Gladstone Wealth Partners (referred to as “Gladstone,” “we,” “us,” “our,” “Firm,” or “Adviser”) is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940. Gladstone was established in 2015 and is principally owned by GWP Advisory Services, LLC, an indirect wholly owned subsidiary of Integrity Marketing Partners, LLC. Gladstone is based in Boca Raton, Florida, and is organized as a limited liability company under the state laws of Delaware. Gladstone is a fee-only registered investment adviser that primarily provides asset management, retirement, financial planning, and consulting services to individuals, high- net worth individuals, corporations and other business entities, pension and profit-sharing plans, and charitable organizations (each referred to as a “client” or collectively as “clients”) as described below. As of December 31, 2023, Gladstone has $4,003,875,594 regulatory assets under management of which $3,989,903,107 is managed on a discretionary basis and $13,972,487 is managed on a non- discretionary basis. Gladstone serves as a fiduciary to investment advisory clients as defined under applicable laws and regulations. As a fiduciary, we have a duty which requires us to act in good faith with the degree of care, skill, prudence, and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use, in providing investment advice and managing client assets. Gladstone’s business model is based on a network of investment adviser representatives (“IAR,” “representative,” or “supervised person”) with offices located throughout the United States. Investment adviser representatives operate their business as independent contractors and are subject to our supervision and oversight from a centralized location. It is important to understand that the more assets there are in your account, the more you will pay in fees. Our investment adviser representatives are paid a portion of those fees for delivering investment advisory services to you. The portion of fees that an investment adviser representative receives is not incentive-based but can vary based on the specific agreement the investment adviser representative negotiated with the Firm. Many of our investment adviser representatives engage in business activities that may create conflicts of interest when providing client recommendations. Further information about the investment adviser representative managing your account, as well as potential conflicts that may impact their recommendations, are outlined in the individual representative’s Form ADV, Part 2B, Brochure Supplement provided to you when you opened your advisory account. Contact your investment advisor representative or us at (908) 719-1313 if you need an additional copy of your representative’s Brochure Supplement. Types of Advisory Services Offered We offer investment advisory services primarily to retail investors. These services include portfolio management services through wrap fee programs, including accounts managed directly by your Gladstone Wealth Partners’ investment adviser representative and/or a sub-adviser. Through personal discussions with each client, questionnaires and/or requests for documentation, Investment adviser representatives will gather and analyze information regarding each client’s current investments, goals and objectives, financial circumstances, investment experience, limitations, and risk tolerance, among other information. If appropriate, based on this analysis, the representative will either develop and directly manage the client’s portfolio, which may include recommendation of one or more sub- advisers, or an investment program sponsored by a sub-adviser, and if applicable, assist the client in selecting a model portfolio offered by a recommended sub-adviser. Sub-advisers may outsource the construction, monitoring, or modification of their portfolios to other third parties at their own expense and in their discretion. When directly managing a client account, the investment adviser representative will create a portfolio typically consisting of one or more of the following: individual equities, bonds, mutual funds, exchange traded products (ETPs), cash and cash equivalents, and/or other investment products. The representative will typically allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. If appropriate, the representative may recommend that all or a portion of the client’s account be managed by one or more sub-advisers subject to the representative’s supervision. Portfolio weighting among various investments and market sectors will be determined by each client’s individual needs and circumstances. Investment adviser representatives are required by applicable laws, rules, regulations, and Firm policies to obtain certain licenses or credentials and complete regular training in order to recommend particular investments, products, and/or services. Your investment adviser representative, depending on their licenses or training, may or may not be able to recommend or utilize certain broker/custodians, investment strategies, programs, or services. Please ask your investment adviser representative whether any limitations apply. Wrap Fee Programs A wrap fee program is any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services, which may include portfolio management or advice concerning the selection of other investment advisers, and the execution of client transactions. In other words, transactions in a client’s wrap fee account are generally effected without separate commission charge to the client and a portion of the wrap fee is generally considered as being in lieu of commissions. Depending on the program, wrap fee clients will incur certain additional costs, such as custodial fees, odd-lot differentials, step-out fees (when trades are placed with a broker other than the custodying broker), fees and expenses charged by mutual funds and exchange traded products (ETPs) to their shareholders, exchange fees, transfer taxes, wire transfer and electronic fund fees and certain administrative fees charged in connection with wire transfers or certificate issue. In general, a wrap fee account is more cost effective for the client when periodic trading activity is anticipated, though a wrap fee account may be more expensive than a non-wrap fee account when trading activity is low. Each wrap fee program offered by Gladstone Wealth Partners is described in a separate disclosure document (Form ADV, Part 2A, Appendix 1, Wrap Fee Brochure) that will be delivered to the client, as applicable. A firm brochure will also be provided for any third- party investment adviser that provides advisory services to a client as part of the wrap fee program. Each account is managed by one or more investment adviser representative who serves as the primary point of contact between the Firm and the client and who determines which available resources to utilize in connection with providing individualized investment advisory services. Some investment adviser representatives choose to incorporate more available resources in their provision of investment advisory services than others. Investment strategies utilized by investment adviser representatives can vary greatly as warranted by individual circumstances. Not all services are available to all clients, through all investment adviser representatives, or in all jurisdictions. Recommendations presented to clients by Gladstone Wealth Partners and the implementation of such recommendations are dependent upon the information provided by the client to build the client’s financial profile, which outlines each client’s current situation (e.g., income, investment objectives, and risk tolerance levels) and is used to construct a client specific action plan to aid in the selection of an investment program, portfolio and, as appropriate, a sub-adviser, that matches their restrictions, needs, and targets. Gladstone Wealth Partners encourages clients to notify their investment adviser representative promptly if they experience any material change in their financial circumstances or investment goals. Clients may impose reasonable restrictions on the management of their account. All restrictions or requests to change investment strategies must be submitted in writing to your investment adviser representative. Based on their nature, however, clients may not set restrictions on the management of certain sub-advisers, the subaccounts for variable annuities or the management of plan participant accounts. Should the restrictions prevent Gladstone Wealth Partners from properly servicing the client account, or if the restrictions would require Gladstone Wealth Partners to deviate from its standard suite of services, Gladstone Wealth Partners reserves the right to refuse or terminate the relationship, as applicable. When transferring your account to be invested, generally, existing positions will be liquidated. Liquidation of your account likely will have tax consequences, which you should discuss with your tax adviser. However, if there are certain securities you own that you do not want to liquidate, you must notify your investment adviser representative in writing and they will be transferred in-kind for custody, but neither Gladstone Wealth Partners nor the sub-adviser, as applicable, will advise on those positions. Any transaction costs incurred in the liquidation of transferred assets are the responsibility of the client. In addition to Gladstone Wealth Partners’ disclosures, clients should carefully review the Form ADV, Part 2A Disclosure Brochure or Appendix 1, Wrap Fee Program Brochure, and Form CRS for any recommended sub-adviser and program for important additional information regarding the sub- adviser’s services, fees, conflicts of interest and other important information. Depending on client preference, Gladstone Wealth Partners may retain the discretionary authority to hire and fire sub- advisers, as necessary, to better service our clients’ accounts. Recommended investment programs are detailed below and in separate disclosure brochures, as applicable. For all portfolio management services programs, Gladstone provides continuous and regular supervisory or management services. None of the services described herein are intended as, or meant to be, a substitute for legal, accounting, or tax advice. There can be no assurance that any advisory service or investment strategy will produce favorable results or will be successful in achieving a client’s investment goals and objectives. 1. Strategic Wealth Management II Strategic Wealth Management (“SWM”) is a Gladstone sponsored wrap fee program where the investment adviser representative tailors advisory services to the individual needs of the client based on investment objectives chosen by the client. Accounts are custodied at LPL Financial, LLC (“LPL”), an unaffiliated SEC-registered broker dealer and FINRA/SIPC member where LPL provides clearing, custody, or other brokerage services. Clients can elect to have a discretionary or non-discretionary advisory account. A discretionary account is an account that gives the investment adviser representative the authority to make individual trade without the consent of the client. A non-discretionary account is an account where the client ultimately decides whether or not to make a trade. Depending on the investment strategy, securities used in SWM include equities, fixed income securities, mutual funds, ETPs, and alternative investments, but can include other securities and products available on the platform. If structured products, alternative investments, or annuities are utilized as part of the investment strategy, the assets will be reported on LPL’s account statements, but the actual securities are typically held with and valued by the specific issuer. There is no minimum account size in the SWM program. Clients can impose restrictions on investing in certain securities or groups of securities in the Investment Management Agreement or by notifying the investment adviser representative in writing. Given the long-term nature of many of the individual strategies employed in the program, an account may have little or no trading activity during a given period. Clients should refer to LPL’s pricing guide/fee schedule for specific information regarding services that have associated fees which are separate from and in addition to the fees the client pays us. 2. Manager Asset Select Manager Asset Select (“MAS”) is an LPL sponsored wrap fee program that makes available to investment adviser representatives and their clients the investment advisory services and/or model portfolios of third-party portfolio management firms. MAS offers two alternatives (i) the Separately Managed Account Platform (“SMA Platform”); and (ii) the Model Portfolio Platform (“MP Platform” and collectively the “Platforms”). LPL serves as the custodian of the assets, typically provides brokerage and execution services as broker-dealer on transactions, and performs administrative services, such as billing and reporting. The Platforms’ portfolio manager, and not the investment adviser representative, has authority to purchase and sell securities on a discretionary basis. The investment adviser representative assists the client to determine the client’s financial circumstances, and to identify any investment restrictions on the management of the account, and, in the case of the SMA Platform, to select an investment strategy and SMA portfolio manager, or in the case of the MP Platform, to select a model portfolio provided by LPL’s Research Department or third-party investment advisor(s). Minimum account values vary based on money manager and strategy, starting at $50,000. Each manager may set a minimum account size above the Platform minimum. Clients should note that an account will not be invested until the applicable minimum for the investment strategy of the model portfolio or model advisor has been reached. Clients should consult with their investment adviser representative to obtain more information about the applicable investment minimum based on the strategy selected. Gladstone is unaffiliated with LPL and any third-party portfolio management firms utilized under the MAS program. Clients should refer to their account application package and applicable third- party portfolio manager firm brochure for specific information on fees imposed which are separate from and in addition to the fees the client pays to us. 3. Model Wealth Portfolios Model Wealth Portfolios (“MWP”) is an LPL sponsored wrap fee program that offers clients professionally managed asset allocation models designed by LPL or other third-party investment advisor firms. The investment adviser representative assists the client to determine the client’s financial circumstances, including investment objectives and risk/return preferences, and to identify any investment restrictions on the management of the account. The investment adviser representative exercises discretion with respect to one or more model portfolio of securities in connection with providing investment advice. Portfolios are designed by LPL’s Research Department or a third-party investment strategist consistent with the client’s stated investment objectives. MWP portfolios typically contain mutual funds, ETPs, closed-end funds, or equities, but may contain other securities. The investment adviser representative provides ongoing advice on the selection or replacement of a portfolio based on the client’s individual needs. The investment adviser representative may choose more than one portfolio strategy to be managed within a single MWP account. The investment strategist is responsible for selecting the securities within a portfolio and for making changes to the securities selected. LPL has discretion to buy and sell securities in the account according to the Portfolio selected and liquidate previously purchased securities that are transferred into the account. LPL acts as the overlay manager in coordinating the trades in the account. LPL tracks the portfolios, applying discretion only to address particular account issues, including tax rebalancing, loss harvesting, customized requests, and investment restrictions put on the account. MWP requires a minimum asset value for an account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum portfolio is $10,000. In certain instances, a lower minimum for a portfolio will be permitted. An account will not be invested until the applicable minimum for the portfolio(s) and allocation has been reached. Clients should consult with their investment adviser representative to obtain more information about the applicable investment minimum based on the portfolio(s) selected and the allocation amongst portfolios. LPL acts as custodian to MWP accounts, provides brokerage and execution services as the broker on transactions, and performs administrative services, such as quarterly performance reporting to clients. Gladstone is unaffiliated with LPL and any third-party portfolio management firms utilized under MWP. Clients should refer to their account application package and applicable third-party portfolio manager firm brochure for specific information on fees imposed which are separate from and in addition to the fees the client pays to us. 4. Optimum Market Portfolios Optimum Market Portfolios (“OMP”) is an LPL sponsored mutual fund asset allocation wrap program that utilizes Optimum Fund Class I shares. Under the OMP program, the client authorizes LPL, as third-party portfolio manager, to purchase and sell Optimum Funds on a discretionary basis pursuant to investment objectives chosen by the client. The investment adviser representative will assist the client in determining the suitability of the OMP program for the client and assist the client in setting an appropriate investment objective based on the client’s financial circumstances. The investment adviser representative shall also exercise discretion with respect to selecting a model portfolio of mutual funds designed by LPL’s Research Department in connection with providing investment advice. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client and have the authority to rebalance the account. A minimum account value of $1,000 is required for the OMP program. Accounts below $10,000 are required to have systematic contributions in place. LPL acts as custodian to OMP accounts, provides brokerage and execution services, and performs administrative services, such as quarterly performance reporting to clients. Gladstone is unaffiliated with LPL and Optimum Funds. Clients should refer to their account application package and applicable third-party portfolio manager firm brochure for specific information on fees imposed which are separate from and in addition to the fees the client pays to us. 5. Guided Wealth Portfolios Guided Wealth Portfolios (“GWP”) is an LPL sponsored advisor-enhanced digital advice wrap program that offers clients the ability to participate in a centrally managed investment program, which is made available to users and clients through LPL Account View, a web-based, interactive account management portal. The program utilizes investment recommendations based upon the model portfolios constructed by LPL strategists and selected for the account. Communications concerning GWP are automatically generated and occur primarily through electronic means including, but not limited to, email or through the Account View platform. Your investment adviser representative is also available to discuss investment strategies, objectives, or the account in general in person or via telephone. A preview of GWP is provided to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL and Gladstone. Based on the user’s profile, the education tool (aka “proposal tool”) generates sample asset allocation recommendations to assist users in determining whether to utilize the advisory service. The education tool and the advisory service are described in more detail in the GWP brochure. Users of the education tool are not considered clients of Gladstone or LPL, do not enter into an advisory agreement with Gladstone or LPL, do not receive ongoing investment advice or supervision of their assets, and do not receive any trading services. Clients who decide to participate in advisory services complete an account application and enter into an agreement with Gladstone and LPL. As part of the account opening process, clients are responsible for providing complete and accurate information regarding, among other things, their age, risk tolerance, and investment time horizon. Based on the information provided, Gladstone determines the suitability of the program for clients and LPL determines an appropriate investment allocation and model portfolio. Model portfolios are designed and managed by LPL and typically include tactical holdings in ETPs and open-end mutual funds. Only a single model portfolio is permitted per account. By executing the account agreement, client authorizes LPL to have discretion to buy and sell securities in accordance with the model portfolio and to liquidate previously purchased non-model holdings transferred into the accounts. A minimum account value of $5,000 is required for the GWP program. In certain instances, a lower minimum for the GWP may be permitted. LPL acts as custodian to GWP accounts, provides brokerage and execution services, and performs administrative services, such as quarterly performance reporting to clients. Gladstone is unaffiliated with LPL. Clients should refer to their account application package and applicable third-party portfolio manager firm brochure for specific information on fees imposed which are separate from and in addition to the fees the client pays to us. 6. Charles Schwab Institutional Charles Schwab Institutional is a Gladstone sponsored wrap fee program where the investment adviser representative tailors advisory services to the individual needs of the client’s account custodied at Charles Schwab & Co., Inc. (“Schwab”), an unaffiliated SEC-registered broker dealer and FINRA/SIPC member, where Schwab provides clearing, custody, or other brokerage services. Clients can elect to have a discretionary or non-discretionary advisory account. A discretionary account is an account that gives the investment adviser representative the authority to make individual trade without the consent of the client. A non-discretionary account is an account where the client ultimately decides whether or not to make a trade. Depending on the investment strategy, securities used in the Charles Schwab Institutional program include equities, fixed income securities, mutual funds, ETPs, and alternative investments, but can include other securities and products available on the platform. If structured products, alternative investments, or annuities are utilized as part of the investment strategy, the assets will be reported on Schwab’s account statements, but the actual securities are typically held with and valued by the specific issuer. investment adviser representatives provide investment management services tailored to the individual needs of the client based on the investment objectives chosen by the client. There is no minimum account size in the Charles Schwab Institutional program. Clients can impose restrictions on investing in certain securities or groups of securities in the Investment Management Agreement or by notifying the investment adviser representative in writing. Given the long-term nature of many of the individual strategies employed in the program, an account may have little or no trading activity during a given period. Clients should be aware that Gladstone shares confidential client information with LPL including personally identifiable information including financial information, transactions and holdings for accounts established through the Charles Schwab Institutional program for associated persons of LPL, even if the client does not establish an account through LPL. Schwab is not affiliated with Gladstone. Clients should refer to Schwab’s pricing guide/fee schedule for specific information regarding services that have associated fees which are separate from and in addition to the fees the client pays us. 7. Fidelity Institutional Wealth Services Fidelity Institutional Wealth Services (“Fidelity IWS”) is a Gladstone sponsored wrap fee program where the investment adviser representative tailors advisory services to the individual needs of the client’s account custodied at Fidelity Investments (“Fidelity”), where Fidelity provides clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services, LLC, members FINRA, SIPC. Clients can elect to have a discretionary or non-discretionary advisory account. A discretionary account is an account that gives the investment adviser representative the authority to make individual trade without the consent of the client. A non-discretionary account is an account where the client ultimately decides whether or not to make a trade. Depending on the investment strategy, securities used in Fidelity IWS include equities, fixed income securities, mutual funds, ETPs, and alternative investments, but can include other securities and products available on the platform. If structured products, alternative investments, or annuities are utilized as part of the investment strategy, the assets will be reported on Fidelity’s account statements, but the actual securities are typically held with and valued by the specific issuer. In the Fidelity IWS program, investment adviser representatives provide investment management services tailored to the individual needs of the client based on the investment objectives chosen by the client. There is no minimum account size in the Fidelity IWS program. Clients can impose restrictions on investing in certain securities or groups of securities in the Investment Management Agreement or by notifying the investment adviser representative in writing. Given the long-term nature of many of the individual strategies employed in the program, an account may have little or no trading activity during a given period. Clients should be aware that Gladstone shares confidential client information with LPL including personally identifiable information including financial information, transactions and holdings for accounts established through the Fidelity IWS program for associated persons of LPL, even if the client does not establish an account through LPL. Fidelity is not affiliated with Gladstone. Clients should refer to Fidelity’s pricing guide/fee schedule for specific information regarding services that have associated fees which are separate from and in addition to the fees the client pays us. 8. Gladstone Capital Management The Gladstone Capital Management program (“GCM”) is a Gladstone sponsored wrap fee program that provides the client with access to the Investment Strategies of Kessler Investment Group, LLC (“KIG”), an independent manager and professional third-party portfolio management firm for the individual management of the client’s account.1 The investment adviser representative will assist client in selecting an appropriate Investment Strategy from a list of strategies made available by KIG. KIG, as a third-party portfolio manager, will manage client assets on a discretionary basis. The investment adviser representative will provide initial and ongoing assistance regarding investment strategy selection process and serves as the point of contact between the client and KIG regarding changes to the client’s investment objective, financial circumstances, and investment restrictions (if any). Typically, equities, fixed income securities, mutual funds, and ETPs are utilized to execute the investment strategies, but other securities may be used. Clients have the ability impose restrictions on investing in certain securities or groups of securities by indicating preferences in the Agreement. A separate account will be established for each investment strategy selected and each account will be managed independently of any other accounts of the client. When utilizing the GCM program, clients can select

Schwab or Fidelity to serve as custodian and executing broker for assets in the account. Minimum account values range from $10,000 to $100,000 depending on the investment strategy selected; however, in certain instances, the minimum account value may be lower or higher. Clients should refer to their account application package and KIG brochure for specific information on fees imposed by third parties which are separate from and in addition to the fees the client pays to us. 9. Third Party Asset Management Programs Gladstone makes available to investment adviser representatives and their clients Third Party Asset Management Programs (“TAMPS”) which provide access to professional third-party portfolio managers on the Schwab and Fidelity platforms. TAMP sponsors offer access to a variety of model portfolios with varying levels of risk from which to choose. TAMP program accounts are managed by one or more third-party portfolio managers on a discretionary basis, and they may consist of a variety of different security types, including stocks, bonds, mutual funds, ETPs and derivatives. In most instances, the third-party portfolio manager will require a minimum account value for an account to be managed. Minimum account values typically range from $10,000 to $100,000 but can be more or less depending on the portfolio manager and/or model strategy selected. Gladstone is not the sponsor of TAMP programs. Gladstone may act in a “sub-adviser” or “promoter” capacity to accounts under the TAMP program. a) Sub-adviser: Under an adviser or sub-adviser relationship between us and the sponsor of 1 Additional information about Kessler Investment Group, LLC (CRD#: 11536696/ SEC#: 8001-71393) is available on the SEC Investor Website at www.adviserinfo.sec.gov. the TAMP program, your Gladstone investment adviser representative provides you with continuous and regular supervisory or management services with respect to your account along with the third-party portfolio manager. This means that your Gladstone investment adviser representative will obtain financial information from you to determine your investment objectives and risk tolerance and is responsible for the selection and retention of the third-party portfolio manager. Clients can select either Charles Schwab & Co. or Fidelity Institutional as broker/custodian for accounts in the TAMP program. Gladstone is unaffiliated with TAMP sponsors, broker/custodians, and third-party portfolio managers utilized under the TAMP program. b) Promoter: When acting as a promoter, your Gladstone investment adviser representative provides asset monitoring services only and does not provide you with continuous and regular supervisory or management services. As part of these services, your Gladstone investment adviser representative provides an endorsement by referring you to one or more suitable third-party investment advisers based on your investment objectives and risk tolerance and subject to compliance with applicable requirements under the SEC’s investment adviser marketing rule (Advisers Act Rule 206(4)-1).See “Item 14. Client Referrals and Other Compensation” for more information on TAMP programs where your Gladstone investment adviser representative acts as a promoter. Asset Management Fees Gladstone is a fee only advisory firm, meaning we do not receive commissions, marketing and distribution fees, or other compensation from the investments and services we recommend. By refusing compensation other than client fees, we are better able to provide you with unbiased financial advice. Our fee for asset management is assessed at an annual percentage fee of up to 2.00% of assets under management. Fees are assessed on all asset types, including securities, cash, and cash equivalents. Fees are paid quarterly in advance and are negotiable and are established in writing in our Investment Management Agreement or broker/custodian agreement with you prior to our working together. The fee that you negotiate with your investment adviser representative may be more or less than the fees charged by other investment adviser representatives or consultants at Gladstone or other firms for similar services. Investment adviser representatives take various factors into consideration when establishing their fee including, but not limited to, the complexity of the engagement, market value of assets, the level and scope of the overall asset management and/or consulting services to be rendered, and other objective and subjective factors. Investment adviser representatives have a conflict of interest in establishing their fee in that the higher the fee is to you, the more profitable their business is. You should understand that your asset management fee is a wrap fee that may be higher than a comparative broker-dealer per transaction commission cost during periods of low or no trading activity. Fees for asset management services can be structured utilizing a flat asset-based fee or on tiered fee basis, with a reduced percentage rate based on the account reaching certain thresholds. In most instances investment adviser representatives receive a portion of the fee paid to Gladstone for their services. You have the option to purchase investment products that we recommend through other unaffiliated brokers or agents. By signing our Investment Management Agreement, you authorize us to deduct fees quarterly and in advance from your account. We will have no other authority to deduct monies from your account, except to request the custodian disburse funds directly to you or your agents upon your specific written instructions. Either you or we may terminate the client agreement at any time. In the event of termination, you are responsible for monitoring the securities in your account, and we as the investment adviser will have no further obligation to act or advise with respect to that account. If the agreement is terminated prior to the last day of the calendar quarter, a prorated portion of the fee previously paid for that quarter based on the number of calendar days remaining will be refunded to you or your account. Since Gladstone began providing these services, it has had other fee structures in effect, which may have been lower or higher or different than that described above. As new fee structures are put into effect, they are generally made applicable only to new clients, and fees to existing clients are generally not affected. Other Fees and Expenses You Pay in Connection with Asset Management Gladstone offers wrap program options to its advisory clients. In most circumstances, our broker/custodians do not charge separately for custody, trade execution, clearance, and settlement of transactions but are compensated by charging Gladstone an asset-based fee (see “Item 12 – Brokerage Practices” for more information on “Asset-Based Pricing”). Each of our broker/custodian’s asset-based fee arrangements are independently negotiated and are based on the condition that the Firm collectively maintains a minimum dollar amount of assets at the broker/custodian. Certain types of accounts, such as Personal Choice Retirement Accounts (PCRA),Retirement Plan Services (RPS), Stock Plan Services (SPS), Health Savings Brokerage Accounts (HSBA), and Managed Account Services, as well as asset types, such as unit investment trusts (UITs), American depository receipts (ADRs), alternative investments (AI), and other non-standard assets are exempt from asset-based pricing and subject to separate custody and/or commission charges by the broker/custodian that the client is responsible for paying. The broker/custodian does not share commission or ticket charges with Gladstone or its investment adviser representatives. Clients should also be aware that they are responsible for paying all other applicable transaction costs, custodian fees, mutual fund expenses, brokerage commissions, third-party manager fees, administrative fees, and other miscellaneous fees, charges, or expenses associated with their account. This includes, but is not limited to, charges imposed directly by a mutual fund, index fund, or exchange traded product, administrative fees and expenses, commissions, ticket charges, third-party manager advisory fees, algorithm-driven advisory fees, transaction fees for trades executed away from the prime broker (i.e., “step- out trades”), mark-ups, mark-downs, spreads paid to market makers, international settlement charges, foreign currency exchange transaction fees, international dividend/reorganization fees, access fund fees, M&E&A charges, retirement account fees, wire and electronic fund transfer fees, overnight check fees, overnight carrier fees, margin account balance fees, interest charges, account termination fees, retirement account closeout fees, rollover expenses, and any and all other administrative, account maintenance, cash management services, investment-specific, and miscellaneous fees and charges associated with your account. The list below does not include a description of every potential additional fee or expense applicable to client accounts; rather, this is a general description of the most common fees inherent to the types of accounts and transactions we offer. As noted throughout this brochure, clients should refer to applicable account opening documents, broker/custodian fee schedules, prospectuses, third-party portfolio manager brochures, and any other disclosure documents for specific details regarding applicable fees and expenses in connection with your account, product, transaction type, or third-party manager. Mutual Fund Share Class Fees Gladstone has available for purchase through its broker/custodian platforms, mutual funds which are no-load or load-waived share classes. Most mutual fund share classes charge marketing and distribution fees (i.e., 12b-1 fees) which are paid to the broker/custodian and not directly or indirectly paid to Gladstone or its investment adviser representatives. 12b-1 fees are not credited back to client accounts. Clients should also be aware that advisory assets may be held in a mutual fund share class that charges higher 12-b1 fee when a lower-cost share class is available on the broker/custodian’s platform for the same fund. While Gladstone endeavors to use the lowest-cost share class available and periodically reviews its fund holdings to convert higher cost shares to lower cost shares in accordance with its duty of best execution, the Firm cannot ensure that all clients will hold the lowest cost shares available on the broker/custodian’s platform at any given time. Further, some third-party money managers and algorithm-driven strategists are more careful about utilizing the lowest cost share class than others. In many cases, a particular broker/custodian’s platform will not make available the least expensive share class that the mutual fund company offers. Share classes are selected by broker/custodians to be available on their platforms in most cases because the share class pays the broker-dealer compensation for the administrative and record keeping services the broker-dealer provides to the mutual fund. Gladstone is not paid revenue sharing compensation paid by mutual fund distributors to broker-dealers for these services. If a client transfers into an investment advisory account a previously purchased mutual fund and there is an applicable contingent deferred sales charge (“CDSC”) on the fund, client will pay that charge when the mutual fund is sold. If the account is invested in a mutual fund that charges a fee if a redemption is made within a specific time period after the investment, the client will be charged a redemption fee. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund. Many funds available in Gladstone’s advisory programs may be purchased by clients directly from the fund company. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of Gladstone and by making their own decisions regarding the investment. Gladstone encourages all clients to closely review the investment’s prospectus or offering documents for all such investments with their investment adviser representative and to consider aggregate costs. Clients should contact their investment adviser representative with any questions about any particular product’s fees and expenses. Exchange Traded Product Fees Exchange traded products (ETPs) have internal operational expenses and fees that vary considerably. Operational expenses are typically deducted from the fund assets and investors do not pay fees directly to a fund manager. Since ETPs are traded on an exchange like stocks, they may also be subject to brokerage fees. Third-Party Managers Fees Clients with assets in third-party portfolio manager programs are subject to a portfolio manager fee and platform fee. These fees typically range from 15 to 100 basis points (“bps”) of account assets per year but can be higher or lower. These fees are separate and in addition to the advisory fee you pay us. Under the GCM program clients do not pay a separate portfolio manager or platform fees. Investment adviser representatives typically pay Gladstone a minimum asset-based fee of 15 bps of the investment adviser representative’s total assets under management in the GCM program for access to the Investment Strategies, technology, and professional asset management services offered by KIG. This type of fee arrangement presents a conflict in that the Financial Advisor has an incentive to charge clients a higher advisory fee to offset expenses incurred when utilizing the GCM program. Step-Out Trades Broker/custodians will charge you a flat dollar amount or commission as a “prime broker” or “step-out” fee for each trade that is executed by a different broker-dealer but where the securities bought or the funds from the securities sold are settled into your account. These fees are in addition to the asset management fees you pay us. Gladstone’s investment adviser representatives do not “step out” trades; however, some of the professional third-party portfolio managers do step out trades at the portfolio manager’s discretion, subject to their best execution obligations. Step- out trading practices differ from Manager to Manager. Some third-party Managers do not engage in step-out trading while others do. Clients should review the firm brochure for the any third- party portfolio manager selected prior to investing for more information regarding their step-out trade practices including additional costs that will be incurred by the client. Insurance Product Fees Insurance companies impose internal fees and expenses including, but not limited to, policy fees, contingent deferred sales charges, early redemption fees, fees for guaranteed income riders, underlying investment fees, and mortality, expense, and administration charges (M&E&A charges.) Other riders or annuity expenses may apply. These fees are in addition to the management fees you pay us. Complete details of annuity internal expenses are specified and disclosed in each insurance company’s prospectus. Margin Loans and Collateralized Lending If you enter into a margin loan, the broker/custodian will receive interest charged on your outstanding margin loan balance. The amount of interest paid to the broker/custodian will vary depending on the outstanding loan balance and other factors that will affect the interest rate charged to you for the margin loan. We encourage clients to read their particular broker dealer’s Margin Interest Rate Disclosure for more information regarding applicable charges on debit and credit balances. With collateralized lending, in most instances the broker/custodian will be compensated by receiving payments from the lender based on the amount of your outstanding loan balance. The total amount of compensation received by the broker/custodian can vary depending on the terms of the agreement including the interest rate charged to you by the lender. Gladstone is not affiliated with any lender or broker /custodian and does not receive compensation directly in connection with a margin loan or pledged asset line of credit. Clients are strongly encouraged to review the lender's agreements and disclosure documents to understand the fees and expenses they are paying. Your investment adviser representative has an incentive to recommend that you use a margin loan and/or pledged asset line of credit for liquidity purposes rather than liquidating your holdings or using other sources of liquidity. Your investment adviser representative will benefit from your margin loan or collateralized loan because you do not have to liquidate assets in your account to pay for things with cash, which would diminish the assets held in the account and the potential fees that could be earned by your investment adviser representative from holding or engaging in future transactions with those assets. IRA and Qualified Retirement Plan Fees and Rollover Expenses There are additional fees relating to IRA and qualified retirement plan accounts that you normally incur such as annual maintenance fees, fees for loans processed, and retirement account closeout fees. These fees are in addition to underlying investment fees and the management fees you pay us. Other fees may apply. You will find these fees disclosed in the broker/custodian’s account application paperwork provided to you associated with these accounts. Investors may face increased fees and expenses when they rollover assets from an employer- sponsored retirement plan, transfer an IRA to an IRA, or convert to a Roth IRA managed by Gladstone. Investors should be aware that even if there are no costs associated with the rollover or transfer itself, there will be costs associated with account administration and investment management. In addition to the management fees charged by Gladstone or another adviser, some underlying investment products charge additional internal fees and expenses. Custodial and transaction fees may also apply. Withdrawal options, required minimum distributions, tax treatment (particularly with reference to employer stock) may differ. We do not receive payments in the form of commissions, 12b-1 fees, sales loads, revenue sharing payments, or mark ups or mark downs in exchange for rendering fiduciary investment advice. You should also be aware that your investment adviser representative has a financial incentive to rollover your account or plan because the investment adviser representative will be paid on those assets. If you are considering rolling over assets from an existing employer-sponsored retirement plan, you should understand that Gladstone’s investment adviser representatives will provide you with general education regarding the pros and cons of available options to transfer or rollover tax qualified assets and will not recommend one option over the other. Your decision to rollover assets from an employer-sponsored retirement plan should be based on your individual financial circumstances, needs and goals and understanding of the options available to you including: (i) remaining invested in the plan; (ii) rolling over plan assets to a plan of a new employer (if applicable); (iii) rolling over assets to an IRA with a financial institution; or (iv) receiving a cash distribution (which may be fully taxable). If you decide to rollover assets from an employer-sponsored plan into an IRA account, assets will no longer be subject to protections of ERISA or different types of protection from creditors and legal judgments. We strongly encourage you to consult an independent tax or legal advisor prior to rolling over qualified plan assets. Securities held in a retirement plan can often not be transferred into an IRA and commissions and sales charges are typically charged by the plan’s broker when liquidating such securities in the plan prior to the transfer of assets. These fees are in addition to commissions and sales charges previously paid on transactions in the plan. You should understand that you are making an independent decision regarding your rollover options, including any decision to roll out of your current employer-sponsored plan. Your investment adviser representative will speak with you regarding the pros and cons of available rollover options as detailed in the IRA Adoption Application and other applicable disclosures in the account application packet. Investment adviser representatives will not provide you with advisory services in connection with a rollover of employer-sponsored plan assets prior to you making an independent decision to roll assets into an account with us. Cash Sweep Arrangement Fees Gladstone makes available through unaffiliated broker/custodians for cash in an account to be automatically swept to an interest-bearing Federal Deposit Insurance Corporation (FDIC) insured deposit account and, for certain types of accounts, a money market fund. We do not receive a separate fee or compensation for cash sweep arrangements. Clients should understand that interest rates available in these arrangements may be lower than interest rates available if the client makes deposits directly with a bank or other depository institution outside of these arrangements or invests in a money market fund or other cash equivalent. Clients should compare terms, interest rates, required minimum amounts and other features of these arrangements with other types of accounts and investments for cash. Account Termination Fees Fees to terminate an account are a one-time fee charged to an account holder if he/she terminates or transfers an account. The termination fee is levied and retained by the financial institution that custodies the client’s assets. Termination fees are spelled out in the client agreement with the broker/custodian that is entered into when the account is opened. Calculation of Asset Management Fees LPL deducts the asset management fee and other fees and charges associated from the account. LPL calculates and deducts the asset management fee in the method described in LPL’s account agreement, unless other arrangements are made in writing. If a client wishes to be billed for the asset management fee, rather than a deduction directly from the account, the client needs to make a request to LPL through their investment adviser representative. LPL deducts the account fee quarterly in advance. If the account agreement is terminated before the end of the quarterly period, LPL will pay the client a prorated refund of any pre-paid quarterly asset management fee based on the number of days remaining in the quarter after the termination date. However, if the account is closed within the first six months by the client or as a result of withdrawals that bring the account value below the required minimum, LPL reserves the right to retain the pre-paid quarterly asset management fee for the current quarter in order to cover the administrative costs of establishing the account. Payment of fees may result in the liquidation of a client’s securities if there is insufficient cash in the account. Clients receive an account statement from LPL at least quarterly. The statement includes the amount of any fees debited or credited from the client’s’ account pursuant to written authorization. As a courtesy and upon client written request, LPL permits “Group Fee” arrangements for certain eligible investment advisory accounts for “Approved Family Members”. These arrangements allow a group of related accounts to each be billed (i) a flat advisory fee, or (ii) a blended Account Fee based on a tiered schedule of fees, based on the aggregation of account asset values of a group. For accounts in the Charles Schwab Institutional or Fidelity Institutional Service programs, fees are due and payable in advance and are based upon the ending account values as of the close of business on the last day of the previous calendar quarter. Fees are calculated by Gladstone and deducted from the account by the qualified custodian. Fees for the initial quarter are adjusted pro rata based upon the number of calendar days in the quarter that the Investment Advisory Agreement goes into effect. If assets are deposited into or withdrawn from an account after inception of a billing period in an amount equal to or greater than $5,000, the fee payable with respect to such assets is prorated to reflect the change in portfolio value. Payment of fees may result in the liquidation of a client’s securities if there is insufficient cash in the account. The advisory relationship may be terminated by the client or by us at any time on thirty (30) days prior written notice. The client receives a pro rata refund of any pre-paid unearned advisory fees based on the number of days remaining in the quarter after the termination date. Clients receive an account statement from the qualified custodian at least quarterly. The statement includes the amount of any fees debited or credited from the client’s account pursuant to written authorization. For TAMPs where Gladstone is operating as advisor or sub-adviser, fees are due and payable in advance and are based upon the ending account values as of the close of business on the last day of the previous calendar quarter. The sponsor and portfolio manager fees are calculated by Adviser’s Agent and the Adviser’s fee is calculated by Gladstone and deducted from the managed account by the qualified custodian. Fees for the initial quarter are adjusted pro rata based upon the number of calendar days in the quarter that the Investment Advisory Agreement goes into effect. If assets are deposited into or withdrawn from an account after inception of a billing period in an amount equal to or greater than $5,000, the fee payable with respect to such assets is prorated to reflect the change in portfolio value. Payment of fees may result in the liquidation of a client’s securities if there is insufficient cash in the account. The advisory relationship may be terminated by the client or by us at any time on thirty (30) days prior written notice. The client receives a pro rata refund of any pre-paid unearned advisory fees based on the number of days remaining in the quarter after the termination date. Clients receive an account statement from their qualified custodian at least quarterly. The statement includes the amount of any fees debited or credited from the client’s account pursuant to written authorization. For all programs, Gladstone’s process to value client holdings and assess fees based on those valuations are based on the market value assessed by the qualified custodians of the assets. Gladstone neither participates in the valuation nor adjusts those valuations. Cash balances, such as money market funds, are considered an asset class and are included in client’s asset-based fee calculation. If an account is closed withing the first six months by the client or as a result of withdrawals that bring the account value below the required minimum, we reserve the right to retain the pre-paid quarterly account fee for the current quarter in order to cover the administrative costs of establishing the account. Unless stated otherwise in the applicable agreement, Gladstone Wealth Partners or the client may terminate the agreement for portfolio management services for any reason within thirty (30) days’ written notice to the other party. The date of receipt of the written notice will be the effective date of termination. Upon termination of advisory services, we, the broker/custodian, or the sub-adviser will determine the amount of any outstanding fees due to/from the client. Transactions in progress will be completed in the normal course of business. Please refer to your sub-adviser’s disclosure documents for their termination policies. Performance-Based Fees and Side-by-Side Management Performance-Based Fees Performance-based fees are based on a share of the capital gains or capital appreciation of the assets of a client. Our fees are calculated as described in Item 5 below. Side-By-Side Management Side-by-side management typically refers to a situation in which the same adviser manages accounts that are billed based only on a percentage of assets under management and at the same time manages other accounts for which fees are performance-based, which can give rise to certain conflicts of interest. Gladstone Wealth Partners does not provide side-by-side management.