9AT: ATHENA INVESTMENT MANAGEMENT

ATHENA INVESTMENT MANAGEMENT

ATHENA INVESTMENT MANAGEMENT

Adviser Profile

As of Date	03/31/2026
Registration	SEC, Approved, 06/16/1977
Other registrations (1)	California, Cancelled, 04/01/2004
Contact Info	925 xxxxxxx

AUM^*	342,122,662 28%
of that, discretionary	341,411,210 28%
Number of Employees	5 -17%
of those in investment advisory functions	1
Private Fund GAV^*	0
Avg Account Size	857,450 26%
% High Net Worth	50.00% 4%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Charitable organizations
- Corporations or other businesses not listed above

Advisory Activities

- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)

Reported AUM

341M 293M 244M 195M 146M 98M 49M

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Form ADV-E Surprise Examination Reports

Accounting Firm Name	Filing Date	Form ADV-E
Accounting Firm Name ERNST WINTTER & ASSOCIATES LLP	Filing Date03/06/2026	Form ADV-E View Report
Accounting Firm Name ERNST WINTTER & ASSOCIATES LLP	Filing Date03/12/2025	Form ADV-E View Report
Accounting Firm Name ERNST, WINTTER & ASSOCIATES, LLP	Filing Date03/26/2024	Form ADV-E View Report

Brochure Summary

Overview

Athena Investment Management is an independent investment advisory firm managing securities portfolios for individual and institutional clients. Its owner and sole principal is Jack E. Andrews III. He has owned the business since June 30, 1995. The business was founded in 1977 in Pasadena, California by Jack E. Andrews Jr. Athena Investment Management provides comprehensive investment advisory and management services. These include: Preparing and executing a suitable investment plan for each client; providing clear progress reports on a regular basis; advising and facilitating account creation, funding and distributions to optimize tax considerations and to resolve estate matters; maintaining and distributing records necessary for tax filings associated with investment accounts; and maintaining an open dialogue with clients in order to adjust planning as necessary. Client portfolios are managed with the objective of achieving the maximum, long-term, after-tax total return possible given the client’s income and liquidity needs, risk tolerance, time horizon, and tax considerations. Client portfolios are managed individually and are not commingled. There are similarities across

accounts, particularly in security selection, as, when building portfolios of domestic large-cap stocks, Athena focuses on a distinct universe of 100 companies. Similarly, among mutual funds, there is a strong tendency for clients to hold similar funds which meet key criteria for performance, volatility, cost, availability, etc. The exact mixture of securities held in each portfolio, however, is determined by the investment allocation plan specific to that portfolio, which is in turn determined by that client’s risk tolerance and the specific portfolio’s investment horizon and cash flow projections. Individual client preferences regarding specific securities or industries to be avoided or emphasized are accommodated if and when they are not considered to detract materially from prospects for long-term, risk-adjusted performance. As of 12/31/23, assets under management totaled $267.2 million. Of this total, Athena Investment Management had discretionary authority to execute trades over $266.4 million in assets and did not have discretionary authority over $0.8 million in assets under management. Athena Investment Management does not participate in any wrap fee programs.