Description of Firm Kestra Investment Management, LLC (Kestra IM, we, or our) is a registered investment advisor based in Austin, Texas. We are organized as a limited liability company ("LLC") under the laws of the State of Texas. We have been providing investment advisory services since 2021. Kestra IM’s principal owner is Kestra Advisor Services Holdings C, Inc. (d/b/a Kestra Holdings) and its ultimate parent company is Kingfisher Holding LP. Kestra IM provides discretionary sub-advisory, investment management and investment advisory services indirectly to retail clients through intermediaries such as affiliated investment advisors and affiliated trust companies (Affiliated Professionals). These Affiliated Professionals provide their services to clients through Programs they develop. We do not offer services directly to any clients of Affiliated Professionals. The Affiliated Professionals and their investment adviser representative (IAR) work with their client to collect information about their financial situation, risk tolerance, investment objectives, investment time horizon and any other information deemed necessary for their evaluation of the clients. Services are provided through Platform Providers (such as Envestnet or Envestnet/Tamarac) whereby Kestra IM is an investment manager chosen by the Affiliated Professionals to manage some or all a client’s assets. Our services are not offered directly to clients. They are offered only with the involvement of an Affiliated Professionals and their IARs who will work with their clients to collect information regarding the client’s financial situation, risk tolerance, investment objectives, and investment time horizon. This information helps the Affiliated Professionals and IAR determine whether our management services are appropriate given the client's goals and circumstances and they will help guide their clients in the selection of an appropriate portfolio or portfolios of investments (each a Portfolio) that are consistent with their investment objectives. The Affiliated Professionals provides ongoing advice about the selection or replacement of a Portfolio. We act as the Portfolio Manager of the Portfolios and structure both strategic and tactical Portfolios with approaches for both taxable and retirement accounts to address various client needs. Within each Portfolio we will invest in equities, mutual funds and/or exchange traded funds (ETFs) on a discretionary basis. We are responsible for selecting the securities within the Portfolio and making changes as needed. In some cases, we may hire another third-party, unaffiliated investment advisor to provide us with recommendations for structuring Portfolios from an asset

allocation and/or security selection standpoint. Even when this happens, we are still responsible for the discretionary management of the Portfolio and the third-party investment advisor is not authorized to place transactions in the Portfolios. We review our Portfolios on a periodic basis and rebalance assets when it meets our rebalancing criteria. It is possible that Portfolios will not be rebalanced if our thresholds for rebalancing are not met or exceed our thresholds at the time of the review. The Affiliated Professionals will ask their clients to enter into a tri-party investment advisory agreement with their company and a Platform Provider setting forth the terms and conditions of the advisory relationship and appointing us as the Portfolio Manager. The Affiliated Professionals will also have clients enter into a separate broker-dealer and custody agreement with the broker-dealer/custodian that will be responsible for holding client funds and securities and executing transactions at our direction. Affiliated Professionals clients will be required to use affiliated broker/dealers to establish the account(s). National Financial Services, LLC (NFS) or Pershing, LLC (Pershing) are the custodians associated with the affiliated broker/dealers and trust company. We have established a relationship with Platform Providers to provide us and the Affiliated Professionals with access to its technology platform and perform certain administrative services including but not limited to, facilitating the account opening process, placing transactions with the applicable custodian, and billing advisory fees. The Platform Provider will be a party to the agreement clients enter into with the Affiliated Professionals. Wrap Fee Program(s) Certain Programs are offered as Wrap Fee Programs which is a type of investment program that provides clients with access to several money managers for a single fee that includes administrative fees, management fees, and commissions. We are a Portfolio Manager of these wrap fee programs but are not the sponsor. If clients of the Affiliated Professionals participate in a wrap fee program, they will pay a single fee, which includes our management fees, certain transaction costs, platform, custodial and administrative costs. We receive a portion of the wrap fee for our services from the Affiliated Professionals. The overall cost a client of the Affiliated Professionals will incur may be higher or lower than it might otherwise be if separately purchasing the types of securities available in the Program. Assets Under Management As of December 31,2023, we provide continuous management services for $1,514,127,598 in assets on a discretionary basis.