Eko: investment adviser

In addition, Eko licenses the Platform primarily to financial institutions such as banks, credit unions, and financial technology firms (“Financial Institutions”), who then offer Eko’s investment advisory services directly to their customers through Eko’s white-labeled product (“White-label Clients”). Eko provides limited-discretionary and non-discretionary advisory services (as further described below) to Clients, including recommending investment portfolios and giving Clients access to live dashboards through various Platforms (as described above). Eko does not provide investment advice in person, over the phone, in live chat, or in any manner other than through the Platform. The Platform includes educational artificial intelligence tools designed to help Clients better understand investing concepts and the features of the Platform, but which do not provide investment advice to clients. Eko creates personalized investment portfolios for Clients, in line with the Clients’ risk appetite and investment preferences, consisting of publicly traded equities (“Equities”), exchange-traded funds (“ETFs”), and digital assets such as cryptocurrency (“Crypto,” and together with Equities and ETFs, “Securities”). Eko’s investment preferences allow Clients to focus their investment portfolios on various investment topics. The investment topics categorized by Eko include, but are not limited to, aerospace, air transportation, automotive, construction, energy and utility, healthcare, medical manufacturing, retail, and tech companies. Eko deploys several models to capture the financial performance of companies in its investment universe. These financial checks look at volatility over an extended time period, trend data, volume data, Sharpe ratio, analyst ratings, and other technical indicators. These checks are automatically executed every day for all companies in Eko’s universe of Securities, so Eko seeks to recommend investments with a focus on maximizing financial returns while limiting volatility. Eko’s Investment Offerings The availability of Eko’s investment advisory products and services (“Advisory Products”) may be dependent on whether they are direct Clients or White-label Clients. For Eko’s White-label Clients, the White-label Clients’ affiliated Financial Institution(s) will determine which advisory products offered by Eko will be made available to their

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customers. Presently, Eko offers three (3) investment advisory products and services to Clients: ●​ Limited-Discretionary Pre-Built Portfolios. Clients may choose from a list of Pre-Built diversified investment portfolios (“Pre-Built Portfolios”) that consist of Securities that offer exposure to both stocks and bonds. Pre-Built Portfolios include, but may not be limited to the following: (i) a core portfolio that aims to gain exposure to the broader market and is geared towards long-term returns, aiming to reduce risk through diversification; (ii) an impact portfolio that focuses on investing in companies that meet environmental, social, and corporate governance criteria, while maintaining diversification in order to achieve long-term performance goals; and (iii) a technology first portfolio that includes Securities of high-growth potential technology companies within a diversified investment approach. Clients may choose to make certain limited changes to Pre-Built Portfolio holdings such as removing specific Securities or adjusting allocations but may not add Securities to the Pre-Built Portfolio. You may request to remove Securities in a Pre-Built Portfolio by utilizing the tools available to you on the Platform or by contacting Eko at hello@eko.investments. ●​ Limited-Discretionary Hybrid Portfolios. Eko recommends investment portfolios of Securities to Clients based on their risk appetite and investment preferences (“Hybrid Portfolios”). After selecting risk appetite, investment preferences, and investment goals, Eko generates a Hybrid Portfolio using direct indexing, meaning Hybrid Portfolios will primarily consist of individual stocks as opposed to using one or multiple ETFs. In some cases, Eko will add one or more ETFs to the Hybrid Portfolio, which likely will include ETF-traded bonds. The allocation of ETFs will generally not be larger than twenty-five percent (25%) of a Hybrid Portfolio. Otherwise, Eko’s recommended Hybrid Portfolios will generally include 15-50 individual stocks or ETFs and in the discretion of Eko, will include well-diversified ETFs. Prior to and after a Client funds an investment account to purchase the Securities in a Hybrid Portfolio, the Client may remove and/or add a limited number of Securities from and/or to the Hybrid Portfolio. Any additions a Client chooses to make to the Hybrid Portfolio will be from a limited universe of Securities recommended by Eko and based on the Client’s risk appetite, investment profile, and other relevant factors. ●​ Non-Discretionary, Without Qualification, Portfolios. Eko offers non-discretionary, without qualification, portfolios (“Non-Discretionary Portfolios”) for suitable Clients and enables Clients to add limited Securities based on your investment profile and other relevant factors. Securities available to be added to Non-Discretionary Portfolios will be from a limited universe of Securities recommended by Eko and based on the Client’s risk appetite, investment profile, and other relevant factors.

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Clients have the ability to exercise influence over their Advisory Products by restricting specific Securities, including Equities, ETFs, and Crypto, from being included in their investment portfolios. Clients may also customize their portfolios by selecting or excluding certain investment categories/sectors as described above. Advisory Products are monitored and managed by Eko on the Client’s behalf, to ensure that the Advisory Products correlate with the Client’s risk appetite and investment preferences. For both Pre-Built Portfolios and Hybrid Portfolios, Eko has discretionary authority to rebalance the portfolios where such opportunities exist based on various market factors or where the Client’s investment account is no longer aligned with the Client’s risk appetite and investment preferences. Our investing strategies utilize a proprietary quantitative investment model that primarily selects Equities and ETFs. Since our universe of available Securities is constantly monitored, including adding other potential companies into the available universe of Securities, our universe of Securities is subject to change throughout the year. Please refer to Item 6 for an overview of our quantitative investment model. All Clients receive advisory services via Eko’s Platform, which can be accessed through Eko’s website and mobile application, and concerning White-label Clients, through the Financial Institutions’ online websites or mobile applications. Before a Client’s Advisory Product(s) are structured and implemented, whereby Eko provides investment recommendations pursuant to our quantitative models, the Client must fill out an online questionnaire designed to identify investment objectives and tolerance for risk. This questionnaire has two parts: (1) questions regarding the risk appetite of the Client and (2) a selection of investment categories/sectors the Client can pick. When a Client chooses certain investment categories/sectors, Eko’s investment recommendations will focus on including Securities from the applicable categories for the Client’s investment portfolio. Typically, a Client can pick from 10-15 investment categories/sectors in the questionnaire. However, in some cases more investment categories/sectors may be available, if, for example, requested by the Client’s Financial Institution. Clients can choose from, including, but not limited to, the following categories: aerospace, air transportation, automotive, construction, energy and utility, healthcare, medical manufacturing, retail, and tech companies, as well as female-owned and black-owned companies. This second part of the questionnaire, regarding a Client’s interest in investing in certain investment categories/sectors, is optional. Clients may choose not to have specific investment categories/sectors within Eko’s recommended investment portfolio. The responses to the questionnaire are the sole basis upon which Eko recommends an investment portfolio. The Client’s input in the questionnaire, together with the quantitative models that Eko deploys will lead to a final recommended investment portfolio. Our technology does not work with ‘baskets’, instead, every Client will receive a personalized investment portfolio that aligns with their risk appetite and optionally selected investment categories/sectors, which can also be described as direct indexing. -6-

As noted above, direct indexing is an investment strategy where an investor holds individual stocks that make up an index in their own account directly, instead of using a mutual fund or ETF to track the underlying index. After the investment portfolio is recommended, depending on what account-type product is chosen by the Client, Clients may have the possibility to remove certain securities from their investment portfolio. Clients will be required to open a custody account with Alpaca Securities, LLC (“Alpaca” or “Custodian”) who will serve as the “qualified custodian” for all Client accounts. Clients will also be required to execute an investment advisory agreement (“Advisory Agreement”) with Eko that establishes the terms and advisory services that Eko provides. Through the Advisory Agreement with Eko, Clients authorize Eko to open an account with Alpaca, a registered broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). Alpaca provides custody, clearing, and settlement services for Clients with respect to Securities transactions. The Advisory Agreement sets forth the terms and conditions of the advisory services provided by Eko. When Clients enter into an Advisory Agreement with Eko, Clients grant Eko certain discretionary authority to manage his or her account. Alpaca exercises no discretion in determining if and when trades are placed. When a Client opens an account with Eko, they grant us investment discretion (or limited investment discretion, as applicable) to manage the Client’s investment account and execute trades in the investment account, and we may initiate or halt trading at our discretion and for any reason, including halting trading under conditions when we believe that continued trading may pose an undue risk of harm to the Client’s investment accounts. Client onboarding is only complete once a Client (i) has linked the Client’s bank account (“Funding Account”) to the Firm’s broker-dealer/Custodian (Eko will not have access to a Client’s bank account information nor will Eko have access to a Client’s login credentials); and (ii) Eko has accepted and countersigned Eko’s Advisory Agreement electronically. Clients may fund their investment accounts through transfers from their linked Funding Account. In some cases, Clients may also purchase Securities directly from a checking account without using the Funding Account wallet feature. Fund transfers are generally processed using Real-Time Payment (“RTP”) rails, where available and if requested by the applicable Financial Institution, or Automated Clearing House (“ACH”) transfers. Eko expects to offer a round-up feature that allows Clients to automatically invest spare change from everyday purchases. When available, the round-up feature rounds up the purchase amounts from a Client’s linked debit or credit card transactions to the nearest dollar and invests the difference into the Client's investment account. The availability and specific terms of the round-up feature may vary and are subject to change. Only when Client onboarding is complete will the Client’s investment account be actively managed by Eko. Clients should understand that Eko primarily uses electronic (not telephonic) means to provide customer support. Clients and prospective Clients should -7-

be comfortable communicating through those channels. Further, Clients should understand that they will not interact directly with investment advisory personnel. White-label Clients should understand that certain aspects of customer service with respect to their Eko investment account may also be provided through their Financial Institution, although any such customer services provided by the Financial Institution with respect to their investment account advised by Eko may be limited. Eko does not provide comprehensive financial or tax planning or legal advice, and Clients are advised and afforded the opportunity to seek the advice and counsel of the Client’s own tax, financial, and legal advisers. Eko does not provide a complete investment program and Clients should not use it as the sole component of their investment plan. Neither Eko nor any of its affiliates is responsible for establishing or maintaining any Client’s compliance with the requirements of the Internal Revenue Code for a Traditional IRA or Roth IRA, or any other type of account that may be managed by Eko or determining any Client’s individual tax treatment regarding such an account. Furthermore, neither Eko nor any of its affiliates is responsible for withholding any tax penalties that may apply to Client accounts or for any state or federal income tax withholding, except as may otherwise be required by applicable law. Wrap Fee Program Description Eko’s services are offered pursuant to a wrap fee program under which Clients pay a single Management Fee that covers Eko's investment advisory services, trade execution, and custody services provided through the Custodian. The Management Fee does not include certain costs that may be charged by third parties, such as ETF expense ratios or fees charged by Financial Institutions. Under this wrap fee arrangement, Clients may pay more or less than they would if they paid separately for investment advisory services, brokerage, and other services. Whether a wrap fee arrangement is appropriate for a Client depends on factors including the trading activity in the account. Clients who trade infrequently may pay more under a wrap fee arrangement than if they paid for transactions separately. Eko does not receive additional compensation based on the number of trades executed in Client accounts; therefore, Eko does not have a financial incentive to limit trading activity in Client accounts. Fees and Compensation Eko is compensated by charging Clients up to 0.5% per year based on the value of their assets and investments managed and advised by Eko for Pre-Built Portfolios and Hybrid Portfolios (an “AUM-Based Fee”), a flat monthly fee of up to $3.00 per month (a “Flat Fee”), or a combination of both, in each case as determined by the Financial Institution through which the Client accesses the Eko Platform, subject to Eko's review and approval (together, the “Management Fee”). No Management Fee will be charged to Clients who solely have Non-Discretionary Portfolios. The Management Fee is charged monthly in arrears. The AUM-Based Fee is automatically deducted from the Client's custodial account, and the Flat Fee, if any, is automatically deducted from the Client's designated checking or savings

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account, unless Eko notifies the Client of a different collection method through the Eko Platform. If a Client’s investment account does not have enough funds to cover the Management Fee, Eko may be required (as authorized through the Advisory Agreement with the Client) to sell a portion of securities in Client’s investment account to raise funds sufficient to cover our Management Fee. We reserve the right, in our sole discretion, to reduce or waive the Management Fee for certain Client accounts for any period of time that we determine. Further, certain Financial Institutions may determine to offer Eko’s advisory services to White-label Clients at no cost. In such circumstances, Eko will not charge such White-label Clients the Management Fee but instead may charge the Management Fee or additional fees directly to the Financial Institution. In the event Clients wish to terminate our services, a prorated amount of the Management Fee will be charged to your account(s) based on the number of days in the month that the investment account remained active prior to the termination. You must provide notice of termination as outlined in your Advisory Agreement. Upon receipt of such notice, we will proceed to close out your account(s). Crypto Transaction Fee If a Client elects to enable cryptocurrency features on the Eko Platform, Eko charges a transaction fee equal to 1% of the value of each Crypto transaction (the “Crypto Transaction Fee”). The Crypto Transaction Fee is separate from, and in addition to, the Management Fee described above. Eko's services are offered pursuant to a wrap fee program as described above; the Crypto Transaction Fee is not included within, and is charged in addition to, the wrap fee, because Crypto transactions are executed outside of the bundled wrap fee arrangement applicable to Equities and ETFs. The Crypto Transaction Fee is automatically deducted from the Client's custodial account at the time of each Crypto transaction. Financial Institution Fees In some cases, Eko charges a fee to the Financial Institutions to integrate and/or implement Eko’s Platform into the Financial Institution’s platform, in order to provide Eko’s advisory services and Platform directly to White-label Clients. Such fees are separate from the Management Fee that may be charged to Clients, and Clients are not directly charged these platform integration and implementation fees. In addition, Financial Institutions may charge their customers additional fees in addition to Eko’s Management Fee in connection with providing Eko’s advisory services and Platform directly to White-label Clients on the Financial Institution’s platform. Such fees will generally be determined independent from Eko, and while Eko may collect such additional fees from Clients on behalf of the Financial Institution, either from their Funding Accounts or their investment accounts, Eko remits such additional fees to the Financial Institution and no portion of such fees charged by Financial Institutions will be retained by Eko. White-label Clients may therefore be required to pay fees for Eko’s advisory services in excess of the Management Fee which Eko will charge to direct Clients and should review any such fees that may be charged by their Financial Institution before determining to become a White-label Client of Eko.

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Other Fees The issuer of some of the securities or products purchased for Clients, such as ETFs, may charge product fees that affect Clients. Eko does not charge these fees to Clients and does not benefit directly or indirectly from any such fees. An ETF typically includes embedded expenses that may reduce the ETF’s net asset value, and therefore directly affect the ETF’s performance and indirectly affect a Client’s portfolio performance. Assets Under Management As of March 31, 2026, we managed $74.889.305,90 in client assets, $47.927.767,20 of which was managed on a discretionary basis and $26.961.538,70 of which was managed on a non-discretionary basis.

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When evaluating our quantitative-based investment advisory service, Clients should be aware that their relationship with us is likely to be different from the “traditional” investment advisory relationship in several aspects: ●​ Eko is a software-based investment advisor, which means you must acknowledge your ability and willingness to conduct your relationship with Eko on the Platform. Under the terms of your Advisory Agreement with Eko, you agree to receive all account information and account documents (including this Brochure) and any updates or changes to the same, through your access to our Platform or the Financial Institution’s white-labeled website. Alternatively, we use emails, to the email address that is provided by the Client at onboarding to provide information regarding your investment account. Emails regarding your investment account can come directly from Eko, or via the Financial Institution (for White-label Clients). Although we have customer service, we do not guarantee that individual representatives are available at all times to discuss client servicing matters with you. ●​ To provide our investment advisory services and tailor investment decisions to your specific needs, we collect information from you, including specific information about your investing profile such as your financial situation and investment horizon. We maintain this information in strict confidence subject to our privacy policy, which is provided on our Platform. In case there have been updates to a Client’s financial situation, Clients have the option to communicate this to us through our Platform. Eko will also periodically, but no less frequently than annually, reach out to Clients to confirm any changes or updates to the Clients’ financial situation. ●​ The SEC has provided further information for investors to consider when engaging digital advisory services, which can be found at: http://www.investor.gov/additional-resources/news-alerts/alerts-bulletins/investor -bulletin-roboadvisers.

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In all cases, however, our advisory services are exercised in a manner consistent with our fiduciary duties to you and the stated investment objectives for your investment account. Method of Analysis, Investment Strategies and Risk of Loss Eko’s quantitative investment strategies use proprietary, quantitative models and processes to select securities, construct portfolios, manage risk and deliver targeted outcomes. Our strategies can incorporate personalized investing principles to further tailor investment outcomes. Eko’s Quantitative Investment Model Our quantitative investment model uses algorithms (i.e., a set of rules embedded in a computer program) to: ●​ identify Securities (Equities and ETFs) that meet the Client’s risk appetite and investment preferences, and recommend an investment portfolio based on a Client's investment objectives. ●​ identify investment portfolio opportunities and initiate buy/sell orders for the investment opportunities it has identified and recommended. ●​ Perform a periodic review of Client investment accounts to identify rebalancing opportunities as well as to initiate buy or sell orders when such rebalancing opportunities exist. The frequency of this rebalancing depends on several factors, including market volatility. ●​ Initiate buy or sell orders when a Client seeks to withdraw or deposit funds in their investment account. Eko will seek to ensure that such buy/sell orders remain in line with the Client’s risk appetite, investment objectives and any optionally selected investment categories/sectors. Eko provides Clients with investment advice that is based on Modern Portfolio Theory (“MPT”). MPT attempts to maximize an investment portfolio’s expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return,

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by selecting the proportions of various asset classes to be held in the investment portfolio. Eko’s quantitative investment model begins with the determination of a Client’s investment objective, subjective tolerance for risk and optional investment categories/sectors. Eko receives this information via a questionnaire. Based on this, Eko creates a personalized investment portfolio of recommended investments. Measuring Impact Eko provides the option to not only share the financial performance of an investment portfolio, but also the investment portfolio’s sustainability impact performance. We do this by collecting for each company in our universe how much CO2 they emit, obtaining this data either from 1) annual/sustainability reports published by the company or 2) third-party data providers. We then assess how much CO2 a company emits per $1 invested. We then compare this to other companies that are in the same industry, and then derive a sustainability impact performance metric per $1 invested based on the company’s industry. The CO2 emitted per Client is then calculated by multiplying the share a Client owns of a company (e.g., the Client owns 10 out of 100,000 shares = 0.01%) by the total amount of CO2 the company has emitted. Eko is able to conduct this analysis for Securities in a Client’s investment portfolio, to the extent data is available to do so, to obtain the total impact per Client sustainability performance. Account Rebalancing and Ongoing Management Client accounts may be rebalanced from time to time for reasons including, but not limited to, updates to Eko’s quantitative model portfolios, market performance, cash inflows/outflows, client adjustment of investment profile or risk tolerance, a change in the underlying universe of securities selected by Eko, or adjustments to issue/theme preferences identified by a Client. Account rebalancing may occur at any time and without notice to Clients. Typically, investment accounts are rebalanced once every six (6) months, or more often as conditions dictate. All rebalancing is automated for simplicity of execution and is therefore subject to potential automation errors. In the event of a market downturn, it is possible that the rebalancing will sell securities in now overweight sectors to purchase additional shares of securities that are now underweight, which could exacerbate losses in such an environment. Eko reserves the right, in its full discretion, to halt account rebalancing in the best interests of Clients. In addition, as part of our ongoing portfolio management process, Eko can determine whether the Client’s allocation of securities in its investment account should be adjusted as the time horizon of the goal approaches. Tax-Loss Harvesting Eko provides tax-loss harvesting services to Clients. Tax-loss harvesting is a technique designed to help lower a Client’s taxes while maintaining the expected risk and return

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profile of the Client’s portfolio. It harvests unrecognized investment losses to offset taxes due on the account’s other gains and income by selling a security at a loss to accelerate the realization of capital loss, and investing the proceeds in a security with closely correlated risk and return characteristics. The realized loss can be applied to lower your tax liability and the tax savings can be reinvested to grow the value of your portfolio. Tax-loss harvesting is available to all Clients who choose our recommended portfolios. It is also available to Clients who customize our recommended portfolios. The minimum account value for tax-loss harvesting is $10. Summary of Material Risks Investing in securities involves risk of loss that Clients should be prepared to bear. All investments include inherent risks of loss of principal. We do not guarantee rates of return on investments for any period. All Clients assume the risk that investment returns may be negative or below the rates of return of other investment advisers, market indexes, or investment products. You may experience a loss of value in your investments. Past performance does not guarantee future results, and there is no guarantee that your investment objectives will be achieved. While we seek to manage investment accounts so that risks are appropriate to the strategy, it is not possible to fully mitigate all risks. Your investments with us are not a bank deposit and are not insured or guaranteed by the National Credit Union Administration (NCUA), the FDIC, or any other government agency. The risk factors set forth below represent a general summary of the material risks involved in our investment strategies described above: ●​ Market Risk: The value of equity or fixed income securities owned may decline, at times sharply and unpredictably, because of economic changes or other events that affect individual issuers or large portions of the market. Market risk includes the risk that a particular style of investing, such as growth or value, may underperform other styles of investing or the market generally. Economic factors such as inflation, changes in interest rates, geopolitical events, trade policies, pandemics, or other public health emergencies may adversely affect securities markets and result in significant losses. Market volatility may be exacerbated by algorithmic trading, changes in market liquidity, or broader macroeconomic conditions. ●​ Model Risk: Our investment strategies include the use of proprietary quantitative investment models. These quantitative models may not consider all prevailing market conditions when making recommendations to you. Investments selected using such models may perform differently than expected, and there is no guarantee that any model will achieve its objective due to underlying factors such as not performing in line with historical trends or data. The effectiveness of models may be reduced over time as a result of changing market conditions, as models are often based on historical data that may not accurately predict future

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market behavior. Model Risk is the risk that a model does not perform as it was designed, either due to error or failure in the model specification, flawed assumptions, or inappropriate use. The models we use to manage investment accounts are subject to change without notice. The performance of the model in meeting the investment objectives is dependent upon, but not limited to, a number of considerations including the definition of the individual factors, the accuracy of the data used in building and implementing the factors, the interrelationships of factors and changing behavior when multi-factor strategies are employed, and accurate coding in the initial construction of the model and subsequent changes. Different market conditions, volatilities, and correlations among the securities than what existed during the construction and back-testing of the model may lead to performance not consistent with expectations. Additionally, models may be susceptible to overfitting to historical data, which can result in poor performance during future market conditions that differ from historical patterns. ●​ Qualitative Investing Risk: Quantitative investing risk is the risk that the value of securities or other investments selected using quantitative analysis can perform differently from the market as a whole or from their expected performance. This may be as a result of the factors used in building the multifactor quantitative model, the weights placed on each factor, the accuracy of historical data supplied by third parties and changing sources of market returns. ●​ Software Risk: Eko delivers its investment advisory services entirely through software. Consequently, Eko rigorously designs, develops, and tests its software extensively before putting such software into production with actual Client accounts and assets and periodically monitors the behaviors of such software after its deployment. Notwithstanding this rigorous design, development, testing, and monitoring, it is possible that such software may not always perform exactly as intended or as disclosed on the Platform, mobile app, or other Eko disclosure documents, especially in certain combinations of unusual circumstances or during periods of high market volatility or trading volume. For example, there may be occasions where a number of Client accounts may not experience rebalancing back to a Client’s target asset allocation for extended periods of time, due to certain errors in the deployment of the software. Software updates, patches, or changes to third-party dependencies may introduce new errors or unexpected behavior. We strive to monitor, detect, and correct any software that does not perform as expected or as disclosed. ●​ Artificial Intelligence Risk: Eko's Platform includes educational artificial intelligence tools designed to help Clients understand investing concepts and Platform features. The use of artificial intelligence and machine learning technologies involves inherent risks, including the risk that AI systems may produce inaccurate, incomplete, or misleading information. AI systems are trained on historical data and may not accurately reflect current market conditions or account for unprecedented events. AI-generated content should not be relied -15-

upon as investment advice, and Clients should exercise independent judgment when using AI tools. Additionally, AI systems may be subject to bias, errors in underlying data, or unexpected behavior that could negatively impact the quality of information provided to Clients. ●​ Management Risk: A strategy used by the investment advisory team may fail to produce the intended results. ●​ Issuer Risk: The value of a security may decline for a number of reasons, which directly relate to the issuer, such as management performance, financial advantage and reduced demand for the issuer’s products or services. ●​ Research Data: When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, Eko relies on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. Therefore, while Eko makes efforts to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the advice regarding or investment management of a Client account. ●​ Diversification Risks: When a Client selects their own investment categories/sectors, such as tech, renewable energy and/or regional companies, it can be the case that the investment portfolios will be more concentrated in specific industry groups. Such industry concentration could have a material effect on the performance of the investment portfolio if the particular industry sector in which the investment portfolio is invested does not perform well or falls out of favor. Non-diversified portfolios may experience greater volatility than diversified portfolios. The risks of investing in a non-diversified portfolio may also be greater than the risks of investing in a diversified portfolio. ●​ Country, Industry and Market Sector Risk: An investment strategy may result in significant over or under-exposure to certain country, industry or market sectors, which may cause an account’s performance to be more or less sensitive to developments affecting those countries, industries, or sectors. ●​ Tax-Loss Harvesting Risk: Utilizing a tax-loss harvesting service has the following risks: o​ Clients should confer with their own tax advisor regarding the tax consequences of investing with Eko and utilizing a tax-loss harvesting strategy, based on their particular circumstances. Clients and their personal tax advisors are responsible for how the transactions in the Client’s account are reported to the Internal Revenue Service (“IRS”) or any other taxing authority. Eko assumes no responsibility to you for the tax -16-

consequences of any transaction, including any capital gains and/or wash sales that may result from the tax-loss harvesting strategy. o​ Eko’s tax-loss harvesting service is not intended as tax advice, and Eko does not represent in any manner that the tax consequences described will be obtained or that Eko’s investment strategy will result in any particular tax consequence. o​ The performance of the new securities purchased through the tax-loss harvesting service may be better or worse than the performance of the securities that are sold for tax-loss harvesting purposes. o​ Eko’s tax-loss harvesting service is designed to avoid creating “wash sales” in Clients’ accounts. Clients, however, are responsible for monitoring their accounts outside of Eko to ensure that transactions in the same security or a substantially similar security do not create a wash sale. A wash sale occurs when a taxpayer sells a security at a loss and then purchases the same security or a substantially similar security over a period of 61 days: the day of the sale, the 30 days before the sale, and the 30 days after the sale. If a wash sale occurs, the IRS may disallow or defer the loss for current tax reporting purposes. Wash sales can occur even if the securities are sold and then bought in different accounts. o​ Not all the losses may be used to offset gains in the year they were recognized due to wash sales. Thus, certain sales can diminish the effectiveness of tax-loss harvesting by deferring to a future year a tax loss that could have been used to offset income or capital gains in the current year. ●​ Equity-Related Risks: The prices of equity securities will rise and fall. These price movements may result from factors affecting individual companies, industries, or the securities market as a whole. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a decline in response. In addition, the equity market tends to move in cycles, which may cause stock prices to fall over short or extended periods of time. ●​ Large-Cap and Mid-Cap Risks: Large-cap and/or mid-cap segments of the stock market bear the risk that these types of stocks tend to go in and out of favor based on market and economic conditions. However, stocks of mid-cap companies tend to be more volatile than those of large-cap companies because mid-cap companies tend to be more susceptible to adverse business or economic events than larger, more established companies. During a period when large- and mid-cap U.S. stocks fall behind other types of investments, bonds or small-cap

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stocks, for instance, the performance of investment strategies focused on largeand/or mid-cap stocks will lag the performance of these other investments. ●​ ETF Risks, including Net Asset Valuations and Tracking Error: ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depositary Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange traded equity securities, and for which market quotations or valuation may be limited or inaccurate. ●​ Interest Rate Risk: Changes in interest rates may adversely affect the value of fixed income securities and bond ETFs held in Client portfolios. When interest rates rise, the value of existing fixed income securities typically declines. The magnitude of this decline depends on factors such as the duration of the securities and the extent of the interest rate change. In a rising interest rate environment, Client portfolios with exposure to fixed income securities or bond ETFs may experience losses. Conversely, falling interest rates may reduce the income generated by fixed income investments. Interest rate changes may also affect the broader economy and equity markets, potentially impacting the value of other securities in Client portfolios. ●​ Clients should be aware that to the extent they invest in ETF securities, they will pay two levels of compensation – fees charged by Eko, which are currently zero, plus any management fees charged by the issuer of the ETF. This scenario may cause a higher cost (and potentially lower investment returns) than if a Client purchased the ETF directly. ●​ An ETF typically includes embedded expenses that may reduce the ETF’s net asset value, and therefore directly affect the fund’s performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment adviser management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. ●​ Socially Responsible Investing: Investments may focus on “low carbon or other areas of socially responsible investing. These investment strategies may limit the universe of available investments and may result in performance that differs from

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funds that do not apply similar criteria. Due to the consideration of non-monetary factors in investment decisions, these investments may experience a lower rate of return compared to investments that do not consider such factors. Socially responsible investing criteria may vary among investment managers, and there is no standardized definition of what constitutes a socially responsible investment. Additionally, socially responsible investments may be subject to changing regulatory requirements, evolving industry standards, and reputational risks associated with holdings that later become controversial. ●​ Cryptocurrency Risks: Cryptocurrency and digital asset investments are subject to unique and substantial risks, including extreme price volatility, regulatory uncertainty, cybersecurity risks (including hacking and theft), technological risks, and limited operating history. Cryptocurrency markets operate continuously and prices can change significantly at any time, including during periods when traditional securities markets are closed. Cryptocurrencies are not backed by any government or central bank, and the regulatory landscape for digital assets is evolving and uncertain. Federal and state regulators, including the SEC, CFTC, and state regulators, have taken varying approaches to cryptocurrency regulation, and future regulatory actions could materially impact the value or legality of certain digital assets. There is no guarantee that any cryptocurrency will maintain its value, and Clients could lose their entire investment in cryptocurrency holdings. Custody of cryptocurrency assets involves risks related to the security of private keys and digital wallets. Cryptocurrency transactions may be irreversible, and there may be limited recourse in the event of unauthorized transactions, fraud, or errors. Cryptocurrency exchanges and platforms may be subject to hacking, fraud, manipulation, or operational failures. Additionally, the tax treatment of cryptocurrency transactions is complex and subject to change. ●​ Allocation Risk: Asset classes in which the strategy seeks investment exposure can perform differently than each other at any given time so the strategy will then be affected by its allocation among the various asset classes. If the strategy favors exposure to an asset class during a period when that class underperforms, performance may be hurt. ●​ Inflation Risk: Inflation risk is the risk that the purchasing power of a Client's investments will be eroded by rising prices over time. During periods of elevated inflation, the real returns on investments may be lower than the nominal returns, and certain asset classes may be more adversely affected by inflation than others. Inflation may also lead to higher interest rates, which can negatively impact the value of fixed income securities and potentially affect equity valuations. While diversification across asset classes may help mitigate inflation risk, there is no guarantee that investment returns will keep pace with inflation.

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●​ Operational Risk: We rely on various affiliated and unaffiliated service providers to provide services to you, including, among others, custodians, broker-dealers, internet hosting services, cloud computing providers, payment processors, and others. We and our service providers may experience disruptions or operating errors that could negatively impact your account or your ability to get real-time information regarding your account. Such disruptions may result from system failures, power outages, natural disasters, cyberattacks, or human error. While we rely on our service providers to have appropriate operational risk management policies and procedures, their methods of operational risk management may differ from our own in the setting of priorities, personnel, resources available, or the effectiveness of relevant controls. Through our monitoring and oversight of service providers, we seek to ensure that service providers take appropriate precautions to avoid and mitigate risks that could lead to disruptions and operating errors. However, it is not possible for Eko or service providers to identify all of the operational risks that may affect Client accounts or to develop processes and controls to completely eliminate or mitigate their occurrence or effects. ●​ Risk of Loss: We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. You need to understand that recommendations made for your investment account by us are subject to various market, currency, economic, political and business risks. Despite our best efforts, the investment recommendations we make for you will not always be profitable nor can we guarantee any level of performance. Eko does not represent, warrant, or imply that the services or methods of analysis used can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from major losses due to market corrections or crashes. No guarantees are offered that a Clients’ goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by Eko will provide a better return than other investment strategies. Investments in securities and other financial instruments involve risk of loss that investors must be prepared to bear. ●​ Liquidity Risk: Certain securities held in Client portfolios may be difficult to sell at favorable prices or in a timely manner, particularly during periods of market stress or volatility. Liquidity risk may be heightened for less frequently traded securities, securities of smaller companies, or during periods of significant market disruption. In some cases, Eko may be unable to sell securities at desired prices, which could result in losses to Client accounts. Additionally, the 24/5 trading feature offered by Eko may involve trading during periods of lower market liquidity, which could result in less favorable execution prices. ●​ Regulatory Changes: It is possible that changes in applicable laws and regulations may affect Eko’s operations. Regulatory developments affecting investment advisers, digital platforms, artificial intelligence, cryptocurrency, data privacy, or financial technology may require Eko to modify its business practices, increase compliance costs, or limit the services Eko can offer. The SEC and other -20-

regulatory bodies continue to evaluate and propose new rules governing digital investment advisers and the use of technology in providing investment advice. The consequences of additional regulation on the liquidity of markets and the functioning of Eko’s advisory services (and, possibly, on Eko itself) cannot be predicted and may materially affect the investment advisory services offered by Eko. ●​ Taxes: You are responsible for all tax liabilities and tax-return filing obligations arising from the transactions in your Client account. We do not, and will not, offer tax advice to you and we strongly encourage you to seek the advice of a qualified tax professional. You should also understand that we are not responsible for attempting to obtain any tax credit or similar item or preparing and filing any legal document (including, but not limited to, proof of claim) on your behalf. The list of risk factors above are not a complete enumeration or explanation of the risks involved in accounts managed by Eko or the securities in those accounts. Performance-Based Compensation Eko does not receive any fees for advisory services provided to you that are based on a share of capital gains or capital appreciation of your investments. Voting of Client Securities Eko does not have, and will not accept, authority to vote on Client securities. Generally, Clients receive their proxies or other solicitations directly from their custodian broker dealer or a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other solicitations directly to the sender. Trade Execution and Custody Services Provided by the Custodian By entering into an Advisory Agreement with Eko, Clients authorize and direct Eko to place all trades in Client investment accounts through the Custodian/broker-dealer. As such, the Custodian will maintain all Client investment accounts and execute all securities transactions in Client investment accounts. The Custodian exercises no discretion in determining if and when trades are placed; it places trades only at the direction of Eko. Eko offers 24/5 trading, meaning trades may be executed 24 hours a day, five days a week, subject to market availability and Custodian capabilities. Eko’s compliance policies and procedures are designed to seek to obtain the best execution where possible in connection with Client trades, although there can be no assurance that it can be obtained. Clients should understand that the appointment of the Custodian as the sole broker for their investment accounts may result in disadvantages to the Client as a possible result of less favorable executions than may be available through the use of a different broker-dealer. Clients should understand that Eko’s advisory services are not a self-directed brokerage service. Unlike self-directed brokerage accounts, Clients do not enter individual buy and sell orders for specific securities to be executed at particular -21-

times. Rather, Eko places orders to buy and/or sell securities with the Custodian consistent with the discretionary authority (or non-discretionary authority, as applicable) granted to it by Clients in their Advisory Agreement, which includes, among other things (and dependent on the advisory account), the authority to select which securities to buy and sell and when to place orders for the execution of securities. In addition to the Advisory Agreement a Client enters into with Eko, Clients are also required to open a brokerage account with the Custodian. Clients will need to complete a brokerage account application and agree to the Custodian’s client agreement (which may include certain additional fees separate from any Management Fee charged by Eko) to maintain the assets and effect all transactions in your Eko investment account.

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Eko will manage and monitor Client accounts and performance in accordance with the Clients’ investment objectives, on an ongoing basis and rebalance the investment account as required by changes in market conditions and/or a Client’s financial circumstances. On a periodic basis (but no less frequently than annually), Eko will request that Clients update their investment profile.

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Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our personnel are required to follow a Code of Ethics (“Code”). The Code sets forth fiduciary standards that apply to all employees, incorporates our insider trading policy, and governs outside business activities and the giving and receipt of gifts and entertainment. In addition, the Code imposes restrictions on the personal trading activity of Eko personnel, as well as reporting requirements. These personal trading restrictions are intended to ensure that personnel do not misuse client information for their own benefit. Subject to satisfying the requirements imposed under the Code, Eko personnel are permitted to trade for their own accounts (whether at Eko or otherwise) in securities that are recommended to and/or purchased for Clients. In some circumstances, such as where an employee is permitted to invest in the same securities as clients, there is a possibility that employees may benefit from market activity within a Client investment account. Personal trading is monitored for adherence to the Code in order to help ensure personnel comply with its provisions and to help ensure that Eko reasonably prevents conflicts of interest between Eko and its Clients. All Eko personnel must act in accordance with the fiduciary standard applicable to SEC registered investment advisers under the Advisers Act. The Eko Code is available for review by Clients upon request, by contacting Eko at hello@eko.investments. Review of Accounts We provide all Clients with access to their investment account(s) via our Platform or for White-label Clients through the Financial Institution's website, where Clients can access their investment account documents, such as account statements, review performance of their investment account, and see the sustainability impact performance on their investment account. Clients may also receive periodic e-mail communications describing portfolio and sustainability impact performance, investment account information, and product features. Our software-based investment advisory service assumes that Client

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investment portfolios will not stay optimized over time and must be periodically rebalanced back to their original targets to maintain the intended risk level and asset allocations. We review each Client’s investment account when it is opened and, using software, continuously monitor and periodically rebalance each Client’s investment portfolio to seek to maintain a Client’s targeted risk tolerance and investment objective. We also conduct reviews when Clients make changes to their risk profiles. We may consider tax implications and the volatility associated with each of the chosen asset classes when deciding when and how to rebalance; however, no assurance can be made that Clients will not incur capital gains and in certain instances significant capital gains when Client investment portfolios are rebalanced periodically. We assume no responsibility to Clients for any tax consequences of any transaction, including any capital gains that may result from the rebalancing of Client investment accounts. On a periodic basis, we contact each Client to remind them to review and update the personal profile information they previously provided. We also request that Clients reconfirm the same information on an annual basis. These notifications and confirmations include a link to the Client’s current information and contact information for our support team. Client Referrals and Other Compensation Eko does not have any direct solicitation agreements or similar agreements with other parties. Eko expects from time to time to run promotional campaigns to attract Clients to open investment accounts on the Platform. These promotions may include additional investment account services or products offered on a limited basis to select Clients, more favorable fee arrangements, and/or reduced or waived fees for Clients. In the future, Eko may offer certain arrangements in which it pays bloggers and others who can post advertisements. As noted above, Eko licenses its Platform to Financial Institutions, who then have the ability to offer Eko’s investment advisory services directly to their customers through their existing digital platform. In certain circumstances, such Financial Institution may receive compensation from Eko with respect to Financial Institution customers that become White-label Clients of Eko, and as a result Eko may earn Management Fees from such White-label Clients. Any compensation paid by Eko to a Financial Institution is paid out of the Management Fee described above under Fees and Compensation (which, as noted there, is capped at 0.5% per year for the AUM-Based Fee and $3.00 per month for the Flat Fee) and does not result in any additional fee or charge to the Client. In addition, Eko may charge the Financial Institutions a fee for integrating the Eko Platform onto the Financial Institutions website or platform. Such arrangements between Eko and the Financial Institution may be considered solicitation or referrals, as a result of the Financial Institutions’ direct introduction of its customers to Eko. Investment Discretion Eko provides limited-discretionary and non-discretionary (without qualification) services to Clients. Eko obtains limited discretionary authority in connection with the allocation of

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Client funds with respect to Advisory Products, as well as the limited discretionary authority to rebalance a position of an Advisory Product, but only after the Client has made the decision to invest. Once an Advisory Product is selected, Eko is authorized to determine the appropriate amount of funds, based on the Client’s questionnaire, to be allocated to each of the Investments that make up the Advisory Product. Eko will also obtain limited authority to rebalance, buy, and sell Securities based on the Advisory Product a Client chooses to allocate funds towards. Eko may, depending on the assets in a Client’s account, obtain limited authority to sell (liquidate) certain holdings in a Client’s account in order to pay any fees referenced in Item 5. Please see Items 4 - Advisory Services, and Item 5 - Fees and Other Compensation, for more detail on Eko’s limited discretionary authority. This authorization will be granted by the Client through the execution of the Advisory Agreement, as well as through Alpaca’s Customer Agreement. Financial Information Not applicable.

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