the assets held within the accounts and their values which could increase or decrease (potential loss of principal). GI will not execute trades in CDA accounts. GI exceptions will be made for withdrawals to client or assets transferred into a GI managed portfolio. GI will also provide performance reporting on these accounts and can furnish 3rd party analysis reports per the client’s request. Sub-Advisor Services

GI provides services as a sub-adviser, to exchange-traded funds (“ETFs”). GI generally enters into a sub-advisory agreement directly with an ETF’s primary advisor for its services. Such agreements contain GI sub-advisory fees, which are negotiated on a case-by-case basis. Such fees are disclosed in such funds’ offering documents. Currently GI is a sub-advisor for the Innovator Gradient Tactical Rotation ETF (the “IGTR ETF”), a series of Innovator, LLC, organized as a separate series of a 1940 Act registered management investment company. The investment strategy exercised for these products is designed to meet particular investment goals and objectives as outlined in the ETF’s offering documents. Clients should refer to the product’s offering documents, as applicable, for more important information regarding objectives, investments, time-horizon, risks, fees, and additional disclosures. Prior to making any investment, Clients should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investing in the ETF. GI is responsible for providing Innovator the timing and selection of the positions held in the ETF. It is Innovator’s responsibility to execute the purchase and sale transactions, including selecting the broker-dealers to execute said transactions. GI does not tailor its advisory services to the individual needs of investors in the ETF. The ETFs’ offering documents set forth their respective investment strategies, guidelines and restrictions. ERISA Plan Services GI provides services to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans as a 3(38) advisor. 3(38) Investment Manager. GI can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. GI would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. Fiduciary Services under ERISA Section 3(38): 1. Fiduciary Services are:
• GI has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands the GI’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the GI is not providing fiduciary advice as defined by ERISA to the Plan participants. GI will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. GI may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between GI and Client. 3. GI has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Client Tailored Services and Client Imposed Restrictions The investment objective and risk tolerance for each client is documented in our client relationship management system through our Risk Tolerance Analysis and Investment Proposal and Contract. Clients may impose restrictions on investing in certain securities or types of securities in writing on the Investment Proposal and Contract. These restrictions may, however, prohibit investment in certain GI strategies. Agreements may not be assigned without client consent. Wrap Fee Programs GI does not participate in wrap fee programs. Client Assets Under Management GI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $4,881,233,258 $0 9/30/2023