Nepsis, Inc.: investment adviser

Description of Advisory Services Portfolio Management Services We provide discretionary portfolio management services where the investment advice provided is custom tailored to meet your needs and investment objectives. Subject to any written restrictions, which you may choose to provide, you will be granting us discretion and authority to manage the account. Accordingly, we are authorized to perform various functions, at your expense and without your further approval. Such functions include the determination of securities to be purchased and sold and the amount of securities to be purchased and sold. Once the portfolio is constructed, Nepsis provides continuous supervision and re-optimization of the portfolio as changes in market conditions and client circumstances may require. When appropriate, Nepsis may use Sub-Advisors, who are unaffiliated third-party managers, to manage a portion of the client account. Clients receive the Form ADV disclosure brochures of these unaffiliated managers at the time they sign the Advisory Services Agreement. For their services, the Sub-Advisors receive a portion of the collected investment advisory fee. We offer managed accounts with similar management styles for a percentage of assets under management that includes transaction and custodial charges. This program is referred to as a wrap fee program. We receive a portion of the wrap fee for our services.

Participation in Wrap Fee Programs Nepsis, Inc. only offers asset management services in a “wrap fee” program. The asset management fee charged for our wrap fee program includes transaction charges and is calculated based upon on a percentage of assets under management. The asset-based transaction fees are charged to Nepsis Inc. by the custodian. The account custodian may charge fees for such things as margin interest, a fee for a retirement account, or a transfer fee apart from the wrap fee program. The total cost of the individual services provided as part of the wrap fee program, if purchased separately, could be more or less than the costs of each respective program. Cost factors may include your ability to: • obtain the services provided within the programs separately with respect to the selection of investments, • invest and rebalance the selected investments without the payment of a sales charge, and • obtain performance reporting comparable to those provided within each program.

Client Assets Managed by Nepsis, Inc. We manage client assets. As of December 17, 2025, we managed $344,509,038 of client assets. All of the client assets are managed on a discretionary basis.

Financial Planning Services We offer financial planning and consulting services to you regarding the management of your financial resources based upon an analysis of your individual needs. Our Investment Advisor Representatives who are qualified to provide financial planning services will advise on matters involving investments and non-investment related topics. Advice may cover tax planning, estate planning, retirement planning, college and education planning, among others. Once all pertinent information has been collected, reviewed, and analyzed, a written financial plan – focused on achieving your stated financial goals and objectives may be presented to you. The primary objective of this process is to allow us to assist you in developing a strategy for the successful management of income, assets and liabilities in meeting your financial goals and objectives.

Financial plans are based on financial information you provide to us. We rely on you to verify the accuracy of your information. Certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. We cannot offer any guarantees or promises that your financial goals and objectives will be met. As your financial situation, goals, objectives, or needs change, you must notify Nepsis promptly. We also offer consultation services in order to discuss investment, financial market and financial planning issues when you do not need a written financial plan. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning and consulting recommendations. To the extent that you would like to implement any of our investment recommendations through Nepsis or retain Nepsis to actively monitor and manage your investments, you must execute a separate written agreement with Nepsis for our asset management services.

Sub-advisory Services

We offer sub-advisory services to other investment advisory firms. When doing so, we will provide the other investment advisory firm, or its clients, with investment research or suggested trades. We may have investment discretion for the other advisory firm’s clients. The advice we give to these clients may be similar or identical to the advice we give you.

Research Services

We offer a variety of research services, including Research & Analysis, Portfolio Analytics, and Speaking Services. Our Research Services are designed for other financial advisors. These services are described below. 1.

Research & Analysis that includes macro market commentary and is distributed in several documents. a. Weekly Market Recap Word document known as “The Spotlight” b. Monthly global topical research Word document known as “The BLOG” c. Quarterly Economic Update PowerPoint known as “Economic Update & Market Outlook”

2.

Portfolio Analytics includes the development of mutual fund, variable annuity and ETF model portfolios a. Quarterly written summary in Word document of each fund category, why we have chosen each option, and if any changes are warranted. b. Quarterly Fund Rankings Excel Spreadsheet Stoplight report highlighting the ranking of each fund, the return of each model and how they performed vs. the market c. Morningstar Report of each model and each fund option

3.

Speaking Services which includes educational workshops to the public and CE classes for Kaplan University a. Financial Representatives may hire our representatives to speak at client educational workshops b. Kaplan University may hire our representatives to teach Asset Allocation & Beyond to their Continuing Education classes

We charge accounts a maximum annual advisory fee of 2.50% of the value of assets under management. This fee is negotiable at our discretion. Our services are offered as a wrap fee program. The specific level of services you will receive and the fees you will be charged will be specified in your advisory services agreement. An additional asset-based pricing fee (ABP) is charged in lieu of paying standard ticket charges for security purchases & sells That fee is calculated as follows: From 0$ to $75,000, the fee is .20% of assets under management (AUM) From $75,001 to $2,000,000, the fee is .12% of AUM. From $2,000,001 and Above, the fee is .08% of AUM. For managed accounts in the Nepsis, Inc. Wrap Fee program, the ABP fees charged by Pershing will be deducted from client accounts by Nepsis, Inc. The client will be responsible for any other miscellaneous and non standard ticket charges imposed by the Custodian Performance Reporting/ Account Maintenance Fee (Quarterly per account): $21.25 Performance Reporting/ Account Maintenance Fees are deducted from your advisory account. You may terminate the portfolio management agreement within five days of the date of execution without penalty. After the five-day period, either of us may terminate the portfolio management agreement by providing written notice to the other party. In the event the portfolio management agreement is terminated during a calendar quarter, portfolio management fees will be pro-rated and if a refund is due, it will be paid back into the account. The Firm previously offered different fee schedules and some Clients may have arrangements other than what we list in this document. When making cost comparisons, clients should be aware that the combination of multiple mutual fund investments, advisory services, custodial and brokerage services available through each program may not be available separately or may require multiple accounts, documentation and fees. If an account is actively traded or if the client otherwise does not qualify for reduced sales charges for fund purchases, the fees may be less expensive than separately paying the sales charges and advisory fees. If an account is not actively traded or the client otherwise would qualify for reduced sales charges, the fees in these programs may be more expensive than if utilized separately.

Fees for Financial Planning and Consulting Clients that contract with us for financial planning and consulting services will be charged based upon our hourly rate of $250 (subject to adjustment over time) or as a fixed fee agreed upon at the time you sign the investment advisory agreement. The fees for financial planning services are billed to you upon completion of the contracted services and are due and payable at that time.

Nepsis provides financial consulting services under a fixed fee arrangement. A mutually agreed upon fixed fee is charged for consulting services under this arrangement. The fixed fee charged by Nepsis for consulting services will range from a minimum fee of $5,000 up to a maximum fee that is negotiable depending the services to be performed and the complexity of the clients situation, The amount of the fixed fee for your engagement is specified in your agreement with Nepsis. Upon completion for the consulting services the fixed fee is considered earned by Nepsis and any unpaid amount is immediately due. You may terminate the financial planning agreement within five days of the date of execution without penalty. After the five-day period, either party may terminate the agreement by providing written notice to the other party. In the event you terminate the agreement after five days of execution, you will only be charged for the portion of work Nepsis has performed. You may act on our recommendations by placing securities transactions with any brokerage firm you choose. You are under no obligation to act on our financial planning recommendations. Moreover, if you elect to act on any of the recommendations, you are under no obligation to implement the financial plan through us.

Fees for Sub-Advisory Services For our sub-advisory service, we receive a portion of the investment advisory fee from the third- party advisor.

Fees for Research Services Our research services are available for the following costs; but are subject to change based on the amount of time involved and the complexity of the research. For those clients wishing only to pay for basic services, the following schedule is typical. These fees are payable monthly, in advance. 1. Research & Analysis costs $1500 per year 2. Portfolio Analytics costs $4500 per year 3. Speaking Services cost $1000 per educational workshop and $400 per Kaplan University Class

Other Fees Associated with Investing Our advice may include investment in mutual funds. All fees we receive for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds (described in each fund’s prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. Further, there are transaction charges involved with purchasing or selling of securities. Nepsis does not share in any portion of the brokerage fees or transaction charges imposed by the custodian holding the client funds or securities. You should review all fees charged by mutual funds, Nepsis, and others to fully understand the total amount of fees you will pay. You do not typically pay custodial transaction fees because we offer our portfolio management services as a wrap fee program. Your trading costs are included in the wrap fee. You may be charged a fee for such items as margin interest, a fee for a retirement account, or a transfer fee.

• Technical – analysis performed on historical and present data, focusing on price and trade volume, to forecast the direction of prices. We use the following investment strategies when implementing investment advice given to clients: • Long Term Purchases: Securities held at least one year • Short Term Purchases: Securities held less than one year Our primary investment strategies - Long Term Purchases and Short-Term Purchases are fundamental investment strategies. However, every investment strategy has its own inherent risks and limitations. For example, longer-term nvestment strategies require a longer investment time period to allow the strategy to potentially develop. Shorter-term investment strategies require a shorter investment time period to potentially develop but as a result of more frequent trading, may incur higher transactional costs when compared to a longer-term investment strategy.

Primarily Recommend One Type of Security We do not primarily recommend one type of security to clients. Instead, we recommend any product that may be suitable for each client relative to that client’s specific circumstances and needs.

Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal.

Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through our investment management program, as described below: • Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • Equity (stock) Market Risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • Options Risk. Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. • ETF and Mutual Fund Risk. When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Management Risk. Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease.

Insurance Agency/Agents We have created an affiliate company - Nepsis Insurance, Inc. and insurance agency in the state of Minnesota. You may work with your investment adviser representative in his or her separate capacity as an insurance agent though the Nepsis agency. When acting in his or her separate capacity as an insurance agent, the investment adviser representative may sell, for commissions, general disability insurance, life insurance and annuities to you. As such, your investment adviser representative in his or her separate capacity an insurance agent, may suggest that you implement recommendations of Nepsis by purchasing disability insurance, life insurance or annuities. This receipt of commissions creates an incentive for the representative to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as an insurance agent. Consequently, the advice rendered to you could be biased. You are under no obligation to implement any insurance or annuity transaction through your investment adviser representative.

Accounting Services In January 2023 Mark Pearson, President of Nepsis Inc. purchased a CPA firm and branded the company as Nepsis Tax Solutions LLC . If any of the Nepsis Tax Solutions LLC accounting clients need assistance with advisory matters, they will be referred to Nepsis. Nepsis Tax Solutions LLC does not provide advisory services to Nepsis’ clients and does not receive advisory fees. This is a conflict due to Mr. Pearson’s ownership of Nepsis Inc and Nepsis Tax Solutions LLC. While Nepsis Tax Solutions LLC is not directly compensated for accounting client referrals, as one of Advisor’s owners Mr. Pearson receives profits earned by the company. Nepsis, Inc. may also refer advisory clients needing assistance with accounting matters to Nepsis Tax Solutions LLC. Clients are not obligated to use Nepsis Tax Solutions LLC for accounting services, and no referral fees are paid to Nepsis, Inc. if they elect to do so. Please refer to Item 14 – Client Referrals and Other Compensation for a more detailed explanation of the relationship between Nepsis, Inc. and Nepsis Tax Solutions, LLC.

Other Business Activity of the Company Principal For the time period of May 2013 to May 2016 (while Ecoark was a private company) the company president, Mark Pearson was a member of the advisory board of Ecoark Holdings, Inc. As a member of the Advisory Board Mr. Pearson was compensated with 62,500 shares of Ecoark stock as compensation for advising Ecoark management on strategic decisions and direction for the company, including the purchase of Zest Labs, Inc. Significant positions of Ecoark Holdings, Inc stock have been included in client’s investment advisory portfolios managed by Nepsis on a discretionary basis. Nepsis clients have also invested in the shares of Ecoark Holdings, Inc. outside of their managed accounts. The receipt of the shares of stock as compensation created a conflict of interest for Mr. Pearson since he was providing advice on the strategic direction of the company. Mr. Pearson addressed this conflict of interest at the time by only placing the shares of Ecoark Holdings, Inc in to the portfolios of clients whose financial situations and risk tolerance were suitable for an investment in to a private and speculative stock position. Because of Mark Pearson’s extensive experience investing in companies based in China, on November 15, 2016 Mark Pearson entered into a consulting agreement with China Rapid Finance Limited that terminated on March 15, 2017. The purpose of the consulting agreement was to assist analysts, shareholders and management of China Rapid Finance with the following: 1. 2. 3. 4. 5.

Formulation of certain investor communications as well as assisting the company with managing investor relations. Assist the Company with the conduct of market analysis by the company. Assist the Company with analyzing the effect trends in the People’s Republic of China market on the U.S. Assist the Company with performing an investment feasibility analysis. Providing expertise on Chinese Companies/ Stocks and input/ insights on valuation methodology and market opportunity.

Mr. Pearson will supply White River Energy Corp. with detailed analytical reports in exchange for a fixed consulting fee and shares of WTRV stock. Mr. Pearson has also personally invested in the securities issued by White River Energy Corp. Due to the personal relationship the Pearson Family has with the Chairman and CEO of White River Energy Corp., and its’ related companies, from time-to-time business transactions occur jointly. Some transactions may include personal loans. Mr. Pearson also has invested securities issued by White River in the managed portfolios of clients of Nepsis Inc. Currently, Nepsis, Inc. owns a significant ownership interest in White River Energy Corp. Mr. Pearson along with Nepsis associates recommends clients and prospective clients of Nepsis to invest directly in individual well developments as they come available through White River Energy Corp. His position of outside consultant and personal investor in White River Energy and his firm, Nepsis, being a large shareholder of White River Energy Corp., creates a significant conflict of interest that is mitigated by only recommending utilizing White River Energy Corp. securities in the portfolios of suitable Nepsis clients that have received an explanation of the conflicts and have agreement to the transaction. Additionally, Mr. Pearson and family entities invest in oil opportunities. Those opportunities may be made available to Nepsis clients and prospective clients when suitable and appropriate. in January 2023 Mark Pearson, President of Nepsis Inc. purchased a CPA firm and branded the company as Nepsis Tax Solutions, LLC. If any of the Nepsis Tax Solutions, LLC. accounting clients need assistance with advisory matters, they will be referred to Nepsis. Nepsis Tax Solutions, LLC. does not provide advisory services to Nepsis, Inc.’s clients and does not receive advisory fees. This is a conflict due to Mr. Pearson’s ownership of both Nepsis, Inc and Nepsis Tax Solutions, LLC. While Nepsis Tax Solutions, LLC. is not directly compensated for accounting client referrals, as one of Advisor’s owners Mr. Pearson receives profits earned by the Nepsis Tax Solutions, LLC. Nepsis, Inc. may also refer advisory clients needing assistance with accounting matters to Nepsis Tax Solutions, LLC. Investment Advisor Representatives of Nepsis can receive referral compensation for referring advisory clients to Nepsis Tax Solutions, LLC. This also is a conflict of interest which is mitigated by only referring clients that could benefit from the services provided by Nepsis Tax Solutions, LLC and the fact that clients are not obligated to use Nepsis Tax Solutions, LLC. for accounting services. Nepsis Tax has entered into an agreement to sell Tax Credits on behalf of White River Energy Corp. Due to this arrangement Mr. Pearson, his family, Nepsis Inc. and its IAR's may receive compensation for the sale of these tax credit purchases. In April 2024 Mark Pearson entered into an agreement with White River Energy Corp. to sell Tax Credits for which Nepsis Tax Advisors, LLP. was established for the purposes of receiving income from the sale of tax credits from White River Energy Corp. As part of the compensation for selling tax credits, Nepsis Tax Advisors, LLP has received tax credits from White River Energy Corp. This creates a significant conflict of interest that is mitigated by only recommending White River Energy Corp. Tax Credits to clients that could benefit from tax credits; and the fact that clients are not obligated to purchase the tax credits.

These relationships create a serious conflict of interest for Mr. Pearson and clients of the firm. This conflict is mitigated by only recommending utilizing Ecoark and White River Energy Corp. securities in the portfolios of suitable Nepsis clients that have received an explanation of the conflicts and have agreement to the transaction. Associated persons are aware of the rules regarding material non-public information and insider trading. Associated persons may buy or sell a specific security for their own account based on personal investment considerations, which Nepsis, Inc. does not deem appropriate to buy or sell for clients. We have adopted a Code of Ethics to instruct our personnel in their ethical obligations and to provide rules for their personal securities transactions. The Firm and all our personnel owe a duty of loyalty, fairness and good faith to our clients, and the obligation to adhere not only to the specific provisions of the code but also to the general principles that guide the Code. The Code covers a range of topics including general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings and private placements, reporting ethical violations, distribution of the Code, review and enforcement processes, amendments to Form ADV and supervisory procedures. We will provide a copy of the Code to any client or prospective Client upon request.

research and analytic services) • Financial strength, stability and responsibility • Reputation and integrity • Ability to maintain confide tiality The firm exercises reasonable due diligence to make certain that best execution is obtained for all clients when implementing any transaction by considering the back-office services, technology and pricing of services offered. We typically recommend Pershing, LLC member FINRA/SIPC, as custodian. We chose them as our main custodians because of their customer service, technology, trade execution, and low client expenses. They have no transaction fees, relatively low custodial fees, provide and document data on best execution basis for our review and monitoring, and provide many client services free of charge. You may instruct us to use one or more particular brokers for the transactions in your accounts. Clients who may want to direct us to use a particular broker should understand that this could prevent us from effectively negotiating brokerage commissions on your behalf. This arrangement may also prevent us from obtaining the most favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses and execution, clearing and settlement capabilities that you obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. We encourage you to discuss available alternatives with your Investment Advisor Representative.

Aggregate Trading We may “bunch” buy or sell orders for two or more clients into a single large order and place the bunched order with a single broker or dealer for execution (referred to as “block trading”). We are not obligated to place all transactions on a “bunched” basis. When determining whether to “bunch” orders, we rely on our judgment as to what course of action is likely to be fair and in the best interests of the relevant accounts on an overall basis. That is, we seek to avoid putting any client account at an advantage or disadvantage compared to our other client accounts that are buying or selling the same security. Block trading is permitted where the following conditions are met: Orders of two or more clients may be bunched only if we have determined, on an individual basis that the securities order is: 1. In the best interests of each client participating in the order; 2. Consistent with our duty to obtain best execution; and 3. Consistent with the terms of the investment Advisory agreement of each participating client. Where conducting a block trade, we will determine the accounts that will participate, and the specific allocations in advance of the transaction. If the entire order is filled, you will receive your portion of the allocation specified on the trade ticket. All allocations are completed prior to the close of business on trade date. Client accounts participating in the transaction will receive the weighted average price of the security and will incur a pro-rata share of the transaction cost, if any. Our books and records separately reflect, for each client for whom an order is bunched, the securities held by, purchased, and sold for that client. Records are retained for a minimum of five (5) years.

Trade Errors From time to time, errors may occur in trading, such as Nepsis personnel entering an incorrect number of shares to be traded or possibly entering an incorrect investment name, symbol or CUSIP number for the transaction. If such an event occurs, Nepsis will be responsible for any loss that might accrue to the Client. Likewise, in the unlikely event of excess gain, Nepsis does not benefit in any way from this as it stays with the custodian.

Reports to Clients Nepsis will prepare performance reports for asset management clients on a quarterly basis. In addition, Nepsis, Inc. will seek to assure that you will receive statements directly from your account custodian(s) at least quarterly. Financial planning accounts do not receive any reports other than the financial plan included as a part of the services originally contracted for.

Through these arrangements, we will pay a cash referral fee both to the solicitor and to the firm based on a percentage of our advisory fee under the terms of a written agreement. The amount of the fee may vary depending on the agreement executed with the firm. Those firms may in turn share a portion of the referral fee with other individuals or entities from whom the referral was generated. In any case, applicable state laws may require these persons to become licensed either as our representatives or as an independent investment adviser representative. We will request that our clients acknowledge this sub-advisory arrangement prior to acceptance of the Clients’ account for advisory services.

Accounting Firm Relationship Please see Item 10, Other Financial Industry Activities and Affiliations, for additional discussion about our affiliation with the accounting firm of Nepsis Tax Solutions, LLC. Clients of Nepsis Tax Solutions, LLC. may be referred to us for advisory services and we may refer advisory clients to Nepsis Tax Solutions, LLC. for accounting services. You are under no obligation to use our services or the services of Nepsis Tax Solutions, LLC. Because of this affiliation, both Nepsis Tax Solutions, LLC. and we have an incentive to recommend each other to clients before recommending other accounting and financial firms. This creates a conflict of interest.

If an advisory client decides to utilize the services of Nepsis Tax Solutions, LLC. for their tax preparation needs, the Advisor who initiated a program in which the firm may pay Nepsis Tax Solutions, LLC. for all or a portion of the tax preparation fees for advisory clients with assets under management of over $250,000. The decision to pay the tax preparation fees on behalf of qualified clients will not be available to all clients and will be solely at the discretion of the Advisor. As disclosed in Item 10 above, Investment Advisor Representatives of Nepsis can receive referral compensation for referring advisory clients to Nepsis Tax Services, LLC. This also is a conflict of interest which is mitigated by only referring clients that could benefit from the services provided by Nepsis Tax Services, LLC and the fact that clients are not obligated to use Nepsis Tax Services, LLC. for accounting services, and no referral fees are paid to Nepsis, Inc. if they elect to do so.

In addition, for certain client accounts we have the ability to transfer funds from their managed accounts to designated third parties based upon a standing letter of authorization. The SEC has also deemed this activity to be custody of client assets. However, our procedures are designed to meet the requirements established by the SEC. For accounts where we are deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the creation of all accounts and therefore are aware of the qualified custodian’s name, address, and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review all statements received from the custodian and are urged to carefully compare the custodian statement against reports received from us. When clients have questions about their account statements, they should contact us or the qualified custodian preparing the statement.

We do not have access to your funds and/or securities with the exception of having advisory fees deducted from your account and paid to us by the account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the account custodian.

Nepsis does not disclose any nonpublic personal information about its customers or former customers to any nonaffiliated third parties, except as permitted or required by law. In the course of servicing a Client’s account, Nepsis may share some information with its service providers, such as transfer agents, custodians, broker-dealers, accountants and lawyers. Nepsis restricts internal access to nonpublic personal information about the client to those employees who need to know that information in order to provide products or services to the Client. As emphasized above, it has always been and will always be the firm’s policy never to sell information about current or former customers or their accounts to anyone. It is also the firm’s policy not to share information unless required to process a transaction, at the request of a customer, or as required by law.

Class Action Lawsuits From time to time, securities held in the accounts of Clients will be the subject of class action lawsuits. Nepsis has no obligation to determine if securities held by the Client are subject to a pending or resolved class action lawsuit. Nepsis also has no duty to evaluate a Client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Nepsis has no obligation or responsibility to initiate litigation to recover damages on behalf of Clients who may have been injured as a result of actions, misconduct or negligence by corporate management of issuers whose securities are held by Clients. Where Nepsis receives written or electronic notice of a class action lawsuit, settlement or verdict affecting securities owned by a Client, it will forward all notices, proof of claim forms and other materials, to the Client. Electronic mail is acceptable where appropriate, and the Client has authorized contact in this manner.

For more information contact: Nepsis, Inc. (952) 746-2003 • Fax: (952) 746-2006 www.Nepsis.com

© Copyright 2026. Advisory services offered through Nepsis, Inc.: An SEC Registered Investment Advisor. “Investing With Clarity®”, “It’s All About Clarity®”, “Invest With Clarity®”, “Strategic Cost Averaging®” and “The Road to Nepsis®”, are trademarks of Nepsis, Inc.

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