AIM provides asset allocation and investment management services generally on a discretionary basis to individuals and other clients regarding securities in accordance with such client’s investment objectives and financial circumstances and AIM’s own investment and allocation methodologies. AIM manages client accounts generally through two venues: 1) Client transactions are generally affected through AIM’s affiliate, Axiom Capital Management, Inc. (“Axiom Capital”), a broker-dealer registered with the Securities and Exchange Commission (“SEC”) and FINRA, which is compensated in such capacity by receiving commissions and similar transaction fees, charges and compensation (collectively, “commissions”). Client transactions are cleared on a fully disclosed basis by Hilltop Securities Inc. (“HTS”), which acts as the custodian of these accounts. Additionally, AIM may have a sub investment manager manage funds for client accounts domiciled at Axiom Capital through a company called Envestnet which has thousands of money managers on its platform. As an adviser, AIM generally charges an annual management fee, generally payable monthly or quarterly in advance and may also charge performance-based compensation, generally payable annually in arrears. The large majority of AIM’s accounts are managed through this venue. 2) Client brokerage accounts that AIM manages may also be held away at an unaffiliated custodian, bank, or broker dealer other than as set forth above. In this case the broker-dealer with respect to client transactions may be compensated in such capacity by receiving commissions and similar transaction charges. As an adviser, AIM generally charges an annual management fee, generally payable monthly or quarterly in advance and may also charge performance-based compensation, generally payable annually in arrears. AIM also acts as “investment manager” as defined by Section 3(38) of the Employee Retirement Income Security Act of 1974, offering 3(38) manager program services (“3(38) Manager Program Services”) to qualified plan sponsors (“3(38) Program Sponsors”). AIM’s 3(38) Manager Program Services include providing a “model line-up” of investments for each 3(38) Program Sponsor to make available to its plan participants. Plan participants may choose the model line-up option, or other (non-AIM related) investment alternative options offered by the 3(38) Program Sponsor. AIM’s 3(38) Manager Program Services provide that AIM has “discretionary power,” however, such discretionary power is limited to adding or removing investments in the model line-up (i.e., discretion to change the model line-up only). Under AIM’s 3(38) Manager Program Services, AIM has no discretion over any plan participant’s account or the 3(38) Program Sponsors. The 3(38) Program Sponsors, not AIM, are responsible for causing the account to be invested pursuant to the investment option chosen by each plan participant. Consequently, AIM does not include 3(38) Manager Program Services in its calculation of assets under discretionary management and considers them assets under advisement. As of March 15, 2024, AIM manages $213,656,014 on a discretionary basis and does not manage any assets on a non-discretionary basis. As of December 31, 2023, AIM has assets under advisement of $31,529,238. For purposes of the Form ADV Part 1, Item 5.D., 5.F. and 5.K.(1), the regulatory assets under management, types of clients and related information is as of March 15, 2024. Additional Advisor Information: Liam Dalton is the Managing Member and an employee of AIM. Advice rendered by Liam Dalton and advisory personnel under his review is rendered on behalf of AIM. Liam Dalton is a registered person and owner of Axiom Capital and is also compensated by Axiom Capital through a share of its commissions, including for AIM accounts which are charged commissions by Axiom Capital. Robert Doyle is an employee of AIM. Advice rendered by Robert Doyle and advisory personnel under his review is rendered on behalf of AIM. Robert Doyle is a registered person of Axiom Capital and is also compensated by Axiom Capital through a share of its commissions, including for AIM accounts which are charged commissions by Axiom Capital. Additionally, Robert Doyle separately manages assets of a private fund under an entity named “Iron Pier Advisors, LLC” (“Iron Pier”). Assets managed by Robert Doyle under Iron Pier are outside of AIM and are NOT overseen by AIM. Iron Pier is a separate and distinct investment adviser. Jeffrey Mosseri is an employee of AIM, and advisory personnel under their review, conduct their advisory services for AIM under the name of AIM. Assets managed by Jeffrey Mosseri under AIM are overseen by AIM. Additionally, Jeffrey Mosseri separately manages assets under an entity named “Greystone Asset Management LLC” (“Greystone”). Assets managed by Jeffrey Mosseri under Greystone are outside of AIM and are NOT overseen by AIM. Greystone is a separate and distinct state registered investment adviser. Jeffrey Mosseri is a registered person of Axiom Capital and also compensated by Axiom Capital through a share of its commissions, including for AIM accounts which are charged commissions by Axiom Capital. Other AIM employees or supervised persons are also registered with Axiom Capital and through Axiom Capital receive a portion of the commissions generated by their client accounts. Clients are encouraged to ask questions of their AIM adviser about their account and its fees and charges, role of and compensation to Axiom Capital and of the compliance and operations at AIM. There are risks and potential advantages or disadvantages regarding each advisory product (“Advisory Product”). Depending upon a client’s investment objectives and financial circumstances, and the amount, type and frequency of transactions, and the fees and commissions charged, certain Advisory Products may be more advantageous to a particular client than other Advisory Products. For example, accounts with lower advisory fees and greater commissions which trade more actively may be paying greater overall charges than similar accounts which do not trade as frequently. As agreed to with a client, certain accounts will not be charged a separate advisory fee but will pay one fee for both advisory and brokerage (i.e., a wrap fee program) or will be charged only commissions through Axiom Capital/HTS (i.e., a commission-only account). For example, depending upon trading frequency and amount of commissions paid, clients with commission-only accounts should consider whether to switch to a fee plus commission account (where the fee plus discounted commissions may be less over time than the non-discounted or less discounted commissions charged in the commission-only account). Clients are free to change at any time to a new Advisory Product. AIM’s overall compensation will change depending upon which Advisory Product is selected and accordingly, depending upon the frequency, amount and type of trading, AIM has a conflict of interest regarding which Advisory Product is selected by a client as it has an incentive to seek to maximize its compensation while the client has an incentive to seek to pay the least amount for the same or substantially similar advisory (and brokerage) services. This is especially pronounced when multiple Advisory Products (including share classes of the same mutual fund) are available to the client and provide different compensation to AIM or the AIM adviser because the Advisory Products (including share classes) differ only in their (direct or indirect) costs to the client and their benefits to AIM or the AIM adviser. AIM also has a conflict of interest with respect to Axiom Capital and AIM personnel who are registered with Axiom Capital. Unless it is a fee-only account with no commissions charged, or it is a client account which uses another broker-dealer, Axiom Capital, an affiliate of AIM, receives commissions from transactions in client accounts where Axiom Capital acts as broker-dealer; this includes sales loads or fees (whether front end or back end or otherwise) and similar charges in relation to mutual funds (including money market funds). Registered persons at Axiom Capital, some of whom are also employees or supervised persons of AIM, receive a portion of the commissions that Axiom Capital receives. Receipt of 12b-1 fees by its affiliate Axiom Capital (and by individuals registered with Axiom Capital who also are associated with AIM) in connection with a mutual fund purchase also creates a conflict of interest in that it creates a financial incentive to receive or continue to receive such fees. While 12b-1 fees do not directly affect a client’s initial investment and are disclosed in the fund prospectus, such fees

are paid by the fund from its assets and thereby indirectly affect the value of a client’s overall investment. While Axiom Capital historically had received a portion of 12b-1 fees generally up to 1% of the average net fund assets per year for mutual funds in client accounts, for the past few years AIM strives to choose mutual funds or eligible share classes in which 12b-1 fees are not shared with Axiom Capital but that otherwise meet a client’s suitability. If AIM is unable to find a comparably suitable mutual fund or eligible share class that does not pay 12b-1 fees, then AIM will choose the most suitable mutual fund or eligible share class for the client among the funds and classes that pay 12b-1 fees and Axiom Capital shall then rebate to the client’s account the portion of 12b-1 fees it receives. The foregoing includes money market funds used for sweep, cash management or other purposes. AIM also has a conflict of interest regarding the use of Axiom Capital as it generally has an incentive to seek to maximize the compensation of its affiliate (especially given that certain AIM employees are also registered with Axiom Capital) while the client has an incentive to seek to pay the least amount for the same or substantially similar brokerage services. In addition, representatives of AIM, directly through AIM and/or through Axiom Capital, receive additional or different compensation depending upon such factors as the Advisory Product selected by the Client, the compensation Axiom Capital charges, the type of account, the types of instruments traded, and negotiated agreements with AIM and/or Axiom Capital. Accordingly, a conflict of interest exists in that there is an incentive for AIM representatives to select one Advisory Product over another Advisory Product if one provides more compensation to that person or to AIM or Axiom Capital. Regarding mutual funds that may be selected for client accounts: There are different share classes available (although certain clients such as retail clients may not be eligible for classes appropriate for institutional clients), and different classes can charge different fees (directly through the investment or indirectly by the fund paying a distribution, marketing and/or service fee (such as a 12b-1 fee)). AIM (and its affiliate Axiom Capital) has a financial interest in the choice of share classes (i.e., to maximize compensation) that conflicts with the interests of clients (i.e., to reduce expenses). Not every mutual fund is available on every platform and a client’s choices are limited by the choices available through HTS. AIM selection of mutual funds is not dependent upon whether it is an initial or later recommendation or a recommendation to buy more shares. When choosing mutual funds AIM (and individuals at AIM/Axiom Capital) strives for the most suitable for the client under the circumstances, taking into account what funds are available, share classes with different fee structures, expense ratios and other factors. The fee schedules noted in Item 5 are general guidelines and may vary from client to client and advisor to advisor with respect to annual fee percentage, assets under management, commissions, and percent of net profits. Each client’s account is governed by the actual fee schedule (or fee and commission schedule) agreed upon, not by any general or standard fee (or fee and commission) guidelines or schedules. Axiom Capital’s and HTS’ standard undiscounted brokerage commissions/transaction costs for client transactions are disclosed to clients, in the form of an approximated commission schedule, prior to or at the time that the client enters into an advisory relationship. Commissions on accounts held away from Axiom Capital and HTS are not known to AIM, and AIM has no control over commission charges for these accounts. In some instances, a client’s account may be traded on margin. While AIM does not normally recommend trading on margin, some investment strategies do require the use of a margin account. AIM has a financial incentive if clients trade on margin because Axiom Capital as the broker-dealer also may receive additional compensation regarding a client’s margin account. Use of margin may commence upon receipt of written authorization from the client to do so. A margin account provides for the ability to borrow money from a brokerage firm. As clients of AIM and customers of Axiom Capital, clients utilizing margin are borrowing money from HTS. The amount of money borrowed is charged interest at competitive rates. These rates can and do change; generally with the change in the Fed Funds and Prime rates. Generally, a portion of margin interest charged to client accounts will be received by Axiom Capital from its clearing agent. This is called interest fee sharing. A full explanation of margin and the risks involved can be provided upon written request, or at Axiom Capital’s web site (www.axiomcapital.com). Axiom Capital also receives additional compensation regarding client credit balances from HTS and as such AIM has a financial incentive if clients maintain credit balances. Credit balances (such as held as cash or in money market funds) will generally earn interest except in a low interest rate environment. The amount of interest earned by the client is at then competitive rates. These rates can and do change; generally with the change in the Fed Funds and Prime rates. Generally, a portion of the credit interest earned on client credit balances will be received by Axiom Capital from its clearing agent HTS or the money market funds used for such credit/cash balances. This is also called interest fee sharing. The existence of, or amounts shared under interest fee sharing does not reduce the rate of interest clients receive on cash or in money market funds. Axiom Capital may also receive additional compensation as payment for order flow (see Item 12). AIM addresses the conflicts described in this Item 4 through disclosure (including herein and other client disclosures or agreements), discussions with the client regarding alternatives (whether accounts, securities or share classes) and by attempting to minimize these conflicts by, as applicable, reducing the occurrences in which they arise, being aware of the conflict so as to reduce its impact, decreasing or considering differences in the rates of commissions charged or amounts of compensation received, more closely evaluating factors other than those in which AIM or Axiom Capital has a financial incentive, rebating in the case of 12b-1 fees as well as striving to provide the client with an account, securities and services (and accompanying fees) (and commissions if applicable) that is most suitable on an overall basis for the client subject to the limitations described herein (such as the use of Axiom Capital if no other broker has been selected by the client or the HTS platform) and its fiduciary duties. Additional fees may be applied or charged to client brokerage accounts with Axiom Capital for any number of reasons (i.e. settlements other than “regular way”, short interest/debit fees for hard to borrow securities, transfer fees, etc.) Please refer to the brokerage customer agreement and other brokerage disclosures for explanations of fees. Additionally, advisory fees and commissions are negotiable at the discretion of AIM, and commissions are negotiable at the discretion of Axiom Capital, depending upon a variety of factors including, among other things, type of Advisory Product offered, amount of assets under management, the overall relationship with the client, other services offered to the client, prior relationship between the client and AIM’s investment managers and the types and extent of trading for the account. Clients are encouraged to inquire with their AIM adviser and any other personnel of the Firm as to any and all commissions, fees and compensation received by AIM, Axiom Capital and their AIM advisor. Clients may terminate advisory services at any time without penalty generally upon fourteen (14) calendar days prior written notice. Fees charged in advance will be prorated for any partial period upon review and accounting and will be refunded for any partial period upon termination. Fees charged in arrears will also be prorated for any partial period and charged accordingly. AIM may or may not retain the authority to vote proxies. For those advisors that do not retain authority to vote proxies, all proxies solicited by management of corporations with respect to the securities that are registered in a client’s name or in nominee’s name for a client will be mailed to the client by the custodian (or forwarded by AIM to the client) for the client to vote. AIM is not required to take any action or render any advice with respect to voting proxies on securities held in any client’s account.