Tekmen Wells, LLC (also “Tekmen Wells”, “we”, or “the Firm”) has been in business since August 2013. Hakan Ergulec is the Firm’s principal. He brings over 18 years of industry experience. The Firm provides asset management and general consulting services on a fee basis. Asset Management Asset management services will generally be provided on a discretionary basis. When Tekmen Wells is engaged to provide asset management services on a discretionary basis, it will monitor client accounts to ensure that they are meeting asset allocation requirements. As a client, if any changes are needed to your investments, we will make those changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. As a client, you will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements, at least quarterly, from your account custodian. Clients engaging Tekmen Wells on a discretionary basis will be asked to execute a Limited Power of Attorney (granting Tekmen Wells the discretionary authority over the client accounts) as well as an Investment Advisory Agreement that outlines the responsibilities of both the client and Tekmen Wells. In limited circumstances, and as a courtesy to some clients, Tekmen Wells may provide asset management services on a non-discretionary basis. When a client engages us to provide investment management services on a non- discretionary basis, we monitor the accounts in the same way as for discretionary services. The difference is that changes to your account will not be made until we have confirmed with you (either verbally or in writing) that our proposed change is acceptable to you. Clients that participate in our Wrap Program have certain costs and fees covered as part of their management fee. The costs covered in the Wrap Program by the management fee and that are not chargeable to clients that are in the Wrap Program include (1) transaction fees for the purchase or sale of securities, (2) platform fees for our Wrap Program sponsor, Envestnet, and (3) any third-party manager fees for managers on the Envestnet platform that perform separate account management services. Fees that are not included as part of the Wrap Program and that may be chargeable to the clients regardless of whether they participate in the Wrap Program, include (1) expenses related to the use of margin, (2) fees charged to shareholders of mutual funds or ETFs, (3) mark-ups and mark- downs, spreads, odd-lot differentials, (4) fees charged by regulatory agencies, (5) any transaction fees for securities trades executed by a broker-dealer other than Pershing Advisor Solutions, LLC, and (6) fees associated with foreign dividends and servicing agents. Clients who do not participate in the Wrap Program will be responsible for all fees that may apply, including those that are outlined as covered in the Wrap Program. Because of the nature of a wrap fee program, the wrap fee program client may pay more or less than if the client had compensated Tekmen Wells outside of the wrap fee program. For example, if a client’s account is rarely traded, the transaction fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. Tekmen Wells receives a portion of the wrap fee for its services. Third Party Manager Programs Tekmen Wells offers clients Third Party Manager programs. These programs are provided through Envestnet Asset Management, Inc. (“Envestnet”) and can be accessed by clients regardless of whether they participate in the Wrap Program, which is offered by Tekmen Wells and sponsored by Envestnet. Envestnet is a registered investment adviser that offers investment advisory and investment management programs under which Tekmen Wells provides investment advisory

and administrative services. For all the programs described, Tekmen Wells does not maintain custody of the individual funds or other assets owned by each client. The Third-Party Manager programs are offered under an agreement with Envestnet and Tekmen Wells, in which Tekmen Wells may engage third party managers to manage assets for clients. The programs include the use of client sub-accounts managed by registered investment advisers selected by Tekmen Wells from among those available through Envestnet’s platform (each a “Third Party Manager”). All Third-Party Managers enter into sub- advisory contracts with Envestnet. The Third-Party Managers have discretionary authority to direct the investment of the assets allocated to the Third-Party Managers under this program. Separate disclosure statements for the Third-Party Managers and Envestnet are provided to the client by Tekmen Wells. For clients that participate in the Wrap Program and use Third Party Managers, the fees payable to such managers are included in the wrap program, as are fees payable to Envestnet and any transaction fees. The remainder of the wrap fee is the management fee payable to Tekmen Wells. The amount payable to Tekmen Wells varies depending upon the amount of trading in a client's account, and the fees payable to Third Party Managers and Envestnet. The more transactions in the account or the higher the fees to the Third-Party Managers, the less compensation to Tekmen Wells. Accordingly, Tekmen Wells has a financial incentive to avoid trading the account, or to choose managers with lower fees instead of managers with higher fees. This creates a conflict of interest between the firm and its wrap clients. Tekmen Wells attempts to mitigate this conflict by requiring that the firm’s employees acknowledge their fiduciary duty to place client interests ahead of their own and by periodically reviewing whether the wrap program is in the best interests of each client. Further, Tekmen Wells and its principals believe that Tekmen Wells has a greater incentive to protect client assets and guard the best interests of its clients. Recommending the best risk adjusted investments that fit each client's specific investment objectives is the most important way Tekmen Wells can ensure its continued success. Tekmen Wells has a long-term view on its business. It values developing long-term relationships with its clients over minor near-term cost savings to Tekmen Wells. Tekmen Wells believes it is important to offer clients a clear view of their total costs. The Tekmen Wells wrap program enables clients to easily understand the total costs of managing their assets. Tekmen Wells will receive no additional compensation for offering the wrap fee program. Financial Planning and Consulting From time to time, Tekmen Wells may be engaged to perform financial planning or consulting services outside the scope of traditional asset management. Consulting topics by their nature may vary greatly, but may include discussions regarding a client’s business, estate planning, suggestion and diligence of alternative assets, real estate or other personal assets. Clients who engage Tekmen Wells to provide such services will generally be required to execute a Financial Planning Agreement or Consulting Agreement. If you request, Tekmen Wells may recommend the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from Tekmen Wells. If you engage any professional recommended by Tekmen Wells, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Assets Under Management As of December 31, 2023, Tekmen Wells has $72,318,663 in assets under management across 65 accounts, all of which are managed on a discretionary basis.