Firm Description Valeo Financial Advisors, LLC (“Valeo”) is a limited liability company organized in Indiana. We were founded in 2003 and have been registered with the SEC since March 2006. Our principal office is located in Carmel, Indiana. Valeo is entirely owned and managed by our members, with our principal owners being John T. Wortman and John C. Trott. Advisory Services Personal Advisory Services Valeo provides individuals and their families with independent, comprehensive financial planning and investment advice. This generally includes advice related to a client’s business, cash flow, charitable giving, education funding, estate planning, liabilities, insurance, investments, retirement and taxes. Recommendations are tailored to each client’s individual circumstances and, as a result, vary significantly from client to client. As part of the planning relationship, clients have the option to impose restrictions related to certain securities or classes of securities. Meetings with clients are typically agenda driven and focused on client goals, implementation, action items and other proactive recommendations. While investments are important, we help clients manage both sides of their personal balance sheet—assets and liabilities. We work with our client’s existing advisors and may recommend new advisors to fill any voids on their team when appropriate. Institutional Advisory Services Valeo provides institutional advisory services to: trusts, estates, charitable organizations, corporations and other business entities. These services are primarily related to investment management consulting. We assist our institutional clients with the management of their investment decisions and selection of specific investment managers or other service providers. Other Services From time-to-time Valeo advisors may provide pro-bono planning and investment advice services to local and regional non-profits and their clients. Valeo acts as the Manager for a pooled investment vehicle as noted below. However, the pooled investment vehicle is closed to new investors, and Valeo does not receive any compensation for the management of the fund. Valeo’s annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. In the event a client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of the Valeo), Valeo may determine to charge for such additional services pursuant to a stand-alone Financial Planning Agreement (see below). Valeo Financial Advisors, LLC 2 Form ADV Part 2A Brochure Limitations of Financial Planning and Non-Investment Consulting / Implementation Services. As indicated above, to the extent requested by a client, Valeo may provide financial planning and related consulting services. Neither Valeo nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. Valeo does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Valeo, if desired. Valeo does not serve as an attorney, accountant, or insurance agency, and no portion of our services should be construed as such. Accordingly, Valeo does not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.). You are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation that we make. If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Valeo, shall be responsible for the quality and competency of the services provided. It remains the client’s responsibility to promptly notify Valeo in writing if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Valeo’s previous recommendations and/or services. Non-Discretionary Service Limitations. Clients that engage Valeo on a non- discretionary investment advisory basis must be willing to accept that Valeo cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Therefore, in the event that Valeo would like to make a transaction for a client's account (including in the event of an individual holding or general market correction), and the client is unavailable, Valeo will be unable to effect the account transaction(s) without first obtaining the client’s consent. Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Valeo recommends that a client roll over their retirement plan assets into an account to be managed by Valeo, such a recommendation creates a conflict of interest if Valeo will earn new (or increase its current) compensation as a result of the rollover. If Valeo provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Valeo is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Valeo, whether it is from an employer’s plan or an existing IRA. Valeo Financial Advisors, LLC 3 Form ADV Part 2A Brochure Unaffiliated Private Investment Funds. Valeo may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Valeo’s role relative to the private investment funds is limited to its initial and ongoing due diligence and investment monitoring services. Valeo’s clients are under absolutely no obligation to consider or make an investment in any unaffiliated private investment fund. Valuation. If Valeo bills an investment advisory fee based upon the value of unaffiliated private investment funds or otherwise references unaffiliated private investment funds owned by the client on any supplemental account reports prepared by Valeo, the value for all unaffiliated private investment funds owned by the client will reflect the most recent valuation provided by the fund sponsor. The current value of any unaffiliated private investment fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report. Risk Factors. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Private Investment Fund Conflict of Interest. Valeo has and will continue to introduce its clients to private funds that are affiliated with other Valeo clients, thereby creating a conflict of interest. Valeo has an economic incentive to introduce such funds to its clients, because the introduction would benefit the other Valeo clients from whom. Valeo currently earns investment advisory fees that could increase as a result. Given the conflict of interest, Valeo advises all affected clients to consider seeking advice from independent professionals (i.e., attorney, CPA, etc.) of their choosing before becoming a fund investor. Valeo also reminds its clients that they are not under any obligation to become a private fund investor. Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange- traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Valeo), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Valeo does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, Valeo shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Valeo Financial Advisors, LLC 4 Form ADV Part 2A Brochure Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin, Valeo will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services and uses an online ledger with strong cryptography (i.e., a

method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, Valeo will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Valeo does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Valeo considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Asset Aggregation / Reporting Services. In conjunction with the services currently provided by ByAllAccounts, Inc., Valeo may provide access to reporting services that can reflect all of the client’s investment assets, including those investment assets that are not part of the assets managed by Valeo (the “Excluded Assets”). Valeo’s service relative to the Excluded Assets is limited to reporting service access only, which does not include investment implementation. Because Valeo does not have trading authority for the Excluded Assets, the client (and/or another investment professional), and not Valeo, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. Further, the client and/or their other advisors that maintain trading authority, and not Valeo, shall be exclusively responsible for the investment performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party reporting platform may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by Valeo. Accordingly, Valeo shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the third-party reporting platform without Valeo’s participation or oversight. Portfolio Activity. Valeo has a fiduciary duty of loyalty and care, and to provide services consistent with the client’s best interest. As part of its investment advisory services, Valeo will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, the economy, fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Valeo determines that changes to a client’s portfolio are neither necessary nor prudent. Valeo’s advisory fee shall remain due and payable during any such inactive periods. There can be no assurance that those or other investment decisions made by Valeo will be profitable or equal any specific performance level(s). Independent Managers. Valeo may recommend that the client allocate a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to-day Valeo Financial Advisors, LLC 5 Form ADV Part 2A Brochure responsibility for the active discretionary management of the allocated assets. Valeo will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Valeo generally considers the following factors when recommending Independent Manager(s): the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s) are exclusive of, and in addition to, Valeo’s ongoing investment advisory fee, subject to the terms and conditions of a separate agreement between the client and the Independent Manager(s). Valeo’s advisory fee is set forth in the fee schedule at Item 5 below. Availability of Mutual Funds. While Valeo may allocate investment assets to mutual funds that are not available directly to the public, Valeo may also allocate investment assets to publicly available mutual funds that the client could purchase without engaging Valeo as an investment adviser. However, if a client or prospective client determines to purchase publicly available mutual funds without engaging Valeo as an investment adviser, the client or prospective client would not receive the benefit of Valeo’s initial and ongoing investment advisory services with respect to management of the asset. Cross Transactions. In limited circumstances, Valeo may arrange for cross- transactions pursuant to which Valeo may cross transactions between two of its managed client accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when Valeo believes that such transactions are beneficial to its clients). For all such transactions, neither Valeo nor any related person will be acting as a broker or receive any commission or transaction-based compensation. The client may revoke Valeo’s cross-transaction authority at any time upon written notice to Valeo. Cash Positions. Valeo continues to treat cash as an asset class. As such, unless determined to the contrary by Valeo, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Valeo’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Valeo may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Valeo’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Valeo shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Valeo reasonably anticipates that it will utilize the cash proceeds during the subsequent 30- day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Valeo Financial Advisors, LLC 6 Form ADV Part 2A Brochure The above does not apply to the cash component maintained within a Valeo actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Valeo unmanaged accounts. Client Obligations. In performing our services, Valeo shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Valeo in writing if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that Valeo and its third-party service providers use to provide services to Valeo’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Valeo’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Valeo are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Valeo has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Valeo does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Disclosure Statement. Copies of Valeo’s written disclosure statement and client relationship summary, as set forth on Form ADV Part 2 and Form CRS respectively, are provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. Valeo provides investment advisory services specifically tailored to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Valeo will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Valeo’s services. Valeo does not participate in a wrap fee program. As of December 31, 2023, Valeo managed $8,944,535,606 in assets. Approximately $6,976,619,300 is managed on a discretionary basis, and $1,967,916,306 is managed on a non-discretionary basis. Valeo Financial Advisors, LLC 7 Form ADV Part 2A Brochure