A. General Description of the Company Evestia is an automated investment advisor registered with the SEC. Evestia provides clients with software-based investment advisory and portfolio management services through the Evestia Program. This program offers investment advisory services through the custodial platform offered by Altruist Financial LLC (“Altruist”). Custody, clearing and execution services are also provided by Altruist Financial LLC as a self-clearing broker-dealer (a SEC-registered broker dealer and FINRA/SIPC member). Evestia also licenses its propriety investment models to model marketplaces to be used by other investment advisors. These Third-Party Advisor Programs (“TPA Programs”) charge fees based on the value of assets subscribed to Evestia’s models. Third-Party Advisors act as investment advisors to their respective clients (the “TPA Users”) investing through the TPA Programs. These services are delivered solely through Websites. Additional information about Evestia’s products, structure and directors is provided in Part 1 of Evestia’s Form ADV which is available online at www.adviserinfo.sec.gov or at www.evestia.com. We encourage visiting our website www.evestia.com for additional information. B. Summary of Investment Advisory Services Evestia offers an automated investment advisory service that makes it possible for anyone who enters into an Evestia Advisory Client Agreement (the “Advisory Client Agreement”), to access state-of-the-art investment advisory and portfolio management services. As provided in the Advisory Client Agreement, advisory clients (“Clients”) grant Evestia discretionary authority to manage Client assets in accounts (“Client Accounts” or “Accounts”) opened and maintained at the custodian pursuant to the Clearing & Custody Agreement (the “Brokerage Agreement”). Evestia’s investment objective is to seek appropriate long-term, risk-adjusted, net-of-fee returns. Evestia models are also available through TPA Programs to Third-Party Advisors, who in turn act as investment advisors to TPA Users. Taxable Accounts and Individual Retirement Accounts (“IRAs”) Each individualized taxable or IRA account is designed to be consistent with the Client’s individual risk tolerance. Evestia creates an investment plan and manages a Client’s portfolio by seeking to identify: 1) the ideal mix of asset classes based on the Client’s specific risk tolerance; 2) the appropriate mix of investments, individual equities and/or exchange traded funds (“ETFs”) to represent each of those asset classes; and 3) the most appropriate time to rebalance the Client’s portfolio to maintain intended risk tolerance and optimal return for the Client’s risk level. Financial Planning Service Through Software In addition to investment advisory and portfolio management services, Evestia provides certain software-based financial planning tools and

services (the “Financial Planning Service”) to its Clients. The Financial Planning Service allows Clients to use a questionnaire to match their personal financial goals with an appropriate model portfolio for investing account assets. The Financial Planning Service allows Clients to eliminate the need for the traditional financial planner interview that is usually required to acquire the necessary inputs to build a financial plan. Evestia does not represent that the Financial Planning Service is meant to replace a comprehensive evaluation of a Client's entire financial plan considering all the Client’s circumstances. Should a Client choose to implement any recommendation made by the Financial Planning Service, the Client should consult with their tax advisor regarding the Client’s personal circumstances. C. Tailored Services and Investment Restrictions Evestia tailors its software-based investment advisory service to the individual needs of each of its Clients, in accordance with certain investment options designated by Clients, and subject to certain account limitations that prospective investors should consider, as described further below and in Item 7. Evestia uses its software, which is based on academic behavioral economics theory, to determine an investor’s risk tolerance. Evestia asks each prospective Client a series of questions to evaluate both the individual’s objective capacity to take risk and subjective willingness to take risk. We ask subjective risk questions to determine the level of risk an individual is willing to take. D. Evestia Program Client assets at Evestia are managed as part of the Evestia Program (See Evestia Program Brochure, attached). An Evestia Program account for Clients (technically known as a “wrap account”) is a professionally managed investment plan in which all expenses, including brokerage commissions (if any), management fees, and administrative costs, are “wrapped” into a single charge. The Evestia Program provides Clients with investment plans, portfolio management, and necessary brokerage services for one comprehensive fee based on a percentage of the Client’s account assets. Evestia may buy or sell securities consistent with a Client’s investment plan designed to seek an investment return suitable for the goals and risk profile of each Client Account. Evestia determines an appropriate course of action by performing a review of each Client’s account and suitability parameters. This review may include type of account, goals, overall financial condition, income, assets, risk tolerance, and other factors unique to the individual Client’s situation. Evestia manages each Client Account on an individualized basis. In order to implement Evestia’s continuous investment advice, Evestia provides investment advisory and portfolio management services under the Evestia Program only on a fully discretionary basis. E. Discretionary and Nondiscretionary Assets Evestia manages approximately $46,382,655 in client assets through our software-based investment advisory service on a discretionary basis. This total is calculated using the closing U.S. market prices from December 31, 2023. Evestia does not manage any Client assets on a non-discretionary basis.