Established in 2014 by David Clayman, Francesca Federico and Emanuel Frangiadakis, Twelve Points Wealth Management LLC (“Twelve Points Wealth”) provides investment advisory services to clients on a discretionary and non-discretionary basis. Twelve Points Wealth provides discretionary investment advisory services on a fee basis per the fee schedule set forth at Item 5 below. Twelve Points Wealth’s annual investment advisory fee shall generally (with exceptions-see below) include investment advisory services, and, to the extent specifically requested by a retail client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Twelve Points Wealth), Twelve Points Wealth may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. To commence the investment advisory process, Twelve Points Wealth will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, Twelve Points Wealth provides ongoing supervision of the account(s). Before engaging Twelve Points Wealth to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Twelve Points Wealth setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, Twelve Points Wealth will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. Twelve Points Wealth will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, stand-alone planning engagements, etc. for which Firm may charge a separate or additional fee). Please Note. Twelve Points Wealth believes that it is important for the client to address financial planning issues on an ongoing basis. Twelve Points Wealth’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Twelve Points Wealth. Please Also Note: Twelve Points Wealth does not serve as an attorney or accountant and no portion of our services should be construed as same. Accordingly, Twelve Points Wealth does not prepare legal documents or prepare tax returns. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.) including a Twelve Points representative in his/her separate individual capacity as a licensed insurance agent-see Item 10 below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Twelve Points Wealth and/or its representatives. Please Note: If the client engages any Form ADV Part 2A/2B: Investment Adviser Brochure and Brochure Supplements Page 5 recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged unaffiliated licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Twelve Points Wealth, shall be responsible for the quality and competency of the services provided. Please Also Note-Conflict of Interest: The recommendation by a Twelve Points Wealth representative that a client purchase an insurance product presents a conflict of interest, as the receipt of an insurance commission may provide an incentive to recommend insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any insurance commission products from a Twelve Points Wealth representative. Clients can purchase insurance products recommended by a Twelve Points Wealth representative through other, non-affiliated insurance agents. ANY QUESTIONS: Twelve Points Wealth’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. Stand-Alone Planning Engagements. Twelve Points Wealth can be engaged to provide financial planning services per the terms and conditions of a separate agreement and a separate fee as discussed at Item 5 above, the fee for which shall be based upon the individual providing the service and the scope of the services to be provided. Prior to engaging Twelve Points Wealth to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Twelve Points Wealth setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Twelve Points Wealth commencing services. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Twelve Points recommends that a client roll over their retirement plan assets into an account to be managed by Twelve Points, such a recommendation creates a conflict of interest if Twelve Points will earn new (or increase its current) compensation as a result of the rollover. If Twelve Points provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Twelve Points is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Twelve Points, whether it is from an employer’s plan or an existing IRA. Twelve Points’ Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have Form ADV Part 2A/2B: Investment Adviser Brochure and Brochure Supplements Page 6 regarding the potential for conflict of interest presented by such rollover recommendation. Portfolio Activity. Twelve Points Wealth has a fiduciary duty to provide services consistent with the client’s best interest. Twelve Points Wealth will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Twelve Points Wealth determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Interval Funds/Risks and Limitations: Where appropriate, Twelve Points Wealth may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short- term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct Twelve Points Wealth, in writing, not to employ any or all such strategies for the client’s account. Please Note: Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors

must accept these Form ADV Part 2A/2B: Investment Adviser Brochure and Brochure Supplements Page 7 limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by the Twelve Points Wealth), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Please Note-Use of Mutual and Exchange Traded Funds: Twelve Points Wealth utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Twelve Points Wealth’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Unaffiliated Private Investment Funds. Twelve Points Wealth also provides investment advice regarding private investment funds. Twelve Points Wealth, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. Twelve Points Wealth’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Twelve Points Wealth calculating its investment advisory fee. Twelve Points Wealth’s fee shall be in addition to the fund’s fees. Twelve Points Wealth’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, 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/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that Twelve Points Wealth references private investment funds owned by the client on any supplemental account reports prepared by Twelve Points Wealth, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect Form ADV Part 2A/2B: Investment Adviser Brochure and Brochure Supplements Page 8 that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, the Twelve Points Wealth shall calculate its fee based upon the latest value provided by the fund sponsor. Wrap Program-Conflict of Interest. Except for participant directed retirement plan engagements referenced below, Twelve Points Wealth provides services on a wrap fee basis as a wrap program sponsor. Under Twelve Points Wealth’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in Twelve Points Wealth’s Wrap Fee Program Brochure. Conflict of Interest. Because wrap program transaction fees and/or commissions are being paid by Twelve Points Wealth to the account custodian/broker-dealer, Twelve Points Wealth could have an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client’s account. See separate Wrap Fee Program Brochure. Twelve Points Wealth’s Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective client may have regarding a wrap fee arrangement and the corresponding conflict of interest. Please Note: Cash Positions. Twelve Points continues to treat cash as an asset class. As such, unless determined to the contrary by Twelve Points, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Twelve Points’ advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Twelve Points may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Twelve Points’ advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Twelve Points’ Chief Compliance Officer, Kimberly Van Winkle, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Use of Participant Account Management Platform (Pontera). Twelve Points uses a third party platform, Pontera, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. Through Pontera, we do not have custody of Client funds since we do not have direct access to Client login credentials to affect trades. We are not affiliated with Pontera in any way and receive no compensation from Pontera for using the platform. A link will be provided to the Client allowing them to connect one or more accounts to the platform. Once Client accounts are connected to the platform, Twelve Points will review the current account allocations. When deemed Form ADV Part 2A/2B: Investment Adviser Brochure and Brochure Supplements Page 9 necessary, Twelve Points will rebalance the account considering client investment goals, risk tolerance, and investment profile, and any change in allocations will consider current economic and market trends. Twelve Points aims to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client accounts will be reviewed at least quarterly and allocation changes will be made as deemed necessary by Twelve Points in its discretion. ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
• Trustee Directed Plans. Twelve Points Wealth may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Twelve Points Wealth will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Twelve Points Wealth will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. Participant Directed Retirement Plans. Twelve Points Wealth may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between Twelve Points Wealth and the plan. For such engagements, Twelve Points Wealth shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by Twelve Points Wealth), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Client Retirement Plan Assets. If requested to do so, Twelve Points Wealth shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, Twelve Points Wealth shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Twelve Points Wealth’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. Twelve Points Wealth will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Twelve Points Wealth of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by Twelve Points to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of Twelve Points calculating its advisory fee. Twelve Points does not maintain possession of client retirement account passwords. Form ADV Part 2A/2B: Investment Adviser Brochure and Brochure Supplements Page 10 Client Obligations. In performing our services, Twelve Points Wealth shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Twelve Points Wealth if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Twelve Points Wealth) will be profitable or equal any specific performance level(s). Twelve Points Wealth managed $1,190,090,467 on a discretionary basis and $20,693,511 on a non-discretionary basis for a total of $1,210,783,978 of assets under management as of December 31, 2023.