The Company Alpha Principle, LLC (“we,” “us” or “Alpha”) is currently in the process of registering as an investment adviser with the State of Colorado.1 Alpha began operations by its founder and Chief Executive Officer, Eric Koeplin. Alpha is entirely owned by Eric Koeplin, and it is headquartered in Lone Tree, Colorado. Eric Koeplin also serves as Chief Compliance Officer of Alpha. Advisory Services Our Investment Philosophy Our investment philosophy is grounded in a disciplined approach to allocating assets. We believe in broad-based diversification across asset classes with a focus on asset class selection, rebalancing, tax efficiency and reducing investment expenses. Our research- intensive investment process focuses primarily on corporate fundamentals and investment factors such as macroeconomic, microeconomic and investment style factors. When we build portfolios for clients, we look to create a balance, taking into account the client’s financial condition, investment objectives and risk tolerance. In providing our services, we use proprietary strategic and tactical asset allocation investment processes to help guide investment decisions in various financial market conditions, and we use a wide range of different securities to construct client portfolios. Market volatility can sometimes change asset values. When this happens, the values of assets may 1 Registration as an investment adviser does not imply a certain level of skill or training. become somewhat inconsistent with desired asset allocation objectives. If we think it is appropriate, we will rebalance a portfolio to match the account’s allocation objectives. Our investment strategies are more fully described below in Item 8. Our Services We offer the following services:
• asset management services for private investment funds
• discretionary investment management services for individual and entity clients
• financial planning for individual clients Asset Management Services for Private Investment Funds Alpha provides asset management services to two private investment funds organized as limited partnerships: (i) Flagship Fund by Alpha Principle, LP (“Flagship Fund”) and (ii) Lemonade Fund by Alpha Principle, LP (“Lemonade Fund”). In this brochure, the Flagship Fund and the Lemonade Fund are each referred to as a “Fund” and referred to collectively as the “Funds.” The Flagship Fund invests in publicly traded securities and seeks to grow investor capital in a manner that exceeds the S&P 500 stock index; and the Lemonade Fund seeks to hedge against price declines in the US stock market and take advantage of changing conditions related to stock market volatility. Our advice is tailored to meet the needs of each Fund. Underlying investors may not request in writing that we refrain from investing in certain industries or in securities of issuers, and we do not tailor our advisory services based on our analysis of the individual needs of underlying investors. See Item 8 below for more information about: (i) the Funds’ principal investments; (ii) the investment strategies we use in managing the Funds; and (iii) the associated risks of those strategies and investments. We cannot guarantee that a Fund will achieve its investment objective. Note: Our discussion of the Funds in this brochure is required by the SEC. Nothing in this brochure is, or should be construed as, an offer or solicitation to invest in the Funds. All offers to invest are made only by delivery of a private placement memorandum for the Funds to a specific prospective investor who is believed to be eligible or suitable to invest in the Funds. This brochure describes the Funds and includes certain information applicable to investors in the Funds. All information about the Funds included in this brochure summarizes more detailed information provided to investors and prospective investors in the Funds’ governing documents (including a Fund’s private placement memorandum and limited partnership agreement). If any aspect of this brochure is inconsistent with the governing documents of a Fund, the governing documents of the Fund will control. Discretionary Investment Management Services for Individuals We offer investment management services, on a fully discretionary basis, to private funds, individuals, and high net worth individuals. We provide these services through a separately managed account (“SMA”) established by each client that is held by an independent custodian firm. These services are for clients seeking a personalized approach to implementing an individually customized strategy designed to meet their investment goals and objectives through portfolio

monitoring and regular reporting. We use a variety of investments to construct and maintain an investment portfolio, taking into consideration the client’s financial situation, investment objectives, time horizon, and risk tolerance. The specific investments and risk management strategies employed may be consistent across clients that share similar suitability (i.e., financial condition, investment objectives and risk tolerance) or customized to meet a particular set of client needs and/or preferences. All of our SMA clients may, with our approval, impose reasonable restrictions on investing in certain securities, types of securities, industries or sectors. Such clients must advise us of any such desired restrictions in writing. Use of Subadvisers When Alpha believes that a manager has an advantage in a marketplace that includes the ability to trade certain securities (e.g., equites or fixed-income), Alpha suggests and uses subadvisers (“Subadvisers”) in accordance with the investment objectives of its individual clients. Where appropriate, Alpha allocates client assets to certain Subadvisers to actively manage those assets. The specific terms and conditions, including payment of separately managed fees under which Alpha engages a Subadviser are set forth in a separate written agreement between the designated Subadviser and Alpha. When employed, Alpha evaluates various information about the Subadvisers it chooses to manage client portfolios, which include, as appropriate, the Subadvisers’ public disclosure documents, materials supplied by the Subadvisers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Subadvisers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Alpha also takes into consideration each Subadviser’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Alpha continues to provide services relative to the discretionary selection of the Subadvisers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Subadvisers. Alpha seeks to ensure the Subadvisers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. See Item 8 below for more information about the methods of analysis and investment strategies we use in managing the accounts for SMA clients. 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. The way we make money creates some conflicts with your interests, so we operate under a fiduciary rule that requires us to act in your best interest and not put our interest ahead of yours. Under this fiduciary rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest and how we mitigate them. Financial Planning Our comprehensive financial planning services provide clients with holistic advice in a variety of disciplines including, but not limited to, budgeting, debt management, general business, tax, estate planning, retirement planning, college savings, insurance and new family planning. Our financial planning services are tailored to meet your needs, and we seek to develop and nurture a relationship with you that extends beyond the conventional advisor-client dynamic. Generally, we first gather information about your personal financial situation and conduct a meeting with you to clarify your personal financial information and determine your specific needs, objectives, goals and tolerance for risk. We then analyze your current financial situation (and, if appropriate, potential future financial situations), and present a summary of the significant observations, assumptions and recommendations in each area for which we are engaged to provide advice. Assets Under Management As of December 31, 2022, we had $69,440,797.53 in assets under management. All client assets managed by us are managed on a discretionary basis.