Apeiron RIA LLC dba Apeiron RIA “ARIA” is a Registered Investment Adviser (“Adviser”) which offers this wrap fee program for its advisory clients. We are registered through and regulated by the United States Securities and Exchange Commission (“SEC”). ARIA was founded in 2011, and the current owners are JMARS Financial, LLC who is owned by James Marsden and The Hammel Group, Inc who is owned by Scott Hammel, James Marsden also serves as the firm’s Chief Compliance Officer. We offer portfolio management services to individuals, high net worth individuals, trusts, estates, corporate pension and profit‐sharing plans, charitable organizations, foundations, endowments, corporations, small businesses, churches, and other institutional clients. Investment advice is provided by Investment Adviser Representatives (“IAR”) associated with the firm. These individuals are required to be appropriately licensed, qualified, and authorized to provide advisory services while associated with the firm. Factors Used to Select Custodians Schwab’s Brokerage Services In addition to the advisory services, the wrap fee program includes certain brokerage services of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC. We are independently owned and operated and not affiliated with Schwab. Schwab will act solely as a broker-dealer and not as an investment advisor to you. It will have no discretion over your account and will act solely on instructions it receives from us [or you]. Schwab has no responsibility for our services and undertakes no duty to you to monitor our firm’s management of your account or other services we provide to you. Schwab will hold your assets in a brokerage account and buy and sell securities and execute other transactions when we [or you] instruct them to. We do not open the account for you. In recommending a custodian/broker‐dealer, we look for a company that offers relatively low transaction fees, access to desired securities, trading platforms, and support services. We will recommend either the custodian SEI Private Trust Co., and Charles Schwab & Co., Inc. Advisor Services, as the firm to custody client assets although this may change over time. Charles Schwab & Co., Inc. Advisor Services provides us with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset- based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Apeiron RIA ADV Part 2A Appendix 1 Page 5 of 16 Charles Schwab & Co., Inc. Advisor Services also makes available to us other products and services that benefit us but may not benefit its clients’ accounts. These benefits may include national, regional or our specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of us by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of our fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of our accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to us other services intended to help us manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to us by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to us. We are independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. Wrap Fee Program Disclosures The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap [or bundled] fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. Conflict of Interest. When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap [or program] fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. For example, our wrap fee arrangement creates incentives for our firm to trade less frequently or select investments that that reduce our costs, and in some Apeiron RIA ADV Part 2A Appendix 1 Page 6 of 16 cases increase expenses that are borne by the client. Additionally, Schwab generally does not charge commissions or transaction fees for online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these types of securities, we can do so without paying commissions to Schwab. We are available to discuss Schwab’s execution related pricing with you so that you can compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement.] If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. Relative Cost of Wrap Fee Program A wrap fee is not based directly on the number of transactions in your account. Various factors influence the relative cost of our wrap fee program to you, including the cost of our investment advice , custody and brokerage services if you purchased them separately, the types of investments held in your account, and the frequency, type and size of trades in your account. The program could cost you more or less than purchasing our investment advice and custody/brokerage services separately. Fees and Costs not included Our wrap fee covers our advisory services and the brokerage and execution services provided by Schwab. As a result, we have an incentive to execute transactions for your account at Schwab. Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees (such as a commission or markup) for trades executed away from [Schwab/Custodian] at another broker-dealer, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Wrap Fee Program We provide asset management services to individuals and businesses. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We currently provide our asset management services in investment programs that bundle or “wrap” services (investment advice, trade execution, custody, etc.) together and charge a single fee based on the value of assets under management. This is a program that allows us to create an investment model portfolio and manage it within your investment guidelines and financial parameters. This program enables you to pursue your investment objectives with us as manager all in one consolidated portfolio. We will assess the client’s current financial picture and construct a plan to aid in the selection of a portfolio that is tailored to and matches each client's specific situation. Assessment of a client’s financial situation can be through an interview, written assessment, or through an Investment Policy Statement – which will determine the Portfolio Management services to be provided. Portfolio Management may include, but is not limited to, investment strategy; personal

investment policy; asset allocation; asset selection; trading; risk tolerance and portfolio monitoring. The investments in the portfolio account may include mutual funds, stocks, bonds, ETFs, closed end funds, etc. We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, Apeiron RIA ADV Part 2A Appendix 1 Page 7 of 16 wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and recommend an appropriate Wrap Fee Program. You will be provided with a targeted allocation of assets by class. As part of our asset management services provided with our Wrap Fee Programs, we will: review your present financial situation; monitor and track assets under management; provide portfolio statements, asset allocation statement, rebalanced statements as needed; advise on asset selection; determine market divisions through asset allocation models; provide research and information on performance and fund management changes; build a risk management profile for you; monitor our portfolios for style drift and benchmark performance, and provide portfolio rebalancing as necessary; assist you in setting and monitoring goals and objectives; provide personal consultations as necessary upon your request or as needed. You must notify us promptly when your financial situation, goals, objectives, personal circumstances, or needs change. You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. You are responsible for any taxable events in these instances. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is not indicative of future results. We manage assets on a discretionary basis, which means you have given us the authority to determine the following without your consent: securities to be bought or sold for your account; amount of securities to be bought or sold for your account; broker‐dealer to be used for a purchase or sale of securities for your account; commission rates to be paid to a broker or dealer for your securities transaction. Trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule we have determined together. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. We also work with the tax professionals of your choice to assist you with tax planning. We will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. You will also receive our Advisory Agreement which describes what services you will receive and what fees you will be charged. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. Fees and Compensation A wrap fee program allows you to pay a specified fee for portfolio management services and the execution of transactions. The fee is not based directly upon transactions in your account. The fee is bundled with Apeiron RIA ADV Part 2A Appendix 1 Page 8 of 16 our costs for executing transactions in your account(s). Apeiron RIA does not require a minimum account balance. The fee charged by the firm is based upon the amount of money you invest, the fee rate, rate schedule, and terms are negotiated individually by IAR’s of the firm and can therefore vary by IAR based on the investment program selected, the custodian used, and other factors determined by the individual IAR. The firm makes no representation related to the competitiveness of fees among its IAR’s or compared to other firms, and clients should note that they may be able to find comparable services from other IAR’s within the firm or from other firms at a lower cost or fee. Additionally, clients should note that a conflict of interest exists in that an IAR collects additional revenue when under certain programs compared to other programs within the firm and under certain billing terms compared to those other programs offered with in the firm. For information regarding investment management services provide outside the firm’s wrap fee program, see the firm’s Part 2A Brochure. Fees for fee investment management engagements under the wrap program are calculated based on assets under management. The firm may charge a single flat rate or may charge a multi‐tiered rate which reduces for higher account balances. The maximum fee rate however is 1.95% of assets under management, and fees are negotiable. With some exceptions, multi‐tiered fee arrangements, multiple accounts of one household (i.e., at the same mailing address), held at the same custodian, will be considered one consolidated account in order to qualify for fee discounting. Clients should therefore note that a conflict of interest exists in that an IAR collects additional revenue when offering billing terms that do not consolidate accounts for purposes of fee discounting or when charging a higher fixed fee over a potentially lower tiered fee, and so an IAR has an incentive to charge fees in a manner that results in a higher fee. The following is the ARIA standard fee schedule: Total Assets Under Management Maximum Annual Fees $ 0 to $ 250,000 1.95 % $ 250,001 to $ 500,000 1.85 % $ 500,001 to $ 1,000,000 1.75 % $ 1,000,001 to $ 2,000,000 1.65 % $ 2,000,001 and up 1.55 % ARIA may bill in advance or in arrears and typically monthly. For accounts billed in advance, ARIA uses the account balance on the last business day of the month prior to billing for the market value of the assets upon which the Advisory Fees are based. If the account is closed prior to the end of the period for which it has been billed in advance, the client will receive a pro-rata refund. In some cases, cash flows deposits or withdrawals will also receive a pro-rata fee or credit in the following month’s bill. In other situations, cash flows will not be adjusted. For accounts billed in arrears ARIA uses the account balance on the last business day of the month prior to billing for the market value of the assets upon which the Advisory Fees are based. To ensure accounts are billed appropriately, fees are adjusted to reflect cash inflows and outflows during a billing period. For example, if a contribution is made during a billing period, the contribution amount is only billed for the number of days it was in the account. Alternately, if withdrawals are made during the billing period, the withdrawn amounts are only billed up to the date they leave the account. The Advisory Agreement will explain in further detail whether accounts are billed in advance or arrears and how the Apeiron RIA ADV Part 2A Appendix 1 Page 9 of 16 Advisor Fees are calculated. No increase in the annual fee shall be effective without prior written notification to you. Your account at the custodian may also be charged for certain additional assets managed for you by us but not held by the custodian (i.e., variable annuities, mutual funds, 401(k)s). The fees we charge will be deducted directly from your account at the custodian, and the ongoing fee deduction instruction will require your written authorization. You will be provided with a monthly or quarterly statement reflecting deduction of the advisory fees. Services purchased through this program could potentially cost clients less than purchasing similar services from the firm on a stand‐alone basis, in that brokerage costs (if any) are paid on behalf of the client through the wrap program. However, since most trading done by the firm is made with no transaction costs, there is relatively little if any cost difference between wrap versus non‐wrap structures. Generally, whether wrap or non‐wrap structure is offered is based on the program used by the IAR, although an IAR may for example elect to recommend a non‐wrap structure for accounts with client directed securities (i.e., securities selected by the client rather than the IAR) which will incur transaction fees not covered by the firm. Nevertheless, since the firm absorbs certain transaction costs in wrap program accounts, it should be noted that we may have a financial incentive not to place trade orders in those accounts, so clients should be aware that this potential conflict of interest may exist. Clients are encouraged to compare the costs they may incur in this wrap program vs. a typical investment management account, as the anticipated level of trading activity will impact the costs associated with each type of arrangement. Although we believe our advisory fee is reasonable considering the fees charged by other investment advisers offering similar services/programs, we cannot guarantee that our fees will be lower than other advisers. Clients should note that they may be able to find comparable services from other IAR’s within the firm or from other firms at a lower cost or fee. Pontera Apeiron RIA LLC provides an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSAs, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. All client engaging in Investment Management Services would pay an effective fee of 0.30%. We may bill in advance or in arrears and typically monthly. As of December 31, 2023, Apeiron RIA LLC manages approximately $695,000,000, where $650,000,000 is managed on a discretionary basis and $45,000,000 is managed on a non-discretionary basis. Apeiron RIA ADV Part 2A Appendix 1 Page 10 of 16