A. Description of the Advisory Firm Apollon Financial, LLC (“Apollon Financial” or the “Advisor”) is a limited liability company organized in the State of Delaware. Apollon Financial is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”). Apollon Financial’s registration with the SEC became active on June 2, 2022. Apollon Wealth is wholly owned by Apollon Holdings, LLC. Our firm offers services through our network of investment advisor representatives (“Advisor Representatives” or “IARs”). IARs may have their own trade names and logos that are used for marketing purposes and may appear on marketing materials or client statements. These are trade names that Apollon Financial is Doing Business As (“DBA”), for purposes of providing its advisory services. The IARs using the separate DBA’s are under the supervision of Apollon Financial, as are the advisory services offered by the IAR. Foxen Financial is an example of a DBA used to conduct advisory services for Apollon Financial. All statements in this brochure, including those made in the present tense, describe the prospective business of Apollon Financial. If you have any questions regarding the contents of this Disclosure Brochure, please do not hesitate to contact our Chief Compliance Officer, Michael Herman by telephone at (843) 579-0018 or by email at [email protected]. B. Types of Advisory Services Apollon Financial offers investment advisory services to individuals, high net worth individuals, families, family offices, trusts, estates, businesses, charitable organizations, retirement plans and pooled investment vehicles (each a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest by putting the best interest of its Clients ahead of its own interest. Apollon Financial’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Financial Planning and Consulting Services Apollon Financial provides a variety of comprehensive financial planning and consulting services to Clients. Such engagements may be part of the investment advisory engagement or pursuant to a separate engagement. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to cash flow analysis, investment planning, retirement planning, estate planning, personal savings, educational savings, and other areas of a Client’s financial situation. For certain Clients, Apollon Financial offers specialized planning for businesses of Clients that focuses on exit strategies and succession plans. A financial plan developed for, or financial consultation rendered to the Client will typically include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence, or alter retirement savings, establish education savings and/or charitable giving programs. Apollon Financial may recommend its own services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Apollon Financial recommends its own services, as such a recommendation may increase the advisory fees paid to Apollon Financial. The Client is under no obligation to act upon any of the recommendations made by Apollon Financial or its IARs under a financial planning or consulting engagement to engage the services of any such recommended professional, including Apollon Financial itself. Apollon Financial will not provide investment advisory services, including any ongoing investment recommendations for Client assets for which it does not receive written authority from the Client for such advisory services. For certain Clients, such as small businesses, Apollon Financial may provide specialized needs analyses, planning, business valuation analysis, or business performance reviews or other services as may be required by such Clients. Clients may hire Apollon Financial to provide financial guidance services on a one-time basis or continually until canceled. Client deliverables, including written financial plans or recommendations for implementation of financial guidance will be presented within six (6) months of the date of the Client’s execution of an investment management agreement with Apollon Wealth. Apollon Financial does not provide tax preparation and filing services. Clients are urged to consult with a tax professional for any tax advice. Certain Apollon Wealth advisors may also provide tax related services to Clients; however, these services are provided as an outside business activity that is not affiliated with or conducted through Apollon Financial, and such services are not subject to the supervision or oversight of Apollon Wealth or any of its affiliates. General Description of Investment Management Services Apollon Financial provides investment management services to its Clients using a variety of asset classes and investment vehicles that typically include mutual funds, exchange traded funds (“ETFs”), equity securities, fixed income securities, and other related securities. Client accounts are generally invested in strategies, with similar accounts invested in the same securities. Accounts are also managed at a custom level, with security selection varying from one Client to another. Apollon Financial IARs work with Clients to understand the Client’s risk tolerance, investment objectives, investment attribute preferences, and to determine an appropriate asset portfolio construction. Apollon Financial IARs determine an appropriate portfolio for each of their clients. Depending on how the Client’s assets are allocated, they are managed in different ways. One of the ways assets are managed is through centrally-managed strategies, with well-defined strategy mandates, or in custom investment portfolios. Apollon Financial’s Investment Committee oversees these strategies to ensure the assets are managed as expected and according to the strategy mandates defined by Apollon Wealth, where applicable. The other way assets are managed is through local Apollon Financial offices. For local office management, Apollon Wealth’s IAR’s retain primary portfolio management decision-making responsibilities, with additional oversight by Apollon’s Local Office Due Diligence Sub- Committee. Members of the Investment Committee and IAR’s that retain portfolio management decision making responsibilities are generally required to have both a high school and college education or equivalent experience. In addition, all personnel who provide investment financial guidance are required to have financial, analytical or portfolio management experience, or to have passed the Uniform Investment Adviser Law Examination (Series 65 or Series 66), or other relevant qualifying examinations, or to have obtained a professional designation such as Charted Financial Analyst or CERTIFIED FINANCIAL PLANNER™, or other valid educational background or professional designations as permitted by regulations. Generally, Client assets are managed in investment strategies in which multiple accounts are invested in the same securities with the same allocation. Client assets may also be managed on a custom and/or non- discretionary basis. All Clients have the ability to request reasonable restrictions on how their account is allocated, but Apollon Financial may not be able to accommodate all restrictions based on specific mandates of particular strategies. If Apollon Financial cannot accommodate a requested restriction, the Client will be notified and given the option to withdraw their request, or the Client can work with their IAR to find an investment solution that meets the Client’s expectations. If Apollon Financial is unable to accommodate a Client’s requested restrictions, the Client will need to find another firm to help meet their financial objectives. Unless the Client specifically directs otherwise in their written investment management agreement (the “IMA”), the Client grants Apollon Financial authority to:  use its discretion in determining the types of securities bought and sold, along with the percent allocation,  direct trades to the custodial agent,  reallocate the Client’s portfolio to keep it in line with the Client’s investment goals and risk tolerances,  rebalance the Client’s account periodically to conform to the asset allocation expectations of the individual account,  replace the custodial agent if deemed necessary, after obtaining the Client’s consent,  select the broker-dealer for execution of securities transactions,  hire and fire Sub-Managers,  act as the Client’s agent and attorney-in-fact to receive prospectuses, periodic reports, transaction confirmations, proxy materials, any Sub-Manager Form ADV, Form ADV Part 2A, and other communications from issuers of securities, as applicable, and  deduct investment management fees directly from the Client’s account. The frequency and timing of transactions made in Client accounts may vary significantly, depending on the investment options chosen. Certain investment strategies offered by Apollon Financial were created to limit the amount of trading activity. Other strategies are tactical and adjust depending on micro and macroeconomic indicators. For all models, the Apollon investment team will screen investments using both qualitative and quantitative factors to determine the best fund(s) for each asset class. Qualitative factors include, but are not limited to, the fund’s portfolio management team and any turnover, the stability and financial condition of the firm, and its investment process. Quantitative factors include, but are not limited to, the fund’s expense ratio, performance returns, tracking error versus its benchmark, fund AUM and average trading volume, and other risk/return statistics. See important risk disclosures relating to the management of assets, under Item 8, below. There are several reasons that would cause one client to have a different performance outcome than another client, where their assets are invested in a similar manner. Examples of situations where there would be a difference include, but are not limited to:  Due to custodial restrictions, not all mutual fund share classes are available at each custodian. Therefore, different share classes of the same mutual fund may be purchased for different clients. This creates a conflict of interest, since some clients may pay higher mutual fund expenses than other clients, based on where their accounts are held in custody. To mitigate this conflict, in no instance will Apollon have any benefit based on the share class that is used and will attempt to find the lowest share class available. Additionally, Client’s have the right to change the custodian for their account to access lower costs investment options, where Apollon can reasonably associate with the custodian to provide advisory services.  Custodians may have different mutual fund selling agreements, so certain funds may be available only at certain custodians. If a fund is not available at a custodian, Apollon may select an alternate fund within that custodian’s fund universe.  Certain Exchange Trades Funds (ETFs and ETNs) have no transaction fees at certain custodians. When this is the case, Apollon may replace the model ETF for a similar ETF, in an attempt to reduce costs.  Client request to hold specific securities in their accounts will impact the holdings in the account that is managed to the model.  The investment advisor overseeing the account may request changes to the model for certain Clients, which will impact the performance of the account that is otherwise managed to the model.  The account is managed in a custom manner, different from other Client accounts, for reasons including but not limited to the management of legacy investments, tax considerations, and Client requested accommodations. Apollon Financial also manages a set of Environmental, Social and Governance (ESG) risk-based models across different client risk profiles. In addition to applying the same quantitative and qualitative factors to screen investments, Apollon also considers the fund’s sustainability ratings from third-party research providers as a key criteria to selecting underlying funds. While Apollon Financial leverages third-party research, the Apollon investment team will also conduct its own independent review of individual funds it considers for inclusion in the ESG models. Certain asset classes may not have a universe of funds that can differentiate themselves with sustainability ratings, so the Apollon team will lean more towards its quantitative and qualitative factors in those cases. For the ESG models, Apollon Financial will use both open end mutuals funds and ETFs. Apollon Financial relies on ESG classification of holdings provided by the mutual fund or ETF issuer and does not independently verify that underlying investments are categorized appropriately. As part of Apollon Financial’s management of Client assets, there is a potential that a wash sale might occur. A wash sale negates the taxable advantage of realizing investment losses from the sale of securities. Other strategies attempt to improve the taxable consequence of the assets invested, using tax loss harvesting and other tax management strategies, including Direct Indexing. When deploying tax loss harvesting and other tax management strategies, Apollon Financial does not guarantee the ability to reduce the taxable consequence from managing assets. Further, attempts to reduce the taxable consequence of a portfolio may cause a disparity in the performance of the managed account, because certain assets may not be sold, when they might have been sold if taxes weren’t considered. Clients are urged to work with their IAR to help choose the investment strategy that best meets their goals and objectives. When deciding the appropriate method for executing transactions, Apollon Financial may choose to:  execute all Client transactions at the same time in a block transaction,  stage transactions, and/or  submit each Client’s transaction independently. When trades are placed in a “block” all Client shares as part of that block are aggregated and provided an average execution price. At times, because of the size of a transaction, Apollon Financial, at its discretion, may choose to stage transactions. Staging transactions means that Apollon Wealth, or its trading agent, will submit the transactions for execution at varying times and/or days. This is done to minimize the price movement of the security attributable to the transaction. Other than its authority to request the deduction and payment of agreed upon management fees from the Client’s account, Apollon Wealth does not take or exercise custody of Client assets. Discretionarily managed accounts typically hold a portion of the account in cash or cash like securities. The cash is important for a number of reasons, including but not limited to providing a reasonable buffer to allow for the rebalancing of accounts, to address cash flow needs of the Client, as a means to reduce risk exposure, and to help settle expected purchases. Cash is typically held in the custodian cash sweep account. The interest rate paid to Clients by the account custodian for assets held in sweep accounts may vary significantly from custodian to custodian and can be significantly less than the rate of return available in non-sweep accounts. Clients may request to have cash moved to a different account, with a higher yield, but reducing the cash below a reasonable buffer can cause an account to have insufficient cash available to settle transactions. To address this concern, Apollon Wealth typically has a target cash balance of approximately 1 to 5 percent of the account value. As noted, the actual cash position may be significantly higher at times. Apollon Financial may invest Client assets in Initial Public Offerings (IPOs). When an IPO is made available to Apollon Financial, it is typically in a limited capacity. Typically, an indication of interest is required to be submitted to the underwriter of the IPO. The investment will only be made available to a limited number of Clients that have specifically expressed an interest in investing in IPOs, have had historical experience investing in IPOs or whose IAR believes that the IPO meets the Clients investment objectives. Non-Discretionary Account Management Clients may hire Apollon Wealth to manage their assets in a non-discretionary capacity. Non-discretionary management of assets fall into two categories, a Client’s expectation that transactions are pre-cleared by them before executing changes to a portfolio and transactions that require a Client to sign third-party documents prior to entering into a transaction, such as the purchase of alternative investments (i.e. a private placement or limited partnership). When a Client requests that all transactions be pre-cleared, they do so through their investment management agreement with Apollon Wealth. Sub-Manager Limited Discretion, Provided to Apollon Financial For certain strategies, on a limited discretionary basis, Apollon Financial outsources a portion of the investment selection to independent professional asset managers, who are not affiliated with Apollon Financial, who serve as sub-advisers (“Sub-Manager,” “External Manager,”

or “Sub-Advisor”). A Sub-Manager’s responsibility varies and may include the authority to:  exercise discretion to determine the types of securities bought and sold, along with the percentage allocation  apply their discretion on when to buy and sell  apply their discretion on the timing of transactions  select the broker-dealer for execution of securities transactions, if appropriate and  take other portfolio management actions that Apollon Wealth delegates or deems appropriate. Apollon Financial has also hired third-party non-affiliated advisers, Sub-Managers, to provide research to assist with the investment management of Client assets. These non-affiliated advisers do not have any authority to exercise discretion over the management of Apollon Financial’s Client’s assets. The Client may be required to enter into a separate agreement with the Sub-Manager[s], which will set forth the terms and conditions of the Client’s engagement of the Sub-Manager. Clients grant Apollon discretionary authority to select Sub-Managers. Apollon Financial also assists in establishing the Client’s investment objectives for the assets managed by the Sub-Manager, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated Sub- Manager[s], or research provider, together with the fees charged by the corresponding designated broker- dealer/custodian of the Client’s assets, may be exclusive of, and in addition to, the annual advisory fee charged by Apollon Financial. When working with Sub-Managers, their activities are overseen by the Apollon Financial Investment Committee. As part of the discretionary investment management agreement the Client executes with Apollon Financial, the Client appoints Apollon Financial as a limited power of attorney for the Client’s assets that are invested through Sub-Managers. The limited power of attorney grants Apollon Financial the right to receive certain documents from the Sub-Manager on the Client’s behalf, including but not limited to prospectuses, shareholder reports, privacy notices, proxies and Part 2A of the Sub-Manager’s Form ADV, and other documents. This limited power of attorney granted by the Client may be rescinded by the Client at any time upon written notice to Apollon Financial. Upon request, Apollon Financial will provide Clients with information about any Sub-Manager participating with Apollon Wealth to provide Client services. This information may include content provided by a Sub- Manager explaining its investment style, or an explanation from Apollon Financial describing the Sub- Manager’s investment style. Additionally, Apollon Financial will provide Clients with a copy of the Sub- Managers Form ADV Part 2 upon request. In some instances, the Apollon Financial may utilize Affiliated registered investment advisers (“RIAs”) (as noted in Item 10) models when a Client’s investment objectives are well suited. This practice presents a conflict of interest as the Apollon Financial will benefit from compensation and revenue generated through the RIA’s models. To mitigate this conflict of interest, the Apollon Financial will only utilize the models when Apollon Financial’s believes they are an appropriate option to help meet the Client’s needs. Clients are under no obligation to invest in these models. There is no assurance that other investment options will cost less. LPL Financial Program Apollon Financial provides advisory services through certain programs sponsored by LPL Financial LLC (LPL), a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory program available to Apollon Financial. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. Advisory Services Manager Access Select Program Manager Access Select offers clients the ability to participate in the Separately Managed Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”). In the SMA Platform, Apollon Financial will assist client in identifying a thirdparty portfolio manager (SMA Portfolio Manager) from a list of SMA Portfolio Managers made available by LPL, and the SMA Portfolio Manager manages client’s assets on a discretionary basis. Apollon Financial will provide initial and ongoing assistance regarding the SMA Portfolio Manager selection process. In the MP Platform, clients authorize LPL to direct the investment and reinvestment of the assets in their accounts, in accordance with the selected model portfolio provided by LPL’s Research Department or a third-party investment advisor. A minimum account value of $50,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Apollon Financial will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Apollon Financial will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a lower minimum account size. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. Advisor will also have discretion for selecting third party money managers (PWP Advisors), mutual funds and ETFs within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds, ETFs and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. Apollon Financial will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. Apollon Financial will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department, a third-party portfolio strategist and/or Advisor, through its IAR, may act as a portfolio strategist responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Small Market Solution (SMS) Program Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a series of different investment menus (“Investment Menus”) consisting of a mix of different asset classes and investment vehicles (“investment options”) for clients that sponsor and maintain participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it believes is appropriate based on the demographics and other characteristics of the Plan and its participants. LPL Research is responsible for the selection and monitoring of the investment options made available through Investment Menus. The investment options that are offered through SMS are limited to the specific investments available through the record keeper that the Plan Sponsor selects. The Plan Sponsor may only select an Investment Menu in its entirety and does not have the option to remove or substitute an investment option. In addition to the services described above, Plan Sponsor may also select from a number of consulting services available under SMS that are provided by Apollon Financial. These consulting services may include, but are not limited to: general education, and support regarding the Plan and the investment options selected by Plan Sponsor; assistance regarding the selection of, and ongoing relationship management for, record keepers and other third-party vendors; Plan participant enrollment support; and participant-level education regarding investment in the Plan. These consulting services do not include any individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange- traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although Apollon Financial will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and Apollon Financial by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or Apollon Financial, do not enter into an advisory agreement with LPL, FutureAdvisor or Apollon Financial, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. SWM II Program Although clients do not pay a transaction charge for transactions in an SWM II account, clients should be aware that Apollon Financial pays LPL fees for those transactions. The fees paid by Apollon Financial are a fixed percent of the Client’s assets invested in the SWM II account, which is also called asset-based fees. Because Apollon Financial pays for the transactions in SWM II accounts, Clients should understand that the cost to Advisor may be higher than investment options where Apollon Financial does not pay these fees. As such, Apollon Financial has an incentive to recommend investment options other than SWM II accounts, where it does not pay these fees. In many instances, LPL makes available mutual funds in a SWM II account that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund in SWM II may not be the least expensive share class that the mutual fund makes available, and was selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through SWM II. In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay LPL a 12b-1 fee for providing shareholder services, distribution, and marketing expenses (“brokerage- related services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes, it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time, and keep more of his or her investment returns than an investor who holds Class A Shares of the same fund. Apollon Financial does not get paid any mutual fund 12b-1 fees and is not incentivized to offer, or purchase, a certain share class versus another. Apollon Financial pays asset-based fees to LPL based on the value of the entire account, regardless of the securities held in the account and does not have a direct incentive to choose one share class versus another. The asset-based fee is determined by LPL. When determining the asset-based fee, LPL may consider what underlying assets are typically held in SWM II accounts, including which mutual fund share classes. While LPL may use this as a factor, along with other considerations, there are no expectations or obligations that Apollon Financial use one asset class versus another. It is solely LPL’s decision to determine the underlying assets and the share class. At no time will Apollon Financial accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Plan Advisory Services Apollon Financial provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services can include:  Vendor Analysis  Plan Participant Enrollment and Education Tracking Investment Oversight Services (ERISA 3(21)) Discretionary Investment Management (ERISA 3(38)) Performance Reporting Ongoing Investment Recommendation and Assistance ERISA 404(c) Assistance Benchmarking Services These services are provided by Apollon Financial as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Apollon Financial’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects to receive under the engagement. For certain retirement plans that Apollon Financial provides plan advisory services, Apollon Financial also acts as the discretionary manager for individual plan participants of the plan. When this is the case the plan participant is response for paying Apollon Financial an advisory fee that is separate and distinct from the fee paid to Apollon Wealth by the Plan Sponsor. This presents a conflict of interest, as Apollon Financial is paid from the plan and from the participant. To address this conflict, the participant is under no obligation to hire Apollon Financial to provide the additional services. To receive individualized investment management services, the tplan participant is required to enter into a separate Investment Management Agreement with Apollon Financial. Client-Tailored Advisory Services Client portfolios are managed based on individual Client’s financial situation and investment objectives. Apollon Financial consults with Clients on an initial and ongoing basis to assess their specific risk tolerances, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. If Clients’ financial situations change, or if their investment objectives or risk tolerances change, Clients are advised to promptly notify Apollon Financial of such changes. Clients may impose reasonable restrictions on the management of their accounts if Apollon Financial determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Apollon Financials management efforts. Assets Under Management As of December 31, 2023, Apollon Financial manages $482,318,690 in Client assets, on a discretionary basis.