FIRM DESCRIPTION Hedges Asset Management LLC (hereinafter referred to as “Hedges Asset Management,” “we,” “us,” “the Firm,” or “our Firm”) is a Nevada limited liability company with its principal office located in Reno, Nevada. The principal owner and Chief Compliance Officer of Hedges Asset Management is William Hedges. As a registered investment adviser, we are a fiduciary to you, our client, meaning we have a fundamental obligation to act and provide investment advice that is in your best interest. Should any material conflicts of interest exist that might affect the impartiality of our investment advice, they will be disclosed to you in this Brochure. We urge you to review this Brochure carefully and consider our qualifications, business practices and the nature of our advisory services before becoming our client. Hedges Asset Management is a newly established investment adviser with approximately $150,000,000 under management. ADVISORY PROGRAMS Hedges Asset Management provides investment management services to our clients. In connection with our investment management services, Hedges Asset Management provides advice with respect to stocks, bonds, mutual fund, municipal securities, U.S. Treasuries, options, limited partnerships, and certificates of deposits. Hedges Asset Management’s advisory services are tailored to the needs of our clients based on their individual investment objectives, risk tolerance, cash or income needs, and any investment restrictions. Although Hedges Asset Management seeks to accommodate any reasonable investment restrictions or guidelines set by our clients, we may decline to accommodate certain investment restrictions that are incompatible with our Firms’ investment philosophy or that may have an adverse effect on our ability to manage your account. Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets

to a new employer’s plan (if available and rollovers are permitted); (3) Rollover Employer Plan assets to an IRA; or (4) Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, Investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. Hedges Asset Management encourages you to discuss your options and review the above-listed considerations with an accountant, third-party administrator, investment advisor to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. Form ADV Part 2A 5 By recommending that you rollover your Employer Plan assets to an IRA, Hedges Asset Management may earn asset-based fees as a result. In contrast, leaving assets in your Employer Plan or rolling the assets to a plan sponsored by your new employer likely results in little or no compensation to Hedges Asset Management. Hedges Asset Management has an economic incentive to encourage investors to rollover Employer Plan assets into an IRA managed by Hedges Asset Management. Investors may face increased fees when they move retirement assets from an Employer Plan to a rollover IRA account. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client’s investment guidelines, we will maintain quarterly contact with our clients in terms of portfolio construction, transactions and performance. Hedges Asset Management enters into formal written agreements with our clients setting forth the terms and conditions under which we will provide our advisory services (the “Investment Management Agreement”). The Investment Management Agreement sets forth the scope of the services to be provided and the compensation we receive from the client for such services. The Investment Management Agreement may be terminated by either party in writing at any time by giving thirty (30) days signed written notice to the other party. Our advisors offer the advisory service described below to our clients: ASSETS UNDER MANAGEMENT Hedges Asset Management manage $ 155,000,000.00 on discretionary basis on Asset under Management as of December 31, 2022.