Introduction Hadley Investment Co. (“Hadley” or the “Firm”) is a Delaware corporation with its principal office located in West Hollywood, CA and is registered with the Securities and Exchange Commission (the “SEC”) as an investment advisor. The Firm was formed in August 2020 and is solely owned by Joshua Evan Miller. Mr. Miller is the CEO and CCO of the Firm. Advisory Business Hadley provides investment advisory services to retail investors exclusively through an investment services technology platform offered through its website and proprietary mobile application (the “Platform”). The Firm is an investment advisor that owns and maintains the Platform through which advisory clients receive investment recommendations to invest in 529 plans which are offered across the 50 U.S. states and several territories. Hadley will only offer investment recommendations with respect to 529 plans and not individual securities. The investment recommendations are provided to clients directly by Hadley via the Platform and clients will directly choose their 529 plan investments. 529 Plans 529 Plans are tax-advantaged savings plans designed to encourage saving for future education costs. 520 Plans, legally known as “qualified tuition plans”, are sponsored by states, state agencies or educational institutions and are authorized by Section 529 of the Internal Revenue Code. Most of the fifty states and the District of Columbia sponsor at least one type of 529 Plan. The three types of 529 plans are prepaid tuition plans, education saving plans and 529 ABLE plans. Hadley will focus its initial investment services in education saving plans. Client Tailored Services Hadley utilizes the Platform to collect information with respect to each client and prospective clients, to deliver account notifications and content, and to provide Hadley’s investment recommendations. Upon account opening (“Client Onboarding”), the client will be prompted to complete a series of questions that will be used, in combination with other available client information collected through the Platform, to deliver 529 plan recommendations. These series of questions are important to the development of Hadley’s investment recommendations. Client Onboarding is complete once a client has (i) electronically accepted and countersigned Hadley’s investment advisory agreement, (ii) acknowledged receipt of Hadley’s Form ADV Part 2 (Brochure), Form CRS (Client Relationship Summary) and Privacy Notice. There will be no exceptions. Only when Client Onboarding is complete will a client have the availability to receive recommendations and enroll in 529 plan(s) via the Platform. The Platform Hadley’s Platform will recommend to its clients a variety of 529 plans which are dependent on a client’s risk tolerance and asset allocation strategy preference (e.g., static or “age based” portfolios), and client’s state of residence. Clients initially complete an online questionnaire and based on those answers a variety of 529 plans are recommended by the Platform. While the Firm provides recommendations with respect to 529 plans solely through the Platform, the client makes the ultimate decision regarding the purchase or sale of such 529 plans. Hadley will recommend the most advantageous 529 plan to a client based on the client’s state of residence. This information

helps Hadley inform the client, via the Platform, if the client’s state of residence is a tax neutral state, a tax parity state or if the client qualifies for an in-state income tax deduction. Hadley recommends that clients contact their tax professional before making a decision to invest in a 529 plan. After selecting their state of residence, clients will be prompted by the Platform questionnaire to choose whether their 529 plan should be 1) age-based or static, and 2) aggressive, moderate, or conservative in risk. 529 Plan Ratings Hadley’s algorithm will recommend 529 plans via the Platform based on the interests the client selects on the initial questionnaire completed by the client during Client Onboarding. The 529 plan recommendations will be delivered for viewing over the internet via the Platform. The Platform will show the name of 529 plan(s) that is recommended, the state issuing the 529 plan, Morningstar rating of gold, silver bronze, neutral, negative, or not scored, whether there was a rating change, and other available information (such as fees, rate of return, etc.) for each 529 plan recommendation. Each client is ultimately responsible for deciding whether to accept and act upon the suggested 529 plan recommendations. Clients also have the ability to search for 529 plans within the Platform that have not been recommended and decide whether to purchase those 529 plans. Hadley will recommend the highest-tier rated 529 plan that is connected to the Hadley platform. Hadley is expecting to connect client with states that offer either gold-rated plans or state income tax deductions for in-state 529 plan contributions. Since ratings change yearly, Hadley expects to introduce a “race to the top” competitive dynamic that incentivizes states to offer compelling and competitive 529 plan options. Client Support Clients should consider that Hadley primarily uses electronic (not telephonic) means to provide customer support. To receive customer support, clients may contact the Firm using email or through the Platform. Clients and prospective clients should be comfortable communicating through those channels. Further, clients should understand that they will not interact with investment advisory personnel. Hadley reserves the right to deny any prospective client access to the Platform and to terminate client accounts for reasons related, but not limited, to unsuitability and/or if clients fail to timely maintain financial and other information previously provided by the client on the Platform or update this information on at least an annual basis. A client’s failure to timely update their information in the Platform could materially impact the quality and applicability of Hadley’s investment recommendations. Non‐Discretionary Recommendations Hadley offers non-discretionary investment recommendations and advisory services to individual investors. Hadley interacts with investment advisory clients, as well as prospective clients, solely through the Platform. Hadley does not offer financial planning services, tax, accounting, or legal advice. Wrap Fee Programs Hadley does not currently participate in any wrap fee programs. Assets Under Management Hadley does not currently have any assets under management.