Firm Description Gradient Advisors (GA) is an SEC-registered investment advisor with its principal place of business located in Arden Hills, Minnesota. GA is a limited liability company organized in the state of Delaware. GA has been offering investment advisory services since its founding in 2009. Charles E. Lucius Arizona Separate Property Revocable Trust is 100% owner. Types of Advisory Services Investment Advisory services of Gradient Advisors, LLC (“GA”) are provided through Investment Advisor Representatives (IAR) affiliated with the firm. Advisory services include investment management, financial planning and consulting services. GA accepts appointment and a fiduciary duty of utmost good faith to act solely in the best interest of each client pursuant to the terms and conditions set forth in this Agreement and to comply with impartial conduct standards of: Charging no more than reasonable compensation for services provided; and making no misleading statements regarding investments, compensation and conflicts of interest. Below are descriptions of the primary advisory services offered through GA. Financial Planning and Consulting Services A financial plan is designed to help the client with all aspects of their financial situation through an evaluation of a client’s current and future financial needs. The financial plan components are created through a customized suite of financial planning tools. The financial plan will include knowledge and considerations of the client’s financial goals and make specific recommendations to help clients pursue those goals. The financial planning advice on more than an occasional basis will include financial planning matters such as taxation issues, insurance and trust services that often include estate planning. Detailed investment advice and specific recommendations may be provided as part of a financial plan. Implementation of the recommendations is at the discretion of the client. Financial consulting services cover various activities provided by advisors specifically designed to assist individuals and companies pursue their financial objectives. This is accomplished by analyzing the client’s data, design and implement strategies to address individual planning needs. Investment advisor representatives of GA may charge clients for financial planning or consulting services on an hourly or negotiable fixed fee basis described in detail in Item 5 of this brochure. Financial Consulting services are exclusive of investment management. Asset Management Services GA offers asset management services to clients. We discuss the investment goals with the client and work together to design a strategy to help pursue the client’s investment objectives. Referral Arrangements Gradient Advisors LLC solicits the services

of Third-Party Money Managers (TPMM) to manage client accounts. In such circumstances, the advisor receives referral fees from the Third-Party Money Manager. GA and the Investment Advisor Representatives (IAR) act as the liaison between the client and the TPMM in return for an ongoing portion of the advisor fees charged by the TPMM. Advisor helps the client complete the necessary paperwork of the TPMM, provides ongoing services to the client, and will provide the TPMM with any changes in client status as provided to advisor by the client. Advisor will deliver the Form ADV Part 2, Privacy Notice and Disclosure Statement of the TPMM. Clients placed with TPMMs will be billed in accordance with the TPMM’s Fee Schedule which will be disclosed to the client prior to signing an agreement. This is detailed in Item 10 of this brochure. Investment Accounts Involving Supervisory Services In some cases, GA offers discretionary and non-discretionary direct asset management services to advisory clients. GA and the IAR will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment program will be based on the above factors. In the case of discretionary management, the client will grant discretionary authority to execute selected investment program transactions as stated in the Investment Advisory Agreement. Investment Accounts Not Involving Supervisory Services GA will assist in the opening, closing and transferring of accounts. An administrative fee up to 0.60 percent annually may be charged for all accounts that are maintained by GA. GA will not have discretion at any time on these accounts. Client Tailored Services Advisory services are provided based on the individual needs of the client. The risk tolerance, goals and objectives for each client are documented in our client relationship management system. The Color of Money Risk Analysis (COMRA) is completed by the client to assess their risk tolerance. The Client Profile Form was created to reflect the stated goals and objectives. Wrap Fee Programs GA does not sponsor any wrap fee programs. Client Assets Under Management As of December 31, 2023, GA had approximately $206,495,127 regulatory assets under management (AUM), which we manage on a discretionary basis. In addition, the firm had $637,933,449 assets under administration (AUA). The firm provides administrative services regarding the assets under administration, it does not currently provide continuous investment management services to these assets, this service is provided by the third- party money managers. Accordingly, GA has total platform assets of $844,428,576.