A. OWNERSHIP/ADVISORY HISTORY SGH Wealth Management (“We”) is a S-Corporation formed in 2005 and was subsequently registered as a Michigan investment adviser in 2016. In 2018 we began the process of registering as a large advisory firm with the Securities and Exchange Commission (SEC). Sam G. Huszczo, CFP®, CFA® (“Mr. Huszczo”) is our owner and investment adviser representative. Additional information about Mr. Huszczo can be found under Item 19 and his attached Supplement Brochure. B. ADVISORY SERVICES OFFERED We offer discretionary investment management services and financial planning services. Before we enter into an advisor-client relationship, we may offer a complimentary general consultation to determine a prospective client’s needs and discuss services available that meet those needs. Only after a prospective client has had time to review our solutions/services can they determine whether a relationship might benefit them. Investment advisory services begin only after we and the client formalize the relationship with a properly executed agreement setting forth the terms and conditions under which we will provide our services. i. FINANCIAL PLANNING We offer clients limited financial planning services to evaluate their financial situations, goals, including risk tolerance, and time horizon, upon request. Through a series of personal exploratory interviews and the use of questionnaires, the firm will collect pertinent data, identify goals, objectives, financial problems, and potential solutions. This initial meeting will determine the extent to which financial planning and investment management is necessary. We will prepare and present specific recommendations and implement those recommendations, as agreed upon with the client. As a result of these actions, our advice may be provided on, (but is not limited to): financial and cash flow management, asset allocation and diversification planning, estate planning, strategic income tax planning, retirement planning, educational funding, goal setting, a review of insurance policies with risk management, review of employer sponsored retirement plan options or other needs as identified by the client and the firm, all potentially provided with recommendations. We may offer comprehensive planning services or the client may desire advice on certain planning components; the firm can tailor services as desired by the client. At the conclusion of the financial planning service, the firm may present the client with a written financial plan. This financial planning service involves rendering a financial consultation for you based upon an analysis of the documents and information that you provide us. We may recommend that you utilize various financial products, such as insurance or other advisory services, to implement our recommendations and to achieve your goals. You are not obligated to follow our recommendations. We also may recommend that you work with other professionals, such as attorneys or accountants. Additionally, SGH Wealth Management takes no responsibility for the outcome of our advice related to employer sponsored retirement plans in part due to the limited options available within these type of plans. ii. PORTFOLIO MANAGEMENT SGH Wealth Management Page 5 ADV Part 2A – 1/1/2024 We provide investment management services to interested clients on a client specific basis, based upon your unique facts and circumstances. Although we manage your accounts based on your individual needs, we construct client portfolios in accordance with our model asset allocation strategies, which are adjusted for each client’s risk profile. The model asset allocation strategies range from aggressive growth to capital preservation. They also differ according to the type of account such as individual retirement accounts verses non-qualified accounts. Upon selecting your risk tolerance profile, allocations are made to each of the models depending upon what is appropriate for you. We rely on the client to accurately specify their own risk tolerance to be able to fit their needs to the appropriate model portfolio. All of the model strategies include some combination of individual stocks, mutual funds, exchange traded funds, alternative investments, options, individual bonds, certificates of deposit, and may potentially include other investment products. We develop these models based upon our proprietary research on markets and market conditions as well as perceived value in selecting securities. Please see Item 8 for additional details. We periodically review your accounts on an ongoing basis (by monitoring our models) to ensure that risk levels stay within the parameters established by your risk tolerance. We rebalance your portfolios as necessary. More or less frequent rebalancing may be required depending on macroeconomic, market or sector factors, as well as changes in your personal or family circumstances. C. TAILORED SERVICES We tailor all of our services to the client’s stated goals, needs and objectives. For our portfolio management service clients, we allow them to impose restrictions on investment in certain securities or types of securities. All restrictions must be presented to us in writing. D. WRAP PROGRAM We offer a wrap fee program. Our wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different fashion than non-wrap accounts. Additional information about our wrap program can be found in our Appendix 1 to the ADV Part 2A (i.e. Wrap Fee Program Brochure). E. CLIENT ASSETS MANAGED As of January 1st, 2024 SGH Wealth Management manages approximately $354,220,665 in assets: All assets under management are managed on a discretionary basis at this time. F. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent specifically requested by the client, SGH shall generally provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. SGH will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions do occur based upon assets under management, special projects, etc. for which SGH may charge a separate planning fee as discussed at Item 5 below). Please Note: SGH does not serve as an attorney or accountant, and no portion of our SGH Wealth Management Page 6 ADV Part 2A – 1/1/2024 services should be construed as legal or accounting services. Accordingly, SGH does not prepare estate planning documents or tax returns. To the extent requested by a client, SGH may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.), including SGH representatives, in their separate individual capacities as licensed insurance agents. 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 SGH and/or its representatives. Please Note: If the client engages any 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. Please Also Note-Conflict of Interest: The recommendation by SGH that a client purchase an insurance commission product from a SGH representative in his/her separate individual capacity as an insurance agent, presents a conflict of interest, as the receipt of commissions 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 product from a SGH representative. Clients are reminded that they may purchase insurance products recommended by SGH through other, non-affiliated insurance agents. SGH’s Chief Compliance Officer, Sam Huszczo, remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. 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 Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, Registrant serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both. No client is under any obligation to rollover retirement plan assets to an account managed by SGH. SGH’S Chief Compliance Officer, Sam Huszczo remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Bundled (Wrap) vs Unbundled Services. As indicated in this Brochure, SGH sponsors a wrap program. The wrap program will generally be offered to clients who maintain in excess of $500,000 of assets under SGH’s management. Under a wrap program, the client pays one “bundled” fee which includes both SGH’s advisory fee (see Item 5 below) and the transaction fees charged by the account custodian-see Wrap Program Conflict below. For clients with less than $500,000 under SGH’s management, SGH’s advisory fee does not include transaction fees charged by the account custodian-the client remains responsible for the payment of all transaction fees. ANY QUESTIONS: Our Chief Compliance Officer, Sam Huszczo, remains available to SGH Wealth Management Page 7 ADV Part 2A – 1/1/2024 address any questions that a client or prospective client may have regarding wrap vs. unbundled advisory services. Please Note: Wrap Program Conflict. As indicated in this Brochure, SGH sponsors a wrap program. The wrap program will generally be offered to clients who maintain in excess of $500,000 of assets under SGH’s management. Under a wrap program, the client pays one “bundled” fee (see Item 5 below) which includes both SGH’s advisory fee and the transaction fees charged by the account custodian. When managing a client’s account on a wrap fee basis, we shall receive as payment for our investment advisory services, the balance of the wrap fee after all wrap- fee costs (including account transaction fees) have been deducted. Accordingly, we have a conflict of interest because we could have an economic incentive to maximize our compensation by seeking to minimize the number of transactions/total costs in the client's account. Participation in the Program may cost more or less than purchasing such services separately. The fee that we charge for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. ANY QUESTIONS: Our Chief Compliance Officer, Sam Huszczo, remains available to address any questions that a client or prospective client may have regarding the corresponding conflict of interest a wrap fee arrangement may create. Please Note-Use of Mutual Funds: Most mutual and exchange funds are available directly to the public. Thus, a prospective client can obtain many of the mutual and exchange traded funds that may utilized by SGH independent of engaging SGH as an investment advisor. However, if a prospective client determines to do so, he/she will not receive SGH’s initial and ongoing investment advisory services. Schwab. As discussed below at Item 12, when requested to recommend a broker-dealer/custodian for client accounts, SGH generally recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions and/or transaction fees for effecting securities transactions. In addition to SGH’s investment advisory fee, brokerage commissions and/or transaction fees, 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). Unless the client has engaged SGH on a wrap fee basis (see above), the fees charged by Schwab or any broker-dealer/custodian directed by the client, are in addition to SGH’s advisory fee referenced in Item 5 below. Portfolio Activity. SGH has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, SGH 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, mutual fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when SGH determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by SGH will be profitable or equal any specific performance level(s). SGH Wealth Management Page 8 ADV Part 2A – 1/1/2024 Client Obligations. In performing our services, SGH 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, each client is advised that it remains his/her/its responsibility to promptly notify SGH 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 SGH) will be profitable or equal any specific performance level(s).