General Information Nicholas Hoffman & Company, LLC (“we,” “us” or “NHCO”) was formed in 2007 and provides financial planning and portfolio management services to its clients. Nicholas J. Hoffman is the sole principal owner of NHCO. Please see Brochure Supplements, Exhibit A, for more information on Mr. Hoffman and other individuals who formulate investment advice and have direct contact with clients or have discretionary authority over client accounts. As of December 31, 2023, we managed $5,863,278,450 on a discretionary basis, and $818,289,314 of assets on a non-discretionary basis. SERVICES OFFERED At the outset of each client relationship, we spend time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and broadly identifying major goals of the client. Clients may elect to retain us to prepare a full financial plan. This detailed analysis is presented to the client for consideration. In most cases, clients subsequently retain us to manage the investment portfolio on an ongoing basis. For those financial planning clients making this election, and for other clients who do not need financial planning but retain us for portfolio management services, based on all the information initially gathered, we generally develop with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile” or “Profile”);
• the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments we will make or recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client but are not necessarily written documents. Financial Planning One of the services offered by us is financial planning, described below. This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial planning may include advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client’s particular situation, financial planning may include some or all of the following:
• Gathering factual information concerning the client's personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
• Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
• Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Providing estate planning, and
• Reviewing goals and objectives and measuring progress toward these goals. Once financial planning advice is given, the client may choose to have us implement the client’s financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by us under a financial planning engagement and/or engage the services of any recommended professional. Portfolio Management As described above, at the beginning of a client relationship, we meet with the client, gather information, and perform research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by us based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, we will manage the client’s investment portfolio on a discretionary basis or a non-discretionary basis. As a discretionary investment adviser, we will have the authority to supervise and direct the portfolio without prior consultation with the client. Under a non-discretionary arrangement, clients must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Notwithstanding the foregoing, clients may impose certain written restrictions on us in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of ours. Private Funds We will from time to time, based on the client’s risk tolerance, sophistication and financial qualifications, recommend that a portion of the client’s assets be invested in certain private investments. These include private equity, private debt and real estate funds, hedge funds, and other types of private investment vehicles (collectively “Private Funds”). We will assist clients in implementation of such recommendations to invest in Private Funds; however, we do not exercise discretion with respect to these types of investments. We will continue to render the advisory services to the client, relative

to the ongoing monitoring and review of asset performance and due diligence of the Private Fund. Clients are provided with private placement memorandums and other offering and subscription documentation that detail the nature, risks and associated fees of each Private Fund. It is important that the client read and review these documents with their legal and tax advisors, before investing, to fully understand the types of investments, risks and conflicts pertaining to the Private Funds. Separate Account Managers When appropriate and in accordance with the Investment Plan for a client, we may recommend the use of one or more separate account managers, each a “Manager”. Having access to various Managers offers a wide variety of manager styles and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client. We will select the Manager(s) we deem most appropriate for the client. Factors that we consider in recommending/selecting Managers generally includes the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research. The Manager(s) will be granted discretionary trading authority to provide investment supervisory services for the portfolio, but we normally retain the authority to terminate the Manager’s relationship or to add new Managers without specific client consent. With respect to assets managed by a Manager, our role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), conduct on-going due diligence, and to assist the client in understanding the investments of the portfolio. In instances where the services of one or more Managers are utilized, the fee assessed by the Manager(s) will be separate and in addition to our fee and will be detailed in a Management Agreement signed by the client. Additionally, certain Managers may impose more restrictive account requirements than NHCO, and billing practices may vary. In such instances, we may be required to alter our corresponding account requirements and/or billing practices to accommodate those of the Manager(s). Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. We will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, we will be considered a fiduciary under ERISA. With respect to any account for which we meet the definition of a fiduciary under Department of Labor rules, we acknowledge that both NHCO and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between us and Client. Fiduciary Consulting Services
• Investment Selection Services We will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice We provide Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding asset classes and investments.
• Investment Monitoring We will assist in monitoring the plan’s investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and we will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties. Non-Fiduciary Services
• Participant Education We will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages us for such services. Plan Participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment We will assist with group enrollment meetings designed to increase retirement Plan participation among employees and investment and financial understanding by the employees. Retirement Plan Rollovers We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries 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. We must act in your best interest and not put our interest ahead of yours. If we recommend that you roll over or transfer your retirement assets into an account to be managed by us, such a recommendation creates a conflict of interest if we will earn a new (or increase our current) advisory fee because of the rollover/transfer. You are under no obligation to roll over retirement assets to an IRA managed by us or to engage us to monitor and/or manage the account while maintained at your employer.