Description of the Advisory Firm Navigate Wealth Management, LLC (hereinafter “Navigate”) is a Limited Liability Company organized in the State of Alabama. The firm was formed in September 2014, and the principal owners are Carl Johan Grahs and Caleb Ryan Hopkins. Types of Advisory Services Portfolio Management Services Navigate offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Navigate creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio management Navigate evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Navigate seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Navigate’s economic, investment or other financial interests. To meet its fiduciary obligations, Navigate attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Navigate’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Navigate’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Subadviser

Services Navigate may also act as a subadviser to advisers unaffiliated with Navigate. These third-party advisers would outsource portfolio management services to Navigate. This relationship will be memorialized in each contract between Navigate and the third-party advisor. Financial Planning Services Under the dba Abeona Wealth, and through the efforts of Mary Meadows Livingston (CFP), the firm offers financial planning services to clients. These engagements are documented with client agreements. Navigate serves as the Chief Investment Officer and assists Abeona with portfolio construction, investment monitoring, and staying up-to-date on current research and market events. Client Tailored Services and Client Imposed Restrictions Navigate will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by Navigate on behalf of the client. Navigate may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Navigate from properly servicing the client account, or if the restrictions would require Navigate to deviate from its standard suite of services, Navigate reserves the right to end the relationship. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Navigate does not participate in any wrap fee programs. Assets Under Management Navigate has the following assets under management as of December 31, 2023: Assets Under Management: Discretionary: $294,469,433 Non-Discretionary: $0 Total: $294,469,433