This brochure explains Navellier’s advisory business and provides important information about our operations. We encourage you to read this brochure completely and carefully. You may contact us at the number provided on the cover page if you have any questions or to request another copy of this brochure, free of charge. Navellier registered with the SEC in 1987 as a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). We provide investment advisory services and manage investment advisory accounts for taxable and tax-exempt clients, including individuals, trusts, estates, charitable organizations and endowments, professional and religious organizations, corporations, pension plans, Taft-Hartley plans, and open-end investment companies. We are headquartered in Reno, Nevada. Navellier is independent and 100% owned by Louis G. Navellier. Individual Portfolio Management Navellier specializes in the quantitative construction of securities portfolios covering a broad range of investment styles (growth, value, international, global, and combinations of these) and market capitalization (micro, small, mid, large, and combinations of these). We use a multi-step screening process that incorporates fundamental and quantitative analysis to construct our portfolios. We primarily manage accounts on a discretionary basis and have full authority in determining which securities are purchased and sold. On a case-by-case basis, we will tailor our advisory services to the individual needs of clients. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry groups. All portfolios are reviewed on a monthly or quarterly basis, and if necessary, the portfolio will be rebalanced. We also offer accounts on a non-discretionary basis. Navellier participates in certain Wrap Fee or Managed Account Programs in which clients pay an “all-in” fee that includes brokerage fees and charges and our management fee. Navellier may not have discretionary authority to select the brokerage firm or the commission rates to be paid for Wrap Fee or Managed Account Program accounts we manage. In addition, some clients direct Navellier to use a particular broker (i.e., a custodian broker, a Wrap Fee or Managed Account Program broker, a referring broker, or simply the client’s personal choice). In all these cases, the client may pay a higher commission or receive smaller discounts than if Navellier had discretion to choose a broker or may receive a worse price for the security than other clients for the same security. (Please refer to Item 12, Brokerage Practices, for more information regarding brokerage selection.) Navellier offers the following strategies:  Navellier Large Cap Growth  Navellier Small-to-Mid Cap Growth  Navellier Mid Cap Growth  Navellier Small Cap Growth  Navellier All Cap Core  Navellier Fundamental ‘A’  Navellier Power Dividend  Navellier Select Dividend Income  Navellier Vantage  Navellier Defensive Alpha Portfolio  Navellier Libertas 30  Navellier High Dividend Income  Navellier Tactical U.S. Equity Sector Plus featuring AlphaDEX®  Navellier Tactical Global Allocation Plus  Navellier Covered Call Income  Navellier Concentrated Covered Call Income  Navellier Concentrated Covered Call Growth From time to time, Navellier will construct a customized portfolio upon request and at our discretion. (Please review Item 8, Methods of Analysis, Investment Strategies, and Risk of Loss, for more detailed information regarding the strategies listed above.) Money market reserves or cash equivalents will typically range between 0% and 20% for managed accounts Our Covered Call, Large Cap Tactical, Power Dividend, Defensive Alpha, and Navellier Tactical strategies may take higher money market reserves or cash equivalent positions. (Please see Item 8, Methods of Analysis, Investment Strategies, and Risk of Loss, for more information.) Research Assistance Navellier receives research from several persons or entities, which Navellier may or may not use in connection with its exercise of investment discretion as to the following Navellier

strategies: Defensive Alpha Portfolio: Navellier receives investment research which it may or may not use in connection with our Navellier Defensive Alpha Portfolio. The Langsen Group provides this research to Navellier. Navellier pays a fee to The Langsen Group for its research. (Please review Item 8, Methods of Analysis, Investment Strategies, and Risk of Loss, or the firm’s website, www.navellier.com, for more detailed information regarding the strategy.) Navellier Tactical Strategies: Until March 1, 2019, Navellier, as part of its own research and Management received investment research from Helix Technology® Ltd., which we had discretion to follow, not follow or modify, to manage our Navellier Tactical strategies. Navellier no longer uses any of that research. The strategies were and still are based on our internal research and management with no material change in management of these strategies. Navellier Tactical products include the following strategies:  Navellier Tactical U.S. Equity Sector Plus featuring AlphaDEX®  Navellier Tactical Global Allocation Plus  Navellier Libertas 30 Signals: Navellier also provides for a fee to investment advisors and brokers on a periodic basis signals as to what trades Navellier has made for particular Navellier investment strategies. We do not have investment discretion over the accounts managed by these investment advisors or brokers. We do not have trading, advisory, or any other responsibilities for their portfolios, which we do not manage. We do not have an advisory relationship with these investment advisers’ or brokers’ clients. Private Client Group Navellier reviews the financial situation and goals of interested individual investors and offers them a customized, diversified investment portfolio designed to attempt to achieve their indicated investment goals using various Navellier strategies. (Please review Item 8, Methods of Analysis, Investment Strategies, and Risk of Loss, for more detailed information regarding Navellier’s investment strategies.) Although each client’s portfolio is unique, most clients can be grouped into four broad categories according to their goals and risk tolerances: Conservative Income, Conservative Blend, Moderate Blend, and Aggressive. We then personalize from the broad categories based on what we believe best suits the client’s investment goals and risk tolerances and create a custom Navellier strategy mix. We will not take physical custody of client’s assets, so clients must have an account with a brokerage firm or qualified custodian. There is no charge or obligation to clients for us to review and offer investment options. Private Client Group clients can choose to pay either an annual fixed fee based on the value of the clients’ assets under management or a performance based fee (if they qualify) for our investment advisory services. Please refer to Item 6, “Performance-Based Fees” and “Performance-Based Fee Disclosures” below for all qualifications and more information. Advisory Services In addition to providing the above investment advisory services, Navellier is a consultant for Advisors Asset Management, Inc. (“AAM”). AAM sponsors, underwrites, and distributes a wide array of unit investment trusts (“UITs”), including Navellier/Dial High Income Opportunities. Navellier selects debt or equity securities according to selection criteria set by AAM for inclusion in the UIT series. In the case of the Navellier/Dial High Income Opportunities series, Navellier has a contract arrangement with Dial Capital Management, LLC for assistance selecting securities. Navellier’s assets under management do include UIT assets; they are categorized as non- discretionary. Navellier also occasionally manages custom accounts by request. Assets Under Management As of December 31, 2023, Navellier actively manages $743,578,818 in client assets on a discretionary basis and manages $96,546,320 in client assets on a non-discretionary basis (the non-discretionary assets are AAM UIT assets).