A. Firm Information - Kaizen Retirement Plan Advisors, LLC (“Kaizen” or the “Advisor”) is a Registered Investment Advisory firm which is organized as a Limited Liability Company (LLC) under the laws of the Commonwealth of Massachusetts. Kaizen was founded in 2017 and is owned and operated by William D. Gleavy (Principal). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Kaizen. The primary focus of Kaizen is providing co-fiduciary investment advice at the plan level (both discretionary and non-discretionary) and fiduciary governance consulting to employers that sponsor retirement plans such as 401(k), defined benefit, 403(b), money purchase, target benefit and cash balance. Co-fiduciary services are provided in two methods: Section 3(21) co-fiduciary services or section 3(38) co-fiduciary services. Section 3(21) – Kaizen will offer plan level advice and investment recommendations pertaining to investments for a given portfolio. The client will either accept or reject the advice. This is the “help us do it” method. This will be disclosed in the investment advisory contract. Section 3(38) – client will allow Kaizen full discretion (per singed 3(38) investment advisory contract) to implement investment decisions on their behalf. Kaizen will provide discretionary advice for the plan sponsor. Kaizen believes that the creation and implementation of a superior fiduciary governance process for plans sponsors of 401k and defined benefit plans is the first step to providing employees with better retirement outcomes. The changing laws and regulations require a focused advisor in this discipline. Our goal at Kaizen is to help our clients and their employees attain positive retirement outcomes by helping them attain the ability to retire with financial comfort and dignity. As a firm that also believes in the importance of goal-based retirement planning for individual investors in connection with investment management, we feel strongly about being able to offer Clients of all levels of net worth a dynamic investment solution that can help them excel. B. Advisory Services Offered - Kaizen offers investment advisory services to companies that sponsor retirement plans under ERISA such as Section 401(k), 403(b), defined benefit plan, cash balance plan, money purchase plans, target benefit plans, group variable annuities, and other client accounts (“Advisory Accounts”) individuals and families, in Massachusetts and other states (each referred to as a “Client”). Kaizen investment advisory services to plan sponsors include employee education, investment consulting (selection and monitoring), vendor fee benchmarking, vendor search and selection and plan design consultation. These services are all inclusive and fees are described in section 5. Account Portfolio Management Kaizen provides customized investment advisory solutions for its clients. This is achieved through continuous proactive Client contact and interaction while providing either discretionary or non-discretionary investment management and consulting services. Kaizen works with each Client to identify their goals and objectives as well as risk tolerance and financial situation to create a custom portfolio allocation. Kaizen will then construct a portfolio, consisting of mutual funds or exchange traded funds (ETF) to achieve the Client’s investment goals. The Advisor may also utilize other security types as necessary to meet the needs of its clients. At Kaizen, our investment philosophy is based on a “core and explore” strategy. We believe that markets are efficient over the longer term but can sometimes be inefficient and irrational over the shorter term. Our investment philosophy is a tactically managed Asset Allocation strategy that is predominately market index orientated (“core”) but seeks to capture market inefficiencies (“explore”) in various less efficient asset classes. This provides plan sponsors and individuals with a longer-term core solution which is aligned with our belief that markets are efficient and rational over longer periods of time. However, in aligning with our belief that markets can operate

away from the fundamentals over the shorter term, Kaizen employs an active fund - based strategies that are designed to capitalize on less efficient asset classes. Kaizen will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the acceptance by the Advisor. Kaizen may periodically rebalance or adjust client accounts under its management. If the client experiences any significant changes to his/her financial or personal circumstances, the Client must notify the Firm so that the Firm can consider such information in managing the Client's investments. Kaizen evaluates and selects no-load mutual funds and sometimes ETFs for inclusion in Client portfolios only after applying their internal due diligence process. Kaizen may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Kaizen may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement, which may adversely affect the portfolio. Kaizen may recommend selling positions for reasons that include, but are not limited to, business or sector risk, exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Prior to rendering investment advisory services, Kaizen will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objectives. Kaizen will provide investment advisory services and portfolio management services and will not provide securities custodial or other administrative or record keeping services. At no time will Kaizen accept or maintain custody of a client’s funds or securities. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client Investment Advisory Agreement. C. Client Account Management - Prior to engaging Kaizen to provide investment advisory services, each Client is required to enter into an Investment Advisory Service Agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services will include: ➢ Establishing an Investment Policy Statement – Kaizen, in connection with the Client, may develop a statement that summarizes the Client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet the objectives. An Investment Policy Statement defines the purpose, investment objectives, roles and responsibilities, investment monitoring and reporting, specific information on the Client’s stated goals, time horizon for achieving the goals, investment strategies, Client risk tolerance and any restrictions imposed by the Client. ➢ Asset Allocation – Kaizen will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client. ➢ Portfolio Construction – Kaizen will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ➢ Investment Management and Monitoring – Kaizen will provide investment management and ongoing oversight of the Client’s portfolio and overall account. ➢ Fiduciary Governance Process – in addition, for corporate retirement plan clients, Kaizen will create and implement a Retirement Plan Committee Charter and an Education Policy Statement. D. Wrap Fee Programs - Kaizen does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Kaizen. E. Assets Under Management – Kaizen was founded in October of 2017. As of March 28, 2024, discretionary assets under management were $32,000,000, and non-discretionary assets under management were $98,939,035.