ABOUT US Founded in 2006, Brookstone Capital Management, LLC ("BCM") is an investment advisory firm providing fee- based asset management services through its investment advisor representatives ("IARs") of BCM and IARs of its affiliate, Brookstone Wealth Advisors, LLC (also known as Retirement Wealth Advisors or RWA). BCM also provides these services to unaffiliated registered investment advisors (“RIAs”) and their IARs who wish to have access to BCM’s Platform of products and services (hereinafter, “Outside RIAs”; collectively referred to as “Advisors”). BCM offers its services through a turnkey asset management program (“TAMP”) known as the "BCM Platform" or "Platform" and is sponsor of the BCM Wrap Account Program. Outside RIAs that engage BCM for the Platform will be required to execute a Selling Agreement and Solicitor’s Agreement with BCM for these services. Through these agreements, BCM is appointed as a third-party asset manager with full discretion to perform investment management services to the Outside RIA's clients and appoints the Outside RIA to serve as a solicitor for BCM's Platform. Details relating to the BCM Platform are outlined below. BCM is an investment advisor registered with the SEC, and is directly owned by AL BCM, LLC ("AL BCM"), a Delaware domiciled limited liability holding company. AL BCM is majority owned by Dean Zayed and AL Marketing, LLC (AmeriLife). Mr. Zayed received his Bachelor of Arts Degree in Economics from Northwestern University. He completed the Business Institutions Program, the undergraduate Leadership Program and was a member of Omicron Delta Epsilon Economics Honor Society. He received his Juris Doctor degree from Northwestern University School of Law. He received his Master’s Degree in Taxation (LLM) from Chicago-Kent College of Law. Dean is a Certified Financial Planner (CFP®) and holds an Illinois insurance license for life, health and long-term care, in addition to being an IAR. Mr. Zayed is the CEO of BCM and provides the firm with principal management. AL Marketing, LLC is a sub-division of AmeriLife Holdings, LLC (“AmeriLife”). AmeriLife is a Florida domiciled insurance company that markets and distributes annuity, life and health insurance products and is a portfolio company of Thomas H. Lee Partners, L.P, a private equity firm and Genstar Capital Partners, LLC, a private equity firm located in San Francisco, California (“Genstar”). INVESTMENT ADVISORY FIDUCIARY STANDARD As investment advisors, BCM and its IARs act as fiduciaries for all of our investment management clients. This means that we have an obligation to act in the best interests of our clients and to provide investment advice in the clients’ best interests. While BCM strives to not engage in activities that create a conflict of interest with our clients, if a conflict of interest does arise, we will disclose that conflict to the client. Reasonable care is employed by BCM and Advisors to avoid misleading clients and full and fair disclosure of all material facts (including fees) are made to our clients and prospective clients. We fulfil our fiduciary obligations by collecting information about you and your investment goals so that our recommendations are customized to be in your best interests. We disclose our services, advisory fees, compensation arrangements and material conflicts of interest within this brochure and in the client agreement (Investment Policy Statement parts A and B) which are acknowledged by your signature. THE BCM PLATFORM As mentioned above, BCM offers the BCM Platform through its IARs, affiliated IARs and through Outside RIAs, each of which is responsible for implementing the Platform on behalf of its clients. BCM also sponsors a wrap-fee program. Please refer to BCM's Appendix 1 Wrap Brochure, for more information related to the firm's wrap-fee program. Models recommended as part of the Platform may include funds managed by BCM’s affiliated investment advisor, Brookstone Asset Management (“BAM”). Thus, a conflict exists. When BCM invests assets in your account in shares of our affiliated mutual funds and ETFs, you are subject to those funds’ internal management fees and other expenses in addition to the annual management fee you pay us for advisory services. This additional compensation that we earn from the internal management fees on our proprietary funds creates a conflict of interest FORM ADV PART 2A – DISCLOSURE BROCHURE Page 5 of 28 by incentivizing us to use our funds instead of unaffiliated mutual funds and ETFs. We seek to mitigate this conflict of interest by disclosing this additional compensation to you and providing advisory fee discounts, which together help ensure transparent and fair pricing to our clients. Specific management fee and related expense information for the funds are found in the prospectus. Please refer to Item 10 of this Brochure for more information regarding this BCM affiliate. ANNUITY RECOMMENDATIONS Most BCM investment advisor representatives (IARs) also provide insurance or annuities to their clients when appropriate. Insurance, including fixed index annuities, are not offered through BCM but are sold by insurance licensed agents using various insurance companies. The issuing insurance companies are not affiliated with BCM. However, sometimes the fixed insurance product could be used as a replacement or alternative to the BCM fixed income portion of a portfolio. However, annuity products present their own differences from traditional fixed income securities, such as bonds, including, but not limited to liquidity, tax implications, and underlying fees. Unlike bonds, there is no secondary market for annuity products. Annuities also may be subject to caps, restrictions, fees and surrender charges as described in the annuity contract. Any annuity guarantees are backed by the financial strength and claims paying ability of issuer. BCM does not charge management fees on commission based fixed index annuities. However, if the IAR/insurance agent implements an insurance transaction, the agent will receive a sales commission from the recommendation of an insurance product, like a fixed index annuity. This creates a conflict of interest since the IAR/insurance agent is incentivized and earns insurance commission(s) for implementing insurance product recommendations. This conflict is mitigated by the IAR/insurance agent always acting in the best interest of the client and providing full and frank disclosure to the client when such a conflict exists. If a BCM IAR is licensed as an insurance agent and makes a recommendation for transacting in a fixed annuity and/or life insurance product, this gives rise to conflicts of interest due to the fact that such BCM IAR is receiving remuneration in the form of commission and in some cases, other compensation (such as a percentage of an organizations’ profits for selling fixed annuities and/or life insurance) which incentives such IAR to sell that product. BCM IARs mitigate this conflict by making recommendations that are in the client’s best interest and are suitable for them based on their investment objectives and needs outlined in the client’s investment policy statement. SERVICES WE OFFER BCM provides Asset Management and Financial Planning Services for its clients, each of which is described more fully below. Clients collaborate with Investment Advisor Representatives (IARs) to determine which services to employ to best help clients reach their financial goals. Asset Management Services BCM’s principal service is providing fee-based investment advisory services through the BCM Platform. BCM manages investment portfolios, on a discretionary basis, depending on the particular custodial account, either based in a wrap-fee program or transaction-based program, and according to the client’s objectives. BCM obtains data from potential clients addressing financial objectives, needs, risk tolerance, investment horizon and other pertinent information. This information is gathered and reported on an Investment Policy Statement (IPS) and Risk Profile Questionnaire and is analyzed by BCM IARs or RIAs. Once the analysis is completed, the IAR or RIA develops an investment strategy with the client that addresses specific investment styles and allocation of the client’s assets. BCM may use a combination of equities, mutual funds, exchange traded funds, structured products (including certificates of deposit and notes), individual bonds, and options in securities to accomplish these objectives. BCM may partner with Sub-Advisory firms to create and manage portfolio strategies. A client’s portfolio is allocated according to the client’s risk profile and documented on the IPS. BCM generally uses Unified Managed Accounts (UMA) whenever possible. This allows for multiple strategies to be managed and held within the same account. Accounts holding options cannot participate in UMA. In addition, BCM offers discretionary Asset Management Services to clients through customized individual FORM ADV PART 2A – DISCLOSURE BROCHURE Page 6 of 28 investment accounts (aka separately managed accounts). In such accounts, BCM transacts in mutual funds, ETFs, equities, fixed income securities and other securities pursuant to the client’s IPS information. Asset Management Clients are encouraged to refer to the individual mutual fund or ETF prospectus for the risks associated with each specific fund. Another asset management service available, the RAISE 360 Portfolios, consists of pre-selected model portfolio allocations created by BCM and its investment team to align with specific risk tolerances. These portfolios typically contain mutual funds, exchange traded funds, equities, and other securities authorized by BCM, and are managed on a discretionary basis by the BCM investment

team pursuant to investment objectives as chosen by the client via the Risk Profile Questionnaire. Please see Items 5, 8 and 10 of this Brochure for more information related to our asset management fees, risks and conflicts of interest. Financial Planning Services Through its IARs, BCM also offers comprehensive financial planning services for individuals, families, and businesses. Our Financial Planning services include data gathering and analysis, along with creating a financial plan with specific recommendations and implementation advice tailored to client needs. Specific areas of advice include investment planning, insurance needs assessment and advice, retirement planning, cash flow management, debt consolidation, capital needs assessments, educational planning, estate planning, and business planning. Fees for financial planning services are outlined in a Financial Planning Agreement signed by both the client and IAR, and any client participating in this program will receive a copy of the Financial Plan created. Should a client decide to implement any recommendations contained in their financial plan, the client may, but is under no obligation to, utilize BCM or one of its IARs to implement those recommendations. Financial planning clients who wish to engage BCM for portfolio management services will be required to enter into a separate written agreement with the firm for such services, for which BCM is paid a separate and additional fee based on assets under management in accordance with the fee schedule set forth under Fees and Compensation, below. As part of the financial plan, BCM may also make estate planning recommendations. Clients are made aware both as part of this Brochure, and the client’s individual agreement, that BCM does not provide tax or legal advice, and that it is the client’s sole responsibility to find independent advice in connection with such services. BCM does however recommend the services of a third party affiliated law firm, Perkins & Zayed, PC, for performance of estate planning services. Should a client elect to utilize Perkins & Zayed, PC for estate planning services, the client will be required to enter into a separate written agreement for such services and pay applicable legal fees. Clients should be aware that any applicable legal fees are in addition to and separate from the financial planning fees incurred for services as outlined in the Financial Planning Agreement. Dean Zayed, founder and CEO of BCM, serves as Principal of Perkins & Zayed, PC. Consequently, such referrals to this law firm creates a conflict of interest since Mr. Zayed will receive remuneration as a Principal of the firm from any BCM referred legal engagement. Please see Item 10 for additional information. There can be no assurance that BCM’s financial planning services or any products recommended by a financial plan are at the lowest available cost. Clients are advised that conflicts of interest exist if BCM recommends its own investment management services, or a third party for which BCM will receive a referral fee. Specifically, clients should be aware that a conflict exists between BCM’s interests and the interest of the client if the client implements the financial plan through the firm, or a recommended third party, for BCM will receive additional payment from the client in the form of advisory fees and/or referral fees. This could act as an incentive to BCM to make certain recommendations in the financial plan or to advise the client to instruct BCM to implement the plan. Clients also should be aware that other advisory firms may charge lower fees for providing such services. Recommendations of Strategies Outside the BCM Platform In addition to the programs managed through the BCM Platform, other programs offered by BCM are sponsored and managed by various outside and unaffiliated registered investment advisors. Each of these programs will have FORM ADV PART 2A – DISCLOSURE BROCHURE Page 7 of 28 disclosure documents (ADV Part 2A) which will further describe the program, account minimums, fees and risks. These additional disclosure documents are available from your IAR. Clients should be aware that by engaging in these services, they will pay a direct management fee to these program managers in addition to an indirect management fee to BCM. 401(K) Accounts (Services for Qualified Retirement Plans) Under the Qualified Retirement Plan (QRP) program, the advisor may construct a model portfolio or customize a portfolio for each 401(k) plan account. The 401(k) plan is held at the custodian chosen by the 401(k) plan administrator. The portfolio is constructed based on the investments or funds available within each individual client’s 401(k) plan. The IAR or Outside RIA shall provide investment management services by allocating and reallocating assets within the plan consistent with the model or portfolio allocation chosen by the client. Additional 401(k), 403(b), and other retirement plan advisory services are offered. These plans will vary based upon the third party administrator (TPA), plan custodian, and investment selections available under each plan. BCM may use independent third party advisors to manage the plan. In these instances, clients must receive copies of the third party advisor’s Form ADV Part 2A and any other applicable disclosure documents and must complete the account opening paperwork required by the outside advisor. Variable Annuities BCM offers a variable annuity model through Nationwide. The investment selections for the variable annuity may be limited to the choices offered through the specific product. Specifics regarding the annuity are found in the annuity prospectus and application documents. IMPORTANT INFORMATION RELATING TO THE FIRM’S SERVICES Information Received by Individual Clients BCM will not assume any responsibility for the accuracy of the information provided by the client. BCM is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying BCM in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. In the event that a client notifies BCM of changes in the client’s financial circumstances, the firm will review such changes and recommend any necessary revisions to the client’s portfolio. Advisory Services, Agreements and Disclosures Prior to engaging BCM to provide Asset Management or Financial Planning services, the client will be required to enter into one or more written agreements with BCM setting forth the terms and conditions under which the firm shall render its services (collectively the “Agreement”). In accordance with applicable laws and regulations, BCM will provide this brochure, the ADV Part 2B brochure that is specific to the IAR, the Wrap Brochure (if applicable), and the Client Relationship Summary (Form CRS) to each client or prospective client prior to or contemporaneously with the execution of the Agreement. The Agreement between BCM and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to the client. Neither BCM nor the client may assign the Agreement to a third party without the consent of the other party. Transactions that do not result in a change of actual control or management of BCM shall not be considered an assignment. BCM will provide Asset Management services and Financial Planning services but will not provide custodial services. At no time will BCM accept or maintain custody of a client’s funds or securities. Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker/dealer, unless otherwise negotiated. Please refer to the Brokerage Practices section for more information. FORM ADV PART 2A – DISCLOSURE BROCHURE Page 8 of 28 Serving as a Sub-Advisor to Independently Sponsored Advisory Programs BCM may from time to time participate as a sub-advisor under other firms’ advisory programs. A client of the other firm selects a registered investment advisor, such as BCM, from a list of approved advisors to provide investment management services. BCM receives a fee for account management services provided to clients of an outside firm as outlined in a sub-advisory agreement. This agreement may also outline items such as the advisory services to be provided, the responsibilities of BCM and the other firm and the terms of engagement including fees and termination. Responsibilities such as collecting the client’s investment objectives, determining the strategy best suited for the client, and communication with the client will be the responsibility of the outside firm. BCM has no responsibility to assess the value of services provided by the outside firm, therefore the client should evaluate whether such a program is suitable for their needs and objectives, and whether comparable or similar services are available at a lower cost elsewhere. Restrictions/ Guidelines Imposed by Clients The advisory services described in this item are tailored to each client; if any client requires any restrictions on any types of stocks or market segments, the client needs to inform their IAR or RIA of the restrictions in writing. If, for any reason, BCM is not able to meet the client restrictions, the firm will notify the client of that fact. ASSETS UNDER MANAGEMENT BCM has discretionary assets under management of $7.66 billion. The calculation for determining the assets under management was completed as of October 31, 2023.