EAM is an investment adviser with its principal place of business located in Ohio. EAM has three principal owners (i.e., controlling 25% or more of EAM). The three principal owners are Brian Lysaght, Member, Patrick Lysaght, Member, and Casey Lysaght, Member. EAM offers Model Portfolio Management services to its advisory clients. Please see the disclosure below in this Item for additional information regarding this service. MODEL PORTFOLIO MANAGEMENT Our firm provides portfolio management services to clients using model asset allocation portfolios. Each of our model portfolios is designed to meet a particular investment goal. We manage these advisory accounts on a discretionary basis only. Account supervision is guided by the client's stated objectives (e.g., growth or a balance between growth and income), as well as tax considerations. Through personal discussions with the client in which the client's goals and objectives are established, we determine which of our model portfolios is suitable to the client's circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will generally include advice regarding the following securities: stocks (common and preferred), bonds, exchange-traded funds (“ETFs”), and options. Because some types of investments, such as options, involve certain additional degrees

of risk, they will only be used when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: - at least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; - be reasonably available to consult with the client; and - maintain client suitability information in each client's file. Our portfolio management services are typically provided to clients through the Eukles Asset Management Strategic Wealth Management Wrap Fee Program (hereinafter “Program”). The Program is a “wrap fee” program sponsored by Eukles Asset Management, LLC. A wrap fee program is an advisory program under which a specified fee not based directly on transactions in a client's account is charged for both our advisory services and the execution of client transactions. We do, however, offer our portfolio management services outside of the Program on a non-wrap fee basis. For more information about our fees, please see our disclosure below at Item 5 of this Brochure. We manage client portfolios wrap accounts in the same manner in which we manage client accounts employing similar investment strategies in non-wrap accounts (i.e., where clients pay for advisory and execution services separately). AMOUNT OF MANAGED ASSETS As of 2/29/2024, we are actively managing $337,221,710 of clients’ assets on a discretionary basis.