Hardworking Capital Advisors, LLC ("HWC") is a registered investment adviser firm established in August 2015 to provide investment advisory and financial planning services to high net worth individuals, Individuals (other than high net worth individuals), Charitable organizations and Corporations or other businesses (herein referred to as "Client" or "Clients"). Principal Owners HWC's principal owner is HWC Holdings Corp., which is owned by Mathew Mellier. Below we provide information about our programs and services. Please note that the terms of each Client's Investment Advisory Agreement (the "Advisory Agreement") are negotiable; therefore, the following information is necessarily general and does not address the specific details applicable to each Client. Clients should refer to their individual Advisory Agreement for specific terms that apply to them. Full Advisory Services We offer ongoing discretionary Investment Management Services and tailored Financial Planning, as described below, to meet the needs of clients with a wide range of financial needs, as more fully described below. As applicable, the Client will meet with the Representative to identify the nature and scope of the services, which may include, for example, a focused (limited-scope) financial plan, investment plan, or individual consultations Regarding the Client's financial affairs. Through the meetings between the Representative and Client, they will agree on the process for gathering data regarding income, expenses, taxes, insurance coverage, retirement plans, wills, trusts, investments or other relevant information pertaining to the goals for the particular service. From this, a series of recommendations or alternative strategies may be developed to assist Client to achieve a particular goal or objective. In many cases, the plan we provide is delivered to the Client orally during meetings; unless specifically provided in the written agreement for Consulting Services, no written plan or report will be provided pursuant to The Consulting Services. Clients seeking a written financial plan should discuss with the Representative our separate standalone Financial Planning Services. It is important to understand that the data gathering and process of working with the Representative have significant benefits in understand the Client's personal and financial situation, and supporting the Investment Management Service. The Insight Service is not intended to provide a comprehensive financial plan. Clients seeking a comprehensive financial plan or more robust financial planning services may engage HWC for our separate standalone Financial Planning Services, described below. Portfolio Navigator Services Through the Investment Management Services, Portfolio Navigator, the Client's Representative works closely with the Client in order to develop a thorough account profile for the "Managed Assets," including information about the Client's personal and financial situation, investment objectives, risk tolerance, liquidity needs, and investment time horizon (all the "Suitability Information"), and as well as reasonable investment restrictions the Client wishes to impose on the Client's accounts ("Reasonable Restrictions"). Using this information, the Representative will be responsible for developing and maintaining a Portfolio, providing continuous and regular investment management services of the client's Managed Assets, placing orders for the purchase, sale, and exchange of Managed Assets; modifying the Portfolio in a manner intended to achieve the account's objective, on a fully discretionary basis, subject to any investment restrictions Client imposes, and re-allocating and adjusting the Portfolio, as appropriate. If Client desires to have any of the Portfolio managed by a third-party, based on information provided in the account profile, the Representative will assist Client to select a third-party investment program approved by HWC (a "Third-Party Program") sponsored by an institutional investment manager (each a "Sponsor"), and the initial designation of a third-party portfolio manager (each a "Third-Party Manager") available through the Third-Party Program. Each Third-Party Manager designated for the Client's Account will be responsible for management of one or more specific asset classes of the Client's portfolio allocated to that Third-Party Manager. The selection of a Third-Party Manager is based on each manager's investment style and consistency with achieving the overall intended objective of the Account and the Third-Party Manager's role among any other Third-Party Managers for the Account. Client is required to grant HWC and Representative full authority and discretion to manage the Managed Assets according to the terms of the Investment Management Service and the Advisory Agreement. HWC and Representative shall have the authority and discretion without notice to "hire, fire, replace, and substitute" any Third-Party Manager, and to direct the termination and liquidation of Client's investment and terminate the Client's participation in the any Third-Party Program; provided, HWC has no authority to direct any destination for the proceeds of any such liquidation, other than the qualified custodian, to the account in the Client's name from which the assets originated, and if none, then to be held by the custodian pending direction by Client. Accordingly, we may customize an investment portfolio for you according to your risk tolerance, investment objectives, and other factors as described above, or we may invest your assets according to one or more model portfolios developed by our firm and/or other registered investment advisers (third-party model providers), available to us through a third-party platform provider, such as SMArtX Advisory Solutions LLC (SMArtX). Primarily, SMArtX assists our firm with back-office support, trading, report preparation, and billing. In any case, once we construct an investment portfolio for you, or select a model portfolio developed by us or a third party, we will monitor your portfolio's performance on an ongoing basis, and we or SMArtX will rebalance the portfolio as indicated by changes in market conditions and your financial circumstances. When SMArtX acts as a Sub-Adviser, Clients will be provided with a current copy of SMArtX’s Form ADV Part 2 Brochure at the inception of services. This document provides important disclosures about SMArtX’s services, portfolio models, fees, conflicts of interest, disciplinary history (if any), and other important information that would help Clients understand the scope of the Sub-Advisory services provided by SMArtX. Carefree Solutions Services As an important enhancement to inform and support the delivery of the Investment Management Services, we offer Clients, our personalized Carefree Solutions Services. Carefree Solutions is our active and on-going involvement throughout the year for the implementation of Client's personal plan. The scope of the services needed may include a comprehensive financial plan, semi-annual review, financial concierge service, retirement planning, tax planning, coordination with tax professional, estate planning, short term objectives planning, coordination with estate attorney, debt/mortgage analysis, long term objectives planning, coordination of refinance, comprehensive, insurance planning, charitable gifting strategies, coordination with insurance professional, investment analysis, portfolio review, and/or special needs as specified in the executed Advisory Agreement. Strategic Wealth Planner Services Strategic Wealth Planner is the review of Client's personal planning needs. The scope of the services needed may include retirement planning assessment, estate planning assessment, debt/mortgage assessment, risk management assessment, investment analysis/portfolio assessment, tax planning assessment, cash management assessment, and/or special needs as specified in the executed Advisory Agreement. Financial Planning Services HWC offers separate, standalone financial planning services for Clients seeking comprehensive or more in-depth financial planning services more in-depth than provided as part of our Carefree Solutions Services. For these services, the Client will meet with the Representative to identify the nature and scope of the financial planning services (the "Planning Services") to be provided, and which will be described in the Schedule to the Advisory Agreement. The Representative will assist Client to identify and establish Client's goals and objectives. Client recognizes that the value and usefulness of the Planning Services is dependent upon Client providing Representative promptly with all relevant data and information. We may use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our

financial planning software, for most engagement, we will deliver written outline or plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the outline or plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. A conflict exists between the interest of HWC, the Representative, and the interests of the Client, to the extent recommendations are made for the purchase of securities or insurance products which the Representative will sell as a registered representative of a broker-dealer or insurance agent of an insurance company for which the Representative will earn usual and customary commissions or other sales-related compensation, and any additional distribution fees or shareholder service fees (such as 12b-1 Fees) in connection with certain mutual fund and ETF shares. The opportunity to receive such compensation may influence the decision by HWC or the Representative to recommend a security or insurance product to benefit rather than considerations of the investment needs of the client. Although HWC addresses this situation by alerting the client of this conflict, and monitoring the recommendations made to its clients, such efforts may not be sufficient to prevent recommendations improperly influenced by self-interest. Further, Client is under no obligation to act upon any recommendation by HWC or its Representative to purchase any security or insurance product, or may purchase any such product from another financial intermediary or insurance company of the Client's choosing. Refer to Item 10 for further information. Material conflicts of interest are disclosed regarding the investment adviser, its Representatives, or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. While the firm endeavors at all times to offer Clients its specialized services at reasonable costs, the fees charged by other advisers for comparable services may be lower than the fees charged by HWC. Unless specifically provided in the Advisory Agreement, no written plan or report will be provided pursuant to the Planning Services; however, in view of the more in-depth nature of these services, they will tend to be accompanied by a written report. Hourly Consultation Services In addition to Investment Management Service and Financial Planning Services, the Client's Representative may also offer general Consulting Services on an hourly basis. For consultation services, Client may agree to pay HWC an hourly fee of $350.00 per hour. This hourly Consulting Services may take the form of general consulting and/or general investment advice for individuals or businesses. It may also take the form of investment advice for individuals or businesses that do not meet the minimum requirements for another service. Additionally, it may also take the form of corresponding and/or coordinating with attorneys, CPAs or other professionals, as well as document production and other administrative services; provided, Client recognizes and acknowledges that neither HWC nor the Representative is a law firm or lawyer, and cannot provide legal advice or legal services. Unless specifically provided in the Advisory Agreement for Consulting Services, no written plan or report will be provided pursuant to the Consulting Services. HWC offers additional services addressing a variety of investment and non-investment related matters, such as investment consultations, and other matters of interest to Clients. The scope of these project-based services varies, as each engagement is individually negotiated and tailored to accommodate the specific needs of a particular Client. In these cases, the services we provide will be included in a written agreement individually negotiated by the firm and Client. Our fee will vary depending on the nature, scope, and complexity of the services to be provided. Advice is based on objectives communicated, either orally or in writing, by the Client or the Client's advisors. Advice may be provided through individual consultations or a written report, as agreed in writing between HWC and Client. 401(k) Services We offer non-discretionary pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary (the "client"). In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. Fiduciary Services: In performing the Fiduciary Services, we will act as a fiduciary of the plan under the Employee Retirement Income Security Act ("ERISA") only for the purpose of advising client regarding client's investment selections (non-discretionary investment advice). We do not (and will not) exercise discretion regarding the selection of plan investments. Client is solely and exclusively responsible for selecting, removing, adding, and replacing any plan investment options.
• We will provide non-discretionary investment advice to client about investment alternatives available to the plan in accordance with the plan's investment policies and objectives. Client shall have the final decision-making authority regarding the initial selection, retention, and removal of investment options.
• We will assist in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the plan, and shall set forth the asset classes and investment categories to be offered under the plan, as well as the criteria and standards for selecting and monitoring the investments. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt the investment policy statement.
• We will prepare periodic investment advisory reports that document consistency of fund management and performance to the guidelines set forth in the IPS and we will make recommendations to maintain and replace investment options.
• We will meet with client on a periodic basis to discuss reports and recommendations.
• We will provide investment advice to the client with respect to the selection of qualified default investment alternative (QDIA) for participants who fail to make an investment election. Non-Fiduciary Services: In performing the Non-Fiduciary Services, we are not acting as a fiduciary of the plan as defined under ERISA:
• We will assist in the education of the participants in the plan about general investing principles and the investment alternatives available under the plan.
• We will assist in the group enrollment meetings to explain retirement plan participation, savings and investing for eligible employees. We may also provide investment-related educational seminars to plan participants on such topics as:
• Diversification
• Asset allocation
• Risk tolerance
• Time horizon In performing both Non-Fiduciary and Fiduciary Services, we do not act as, nor will we agree to assume the duties of, a trustee or the plan administrator, as defined under ERISA, and we have no discretion or responsibility to interpret the plan documents, to determine eligibility or participation under the Plan, or to take any action with respect to the management, administration or any other aspect of the plan. We do not provide legal or tax advice. We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Termination of Account Clients who wish to terminate their account must notify HWC in writing. If services are terminated within (5) business days of executing the Advisory Agreement, services will be terminated without penalty. After the initial five (5) business days, the client may be responsible for payment of fees for the number of days services are provided by HWC prior to receipt of the notice of termination. HWC shall refund any/all pre-paid unearned fees on a pro-rata basis. HWC may tailor its advisory services to the specific needs and objectives of each advisory client. Clients may also impose restrictions on investing in certain securities or types of securities. Most of which is generally covered in the client's Advisory Agreement. Assets under Management As of December 31, 2023, HWC had approximately $171,062,142 in discretionary regulatory assets under management and no non-discretionary regulatory assets under management.