This section of the brochure tells you about our business, including ownership, and a description of the services we offer. Zanetti Financial, LLC is referred to in this document as “Zanetti Financial”, “the Company”, “us”, “we”, or “our”. In this document we refer to current and prospective clients of Zanetti Financial as “you”, “client”, or “your”. Zanetti Financial was created in 2015 and is owned by its principal Gregory Zanetti. Types of Advisory Services Investment Supervisory Services Our clients enter into a written Investment Advisory Agreement, where Zanetti Financial and our investment adviser representatives provide asset management services on a continuous and ongoing basis guided by the individual needs of the client. Using the information provided by you, the investment advice provided to you is tailored to your individual situation. We regularly inquire about, and you are responsible for providing, information about your investment goals, time horizon, and risk tolerance. These investment supervisory services are generally not provided to all your holdings or net worth but rather only to assets specifically designated by you and agreed to by us as managed assets. Advice on Matters Not Involving Securities Retirement of Employee Benefit Plan Services In the event that Zanetti Financial, LLC is involved in Retirement or Employee Benefit Plan services as outlined in Section 3(21) of ERISA, the plan sponsor/trustee retains ultimate decision-making authority for the investments and may accept or reject recommendations. If Zanetti Financial acts in this capacity, then the firm will provide

advisory services on a non-discretionary basis for employee benefit plans subject to ERISA. Types of Investments Used We consider many different types of securities when formulating the investment advice we give to you. If you come to us with existing investments, we evaluate them with respect to your financial goals, risk tolerance, and investment time horizon. Depending upon your situation, your account(s) managed by us may contain individual stocks, corporate and/or government bonds, mutual funds, or exchange traded funds (“ETFs”). Negatively Correlated Investments We may invest a portion of your portfolios in negatively correlated mutual funds or ETFs. Negatively correlated mutual funds or ETFs may rise in value while the general stock market declines and vice versa. We may add these negatively correlated mutual funds or ETFs in an attempt to reduce the volatility of your portfolio. The addition of negatively correlated investments does not in any way guarantee that the volatility, draw down, or loss of portfolio principal will be lower and it may actually reduce long-term portfolio performance. Tailored Services and Investment Restrictions We attempt to tailor your investment portfolio to your situation as you have described it to us. This is why it is so important that you let us know about changes to your financial situation, goals, or investment time horizon. You may impose restrictions on investing in certain securities or types of securities. You must clearly identify these restrictions in writing to us. Assets Under Management As of May 30, 2023, Zanetti Financial LLC has $215,897,023 under management.