Firm Description and Types of Advisory Services Capital Wealth Management, LLC is an investment adviser providing investment advisory services to individuals, high net worth individuals, pension and profit-sharing plans, charitable organizations, trusts, and estates. These services include asset management services, financial planning and advisory services for retirement plans and plan participants. Principal Owners The Firm is owned by Capital Wealth Holdings, LLC, which is primarily owned by Capital Wealth Management, LLC. Capital Wealth Management, LLC is primarily owned by Lee Alan Duckworth. Types of Advisory Services Asset Management Services Capital Wealth Management provides continuous advice to clients regarding investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s circumstances are established, Capital Wealth Management develops a client’s Investment Policy Statement which includes risk profile, time horizon, cash needs, investment philosophy, asset allocation, proposed asset allocation, rebalancing, manager selection, tax considerations and reporting. Capital Wealth Management will manage advisory accounts primarily on a discretionary basis only. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, growth and income, etc.). Capital Wealth Management may also offer these services to clients with variable annuity products, whereby Capital Wealth Management will manage the underlying variable annuity sub-accounts and equity indexed annuities (EIA) on behalf of the client. Capital Wealth Management will create a portfolio consisting of one or all of the following: individual equities, bonds, ETFs, oil and natural gas exploration and other alternative investments, other investment products, managed futures, private debt, non-traded REITS, and no-load or load-waived mutual funds. Capital Wealth Management will allocate the client’s assets among various investments taking into consideration the overall investment objective selected by the client. Mutual funds will be selected based on any or all of the following criteria: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager(s); the fund’s investment objectives; the fund’s management style and philosophy; style drift, risk adjusted metrics and statistics, and the fund’s management fee structure. Portfolio weighting among investments and market sectors will be determined by each client’s individual needs and circumstances. Clients will retain individual ownership of all securities. Capital Wealth Management may provide investment advice on such investments as limited partnerships and private placement partnerships, and oil and gas partnerships. Capital Wealth Management reserves the right to advise clients on any other type of investment that it deems appropriate based on the client’s stated goals and objectives. Capital Wealth Management may also provide advice on any type of investment held in a client’s portfolio at the inception of the advisory relationship or on any investment on which the client requests advice. Financial Planning and Consulting Services Capital Wealth Management offers financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. Clients understand that when Capital Wealth Management is engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. Capital Wealth Management meets with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information; sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. The financial plan may include both long and short-term considerations, depending upon the individual scenario. Upon completion, a plan is presented to the client. At this meeting, the client is provided with recommendations that are deemed to be compatible with the client’s stated goals and objectives. An implementation schedule is reviewed with the client to determine which steps will be pursued, and with whom the steps may be accomplished. The client is under no obligation to utilize additional services of Capital Wealth Management and its representatives and is under no obligation to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. Capital Wealth Management also offers investment advice on a more

limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client’s existing portfolio, or any other specific topic. Additionally, Capital Wealth Management may provide advice on non-securities matters; generally, in connection with the rendering of estate planning, insurance, and/or annuity advice. Advisory Services to Retirement Plans and Plan Participants Capital Wealth Management offers various levels of advisory and consulting services to employee benefit plans and to the participants of such plans (Participants). The services are designed to assist plan sponsors (Plan Sponsors) in meeting their management and fiduciary obligations to the Participants under the Employee Retirement Income Securities Act (ERISA) and the Pension Protection Act of 2006 (PPA). Capital Wealth Management will provide services to Plan Sponsors and their Participants as described below. Generally, investment advice provided to Plan Sponsors and Participants is regulated under ERISA and the PPA. Plan Sponsors must make the ultimate decision to retain Capital Wealth Management for pension consulting and other advisory services including, but not limited to, services at the participant level. The Plan Sponsor is free to seek independent advice about the appropriateness of any recommended services for the plan. Capital Wealth Management develops an Investment Policy Statement for each plan, which may include some or all of the following areas: overview, investor circumstances, tax policy, reviews, diversification and investment constraints, selection/retention criteria for investments, investment monitoring and control procedures and duties and responsibilities. Services include: Management of vendor relationships; Request for Proposals (RFPs); Assistance on plan design strategies; Fiduciary consulting and oversight; Investment Management; and Employee Education and Communication Services. Advisory services provided to retirement plans may be solely provided by Investment Adviser Representatives (IARs), or in combination with third parties and their retirement plan services. Tailored Relationships Capital Wealth Management tailors investment advisory services to the individual needs of the client. Capital Wealth Management clients can impose restrictions on the investments in their account. Capital Wealth Management may accept any reasonable limitation or restriction to discretionary authority on the account placed by the client. All limitations and restrictions placed on accounts must be presented to Capital Wealth Management in writing. Fiduciary Statement 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, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs Capital Wealth Management does not participate in a Wrap Fee Program. Client Assets As of December 31, 2023, Capital Wealth Management manages a total of $858,037,632 in assets under management; all on a discretionary basis.