Fortitude Wealth Management: investment adviser

Introductory Interview FWM conducts a no-obligation in-person or telephone interview (using information submitted by the prospective client) to assist in determining specific client needs, goals, objectives, and tolerance/capacity for risk. Should the client wish to engage FWM for its services, the client enters into a written agreement with FWM (the firm’s current ADV Part 2 brochure and Privacy Policy are provided to the client beforehand). Once an engagement agreement is in place, further discussion and data gathering may be conducted to obtain information from the client on financial needs, goals, holdings, etc. Financial advice and/or plans are based upon the information disclosed by the client or their legal agent, and incorporate the client's financial situation at the time the plan is prepared Financial Planning and Investment Consultation Services FWM provides financial planning and investment consultation services which may be either broad based or more narrowly focused, depending on the client’s needs and wishes. Such services may encompass one or more of the following areas, depending on each client's unique needs, circumstances and preferences: cash flow/budgeting, debt management, risk management, college funding, retirement planning, estate planning, tax planning, and asset allocation/portfolio design. Such services typically involve providing a variety of advice or services to clients regarding the management of their financial resources, based upon the analysis of their individual needs. FWM typically utilizes a long-term investment perspective, unless the client specifically requests to the contrary. If engaged for investment consultation, FWM may assist the client in constructing a portfolio deemed appropriate given the client's investment objectives and tolerance for risk. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation made by FWM. Further, it remains each client's responsibility to promptly notify FWM if there is any change in their financial situation or investment objectives for the purpose of evaluating or revising the Firm's previous

recommendations. With the client's consent, FWM may work with the client's other professional advisers (attorneys, insurance agents etc.) to assist with coordination and implementation of agreed upon strategies. The client should be aware that these other professional advisers may bill the client separately for their services, and these fees will be in addition to those of FWM. Periodic reviews are recommended for all clients under written agreement. Firm Services FWM will use its best judgment and good faith effort in rendering its services to its clients. FWM cannot warrant or guarantee any particular level of account performance, or that an account will be profitable over time. Past performance is not necessarily indicative of future results. Except as may otherwise be provided by law, FWM will not be liable to the client, heirs for any loss an account may suffer by reason of an investment decision made or other action taken or omitted in good faith by FWM with that degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; any loss arising from the FWM's adherence to the client or their legal agent's direction; or any act or failure to act by a service provider maintaining an account. Notwithstanding the preceding, nothing within the client services agreement is intended to diminish in any way the Firm's fiduciary obligation to act in the client's best interest or shall in any way limit or waive any rights clients have under federal or state securities laws or the rules promulgated pursuant to those laws.

The Advisor may terminate the agreement without notice if the Client intentionally fails to provide full and complete information relevant or material to any matter such in order to perform the services required under the client’s written agreement.

Fortitude Wealth Management’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, oddlot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Fortitude Wealth Management’s fee, and Fortitude Wealth Management shall not receive any portion of these commissions, fees, and costs. Assets under management (as of December 31st, 2025) Rounded to the nearest 1000

Discretionary: $0.00 Non-Discretionary: $ 112,500,000.00 Total: $112,500,000.00

Fortitude Wealth Management anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which Fortitude Wealth Management has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which Fortitude Wealth Management, its clients, directly or indirectly, have a position of interest. Fortitude Wealth Management’s employees and persons associated with Fortitude Wealth Management are required to follow Fortitude Wealth Management Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of Fortitude Wealth Management and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Fortitude Wealth Management’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Fortitude Wealth Management will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such

decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Fortitude Wealth Management’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee.