Item 5 - Additional Compensation .......................................................................................................................... 19 Item 6 - Supervision ..................................................................................................................................................... 19 Item 7 - Requirements for State-Registered Advisors ................................................................................... 19 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 22 Supervised Person – Cristina Hansen ................................................................................................................... 22 Item 2 - Educational Background and Business Experience ....................................................................... 22 Item 3 - Disciplinary Information ........................................................................................................................... 22 Item 5 - Additional Compensation .......................................................................................................................... 23 Item 6 - Supervision ..................................................................................................................................................... 23 Item 7 - Requirements for State-Registered Advisors ................................................................................... 23 Firm Description Freedom Fiduciaries LLC (“Freedom”) was founded in 2022 and became registered as an investment adviser in 2023. Shane Hanson is 95% owner and Chief Compliance Officer. Cristina Hansen is 5% owner. Types of Advisory Services ASSET MANAGEMENT Freedom offers discretionary direct asset management services to advisory Clients utilizing The Betterment for Advisors (“Betterment”) platform for digital services. On this platform, Freedom has the discretion to delegate the management of all or part of the Assets to one or more model investment portfolios developed by third-party Model Portfolio Providers. To the extent utilized, Model Portfolio Providers will have limited power-of-attorney and trading authority over those assets Freedom directs to them for management. Freedom will supervise the Model Portfolio Providers and monitor and review asset allocation and asset performance. Freedom may change Model Portfolio Providers when, in Freedom’s sole discretion, Freedom believes such changes are in your best interest. NON-QUALIFIED DEFERRED COMPENSATION PLANS Freedom may provide non-qualified deferred compensation plans with the following services: Limited Scope Fiduciary. Freedom may serve as a limited scope fiduciary that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor Freedom has a fiduciary duty to act in the best interest of the plan sponsor. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Freedom can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide investment advice to the plan sponsor about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Plan sponsor will make the final decision regarding the initial selection, retention, removal and addition of investment options. Freedom acknowledges that it is a fiduciary.
• Assist the plan sponsor in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Plan sponsor shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the non-qualified default investment alternative (QDIA) for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The plan sponsor retains the sole responsibility to select the investment vehicle for the QDIA and to provide all notices to the Plan participants as required.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with plan sponsor on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Plan sponsor understands Freedom’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Freedom is not providing fiduciary advice to the Plan participants. Freedom will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• One-time consulting services. Freedom may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Freedom and plan sponsor. 3. Freedom has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to Freedom under this Agreement. Full Scope Manager. Freedom can also act as a Full Scope Manager in which it has discretionary management and control of a given retirement plan’s assets. Freedom would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• Freedom has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the plan sponsor with the selection of a broad range of investment options and the regulations thereunder.
• Assist the plan sponsor in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the non- qualified default investment alternative (QDIA) for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The plan sponsor retains the sole responsibility to select the investment vehicle for the QDIA and to provide all notices to the Plan participants as required. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. plan sponsor understands the Freedom’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Freedom is not providing fiduciary advice to the Plan participants. Freedom will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary

under the Plan. Freedom may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Freedom and plan sponsor. 3. Freedom has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to Freedom under this Agreement. ERISA PLAN SERVICES Freedom provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. Freedom may act as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. Freedom may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor Freedom has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Freedom can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. Freedom acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands Freedom’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Freedom is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Freedom will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Freedom may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Freedom and Client. 3. Freedom has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to Freedom on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. ERISA 3(38) Investment Manager. Freedom can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. Freedom would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• Freedom has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands the Freedom’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the Freedom is not providing fiduciary advice as defined by ERISA to the Plan participants. Freedom will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Freedom may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Freedom and Client. 3. Freedom has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs Freedom does not sponsor any wrap fee programs. Client Assets under Management Freedom has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $255,792,124 $8,000,956 December 31, 2023