Kraft, Davis & Associates, LLC, doing business as ADK Wealth Advisory Group and Steck Wealth Management (hereinafter referred to collectively as “ADK” or the “Advisor”), is an investment advisor registered with the Securities and Exchange Commission (“SEC”). Mr. Cory Kraft and Mr. Daniel Davis are the founding members of ADK. Mr. Davis is the President and Chief Compliance Officer and Cory Kraft is the Chief Executive Officer. Any and all material conflicts of interest are disclosed herein. ADK provides fee-based investment advisory services primarily to individuals and high-net worth individuals. The Advisor is compensated based on a percentage of assets under management, as well as on an hourly and/or fixed fee basis. The individuals associated with ADK are appropriately licensed and authorized to provide advisory services on behalf of ADK. Investment Advisor Representatives (“IARs” or “Representatives”) are restricted to providing services and charging fees based in accordance with the descriptions detailed in this document and the Client Consulting Agreement. However, the exact service and fees charged to a Client are dependent upon the individual IAR working with the Client. IARs are instructed to consider the individual needs of each Client when recommending an advisory platform. Investment strategies and recommendations are tailored to the individual needs of each Client. Individuals associated with ADK are also Registered Representatives (“RRs”) of LPL Financial, a broker-dealer, a member of the Financial Regulatory Authority ("FINRA") and the Securities Investors Protection Corporation (“SIPC”). All securities transactions shall be directed to LPL Financial for execution. ADK and LPL Financial are not affiliated legal entities. Because ADK is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered 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. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients however are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. Asset Management ADK, through its IARs, provides ongoing investment advice and management on assets in the Client’s custodial Strategic Wealth Management (“SWMI”) account held at LPL Financial (“LPL”). SWMI is the name of the custodial account offered through LPL to support investment advisory services provided by ADK to its Clients. More specific account information and acknowledgements are further detailed on the SWM Client Account Application. Clients may participate in either a wrap (SWMII) or non-wrap (SWMI) version of the SWM Program. IARS provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), variable annuity subaccounts, real estate investment trusts (“REITs”), equities, and fixed income securities. The advice is tailored to the individual needs of the Client based on the investment objective chosen by the Client, to help assist Clients in attempting to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary per each Client’s investment profile. There is no minimum account value required for the program. ADK Wealth Wrap Fee Programs Assets managed in a wrap fee account are not managed differently from those maintained in a non-wrap fee account. The primary difference of a wrap fee program is that the transactions costs associated with trading your account are borne by the Program Sponsor. ADK serves as both the Program Sponsor and the Portfolio Manager of a wrap fee program with support from LPL. Additionally, your IAR may recommend to clients one of the wrap fee programs described within this section. Clients should know that services under a wrap fee program are available individually and for a lower cost that an all- inclusive wrap fee. ADK Wealth Wrap Fee Program (SWMII) In the SWMII program, ADK serves as both Program Sponsor and Portfolio Manager to you. ADK will have discretion to execute trades with our account including but are not limited to instructions with respect to buying, selling, assigning, transferring, and trading in securities and commodities and/or contracts relating to the same on margin or otherwise, and stock option transactions, as well as with respect to all other things necessary or incidental to the furtherance of such instructions. You authorize LPL to accept from ADK all instructions relating to the trading of securities as well as the reinvestment of dividends and capital gain distributions in your account. There is no minimum account value required for SWM. A more detailed discussion of ADK Wealth’s Wrap Fee Program is provided in the ADK Wrap Fee Brochure. ADK Wealth Wrap Fee Program (OMP) In the OMP program, ADK serves as both Program Sponsor and Portfolio Manager to you with support from LPL. The Program offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under the Program, Client authorizes LPL and Advisor on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by Client and to liquidate previously purchased securities. There are up to six Optimum Funds that may be purchased within the Account: Optimum Large Cap Growth Fund, Optimum Large Cap Value Fund, Optimum Small-Mid Cap Growth Fund, Optimum Small-Mid Cap Value Fund, Optimum International Fund and Optimum Fixed Income Fund. An account managed on a discretionary basis means the IAR can trade your account without discussing the transaction with the client prior to execution. More specific account information and acknowledgements are further detailed on the OMP Client Account Application. The advice is tailored to the individual needs of the Client based on the investment objective chosen by the Client, to help assist Clients in attempting to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary per each Client’s investment profile. The minimum account value required for OMP is $10,000 but may be waived at LPL’s discretion. Non-Wrap Fee Programs Personal Wealth Portfolios Program (PWP) Developed with high-net-worth clients in mind, investment opportunities include separately managed sleeves, mutual funds, and exchange-traded products (ETPs). PWP offers Clients an asset management account using asset allocation model portfolios designed by LPL. The Advisor will have discretion for selecting the asset allocation model portfolio based on the Client’s investment objective. The Advisor will also have discretion for selecting third-party money managers (PWP Advisors) or mutual funds, within each asset class of the model portfolio. LPL will act as the overlay Portfolio Manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. Model Wealth Portfolios Program (MWP) Using theme-based strategies, ADK can offer clients a powerful combination of mutual fund and ETP selections. ADK IARs will obtain the necessary financial data from the Client, assist the Client in determining the suitability of the MWP program and assist the Client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the Client’s stated investment objective. LPL’s Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The Client will authorize LPL to act on a discretionary basis to purchase and sell selected securities and to liquidate previously purchased securities. The Client will authorize LPL to effect rebalancing for MWP accounts. Rebalancing may occur as agreed upon by ADK and the Client. In the future, the MWP program may make available model portfolios designed by strategists other than LPL’s Research Department. If such models are made available, Advisor will have discretion to choose among the available models designed by LPL and outside strategists. A minimum account value of $25,000 is required for MWP. Manager Select Program (MS) With this separately

manage account platform, ADK can offer high-net-worth clients access to a variety of institutional portfolio managers and a broad range of investment styles, including traditional equity, fixed income asset classes, mutual funds, ETFs, and specialty strategies. Manager Select provides Clients access to the investment advisory services of professional portfolio management firms for the individual management of Client accounts. Advisor will assist Clients in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages Client’s assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Select. However, in certain instances, the minimum account size may be lower or higher, based upon chosen Portfolio Manager’s services and discretion. Financial Planning Services As part of our financial planning services, ADK, through its IARs, provides personal financial planning tailored to the individual needs of the Client. These services may include, as selected by the Client on the Financial Planning Agreement, information and recommendations regarding tax planning, investment planning, retirement planning, pension consulting, estate needs, business needs, education planning, life and disability insurance needs, long-term care needs and cash flow/budget planning. The services consider information collected from the Client such as financial status, investment objectives and tax status, among other data. Fees for such services are negotiable and detailed in the Client Consulting Agreement. The financial plan may include generic recommendations as to general types of investment products or specific securities which may be appropriate for the Client to purchase given his/her financial situation and objectives. The Client is under no obligation to act upon the IAR’s recommendation or purchase such securities through ADK and the IAR. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through the IAR. If the Client desires to purchase securities to implement his/her financial plan, ADK may make a variety of products and services available through its IARs. This may result in the payment of normal and customary commissions or other types of compensation to the IARs, in their separate capacity as RRs of a broker-dealer. A potential conflict exists between the interests of the IAR and the interests of the Client. Depending on the type of account that could be used to implement a financial plan, such compensation may include, but is not limited to, advisory fees; commissions; mark-ups and mark-downs; transaction charges; confirmation charges; small account fees; mutual fund 12b-1 fees; mutual fund sub-transfer agency fees; hedge fund, managed futures, and variable annuity investor servicing fees; retirement plan fees; fees in connection with an insured deposit account program; marketing support payments from mutual fund, annuity and insurance sponsors; administrative servicing fees for trust accounts; referral fees; compensation for directing order flow; and bonuses, awards or other things of value offered by ADK to the IAR. To the extent that IAR recommends that Client invest in products and services that will result in compensation being paid to ADK and the IAR, this presents a conflict of interest. This compensation to IAR and ADK may depend on the product or service that IAR recommends. Therefore, the IAR may have a financial incentive to recommend that a financial plan be implemented using a certain product or service over another product or service. The IAR may receive additional cash or non-cash compensation from advisory product sponsors. Such compensation may not be tied to the sales of any products. Compensation may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings or marketing or advertising initiatives. Retirement Plan Advisory Services We offer retirement plan advisory services to defined contribution retirement plans (the "Plan(s)") and to the Plan's named fiduciary (the "Plan Sponsor"). These services may include either discretionary or non-discretionary investment advice concerning the retirement plan's investment options that are available to participants in the plan. Investment Adviser 3(21) Fiduciary Services The Firm shall serve as an "Investment Adviser" and a "fiduciary" within the meaning of Section 3(21) of Employee Retirement Income Security Act of 1974 ("ERISA"), as amended, with respect to accounts in the Plan. (Although 3(21) fiduciaries provide advice, they do not take control of plan assets, so the Plan Sponsor retains the final say regarding implementation of the recommended investment options.) If we are engaged as an Investment Adviser, we will provide recommendations concerning the selection of the investment options for the Plan, as well as the replacement, addition, or removal of such options on an ongoing basis. In general, these services may include an existing plan review and analysis, investment performance monitoring, and/or ongoing consulting. In providing these services, we will have the ongoing responsibility to select or make recommendations based upon the needs of the Plan. While the ultimate decision to act on behalf of the Plan shall remain with the Plan Sponsor, we will generally provide assistance with the implementation of our recommendations after approval by said Plan Sponsor. Investment Manager 3(38) Fiduciary Services The Adviser shall serve as an "Investment Manager" and a "fiduciary" within the meaning of Section 3(38) of ERISA with respect to accounts in the Plan. (A Section 3(38) fiduciary is an "Investment Manager" that has discretion, authority, and control of a plan's assets. Under ERISA, a Plan Sponsor can delegate the job of selecting, monitoring, and replacing plan investments to the Investment Manager, but the Plan Sponsor retains liability for the selection, monitoring and benchmarking of the Investment Manager.) If we are engaged as an Investment Manager, we will select the investment options that are to be offered to the Plan's participants. We will also monitor the selected investment options and make changes to the investment options as necessary. In addition, we may offer assistance with respect to the establishment and maintenance of an investment policy statement for the Plan. We shall be responsible for selecting the Qualified Default Investment Alternatives ("QDIA") for the Plan as permitted under Section 404(c) of ERISA in the form of an investment fund or model portfolios that seek both long-term appreciation and capital preservation through a mix of equity and fixed income investments. Additional related services may also be offered in support of the plan and its fiduciaries. Participant Services In addition to providing plan-level advisory services, we may offer participant-level education services and may also assist with participant enrollment meetings and provide investment- related educational seminars to plan participants on such topics as diversification, risk tolerance and time horizon. Our educational seminars may include other investment-related topics specific to the particular plan. We may also provide additional types of retirement plan advisory and consulting services to Plans on an individually negotiated basis. All services, whether discussed above or customized based upon a Plan Sponsor's requirements, shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Hourly Consulting Services ADK, through its IARs, may provide consulting services on an hourly or fixed-fee basis. These services may include, as selected by the Client in the Client Consulting Agreement, advice regarding tax planning, investment planning, retirement planning, pension consulting, estate planning, cash flow/budget planning, business planning, education planning, and personal financial planning. The services take into account information collected from the Client such as financial status, investment objectives and tax status, among other data. The IARs may or may not deliver to the Client a written analysis or report as part of the services. The IARs tailor the hourly or fixed fee consulting services to the individual needs of the Client based on the investment objective chosen by the Client. The engagement terminates upon final consultation with the Client. Fees for such services are negotiable and detailed in the Client Consulting Agreement. Assets Under Management ADK offers asset management on a discretionary and non-discretionary basis. As of December 31, 2023, ADK’s discretionary assets under management were $598,911,042.