Sanctuary Wealth Management LLC (“Sanctuary”, “we”, “us”) was founded in 2004 as an Idaho Limited Liability Company. Sanctuary is owned by Washington Financial, LLC, Pintail Management LLC, and Centerpoint Capital Advisors LLC, which are owned by Brett Robison, G. Clay Esplin, and Joel Phillips, respectively. We provide the following advisory services: Financial Planning: Our process starts with a comprehensive interview to determine our clients’ financial objectives, limitations, and timeframe. We gather related information from our clients, such as account statements, balance sheets and income statements, tax returns, client provided verbal account information, and copies of estate planning documents. Based on the interview and compiled information, we formulate a long-term plan appropriate for the client’s situation and the goals they are trying to achieve. This plan evolves and is updated over time as personal events such as birth, death, divorce, retirement, and other events change or impact their financial plan. In the provision of this service, we may use an unaffiliated third party to assist us with the creation of the plan. Unaffiliated third parties will be paid by Sanctuary at an hourly rate which does not change the amount paid by clients to us for this service. Investment Management: Based on the formulation of a client’s financial plan (whether the plan was created by us or another firm), we will manage the client’s portfolio of investment securities according to a risk assessment adopted by the client. A more in-depth discussion of our investment philosophy can be found in Item 8: Methods of Analysis, Investment Strategies and Risk of Loss of this ADV. We typically allocate a client’s investment holdings across a globally diversified portfolio of equities, bonds, real estate, commodities, and cash, primarily using mutual funds or exchange traded funds to help them meet their financial goals. We also recommend investments in private investment funds to clients. We then periodically review the client’s portfolio, compare it against the objectives and requirements of the client’s current risk assessment results, and make recommendations to the client as changes are needed. In some cases, we recommend the use of Betterment LLC (“Betterment”) for customers. Betterment offers software, advice, and digital services on a sub-advisory basis to our clients. Through the completion of an on-line questionnaire, clients will determine the appropriate investment model through Betterment in which to invest. Sanctuary may, after meeting with the client, suggest a different investment model and always retain the discretionary authority to adjust the client’s portfolio. Wealth Management: As our client’s financial affairs become more complex, we

may coordinate with the client’s other professional advisors, such as their accountant, attorney, banker, or insurance agent to help create a team approach to the client’s financial plan and help to work in unison with that team for the client’s benefit. Our wealth management services are highly tailored and customized to each client. Employee Retirement Plan Consulting: For our business-owning clients seeking to provide a corporate retirement plan for their employees, we may provide advisory services to help them establish a corporate retirement plan, enroll eligible employees, advise the employees on available investments and allocations within the plan, and provide reporting services. Most of these services are arranged through various third- party administrators and may be provided separately or in combination. Private investment funds generally involve various risk factors, including, but not limited to, the potential for complete loss of principal, liquidity constraints, and lack of transparency. These risk factors are set forth in each fund’s offering documents, which will be provided to clients contemplating an investment in the affiliated private fund for review. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he or she acknowledges and accepts the various risk factors that are associated with such an investment. We encourage broad-based diversification across thousands of different securities within a client’s portfolio by way of using indexed mutual funds, exchange traded funds, or other investment products. Clients may impose reasonable restrictions on investing in certain securities or types of securities. We do not sponsor a wrap fee program. We may, without the Client’s further consent, delegate any or all our responsibilities to one or more affiliated or unaffiliated advisors on such terms as we may determine. As of December 31, 2023, we have approximately $228,988,940 of discretionary assets under management and no non-discretionary assets under management. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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 are always fiduciaries to our clients under the Advisers Act. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours.