HBE Wealth Management, LLC (hereinafter "HBE") is registered with the Securities and Exchange Commission as an investment adviser with its principal place of business located in Lincoln, Nebraska. HBE began conducting advisory business in 2001. HBE's principal shareholder is HBE, LLP. In addition, the following individuals indirectly own 25% or more of HBE Wealth Management, LLC:
• James D. Schulz
• Krystal L. Siebrandt
• Scott A. Becker As of December 31, 2022, HBE managed $126,226,503 on a discretionary basis and $2,400,839 on a non- discretionary basis. Investment Management Services: HBE manages investment portfolios for individuals, qualified retirement plans, trusts, charitable organizations, corporations and small businesses. HBE will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. HBE uses investment and portfolio allocation software to evaluate alternative portfolio designs. HBE evaluates the client's existing investments with respect to the client's investment policy statement. HBE works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by HBE. HBE will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. HBE will typically create a portfolio of no-load mutual funds, exchange traded funds (“ETFs”) and individual securities and may use model portfolios if the models match the client's investment policy. HBE will allocate the client's assets among various investments, taking into consideration the overall management style selected by the client. HBE primarily recommends portfolios consisting of passively managed asset class and index mutual funds and ETFs. The mutual funds and ETFs HBE recommends typically follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s Investment Policy Statement (IPS). HBE manages mutual fund and equity portfolios on a discretionary or nondiscretionary basis. Clients may impose reasonable restrictions on HBE’s discretionary authority, including restrictions on the types of securities in which HBE may invest client’s assets and on specific securities, which the client may believe to be appropriate. Use of Third-Party Sub-Advisers: HBE has retained Buckingham Strategic Partners, LLC (“BSP”) to act as a sub-advisor for certain client accounts. BSP shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by HBE. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to BSP, which may include, but are not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC. Each Portfolio is designed to meet a particular investment goal which HBE has determined is suitable based on the client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio’s goal and BSP will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, HBE, on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should

immediately contact HBE to determine if changes to an account and the allocation of the assets held in the account are necessary. HBE may also recommend fixed income portfolios to investment management clients, which consist of managed accounts of individual bonds. HBE will request discretionary authority from investment management clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income subadvisor. Pursuant to its discretionary authority, HBE will retain a fixed income subadvisor. The fixed income subadvisor will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s Investment Policy Statement. The fixed income subadvisor will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the fixed income subadvisor is provided with cost basis information). The fixed income subadvisor will obtain HBE’s consent prior to the sale of any client securities. HBE will provide to fixed income subadvisor any updated client financial information or account restrictions necessary for the fixed income subadvisor to provide sub-advisory services. On an ongoing basis, HBE will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. HBE will at least annually review client’s investment policy and risk profile and will re-balance clients’ accounts as necessary. In addition to managing the client’s investment portfolio, HBE may provide financial planning services to clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. HBE will not charge a separate fee for this service. In performing its services, HBE shall not be required to verify any financial information received from the client or from the client’s other professionals, and is expressly authorized to rely on the information provided. Moreover, clients are advised that it remains their responsibility to promptly notify HBE if there is ever any change in their financial situation or investment objectives. Employee Benefit Retirement Plan Services: HBE also provides advisory services to participant-directed retirement plans through third-party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. HBE will analyze the plan's current investment platform, and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. HBE will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. HBE will recommend changes in the plan's investment vehicles as may be appropriate from time to time. HBE generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, HBE also works in coordination and support with BSP. Retirement plan clients will engage both HBE and BSP. BSP will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. HBE will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan.