Sanctuary Wealth Advisors LLC DBA Sanctuary Advisors (hereinafter “SWA”) is a Limited Liability Company organized in the State of Colorado. The firm was formed in September 2016, and the principal owner is Martin Joel Erzinger. Portfolio Management Services SWA offers ongoing non-discretionary portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWA creates an Investment Strategy 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: • Determine Investment strategy • Personal investment policy • Asset allocation • Asset selection • Assessment of risk tolerance • Regular portfolio monitoring SWA 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. SWA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWA’s economic, investment or other financial interests. To meet its fiduciary obligations, SWA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWA’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 SWA’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. SWA generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs and private placements. SWA may use other securities as well to help diversify a portfolio when applicable. SWA 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 SWA on behalf of the client. SWA may use “model allocations” 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, which restrictions will be documented in the Investment Policy Statement. However, if the restrictions prevent SWA from properly servicing the client account, or if the restrictions would require SWA to deviate from its standard suite of services, SWA reserves the right to end the relationship. SWA does not participate in any wrap fee programs. SWA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $235,507,749 12/31/2023