4a: Firm Description Northwest Asset Management was established in July 2008 by managing member Gregory Allen Headrick, CFP®, Chief Compliance Officer. The firm’s Chief Executive Officer is Nelly Mubashi, CRPS®. The main office is located at 2835 82nd Avenue SE, Suite 100, Mercer Island, Washington 98040. 4b: Types of Advisory Services Northwest Asset Management offers a wide range of investment advisory, planning and consulting services tailored to our clients’ needs. Investment Management We provide a customized approach to investment management. Our process includes defining goals, assessing risk, developing a strategy, implementing the strategy, monitoring progress. We provide ongoing reporting that can be accessed via the internet or provided through monthly statements. We understand that every client has unique goals and risk tolerance and we design an investment strategy for those unique circumstances. These may include a traditional and time tested strategic asset allocation approach or new and innovative active asset allocation strategies or a mix of other strategies. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. As fiduciaries we are obligated to do the following:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Outside Portfolio Managers The advisory services may include portfolio management and/or advice concerning selection of an outside portfolio manager. The specific terms and conditions under which a client engages an outside portfolio manager may be set forth in a separate written agreement with the designated outside portfolio manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective outside portfolio manager engaged to manage their assets. We select and review outside portfolio managers based on the following factors:
• Past performance;
• Investment philosophy and style;
• Market outlook;
• Experience of portfolio managers and executive team;
• Disciplinary, legal and regulatory histories of the firm and its associates; and
• Review of ADV, including conflicts of interest We do not calculate portfolio manager performance. Instead, we rely upon the performance figures based on client’s monthly or quarterly statements or reports provided to us by outside portfolio managers. As a result, performance information may not be calculated on a uniform and consistent basis. You should be aware that our firm cannot actively monitor outside portfolio managers conflicts of interest, daily trading activity and other operational issues. Retirement Plans (ERISA, 401(k)) We understand the challenges employers face in providing retirement plan benefits (401K, Profit Sharing, SIMPLE, SEP, etc.) for employees. Our goal is to simplify our clients' lives through a responsive, integrated approach and deliver to you the level of service and expertise that you need, no matter the size or complexity. Retirement Planning Comprehensive retirement planning involves a complete financial review and the development of short-term and long- term strategies for financial success. We review your current situation, explore alternatives, analyze social security choices, and determine how best to structure your assets to help meet your goals. Financial Planning Whether you are saving for a particular goal, or planning for future college expenses, trying to determine if you need more insurance, or trying to figure out how to make the most of charitable contributions, you need to review your complete financial situation first. We will help you understand where you are and will develop a strategy that will help you meet your objectives. Sub-Advisory Investment Management Services for Advisors Northwest Asset Management offers investment sub-advisory services to unaffiliated investment

advisers. Unaffiliated RIAs may choose to engage Northwest's Sub-Advisory Services for investment management of some or all their clients' assets. Northwest shall have day-to-day responsibility for the active discretionary management of the allocated assets based upon the written sub-advisory agreement signed by the unaffiliated advisor authorizing Northwest’s appointment. The unaffiliated advisor RIA shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Consulting We provide a wide array of consulting services, which may vary greatly in depth and scope and may be offered in a variety of different situations or circumstances, that relate to your financial picture. We may consult with you regarding topics that are not covered under our general financial planning services or may not rise to the level of financial planning in the extent of data-gathering and breadth and depth of recommendations. We may consult on such items as a real estate purchase, a sales analysis, investment due diligence or a review of a financial account. Financial accounts may be accounts that are held at other firms or qualified retirement accounts held through the Client’s employer. The scope and cost of our consulting services are defined in writing prior to the engagement and will depend on the complexity of the situation. Consulting services will be offered to any client who the advisor deems to have circumstances that could be aided by our consulting services. Some factors in this determination may be the advisor’s experience and level of expertise with the situation. Client’s always have the right to decide whether to engage the firm for consulting services. Tax Preparation Services In addition to traditional investment advisory services, the Firm also provides tax preparation services to its clients. The tax preparation services offered by the Firm are provided as a separate service from specifically approved IARs and are not included as part of the investment Tax advisory services. RIA Innovations Our RIA Innovations division provides back office services to registered investment advisors and other affiliated businesses, including:  Front Office Support  Back Office Support  Technology  Compliance  Non-Discretionary Investment Management  Succession Planning  Marketing  Bookkeeping  HR Support 4c: Client Tailored Relationships and Restrictions As a fiduciary, Northwest Asset Management always acts solely in the Client’s best interests. Each Client’s portfolio is customized based on the Client’s investment objectives. Clients may make requests or suggestions regarding the investments made in their portfolio. Restrictions on trading that, in the Adviser’s expert opinion, are not in the Client’s best interest cannot be honored. 4d: Wrap Fee Programs This brochure describes Northwest Asset Management’s Wrap Fee Program. Northwest Asset Management is the sponsor of the wrap fee program titled NWAM Choice Solutions Program (“CSP”). A wrap fee program allows our clients to pay a specified fee for investment advisory services and the execution of transactions. The advisory services may include portfolio management and/or advice concerning selection of other advisers, and the fee is not based directly upon transactions in their account. The CSP program is offered only through accounts held at our partner custodians. Northwest Asset Management and the client will select a custodian and mutually agree on the investment strategy used by Northwest Asset Management to manage the account. We will assist the client in determining their current financial situation, financial goals and attitudes toward risk, which will allow Northwest Asset Management to implement appropriate asset allocations. We will continuously monitor client portfolios based on the individual needs of the client. Our advisors receive a portion of the advisory fee that you pay us. This may create an incentive to recommend that you participate in a wrap fee program rather than a non-wrap fee program (where you would pay for trade execution costs) or brokerage account where commissions are charged. In some cases, our advisors may stand to earn more compensation from advisory fees paid to us through a wrap fee program arrangement than they might receive from a different advisory service. 4e: Assets under Management (AUM) Northwest Asset Management, as of December 31, 2023, has $2,233,042,575 in discretionary Assets under Management and $1,038,334,488 in non-discretionary assets under management for $3,271,377,063 total assets under management.