Introduction Wells Global Investment Advisers LLC (“Wells Global”) was established in March 2009 and commenced offering advisory services as a state of Florida registered investment advisor. Effective August 31, 2012, Wells Global became registered with the Securities and Exchange Commission. Wells Global is owned by James P. Wells. Types of Advisory Services The following pages describe our programs and fees. As used in this brochure, the words “we,” “our,” and “us” refer to Wells Global and your investment advisor representative (“IAR”), and the words “you,” “your” and “client” refer to you as either a client or prospective client of our firm. Wells Global offers three advisory services: Managed Assets Advisory Service Programs 1, 2 and 3. Program 1 offers individual accounts managed per a model. Programs 2 and 3 are custom-managed individual accounts. In addition to various publicly-traded stocks, bonds, mutual funds and exchange trade products, programs 1 and 2 may include options contracts. In addition to variously publicly-traded stocks, bonds, mutual funds and exchange trade products, programs 2 and 3 may include variable annuities. Program 1 has limited liquidity and is currently dormant. Further details are provided below. All three programs are discretionary portfolio management services. As such, to participate in a program, we require that you grant our firm discretionary authority to manage your account. Discretionary authority will allow our firm to determine the specific securities, when those securities are to be purchased or sold, and the amount of securities to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the client services agreement you sign with our firm, a power of attorney, and/or trading authorization forms. We work with you to determine the appropriate investment objectives, risk tolerance and other relevant information (the “suitability information”) based on the information you provide initially, and periodically thereafter. Forms used to help obtain this information include but may not be limited to the investor questionnaire and account information form. With this information, you may select one of the programs described in this brochure. With this suitability information, we develop a strategy that enables our firm to give you continuous investment advice and make (or sell) investments on your behalf. Once we construct an investment portfolio for you, we will monitor your portfolio’s performance on an ongoing basis and may make adjustments to the portfolio as changes occur in the market. Adjustments may be made as you advise us of changes in your financial circumstances and/or risk profile. The three programs are suitable for the conservative, conservative to moderate, moderate to growth, growth, growth to aggressive-growth, and aggressive- growth oriented portions of a client’s overall portfolio and/or for a conservative and/or moderate and/or growth and/or aggressive growth- oriented client. In the client services agreement, you indicate that you agree that the program you chose is suitable for you, and you are suitable for the program selected, based on your short-term objectives, intermediate term objectives, long term goals, income, net worth, risk tolerance, liquidity needs, your desire for us to have discretion and potentially other criteria. In the agreement, you acknowledge that you have spent a sufficient and reasonable amount of the time with us prior to signing this agreement in order to evaluate and determine the suitability of any program you select and your suitability for the program. You have the right to have your attorney review the agreement before signing. Individual investments made in any of the programs may or may not be considered a suitable investment for you as a stand-alone investment. The level of risk of the program and individual investments in the overall program may be different from other investments or investment allocations that you may be offered and/or choose elsewhere from another registered investment advisor. You may perceive other investments at other firms to be more suitable. If you conclude this we encourage you to consider hiring that advisor and not us. We and you are aware of the importance of attempting to establish an overall suitability standard. We will work diligently with you to help make this determination. You understand suitability may be somewhat subjective and may be subject to varying interpretations and/or understandings. You understand and accept these facts. You accept the responsibility for determining your suitability

for participating in program 1, 2 and/or 3. The level of risk and individual investments in the programs may be different from other investments, or investment allocations for one client to another client within any of the programs offered in this brochure. In addition, you may determine a difference in suitability from one program to another program. This means you may observe the levels of risk may be lower or higher for one program versus another. You are responsible for determining the level of suitability for each program and to best choose which program or programs are most suitable for you. Subsequent suitability and risk from one client to another may vary just as the investments made in the different programs may vary. Suitability is established with/for/by you and not for “other parties.” In other words, suitability is not considered to/with/for other parties to include but not be limited to other family members, such as spouses, ex-spouses, children, grandchildren, in-laws, and heirs and/or assigns or any individual you give power of attorney to. The level of risk you, the client, selects, may not be suitable for any other parties. Wells Global will not consider risk for other parties. Such parties will be considered disinterested parties per instruction of you, the client. Other parties may be known or unknown to you. We may from time to time furnish investment advice through consultations not indicated above and on more than an occasional basis furnish advice to clients on matters not involving securities, such as financial planning related to estate planning, for example. As of the date of this brochure, Wells Global has assets under management of approximately ninety-one million dollars. Program 1 is model based and not tailored to individuals but to an investment model ranging from conservative to aggressive growth. Programs 2 and 3 are managed on a basis which considers individual needs of clients but is not managed to the exclusive needs of a client. Clients may not impose restrictions in securities or types of securities bought and sold. We, Valor Financial Securities LLC (a company under common ownership) (“Valor”) and affiliates may perform advisory and/or brokerage services for various clients, and we may give advice or take actions for other clients that differ from the advice given or the timing or nature of any action taken for any account for program or client or itself. No one at Wells Global, or any companies under common ownership and none of their associates has guaranteed any investment or promised any investment return. Investment strategies carry investment risk including the potential risk of permanent loss of principal. Client accepts associated risk for all the investment decisions in his/her accounts. This includes the risk of strong swings in volatility in this discretionary program. This risk includes permanent loss of principal. The programs offer no investment guarantees. There is no guarantee that a client's investment objectives will be achieved and past performance is not a guarantee of future results. The client services agreement may be assigned or transferred by Wells Global with written notice from Wells Global. If the Broker/Dealer changes, this contract will remain in effect. This contract is also transferable to another registered investment adviser under the current terms of that registered investment adviser if permitted by current law. Wells Global and Valor Financial Securities LLC reserve the right to reject any instructions from any power of attorney to include and not limited to the transfer of the account(s) to another firm or instructions of what to invest in. You specifically understand and agree to this provision. In the client services agreement, client shall agree to indemnify and hold harmless Valor, Wells Global and any of its associates and any companies under common ownership and their associates and their officers, directors, agents, employees, and affiliates from all loss, cost, indebtedness, and liabilities arising from the investment decisions of the portfolio adviser. This agreement survives the termination of the contract. This authorization is a continuing one and shall remain in full force and effect and will be/is relied upon for any proceeding. Nothing herein contained is intended to constitute a waiver of any right that a client may have under federal or state securities laws. Termination of the client services agreement will not end the liabilities or obligations of the parties arising from transactions initiated prior to termination. We do not participate in wrap fee programs with other money managers.