Stephens: investment adviser

WMAS-2012 LLC, JCS-2012 LLC, and LWS-2012 LLC are each wholly owned by the Warren Miles Amerine Stephens 2012 Trust, the John Calhoun Stephens 2012 Trust, and the Laura Whitaker Stephens 2012 Trust, respectively. Miles Stephens serves as the trustee of the Warren Miles Amerine Stephens 2012 Trust and John Stephens serves as trustee of the John Calhoun Stephens 2012 Trust. Miles Stephens and John Stephens both serve as trustees of the Laura Whitaker Stephens 2012 Trust. B. The Types of Investment Advisory Services We Provide We provide investment advisory services to individuals, pension plans, foundations, corporations, other business entities and other types of clients. Our investment focus is on US equity securities, fixed income securities, mutual funds, exchange-traded securities, American depository receipts of foreign companies, options, commodities and other types of securities that may be purchased for client accounts depending on the investment objective of the client. Stephens also provides advice to certain clients regarding private equity investments, precious metals, other pooled investment vehicles and other investments. C. Advisory Services Stephens’s investment advisory services seek to tailor an investment program for the financial goals and objectives of a particular client. When we are engaged as an investment advisor, the client typically pursues one or more of our investment strategies. Clients may impose investment restrictions on their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. Except with respect to the payment of the fees or service charges or for correction of errors, Stephens is not authorized to withdraw or transfer any money, securities, or property out of a client’s account, without authorization from the client. Client acknowledges and understands that brokerage or securities transaction execution services provided by any person or entity other than Stephens or Pershing LLC (“Pershing”) are separate from and in addition to the wrap fee for the account. Additionally, regular service charges shall apply to client’s account for brokerage services other than securities execution services provided by Stephens. Stephens and its affiliates perform advisory and/or brokerage services including investment reporting for various clients, and Stephens gives advice or takes actions for other clients that differ from the advice given or the timing or the nature of any action taken for your account. In addition, Stephens may, but is not obligated to, purchase or sell or recommend for purchase or sale any security, which Stephens or any of its affiliates may purchase or sell for their own accounts or the account of any other client. Stephens and Pershing will not charge commissions on securities transactions that are executed through Stephens or Pershing for these advisory accounts. Pershing will add a markup or markdown to fixed income transactions. Your account is responsible for paying these markups and markdowns, which are not included as part of your wrap fee. The amount of the markup or markdown varies depending on the type of fixed income security and its maturity. Markups and markdowns can be up to the lesser of 0.065 percent or 0.065 basis points of the par value traded. The trade confirmation you receive will not break out or otherwise specify the amount of these markups or markdowns because

they are incorporated into the net price of the trade. The trade confirmation will identify that Pershing has traded in principal capacity and that it may have received remuneration for this service. Your account is also responsible for paying any commission charges imposed by any other brokerage firm on any securities transactions executed through any other brokerage firm, and such charges would be in addition to the wrap fee and any other applicable charges incurred by your account. By executing trades through Stephens with Pershing, your account might forego benefits, such as participation in block trades or negotiated transactions that might be available through other brokerage firms. On June 5, 2019, the SEC issued its interpretation of the Standard of Conduct for Investment Advisers and rescinded certain previously issued no action letters. As a result of these changes, Stephens will not seek to enforce any provision of an investment advisory agreement with a retail investor which discharges Stephens or its agents from liability to the retail investor client. For Employee Retirement Income Security Act (“ERISA”) and Individual Retirement Account (“IRA”) accounts, when Stephens provides non-discretionary investment advice to the client regarding such an account, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated can create conflicts of interest, so we have established procedures which require us to act in the client’s best interest and not put our interest ahead of the client’s. This is discussed further in Item 5.C. Stephens Insured Bank Sweep Program Stephens makes available to clients whose accounts are custodied at Pershing the opportunity to participate in the Stephens Insured Bank Sweep Program (“Bank Sweep Program”). In this program all of the uninvested cash in a client’s account is automatically deposited, or “swept” into FDIC insured, interest-bearing deposit accounts at one or more banks, which participate in the Bank Sweep Program. None of the banks participating in the Bank Sweep Program are owned by or affiliated with Stephens. For more information about the Bank Sweep Program please review these important disclosures at www.stephens.com/investment-disclosures/ which are incorporated by reference into this Form ADV Part 2A. Stephens offers the Bank Sweep Program as a service and is not obligated to offer this or any sweep product or to make available to you a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. The interest rates paid on Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in other cash equivalent investments through Stephens. The Bank Sweep Program is not available to ERISA plans with accounts at Stephens such as employee benefit plans, retirement plans, defined contribution plans, defined benefit plans, (collectively, “ERISA accounts”) or to traditional and rollover IRA accounts, Roth, SEP, SIMPLE, and inherited IRAs; Keogh plans; and Coverdell education savings accounts. The Bank Sweep Program for your account should not be viewed as a long-term investment option. If you desire, as part of an investment strategy or otherwise, to maintain a cash position in your account for other than a short period of time and/or are seeking the highest yields currently available in the market for your cash balances, please contact your Financial Consultant to discuss investment options that are available outside of the Bank Sweep Program to help maximize your return potential consistent with your investment objectives, liquidity needs and risk tolerance. Please note, however, that available cash accumulating in your account will not be automatically swept into any investment you purchase outside of the Bank Sweep Program. Nothing obligates you to participate in the Sweep Program. You may receive a higher rate of return through products offered outside the Sweep Program, including Money Market Funds offered through your account with Stephens and Pershing. Each Deposit Account constitutes a direct obligation of the Bank and is not directly or indirectly an obligation of Stephens or Pershing. Stephens and Pershing do not guarantee in any way the financial condition of the Banks or the

accuracy of any publicly available financial information concerning such Banks. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order for you to determine the amount of deposit insurance coverage available to you on your deposits. Stephens and Pershing are not responsible for any insured or uninsured portion of a Deposit Account. D .Wrap Fee Programs Our Separately Managed Account Advisory Programs We offer investment management strategies through our programs sponsored by Stephens Capital Management (“SCM”), Stephens Fixed Income Management (“SFIM”) and Private Client Group (“PCG”). Some programs are offered on a discretionary basis while others are offered on a non-discretionary basis. In addition to other indications of individual ownership, including the right to withdraw, hypothecate, vote, or pledge securities held in the wrap fee client’s account, a wrap fee advisory client has the ability to place limitations and/or restrictions on the investments in their portfolio. Where restrictions are imposed, Stephens will not knowingly make any discretionary investments of the client’s portfolio assets in violation of these restrictions, but the investment performance of the client’s account will likely differ (positively or negatively) from other clients following a similar investment strategy, that is not subject to the same restrictions. The minimum account size for wrap fee programs varies from program to program, and a person considering a wrap fee program should review the disclosure document provided by Stephens of the applicable program for details regarding the operation of the program, its risks, fees, and other charges. See Item 5 for further discussions on fees. In determining the suitability of an investment strategy for a particular wrap fee program client, we rely on the information provided by the client regarding the financial objectives of the client for each account. This information comes from, among other sources, personal interviews with the client and written questionnaires completed by the client and other communications with the client or its representative regarding the client’s situation, investment objectives, risk tolerances and investment restrictions, if any. Our strategies are not appropriate for all investors, and investors should only invest a portion of their portfolio in these programs.

Discretionary Wrap Programs In the following types of separately managed accounts, we have the discretionary authority to determine the securities, and the amount of securities, to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain restrictions and limitations placed by the client on transactions in certain types of securities or industries or to restrictions or limitations imposed by applicable regulations. Stephens seeks to fully invest cash balances at all times, investing assets otherwise un-invested in the Bank Sweep Program, or for ERISA and IRA accounts in money market mutual funds. Professional Wealth Management Professional Wealth Management (“PWM”) program is an investment advisory program offered by Stephens. Clients receive advice from seasoned professional managers, with individual attention to the client’s investment needs and objectives. Stephens or the Professional Wealth Management Financial Consultant (“PWM FC”) also provides brokerage and other services to certain clients or engages in other functions and duties associated with the Stephens’ business as advisor or as broker-dealer, to which they may devote as much time as necessary. In the PWM program, Stephens provides investment management services for client assets on a discretionary basis, utilizing strategies that include equity, fixed income, other investments, or a combination, in some cases, that include alternative investments. The goal of the PWM program is to pursue an investment program to address the client’s investment objectives subject to market conditions. In balancing the potential return for a client’s portfolio against the risk exposure in the portfolio, the PWM FCs consider the risk tolerances of the client, and discuss with the client their investment objectives. The client’s stated investment objectives and other information provided by the client, leads to an asset allocation strategy designed to seek to achieve returns based on and commensurate with the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks.

****************************************** Stephens Allocation Strategies The Stephens Allocation Strategies (“SAS”) program is an asset allocation program sponsored and administered through Stephens whereby the client is offered a strategy of purchasing a portfolio of “no load” or “load waived” mutual funds and Exchange Traded Funds (“ETFs”) representing a broad spectrum of equities, fixed income, and alternative investment markets through Stephens. Mutual funds and ETFs are collectively referred to as “Funds” in this document. Funds’ Strategies Stephens, acting as the registered investment advisor manages the selection of Funds representing each asset class included in the SAS asset allocation models in the program and establishes standard SAS model asset allocation portfolios for differing risk and time horizon parameters. Ongoing investment monitoring, fund replacement, periodic rebalancing and investment performance measurement are provided by Stephens. Based on individual consultations with the client and their investment objectives, a SAS asset allocation model recommendation is selected by the FC for the client’s account, intended to reflect the investment objectives, risk tolerance and investment time horizon communicated to the FC by the client. Following the client’s approval of the recommended asset allocation, Stephens will initiate and Pershing will execute all transactions that are required to manage the client’s account in accordance with such asset allocation. Best execution is sought for all transactions. Stephens has investment discretion to change the Funds representing any asset class, to add or eliminate asset classes from the asset allocation model and to adjust the standard SAS asset allocation models, all consistent with the client’s investment objectives and other information as communicated to Stephens. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client holdings, these will be rebated to the advisory client. Stephens Allocation Strategies In the SAS advisory program, we offer a range of models provided by Stephens with a range of mutual funds and ETFs that Stephens has selected and approved. Our SAS Investment Committee evaluates the Funds. Our SAS Investment Committee has developed a disciplined process for evaluating the Funds. Our research is focused on a review of both qualitative and quantitative factors, factors that are designed to deliver a wealth of detailed information about the Funds available through this advisory program. The replacement of Funds in a client portfolio may happen under the following circumstances: • Fund’s philosophy changes; • Fund exposes client’s account to investment style change; • Fund and/or firm undergoes ownership change or major personnel change; • Fund performance lags peer group benchmarks; • Fund holds an unnecessarily large cash position. ***************************************** Stephens Capital Management (“SCM”) Discretionary Program In the Stephens Capital Management Discretionary Program (“SCMD”), seasoned Investment Advisor Representatives (“IARs”) manage client assets on a discretionary basis, utilizing both equity and fixed income strategies and, in some

cases, alternative investment classes. The goal of SCMD is to seek to earn a high total return on investments for the client consistent with the client’s investment objectives and investment strategies, subject to market conditions. From time to time investments include mutual funds or other pooled investment products. IARs are responsible for making day-to-day discretionary investment decisions subject to oversight and review by the SCM Supervisory Principals. **************************************** Stephens Capital Management Fixed Income Strategy In the Stephens Capital Management Fixed Income Strategy (“SCM-FIS”), Stephens Capital Management (“SCM”) manages client assets on a discretionary basis using a fixed income strategy. The SCM-FIS is overseen by the Fixed Income Strategy Investment Committee (“Investment Committee”), which has overall responsibility for investment policy, strategy and advises on security selection parameters. SCM IARs make day-to-day investment decisions for accounts advised in the SCM-FIS program within the parameters set forth by the Investment Committee. The Investment Committee is composed of Larry Bowden, Troy Clark, David Moix, Brian Baumeister, Larry Middleton, and Bo Brister and seeks to provide consistent performance by actively managing portfolios based on a top down macro investment strategy that adjusts duration and sector allocations on the investment committee’s market views in accordance with evolving economic data, developments and themes. The Investment Committee employs a strategy of disciplined management of portfolios constructed primarily of investment grade U.S. government, U.S. government agency and corporate bonds with the objective of maximizing risk-controlled returns over full market cycles. The goal of SCM-FIS is to seek to earn a high total return on income securities for the client consistent with the client’s investment objectives subject to market conditions. SCM-FIS seeks to fully invest cash balances into investment grade debt instruments. Clients choosing the SCM-FIS program will own a portfolio comprised of U.S. Treasury securities, government agency securities, mortgage-backed securities, structured products, municipal bonds and investment grade corporate bonds. Clients may elect to direct deviations from the parameters set forth herein in the management of their particular accounts in appropriate cases. The average maturity of the portfolios will be managed to take advantage of the Investment Committee’s outlook for interest rates. The style of management of the fixed income portfolios managed in SCM-FIS is duration management. ***************************************** Stephens Spectrum Program In the Stephens Spectrum Program (“SSP”), SCM manages client assets on a discretionary basis, utilizing primarily mutual funds and exchange traded funds representing a broad spectrum of equity and fixed income markets. In addition, SCM may invest in mutual funds that seek capital appreciation primarily through short positions in domestically traded equity securities and indices, mutual funds that invest in commodities, mutual funds that employ a merger arbitrage strategy, and interval funds. All accounts are advised and managed by the Spectrum Investment Committee, which has overall responsibility for investment policy, strategy and security selection. The Spectrum Investment Committee is responsible for making dayto-day investment decisions. The goal of SSP is to seek to earn a total return on investments that is consistent with the client’s risk tolerance and time horizon. Prior to January 1, 2022, this program was known as the Asset Allocation and Advisory Services Program (AAA).

***************************************** Stephens Fixed Income Management Stephens Fixed Income Management (“SFIM”) is a division of Stephens. SFIM manages client assets on a discretionary basis, under the Stephens Fixed Income Management program. All accounts are advised and managed by the Fixed Income Management Committee. The goal of SFIM is to seek to earn a high return on income investments for the client consistent with the client’s investment objectives subject to market conditions. SFIM seeks to fully invest balances at all times. The portfolio objective will be to invest in fixed income securities and money market funds, which invest in fixed income securities. *****************************************

Limited-Discretionary Wrap Programs Stephens provides wrap fee programs in which client assets are managed by Stephens or designated third party investment managers (“Sub-Advisors”). Under these programs, the Sub-Advisor provides discretionary investment management services for the management of client assets. Each client enters into an investment Advisory Contract with Stephens. The Sub-Advisor in turn has a separate Sub-Advisory agreement with Pershing. The client pays an agreed fee monthly in advance to Stephens, based on the value of the assets under management that covers the advisory fees of both Stephens and the Sub-Advisor. Stephens seeks to fully invest cash balances at all times, investing assets otherwise un-invested in the Bank Sweep Program, or for ERISA or IRA accounts in money market mutual funds. Stephens Managed Assets Program The Stephens Managed Assets Program (“MAP”) is an asset allocation program sponsored by Stephens wherein Stephens manages the account or the client selects one or more Sub-Advisors to direct the investment of the client’s assets. In this program, Stephens acts as the registered investment advisor establishing a separate account for the client. A separate account is a portfolio of individual securities managed for the client utilizing strategies that include equity, fixed income, other investments or a combination. Where the client chooses to engage one or more Sub-Advisors, the FC will assist in selecting the particular Sub-Advisors to manage or assist Stephens in managing the client’s assets based upon the client’s investment objective as described below. The Strategy A strategy is customized for the client by using sub-accounts (“Sub-Accounts”) which follow a strategy of Stephens or various Sub-Advisors selected by the client. Stephens will recommend Sub-Advisors to the client from the list of SubAdvisors, which are included in Stephens’ list of available Sub-Advisors for the MAP program. The client’s stated investment objectives and other information provided by the client leads in most situations to an asset allocation strategy designed to seek to achieve returns based on and commensurate with the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks. Sub-Advisors not currently available through Stephens may be added, at Stephens’ sole discretion. In the MAP, certain Sub-Advisors provide Stephens with their recommended Model Portfolios, and Stephens can deviate from the recommended Models if it deems appropriate. In these instances, Stephens has discretion over the client’s assets in the Sub-Account rather than the Sub-Advisor (“Model Sub-Advisor”). Where the Sub-Advisors selected by the client manage client’s assets directly rather than through a Model, the Sub-Advisor (“Non-Model SubAdvisor”) has discretion over the client’s account. (Note: the term “Sub-Advisor” without further qualification or description includes both Model and Non-Model Sub-Advisors.) Each Sub-Advisor will be responsible for complying with all legal and regulatory requirements applicable to its activities as the manager of funds in Sub-Accounts they manage.

If Stephens or Pershing removes a Sub-Advisor from the list of Sub-Advisors available through Pershing, Stephens will notify the FC of the change and provide no less than 30 days’ notice to recommend that the client transfer management of any assets previously managed by the removed manager to a new Sub-Advisor or Sub-Advisors, selected by the client and included on the list of Sub-Advisors available through Stephens. Stephens will review the investment activities of the Sub-Advisors in management of assets and provide regular reports on the status and performance of the Sub-Advisors. Pershing will execute all transactions on Stephens’ behalf in the client’s account following the instructions of the client and/or the designated Sub-Advisor(s), unless the investment is below the minimum amount of shares allowed to trade. Information about the client is communicated to Stephens and to the Non-Model Sub-Advisers on the initial opening of the advisory account and from time to time, thereafter. A Stephens New Account Agreement (“Agreement”) and Advisory Contract must be completed by each client and maintained by Stephens. The Agreement contains account name and address, investment objective and specific financial information. Client information may be updated from time to time upon notification from the client of any material changes and noted within the client file. Stephens Managed Assets Program In the MAP advisory program, we offer a wide range of investment strategies provided by Stephens and Sub-Advisors that we have selected and approved. If Sub-Advisors have more than one strategy, we may include only some of those strategies in the program and may assign different statuses to different strategies. Our MAP Investment Committee evaluates Sub-Advisors and strategies. Sub-Advisors and strategies may only participate in MAP if they are on the Stephens approved list. Our MAP Investment Committee has developed a disciplined process for evaluating investment managers. Our research is focused on a review of both qualitative and quantitative factors; factors that are designed to deliver a wealth of detailed information about the investment products available through this advisory program. The client will select investments or an investment strategy or strategies following discussion with their FC about their investment objectives, the recommended allocation and potential Sub-Advisors with which to implement proposed strategies. When the client approves a proposed strategy, the client’s account may be established and assets placed with the agreed Sub-Advisor(s) to operate the plan. The replacement of Sub-Advisors in a client portfolio may be recommended under the following circumstances: • Change of client’s investment situation or goals; • Sub-Advisor philosophy changes; • Sub-Advisor exposes client’s account to investment style change; • Sub-Advisor firm undergoes ownership change or major personnel change; • Sub-Advisor performance lags peer group benchmarks; • Stephens, in consultation with client, determines to effect a change; or • Sub-Advisor holds an unnecessarily large cash position. Sub-Advisor Fees In most cases, when Stephens selects Sub-Advisors, we, on your behalf, pay a part of the fee we receive from you to the Sub-Advisor for services provided to you. The portion of the asset-based fee paid by Stephens depends upon the asset class and the investment style. Stephens generally pays the Sub-Advisors between .25% and .55%. For a limited number of Sub-Advisors available in MAP, you will be billed separately for Stephens’ advisory services and the Sub-Advisor’s services. In these cases, the total combined fee you pay to Stephens and the Sub-Advisor is comparable to the fee you would pay for other Sub-Advisors who do not bill their fees separately. Sub-Advisors who bill for their services separately may do so quarterly rather than monthly. *****************************************

Stephens Unified Managed Account The Stephens Unified Managed Account (“UMA”) program is a wrap fee program sponsored by Stephens that offers clients the ability to integrate investment products into a single advisory account. The program allows clients to construct a portfolio with allocations to various strategies (“Sleeves”) which consist of any of the following investment products (“Products”): (i) mutual funds; (ii) ETFs; and (iii) securities selected in model portfolios by one or more SubAdvisors. Where the client chooses to engage one or more Sub-Advisors, the FC will assist in selecting the particular Sub-Advisors to manage or assist Stephens in managing the client’s assets based upon the client’s investment objective as described below. The Strategy The UMA program is based on asset allocation among various strategy Sleeves. Based upon the client’s stated investment objectives and other information provided by client, an asset allocation strategy is developed to seek to achieve returns based on and commensurate with the client’s risk tolerance and time horizon, without exposing the client’s portfolio to excessive risks. The FC, with approval from the client, can select any asset allocation as long as at least two strategy Sleeves are chosen. Stephens selects the Products that are available in the UMA program and determines which Sleeve will contain each product based upon its respective investment strategy. Products offered in the UMA program do not represent the full spectrum of products available through other programs offered by Stephens. Products available in the UMA program may be subject to certain investment minimums, as may be determined by Stephens and/or the relevant Sub-Advisor or Fund. Products not currently available in the UMA program may be added at Stephens’ sole discretion. In the UMA program, Stephens has investment discretion to change the Product selections within each asset allocation Sleeve. With the client’s written consent, Stephens will add or remove asset classes or otherwise adjust the asset allocation that was approved by the client as long as the assets remain in the UMA program. If Stephens removes a Product from the list of products available in the UMA program, Stephens will notify the FC of the change and provide no less than 30 days’ notice to implement a change to another Product within that Sleeve or contact the client and discuss changes to the overall asset allocation. After the 30-day period, Stephens will select the replacement Product. Stephens will review the performance of the Products, and the FC can provide regular reports on the status and performance of the Products to the client. Pershing will execute all transactions on Stephens’ behalf in client’s account following the instructions from the FC, the client or the designated Sub-Advisor(s), unless the investment is below the minimum amount of shares allowed to trade. Information about the client is communicated to Stephens and to a Non-Model fixed income Sub-Advisor on the initial opening of the advisory account and from time to time, thereafter. An Agreement and Advisory Contract must be completed by each client and maintained by Stephens. The Agreement contains account name and address, investment objective and specific financial information. Client information may be updated from time to time upon notification from the client of any material changes and noted within the client file. Generally, Sub-Advisors in the UMA program either provide Pershing with their model portfolio or direct their trading to Pershing for execution. In both of these situations, Pershing executes these trades at no additional charge to the clients because execution charges are included in the wrap fee the client pays Stephens. However, to achieve best execution and for other reasons, Non-Model Sub-Advisors have the ability to trade away from Pershing. When NonModel Sub-Advisors trade away from Pershing, clients will incur additional costs for fixed income securities. The additional fees are per bond or on a per transaction basis which are embedded in the net price you receive. The number of Non-Model Sub-Advisors in the UMA program that direct trades to other broker-dealers can change as Non-Model Sub-Advisors are added or removed from the program. Account Rebalancing Stephens will review UMA program accounts annually for drift based on their initial allocations to the various strategy Sleeves. Accounts with relative drift of 10% for asset classes or 2% absolute drift on cash will be reviewed for rebalancing. In taxable accounts, rebalancing may cause a taxable event, and you should consult your tax advisor.

Stephens Unified Managed Account Program In the UMA program, we offer a wide range of investment strategies provided by Stephens, Sub-Advisors, and Funds that we have selected and approved. If Sub-Advisors or Funds have more than one strategy, we may include only some of those strategies in the program and may assign different statuses to different strategies. Our UMA Investment Committee evaluates Sub-Advisors and their strategies and Funds. Sub-Advisors and strategies and Funds may only participate in UMA if they are on the Stephens approved list. Our UMA Investment Committee has developed a disciplined process for evaluating investment managers. Our research is focused on a review of both qualitative and quantitative factors; factors that are designed to deliver a wealth of detailed information about the investment products available through this advisory program. The client will select investments or an investment strategy or strategies following discussion with their FC about their investment objectives, the recommended allocation and potential Sub-Advisors and/or Funds with which to implement proposed strategies. When the client approves a proposed strategy, the client’s account may be established and assets placed with the agreed Sub-Advisor(s) and Funds. Sub-Advisors and Funds in a client portfolio are considered for replacement under some of the following circumstances: • Change of client’s investment situation or goals; • Sub-Advisor or Fund philosophy changes; • Sub-Advisor or Fund exposes client’s account to investment style change; • Sub-Advisor firm or Fund undergoes ownership change or major personnel change; • Sub-Advisor or Fund performance lags peer group benchmarks; • The FC or client determines to effect a change; or • Sub-Advisor or Fund holds an unnecessarily large cash position. Sub-Advisor Fees Where Sub-Advisors are selected, Stephens, on your behalf, pays a part of the fee received from you to the Sub-Advisor for services provided to you. The portion of the asset-based fee paid by Stephens depends upon the asset class and the investment style. Stephens generally pays the Sub-Advisors between .25% and .55%. ***************************************** Stephens Small-Mid Cap Core Growth Program Stephens Small-Mid Cap Core Growth (SMID) program is an investment advisory wrap program of Stephens. The investment portfolio of SMID accounts is managed by Stephens Investment Management Group, LLC (SIMG), an affiliate of Stephens. SIMG was organized in July 2005 and is registered with the SEC as an investment advisor. SIMG manages and directs the investment of the assets in each SMID client’s account on a discretionary basis in accordance with its small and mid-cap equity investment style and on the basis of the individual objectives and needs of the client within the criteria established by the SMID. SIMG personnel also provide services to other clients and to other products or programs. In the SMID program, SIMG establishes the investment policy and strategy for the portfolio, selects the securities to be included in the portfolio and makes the day-to-day investment decisions. The goal of SIMG is to seek growth of the equity value of a portfolio of small and mid-cap equity investments for clients, consistent with clients’ investment objectives. SIMG attempts to identify core growth stocks among stocks of companies that have a market capitalization at the time of purchase no larger than the market capitalization of the largest company then included in the Russell 2500TM Growth Index, using a disciplined bottom-up approach, employing financial screening techniques, fundamental research and the portfolio managers’ judgment, with a focus on identifying small-cap companies and mid-cap companies believed to have above-average potential for equity growth. The Russell 2500TM Index is a trademark/service mark of the Frank Russell Company. Russell® is a trademark of the Frank Russell Company. The portfolio benchmark is the Russell

2500TM Growth Index. The Russell 2500™ Growth Index measures the performance of those Russell 2500™ companies with higher price-to-book ratios and higher forecasted growth values. SIMG seeks, as a rule, to fully invest cash balances. SIMG invests SMID assets primarily in long positions in equity securities. However, from time to time SIMG invests SMID assets in other types of securities, including without limitation, short term fixed income securities, exchangetraded funds and other investment company securities, and stock index futures. SIMG generally seeks to fully invest cash balances. Investments made through the SMID program are concentrated in investments in equities of small- and mid-cap growth companies and are not diversified across other asset classes. Small and mid-cap growth strategies may be more volatile and less liquid than other investment strategies. Investing in small-cap and mid-cap issuers involves greater risk than investing in more established companies and investors should only invest a portion of their total portfolio in these securities. Typically, individual investors are advised not to allocate more than ten to fifteen percent of their overall investment portfolio to a small and mid-cap growth strategy. The SMID portfolio is not managed for tax efficiency. The investment strategy used by SIMG in the SMID program is also available to appropriate Stephens clients in the Stephens MAP. *****************************************

Non-Discretionary Wrap Programs Stephens Advisor In the Stephens Advisor (“SA”) program, clients receive advice from the FC with individual attention to the client’s investment needs and objectives. FCs provide advice to clients utilizing strategies that include equity, fixed income, balanced, other investments, or a combination, in some cases that include alternative investments. FCs provide advice and make recommendations to clients at client’s request or as the FC deems appropriate. FCs in the SA program do not have discretionary authority over client assets, and all transactions in client assets are directed by the client or the client’s designee. Investment Services Stephens shall periodically provide clients with investment advice, which can include recommendations regarding investing in available assets in a manner consistent with the client’s investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the SA account. Stephens will not provide advice with respect to positions classified as unsupervised assets in the account. As part of the range of services available to clients in the SA program, advisory variable and fixed annuity contracts may be offered to appropriate retirement investors who are seeking certain income and death benefit solutions afforded by these products. ***************************************** Stephens Capital Management Non-Discretionary Program In the Stephens Capital Management Non-Discretionary Program (“SND”), IARs advise clients regarding their management of client assets on a non-discretionary basis, utilizing both equity and fixed income strategies and, in some cases, alternative investment classes. The goal of SND is to assist clients with the management of their investment assets consistent with the client’s investment objectives and investment strategies, subject to market conditions. From time to time investments include mutual funds.

IARs are responsible for providing non-discretionary investment advice, subject to oversight and review by the SCM Supervisory Principals. The client may pursue its own investment objectives. ***************************************** StephensChoice Program The StephensChoice Program (“SC”) is a platform designed by Stephens to assist qualified retirement plans or other deferred compensation programs (“Plan”) with establishing an appropriate asset allocation for the investment of plan assets through investment in a portfolio of “no load” or “load waived” mutual funds through Stephens based upon a lineup of mutual funds representing a range of designated asset classes. Mutual Fund Strategy The SC standard line-up is comprised of one or more actively managed mutual funds representing each asset class included in the SC program. Stephens establishes and communicates to the Plan Sponsor and/or Trustee such investment line-up and, if chosen by the Plan Sponsor and/or Trustee, a choice of five model asset allocation portfolios (each, an “SC Model”) for differing risk profiles. In some cases, participants may be able to select a custom glide path product that automatically adjusts the mix of funds to become less risky over time based on the participant’s time horizon parameters. Stephens provides ongoing investment selection, monitoring, fund replacement, investment performance measurement and quarterly reporting throughout the life of the account. In addition, periodic rebalancing is provided in certain accounts which are introduced to our clearing broker-dealer Pershing and custodied at Pershing. Stephens provides the services described above to clients under a Plan Services Agreement. For Plan Sponsor/Trustee Directed Accounts Based on individual consultations with the Plan Sponsor and/or Trustee and the risk tolerance questionnaire, one of five SC Models will be chosen from the SC funds line-up for each trustee directed account or for segregated participant accounts. The selected SC Model is intended to reflect the investment objectives, risk tolerance and investment time horizon communicated to Stephens by the Plan Sponsor and/or Trustee. Following the selection of SC Model, Stephens will initiate and execute the transactions that are required to invest the account in accordance with such SC Model’s asset allocation. Best execution is sought for all transactions. Participant Directed Accounts For Plans with participant directed accounts, the Plan Sponsor and/or Trustee makes the determination to use the SC line-up of funds, which Plan participants may elect to use in their individual accounts. If requested, Stephens will conduct group education and enrollment meetings to educate participants on the investment options in the Plan. Following initial enrollment, Stephens is available to communicate with individual Plan participants on an as needed basis, for educational purposes about their Plan account. SC Strategy Changes Stephens may periodically change the mutual funds representing any asset class in the standard SC line-up of funds, or add or eliminate asset classes from the standard SC platform line-up. Stephens communicates such changes in the standard line-up to Plan Sponsor and/or Trustee. The Plan Sponsor and/or Trustee has discretion to adopt or decline such changes, unless they have chosen to be a 3(38) fiduciary. Stephens with the Plan Sponsor and/or Trustee’s consent may realign the standard SC asset allocation models and/or change the mutual fund selections. Fees Fees for the SC program will be billed to the Plan Sponsor and/or Trustee or deducted from client’s Plan Participant’s account assets. Stephens collects fees from the client’s account(s) quarterly in arrears. In accounts for which Pershing acts as custodian, rates are set forth in the Plan Service Agreement, based on the daily average asset value of the assets in the account(s) for that calendar quarter. If the client uses a custodian other than Pershing, Stephens’ fee will be collected by the outside custodian and may be based on a different quarterly accounting method.

SC is a wrap fee program in which the client pays a single fee for investment advisory services and related services, which unless otherwise provided will include executions, custody and clearing charges. Fees for other services, such as administrative or transfer fees, will be charged at Stephens’ standard rates in addition to the wrap fee. Additionally, fees charged by the mutual funds included in each client’s portfolio will be borne by the Plan or Plan participant. Mutual funds typically charge an expense ratio to pay for portfolio management, administration, marketing, distribution, and other expenses. Additionally, many mutual fund companies impose (among other fees) short-term trading fees with respect to any purchase and redemptions of fund shares effected within a time frame designated by the mutual fund company (such as but not limited to sixty (60) or ninety (90) days). Mutual fund companies may also impose other fees from time to time. Any fees imposed by any mutual fund company with respect to SC account assets will be charged to the account, whether resulting from fund transfers, withdrawals, rebalancing transactions, or other transactions in the account. Accounts that elect to use third-party custodians or third-party brokerage services will bear the costs of such third-party services in addition to the fees payable to Stephens. ***************************************** Stephens Spectrum 401(k) The Stephens Spectrum 401(k) (“SSK”) is a platform designed by Stephens to assist clients’ qualified retirement plans or other deferred compensation programs (“Plan”) to establish an appropriate list of investment options for asset allocation of the investment of plan assets. SSK offers clients the opportunity to invest in a line-up of index funds, (either ETFs and/or index mutual funds) (collectively, “Funds”) and/or Stephens designed asset allocation portfolios, that primarily utilize Funds. Stephens selects a line-up of Funds representing each asset class included in SSK and establishes and communicates to clients the lineup of Funds and standard SSK asset allocation portfolios for differing risk and time horizon parameters. Ongoing investment selection, monitoring, fund replacement, periodic reallocation, investment performance measurement and quarterly reporting are provided by Stephens, throughout the life of the account. SSK seeks to fully invest cash balances at all times, in the Stephens designed asset allocation portfolios. Stephens provides investment oversite as a non-discretionary fiduciary to the plan as defined by Section 3(21)(a)(ii) of ERISA. Alternatively, upon the mutual agreement of Stephens and the client, Stephens is able to provide investment oversite as the discretionary fiduciary as defined by Section 3(38) of ERISA. Stephens provides the services described above to clients under a Plan Services Agreement, and Stephens through Pershing also provides, if requested by the Trustee of the Plan, brokerage and/or custodial services needed to effect transactions for SSK accounts and certain compliance functions relating to the services provided by Stephens. If requested by the Trustee, Stephens will conduct group enrollment meetings on dates agreed to by the Trustee and Stephens. Stephens will be available to meet with Plan participants in connection with initial enrollment to assist participants in identifying the participant’s investment objectives, risk tolerance, and time horizon. Following initial enrollment, Stephens will be available to meet with individual participants on an as needed basis for advice and/or education. ***************************************** Pension Management Trust Program The Pension Management Trust Program (“PMT”) is an asset allocation program, made available to Arkansas Local Pension and Relief Plans (“the Plan(s)”) that were formerly participants in the Arkansas Local Government Pension Management Trust, pursuant to a trust agreement. Under the advice of SCM, as investment advisor, the local board selects certain participating investment management companies (the “Active or Passive Managers”) to direct their investments of funds. Assets include, but are not limited to, securities, mutual funds, money market funds, collective funds, exchange-traded funds, select individual fixed income securities and other investments. SCM provides advisory services to the Plans, by establishing asset performance comparisons, risk profiles, assisting participants in developing

and writing investment policies, preparing asset allocation modeling, and ongoing monitoring of plan portfolios. The selected Active or Passive Managers manage their respective portions of the plan’s assets on a discretionary basis, utilizing Index/Active portfolio management. All accounts are advised and monitored by an IAR of SCM. The participating Active or Passive Managers, which are selected by the pension plans, make the day-to-day investment decisions and security selections in the program. From time to time investments in any of the strategies include mutual funds or separate accounts money management. ***************************************** Health Management Trust Program The Health Management Trust Program (“HMT”) is an asset allocation program, made available to Arkansas municipalities that become participants in the Arkansas Local Government Health Management Trust (“Participant(s)”), pursuant to a trust agreement. Under the advice of SCM, as investment advisor, the local board selects certain participating investment management companies (the “Active and/or Passive Managers”) to direct their investments of funds. Assets include, but are not limited to, securities, mutual funds, money market funds, collective funds, exchangetraded funds, select individual fixed income securities and other investments. SCM provides advisory services to HMT and to participating accounts, by establishing asset performance comparisons, risk profiles, assisting participants in developing and writing investment policies, preparing asset allocation modeling, and ongoing monitoring of Participant portfolios. The selected Active or Passive Managers manage their respective portions of the Participant’s Plan assets on a discretionary basis. All accounts are advised and monitored by an IAR of SCM. The managers of the funds or other investment portfolios in which the Participant’s Plan assets are invested make the day-to-day investment decisions and security selections in their respective funds or portfolios. The goal of HMT is to bring together investment managers creating a customized investment strategy subject to market conditions consistent with each Participant’s Plan’s risk profile and investment objectives, as approved by the Participant. From time to time investments in any of the strategies include mutual funds or separate accounts money management. ***************************************** Stephens Capital Management Advisory Services for Employee Benefit Plans The SCM division of Stephens also provides advisory services to employee benefit plan fiduciaries whereby, pursuant to an agreement with plan fiduciaries, SCM assists fiduciaries in choosing primary fund advisers or managers to invest plan funds and in certain cases advises the fiduciaries with respect to allocation of plan assets among funds managed by others. After the initial selection process of the primary adviser, SCM may provide the client with reports analyzing the primary adviser’s performance and comparing such performance with that of other indices with similar investment objectives. In certain cases, the plan compensates SCM for this service based upon a negotiated fee calculated as a percentage of assets under management or a set fee negotiated by the client. In other cases, the primary adviser compensates SCM on a percentage basis. Written agreements between SCM and plan fiduciaries are typically for oneyear terms, subject to renewal. ***************************************** Stephens IA Consultations From time to time Stephens is asked to furnish clients with investment advice through arrangements which involve consultations and recommendations but do not involve trading of securities. In these consulting arrangements a separate investment advisory agreement is entered into specifying the scope of the services which will be provided and the fee to be charged. Consulting services may be provided with a fixed fee, an annual fixed fee paid quarterly, or an annual fee paid quarterly based on a percentage of the assets subject to the consulting agreement. Fees are negotiated in advance and are payable as negotiated and agreed to by the client and Stephens.

Either party may terminate consulting contracts upon written notice. In the course of providing these services, Stephens may develop and present periodic reports regarding the client’s investments. The client and Stephens jointly review many of the client’s applicable financial considerations including, but not limited to time horizon, liquidity needs, risk tolerance, net worth, cash flows, education goals, retirement goals, wealth transfer goals and life and long-term care insurance needs. Stephens provides the client with personalized financial planning and investment recommendations based upon the information provided by the client and the results of the financial plan. The client is under no obligation to act upon the recommendations of Stephens. If the client does elect to act on any of the recommendations, the client is under no obligation to effect the transactions through Stephens. ***************************************** Financial Planning Services Stephens offers comprehensive financial planning services to its clients in order to assist clients in identifying and striving to achieve long-term financial goals for themselves and their families. These services can include personalized financial planning and investment recommendations, and assistance with other financial matters, including trusts and estates and taxation issues. Stephens provides the client with these services based upon the information provided by the client and the results of the financial plan. The client is under no obligation to act upon the recommendations of Stephens. If the client does elect to act on any of the recommendations, the client is under no obligation to effect the transactions through Stephens. *****************************************

Retirement Advisory Platforms – Non Discretionary Stephens Retirement Solutions In the Stephens Retirement Solutions (“RSP”) program, clients receive advice from their FC with individual attention to the client’s retirement investment needs and objectives. FCs provide advice to clients utilizing equity, fixed income, balanced, other investments, or a combination. This program is designed for clients with limited trading requirements. FCs in the RSP program do not have discretionary authority over client retirement assets, and all transactions in client assets are directed by the client or by the client’s designee. Investment Services Stephens shall periodically provide you with investment advice which can include recommendations regarding investing in available assets in a manner consistent with your investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the RSP account. Stephens will not provide you with advice with respect to positions classified as unsupervised assets in the account. **************************************** Stephens Retirement Access The Stephens Retirement Access (“SRA”) program is now closed to new investors. In the Stephens Retirement Access (“SRA”) program, clients receive advice from the FC with individual attention to the client’s retirement investment needs and objectives. FCs provide advice to clients utilizing strategies that include equity, fixed income, balanced, other investments, or a combination. The program is designed for clients with minimal trading requirements. FCs in the SRA program do not have discretionary authority over client retirement assets, and all transactions in client assets are directed by client or client’s designee.

Investment Services Stephens shall periodically provide you with investment advice which can include recommendations regarding investing in available assets in a manner consistent with your investment objectives; and pursuant to your consent, which shall be obtained prior to each transaction, in order to accept transaction in the SRA account. Stephens will not provide you with advice with respect to positions classified as unsupervised assets in the account. *****************************************

Research Advisory Services Equity Research Services In the Stephens Equity Research Services Program we offer research reports and other products and services (“Research Services”) provided by Stephens’ Research Department to a wide variety of Stephens clients. Under certain circumstances, we provide these Research Services for a fee to certain institutions upon their request. We do not offer Research Services for a fee to clients who are individuals. Research Services include but is not limited to any and all of the following types of research products and services: • Research reports produced by research analysts; • Other research-related communications from research analysts relating to published research reports produced by research analysts; and • Access to research analysts in connection with research conferences, calls with clients and client meetings. Our Research Analysts cover approximately 400 stocks focusing on more than 30 sub-sectors within five broad industries: • Consumer • Financial Services • Healthcare • Industrials and Energy • Technology, Media and Telecommunications Beyond essential company research and analysis, we strive to outperform our peers in client services, channel checking and management access. This can take the form of a field trip on a private jet or talking directly to an industry’s client base to acquire unique insights. We are committed to introducing our best investor clients to the best companies and to being the first to present non-consensus opinion. The core of our investment philosophy draws upon our heritage as an investor as well as an intermediary, backed by strong ethical standards. As an independent, privately-owned financial services firm, we are able to take an intermediate- to long-term approach to growth, allowing us to offer advice based solely on the best interests of our clients. Research Services do not include any services or communications provided by Institutional Equity Sales personnel. The delivery of Research Services does not include trade execution, trading or brokerage services provided to clients. Our advisory relationship with our clients is strictly limited to the provision of Research Services, and any trades, transactions or orders that may be executed, routed, or otherwise processed through us on behalf of clients will be handled by us solely in our capacity as a broker-dealer. E. Assets Under Management As of December 31, 2025, we managed the following amount of client assets as follows:

$ $ $ $

13,826,378,185 4,218,466,048 9,100,352,549 27,145,196,782

Discretionary Non-Discretionary Consulting Total Assets Under Advisement

Services similar or comparable to those provided to a wrap program client may be available to the client at a higher or lower aggregate cost elsewhere on an unbundled basis. We encourage you to carefully consider other investment structures and programs which are available in considering whether to establish or maintain an advisory fee-based account. As a general matter, a fee-based advisory account approach may be considered appropriate for clients who rely on investment advice or investment management services or who engage in moderate to high levels of trading activity. A fee-based approach may be more economical for clients who engage in active trading, since the price per trade is reduced as the number of trades increases under a fee-based approach. However, fee-based advisory account arrangements may not be appropriate for clients who rely primarily on their own independent resources and judgments for making their investment selections and decisions and do not wish to purchase advisory services. Excluding SRA, RSP, and SND clients, clients who engage in a lower level of trading activity might prefer a traditional brokerage account with a commission payable on each transaction, particularly if the client typically does not utilize advisory services for trading decisions, as transaction cost savings might be realized in the context of a traditional pay-per-trade commission structure. However, retirement accounts are not available through Stephens as brokerage accounts. Typically, a portion of any revenue that the firm realizes in connection with an advisory account will be included in the calculation of the compensation to be paid by the firm to the IAR or FC; and, therefore, the IAR or FC will experience conflicts of interest similar to those experienced by the firm. Performance Fees In addition to asset based fees, where appropriate, clients can enter into performance fee arrangements with Stephens. These fee arrangements compensate Stephens based on the performance of the client’s account. Clients entering into this type of fee arrangement must be qualified clients as defined in Advisers Act Rule 205-3. The terms of the performance fee are set forth in each client’s investment management agreement. Performance fee arrangements are approved on a case by case basis by Stephens. As specified in each client’s Investment Advisory Agreement, the amount of the Stephens Advisory Fee that the client pays is not considered in the computation of the performance fee. B. Payment of Fees Our advisory fees for investment advisory accounts are paid quarterly or monthly. Typically, Stephens will deduct the fee from the account being charged. In some cases, the client will pay the fee out of its separate assets. Collection of Fees Stephens is authorized to deduct from your account depending on which advisory platform, each quarter or month in advance or arrears the amount of the total quarterly wrap fee as described in the Investment Advisory Agreement, and the other fees, if any, applicable to your account for such calendar quarter. Stephens will issue quarterly reports to you reflecting the transactions in your account and the performance of the investments. Service fees and other transactions charges, if any, will be applied to the account as incurred. C. Other Types of Fees and Expenses Clients May Pay

The wrap fee covers custody services provided by Pershing and securities execution services provided by Stephens and Pershing. Pershing adds a markup or markdown to fixed income transactions. These markups and markdowns are in addition to the wrap fee. See the discussion Advisory Services above in Item 4.C for further information. If a client’s account is under a wrap fee program such as the programs listed in Item 4.D, commission charges are also included as part of the Stephens advisory fee. This is more fully described in the brochure of each wrap fee program. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Stephens Insured Bank Sweep Program The Stephens Insured Bank Sweep Program (“Bank Sweep Program”) is available to Stephens’ clients through our fully disclosed clearing broker-dealer, Pershing, and Pershing has appointed IntraFi Network, LLC (“IntraFi”) to provide certain services in connection with the Bank Sweep Program. In the Bank Sweep Program, each bank participating in the program pays a return based on the amount of funds in your Deposit Account at the bank. The interest rate applicable to your Deposit Accounts is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus: (i) the fees paid to Intrafi Network, LLC, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercises the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. Stephens’ compensation, exclusive of the fees paid to Pershing and IntraFi, for the Bank Sweep Program as applied to all clients will not exceed 6% per annum on the aggregate balances in the Deposit Accounts at the program banks. The total amount of the fee Stephens charges affects the amount of interest payable to clients on their Deposit Accounts since the higher Stephens’ fee is, the lower the amount of interest that is paid to Stephens’ clients. Stephens charges investment advisory fees as a percentage of client assets under management which includes cash assets in the Bank Sweep Program. This means that clients will pay Stephens’ investment advisory fee in addition to the fees charged in the Bank Sweep Program which are described above. More information on the current rates of return and fees is available at www.stephens.com/investment-disclosures/ which is incorporated herein. The interest rates on the Deposit Accounts will vary based upon the aggregate balance of all your “linked” Stephens accounts registered with the same tax ID number. This is referred to as your “Household Balance” and is described in more detail at www.stephens.com/investment-disclosures/. The rates and the Interest Rate Tiers may change from time to time. Further information on the Bank Sweep Program is available at https://www.stephens.com/investmentdisclosures/stephens-insured-bank-sweep-program-rates/. These disclosures are incorporated herein. The interest rates paid on the Deposit Accounts at a Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Bank or other depository institutions in comparable accounts and for investments in the money market mutual funds and other cash equivalent investments available through Stephens. You should compare the terms, interest rates, required minimum amounts, and other features of the Bank Sweep Program with other accounts and alternative investments. In deciding whether to participate in the Bank Sweep Program, clients should consider the return they are expected to receive versus the safety of the program. Banks participating in the Bank Sweep Program are not selected by Stephens, and each bank participating in the Bank Sweep Program is covered by FDIC deposit insurance up to the applicable FDIC limit. Banks in the program are expected to have acceptable credit but may not have “top tier” credit, and clients should evaluate credit quality and FDIC insurance coverage together with the return they are expected to receive. Funds in Advisory Programs Investing in Funds is more expensive than other investment options offered in your advisory account. In addition to our investment advisory fee, you pay the fees and expenses charged by the Funds in which your account is invested. Fund fees and expenses are charged directly to the pool of assets the Fund invests in and are reflected in each of the

Fund’s share prices. These fees and expenses are an additional cost to you and are not included in the fee amount in your account statement. Each Mutual Fund and ETF expense ratio (the total amount of fees and expenses charged by the Fund) is disclosed in the prospectus. You do not pay a sales charge for purchases of mutual funds in your advisory account. However, some mutual funds charge, and do not waive, a redemption fee on certain transaction activity in accordance with its prospectus. In many instances, Client account assets are invested in money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Funds”), and these investments have their own fees and expenses which are borne directly or indirectly by their shareholders. Where Stephens or its affiliates act as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities to such Funds, these Funds are deemed to be “Affiliated Funds.” Stephens or a Stephens affiliate receives the fees paid pro rata by all shareholders or partners of Affiliated Funds as described in the Fund’s prospectus. Client account assets can also be invested in Funds which are unaffiliated with Stephens or a Stephens’ affiliate (“Unaffiliated Funds”). For both Affiliated Funds and Unaffiliated Funds in which Stephens’ client assets are invested, Stephens receives distribution and shareholder servicing fees (“12b-1 fees”) from Funds on an ongoing basis as compensation for the administrative, distribution and shareholder services provided by Stephens. These services include such things as record maintenance, shareholder communications, transactional services, client tax information, reports filings, and similar such services. These fees are paid under a plan adopted by the Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended. If Stephens receives 12b-1 fees from a Fund with respect to a client’s mutual fund investment in the client’s advisory account and the client is paying Stephens an advisory fee on such investment, the 12b-1 fees will be rebated to the client’s advisory account. However, in client brokerage accounts which have mutual fund holdings, Stephens does retain the 12b-1 fees and shareholder servicing fees paid by the funds on these mutual fund holdings. Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client advisory holdings, these will be rebated to the advisory client. Effective November 15, 2019, Stephens has entered into a fully disclosed clearing arrangement with Pershing wherein Pershing provides certain recordkeeping and operational services to Stephens and to Stephens’ clients. The services provided by Pershing will include execution and settlement of securities transactions, custody of Stephens’ client accounts and extensions of credit for any margin transactions. Mutual funds are available to investors in a variety of different share classes, all of which carry different expense ratios. Fund share classes that pay higher compensation carry higher expense ratios than share classes of the same mutual fund with lower expense ratios. Investing in a mutual fund share class with a higher expense ratio will negatively impact an investor’s return. Consistent with our fiduciary duty to clients, Stephens will take reasonable steps to ensure advisory clients are invested in share classes of mutual funds with the most appropriate expense ratio for their advisory account. Not all share classes are available to advisory clients of Stephens, and it is possible that cheaper share classes of a fund may be available directly with the fund, not available on the Pershing platform or away from Stephens. Additionally, because of the large number of mutual funds which are offered in an ever changing variety of different share classes, it is possible that investors may not receive cheaper share classes which come available after their initial investment in a fund. Unit Investment Trust (“UIT”) Sales Charge There are characteristically two components of the UIT sales charge: the transactional sales fee and the creation and development ("C&D") fee. The transactional sales fee does not apply to advisory accounts. The C&D fee is paid to the sponsor of the trust for creating and developing the trust, which includes determining the trust objective, policies, composition and size, selecting service providers and information services as well as providing other similar

administrative and ministerial functions. Your trust pays the creation and development fee as a fixed dollar amount at the close of the initial offering period. The sponsor does not use the fee to pay distribution expenses or as compensation for sales efforts. Additional Fees In an advisory program, you will pay Stephens an asset-based fee for investment advisory and other services provided by Stephens or Pershing. These services include custody of securities and trade executions through Pershing on behalf of Stephens. The program fees do not cover:       

the costs of investment management fees and other expenses charged by Funds and UITs; concessions or dealer concessions Stephens receives when you purchase public offerings of securities for which Stephens participates in the underwriting; markups and markdowns that Pershing receives on fixed income transactions; brokerage commissions or other charges resulting in transactions not effected through Stephens with Pershing; account transfer fees; processing fees; or certain other costs or changes that may be imposed by third parties.

As your Introducing Broker Dealer, Stephens can receive or pay compensation for directing order flow in equity securities. Pershing receives compensation for the direction of order flow in certain equity securities and listed options. The source and nature of the compensation, if any, received in connection with trades will be furnished upon your written request to your FC or IAR. Custodial Services Pershing normally provides custodial services to Stephens’ clients. Custodial services provided by Pershing include custody of securities in your account, periodic statements, certain tax reporting and other similar services. Your account will be subject to the terms and conditions described in the Investment Advisory Agreement/Contract, Agreement and any separate agreement or agreements executed in connection with the account. Stephens includes custodial fees for custody services and securities services provided by Pershing within the wrap fee charge. If a client’s account is under a wrap fee program, commission charges are included as part of the Stephens advisory fee unless the client has selected a third party advisor who “trades away” from Pershing. Pershing applies a markup or markdown to fixed income transactions. For further information, see the discussion of Advisory Services in Item 4.C above. Clients may engage an independent custodian. The fees of any custodian other than Pershing are not covered by the wrap fee and are the separate responsibility of the client. Clients may direct trading through another broker or other execution venue, and, in such a situation, the client will be responsible for all costs and commissions incurred in connection with such trading. Pershing Relationship Pershing is the clearing firm for our securities business. Due to this business relationship, Pershing shares with us a portion of the transaction costs and fees you pay to Pershing for certain transactions and services. The compensation we receive is an additional source of revenue to Stephens, and it defrays our costs associated with maintaining and servicing client accounts. Your advisory fee is not reduced or offset as a result of any revenue that Pershing shares with Stephens. The following is a brief description of some of the revenue and other items.

Pershing pays us on a quarterly basis an Active Account Credit in support of our ongoing investment in various businesses, marketing and technology initiatives relating to the services we offer. This Active Account Credit is based on the total number of Stephens client accounts held on the Pershing platform. Pershing also pays us a Basis Point Credit each quarter which is computed based on the total value of Stephens client accounts held on the Pershing platform. Pershing also provides consulting and other assistance to us from time to time.

Stephens receives revenues from Pershing on any investor free credit balances. These revenues are not received by Stephens for free credit balances in ERISA or IRA accounts. Stephens determines the margin debit interest rate and receives any amounts paid by clients in excess of the Fed Funds Target Rate plus 85 basis points. Stephens determines the interest rate charged to clients who obtain non purpose loans within parameters set by Pershing. Stephens receives 100 basis points of the interest paid on the loan from Pershing except in situations where Stephens has agreed to receive a lesser amount. Pershing pays us a placement fee for each CD purchased through Pershing by a Stephens’ client. Pershing pays us a portion of the revenues it receives for banking services provided to clients.

For the period January 1, 2025, through December 31, 2025, Pershing paid Stephens the following revenues:

A short interest rebate of $1,771,340 Interest based on investor free credit balances of $1,553,629 Margin interest credit of $993,200 Active account and basis point credits of $2,022,170 Non Purpose Loan interest of $685,784 Silver Account (i.e. checking account) fee of $24,000 Fee Income-Pershing-Legal/Transfer $1,200 Pershing-Money Market Invesco ATRR $266,497

Where Stephens receives compensation from Pershing, this presents a conflict of interest because Stephens and your FC or IAR have a greater incentive to make available, recommend, or make investment decisions regarding investments and services that provide additional compensation over those investments and services that do not. The agreement between Stephens and Pershing is for an initial term of 10 years effective November 15, 2019, and it provides for a substantial termination penalty in the event Stephens terminates the Clearing Agreement prior to the end of the initial term. At the outset of the Clearing Agreement, the termination penalty was $15 million, and it declines $2 million each year to $5 million in years 6 through the end of the Clearing Agreement. The termination penalty serves as a disincentive for Stephens to terminate the Clearing Agreement in the event Stephens or its clients have a negative experience with Pershing or if Stephens believes another firm offers superior service. This creates a conflict of interest in that it could influence Stephens’ decision to remain with Pershing even though it may be in the best interest of Stephens or its clients to terminate the Clearing Agreement. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. Pershing’s mailing address: Pershing LLC; One Pershing Plaza; Jersey City, New Jersey 07399. For IRA and other retirement accounts, Pershing may charge termination fees pursuant to an adoption agreement you enter into with Pershing, which authorizes Pershing to act as the IRA custodian for Internal Revenue Service purposes. Pershing may resign at any time as the IRA custodian and then you have the right to appoint a successor IRA custodian (Successor). Where an unaffiliated third party acts as custodian of account assets, Stephens does not have discretion to select where cash reserves will be held. The client and/or custodian will make the selection. ERISA and IRA Fees Fees charged by Stephens to accounts of ERISA or Internal Revenue Code-covered plans will comply with the limitations made applicable under ERISA or the Code. Where Stephens or an FC provides non-discretionary investment advice such as recommending the rollover of a 401k to an IRA account at Stephens, recommending opening an IRA account with Stephens, or recommending the transfer of an IRA from another firm to Stephens, this presents a conflict of interest since compensation will be paid to Stephens and the FC in connection with these services. In addition, Stephens charges different levels of fees on different investment services. Stephens has adopted policies and procedures

to mitigate these conflicts, and to address provisions of and prohibitions under ERISA and the Code with respect to potential conflicts of interest and self-dealing. ERISA Section 408(b)(2) Disclosures You may be, or may be acting on behalf of, a pension plan governed by the Employee Retirement Income Security Act of 1974, as amended (ERISA). ERISA section 408(b)(2) requires most parties that provide services to employee benefit plans to disclose certain information to a responsible plan fiduciary. Generally, the service provider must disclose the services that it provides to the plan and the compensation that it expects to receive in connection with the services. Stephens’ disclosures are available at the following web address:

www.stephens.com/ERISA408b2

If you are the responsible plan fiduciary, please view the disclosures on this website. If you are not the responsible fiduciary, please forward this information to the responsible fiduciary of the plan. Please review this website periodically for any required updates. Principal Transactions Pursuant to SEC Rule 206(3), Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing: 1) the capacity in which it is acting; and 2) the quantity and dollar amount of the securities being purchased or sold. As a practical matter, the above requirements impose delays on the time at which principal transactions can be effected for advisory accounts and thereby can impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. Investment advisory clients are advised that they have the option to seek execution of transactions recommended by the FC or IAR through broker/dealers other than Stephens. However, on transactions executed through Stephens with Pershing, Stephens or Pershing will not charge a commission to the client, except when an underwriting issue in which Stephens participates is purchased for an account; in this case, the sales concession and underwriting fees are built into the offering price. Stephens will strive to obtain “best execution” of transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances. IPO Retail Client Allocations Although underwriting initial public offerings (“IPOs”) on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may participate as an underwriter in no, or only a few, IPOs. Factors that limit IPO product availability to clients through Stephens include:

Market conditions that make raising capital through IPOs less favorable or unfavorable for issuers, such as periods of high market volatility or depressed share prices. Alternative investment options for institutional and retail investors that impact overall demand for IPO investments. Lack of or diminished investor interest in market sectors in which Stephens’ issuer clients operate. The availability of capital through other sources such as the private equity marketplace or attractive debt financing alternatives. Diminished financial strength and business prospects of particular issuer clients that make them poor candidates for IPOs. Lack of specific business needs of particular issuer clients for capital infusions.

In addition, in many instances Stephens will only be a small participant in an IPO underwriting syndicate that is led by another firm or firms and, consequently, will have little or no control or influence over whether, or to what extent, shares in the IPO are allocated to retail accounts and, instead, are directed to institutional clients.

The combination of these factors makes it impractical, if not impossible, for Stephens to determine how much and what types of IPO product will be available for allocation to its retail client accounts over any extended time period. That, in turn, effectively precludes Stephens from utilizing any type of rotational allocation system designed to ensure that all of its retail client accounts are treated equitably. Instead of attempting to allocate shares equitably across all retail client accounts, Stephens bases its share allocation decisions on an account-by-account methodology taking into consideration multiple factors, including the following:

The number of shares available in the IPO for allocation to Stephens’ retail clients. The customary desire of Stephens’ issuer clients to avoid small retail allocations to numerous accounts, which would increase the cost and administrative burden of communicating and dealing with unnecessarily large numbers of investors. Share allocation requests received by the Stephens syndicate department from the FCs and IARs who manage the firm’s retail client accounts. The level of sophistication of the FC or IAR submitting those allocation requests in evaluating and dealing with IPO investments. The stated interest of a particular retail client in participating in IPOs, in general, or in a particular IPO, including the number of shares requested. The suitability of the investment for the client, particularly if it is speculative in nature, as is sometimes the case in IPOs. Whether the requested IPO allocation would result in an overconcentration of the security in the client’s account, resulting in lack of appropriate diversification. Whether the IPO investment would be consistent with the investment strategy and objectives agreed to by the client and the FC or IAR. Any applicable tax considerations. Whether the client has adequate liquidity in the account, or otherwise, to fund the IPO investment. Whether the FC or IAR is able to contact the client on a timely basis and obtain any documentation necessary to participate in the offering. Whether based on the client’s prior investment practices or discussions with the FC or IAR, it appears likely that the client intends to quickly resell the shares in order to obtain short term trading profits as opposed to holding them in order to gain long term appreciation, sometimes referred to as “flipping.”

Given the complexity and sometimes subjective nature of this analysis, and the fact that the applicability of these considerations may vary with respect to a particular retail client at any given time, Stephens does not attempt to ensure that the allocation of IPO shares across all of its retail client accounts is equitable and does not analyze the fairness of its allocation decisions over time. In practice, some retail client accounts will have far greater access to IPO allocations than others. In fact, based on past experience, only a very small percentage of Stephens’ retail clients will participate in IPOs. Nevertheless, clients who are interested in participating in IPOs or a particular IPO are encouraged to advise their FC or IAR of such fact. IPO Related Conflicts of Interest Flipping. Stephens has a long-standing policy of discouraging its FCs and IARs from allocating IPO securities to retail client accounts that appear likely to quickly resell the securities in order to obtain short term trading profits as opposed to holding them in order to gain long term appreciation. Excessive short term trading in the secondary market following an IPO has the potential of causing market disruption and depressing the price of the issuer’s securities, both of which would operate to the disadvantage of Stephens’ issuer clients. Accordingly, Stephens reserves the right to withhold IPO allocations to retail client accounts that have a history of flipping their IPO securities positions or advise their FC or IAR of their intent to flip the IPO securities they wish to purchase in a pending IPO. This policy creates a conflict of interest because, while it favors Stephens’ IPO issuer clients and Stephens’ long term interests as an underwriter, it may not be in the best interest of a retail client seeking to realize short term trading profits on the client’s IPO positions. In addition, Stephens may penalize clients who flip their IPO securities by reducing or eliminating IPO allocations to them in the future.

Favoring Larger Allocations. Stephens’ issuer clients generally prefer that the underwriting syndicate avoid small retail allocations to numerous accounts, which would increase the cost and administrative burden of communicating and dealing with unnecessarily large numbers of investors. Major items of expense in that regard include the printing and mailing of large numbers of investor communications such as proxy statements and annual reports. Further, Stephens, itself, incurs higher transaction and administrative costs if smaller IPO allocations are spread over a larger number of accounts. This overall situation creates a conflict of interest with respect to Stephens’ handling of smaller accounts because larger allocations mean that they will have less opportunity to participate in IPOs and gain the IPO experience that would potentially qualify them for participation in more IPOs. This methodology also has the potential of increasing risk for IPO investors to the extent that larger allocations would be expected to result in more concentration with respect to these types of typically more speculative securities. Advisory vs. Brokerage Accounts. If a retail client has both an advisory and a brokerage account, it may be in the best interest of the client to purchase IPO securities in the brokerage account. The client would pay the same offering price for the securities irrespective of which type of account is selected for the purchase. However, in a brokerage account no additional charges (in the form of commissions) would be incurred until the time the securities are sold, while in an advisory account the client would incur assets under management fees that could exceed the amount of such commissions depending on the length of the holding period. The risk of this disadvantage occurring is increased by Stephens’ policy against flipping, which is designed to encourage longer holding periods. Offerings with Less Demand. Based on Stephens’ previously described allocation process, there is a potential that a retail account that does not frequently participate in IPOs may have a greater opportunity to participate in IPOs that prove to be in less demand, particularly if Stephens receives a relatively large allocation for placement with its retail clients. Although Stephens, and its FCs and IARs, have limited ability to predict client demand for an IPO in advance of the pricing and effectiveness of the offering, certain of the criteria utilized in allocating shares, such as previous IPO experience and favoring larger allocations, may result in more favorable allocations to larger, more experienced retail accounts in connection with high demand offerings. On the other hand, these factors would be expected to have less of an impact with respect to offerings where there is less demand from retail clients relative to the size of the retail allocation Stephens receives. It is likely, although certainly not guaranteed, that IPOs for which there is high demand relative to supply will perform better in the post-offering marketplace for at least some period of time. Clients That Do Not Have Access. Stephens relies primarily on its FCs and IARs to determine whether, and to what extent, their retail advisory clients are interested in participating in IPOs. Many accounts are simply too small to participate in IPOs when concentration and suitability factors are taken into consideration. And, in practice, only a small percentage of Stephens FCs and IARs regularly submit IPO allocation requests on behalf of their clients. In many instances, retail clients are participating in one or more of the Stephens Private Client Group’s advisory platforms providing for fee based, discretionary management by the FC, a firm investment committee or a third party money manager. The vast majority of FCs rely on these platforms to achieve appropriate asset allocation for their clients and typically do not offer their clients the opportunity to participate in IPOs. The same is also generally true with respect to the retail client accounts managed by Stephens Capital Management. Finally, Stephens FCs and IARs, in their discretion, may elect to offer IPO allocations to some clients but not others, and such decisions are unlikely to be reviewed by Private Client Group supervisors or Compliance Department personnel. Given these circumstances, retail clients interested in participating in IPOs should advise their FC or IAR of such fact. These platforms provide for low cost, level fee charges to clients, and Stephens is not allowed to accept any other compensation with respect to the handling of the account, including the compensation it would receive in connection with the sale of IPO securities. Accordingly, Stephens does not allow these types of accounts to participate in IPOs. D. Pre-Paid Advisory Fees In some programs offered by Stephens the client is required to pre-pay the advisory fees. Generally, these fees are billed monthly, though in limited circumstances they may be billed quarterly. Under these programs, Stephens is typically compensated based on a percentage of the value of the assets in each advisory account.

You pay a single asset-based fee, charged monthly or quarterly, which covers the services provided by Stephens. Advisory fees apply to standard accounts and include investment advice, securities execution fees, certain custodial services, associated account reports and investment portfolio reports. This is a wrap fee. The maximum annual fee rate for the SAS, MAP, and UMA programs is 2%. The maximum annual fee rate for all other pre-paid wrap fee advisory accounts is 2.5%. A minimum fee is assessed per account. Fees are negotiable based on a number of factors including the type and size of the account and the range of services provided by the FC. In special circumstances, and with your agreement, the fee charged to you for an account may be more than the maximum annual fee stated in this section. When are Fees Paid and How Fees are Computed Fees Paid in Arrears SCM fees apply to standard accounts and include management, brokerage services, custodial services, associated accounting reports and investment management reports. Only in special circumstances are the fees negotiable or otherwise varied from the above schedules. The fee is deducted from the client’s account by SCM quarterly unless otherwise agreed in writing. The annual advisory fee is prorated based on the number of days in the quarter. Because the number of days in a quarter varies, your quarterly rate will fluctuate based on the number of days in the quarter. The quarterly rate is applied to the average market value of cash and securities in the portfolio as of the close of business on the last day of each calendar month (that ends on or after the date assets are first credited to the account referred to above) of the calendar quarter. If an account has a margin debit balance, the total market value of the account used in computing Stephens’ fee is the total market value of all eligible assets and is not reduced by the margin debit balance. For example, an account with a total market value of $120,000 and a margin debit balance of $20,000 will have a net market value of $100,000. Stephens’ fee would be computed using the total market value of $120,000. In the event a client’s account is closed between quarter-ends, fees will be prorated as of the date of termination. The following programs require fees to be paid in arrears:

Stephens Capital Management Discretionary (“SCMD”) Stephens Capital Management Fixed Income (“SCM-FIS”) Stephens Capital Management Non-Discretionary (“SND”) Stephens Spectrum Program (“SSP”) StephensChoice (“SC”) Stephens Spectrum 401(k) (“SSK”) Pension Management Trust Program (“PMT”) Health Management Trust Program (“HMT”)

Fees Paid in Advance The fee is payable monthly in advance. The fees will be deducted from the client’s account monthly in advance, unless otherwise agreed in writing. If a percentage fee is used, the initial fee is calculated from the date the account is turned over for trading (the “turnover date”) of the advisory account to the end of the then-current calendar month. The fee is obtained by multiplying the market value of eligible assets placed in the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the then-current calendar month.

A prorated fee will be charged when additional assets greater than $25,000 on a single deposit (or monthly aggregate) are placed in the account, in an amount determined by multiplying the market value of the eligible additional assets placed in the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the month. A prorated fee will be rebated when assets greater than $25,000 on a single withdrawal (or monthly aggregate) are withdrawn from the account, in an amount determined by multiplying the market value of the withdrawn assets from the account by 1/12th of the applicable annual fee rate(s), prorated for the remaining percentage of the month. If an account has a margin balance owed, the market value of the account used in computing Stephens’ fee is the total market value of all eligible assets, and it is not reduced by the margin debit balance. For example, an account with a total market value of $120,000 and a margin debit balance of $20,000 will have a net market value of $100,000. Stephens’ fee would be computed using the total market value of $120,000 times 1/12th of the applicable annual fee rate(s) adjusted by the time period. In the event a client’s account is closed before month-end, fees will be prorated as of the date of termination. The following programs require fees to be paid in advance:

Professional Wealth Management (“PWM”) Stephens Advisor (“SA”) Stephens Allocation Strategies (“SAS”) Stephens Managed Assets Program (“MAP”) Stephens Unified Managed Account (“UMA”) Stephens Retirement Solutions (“RSP”) Stephens Retirement Access (“SRA”)

E. Compensation for the Sale of Securities and Investment Products Stephens does not charge clients brokerage commissions for securities trades executed through Stephens with Pershing for the client’s account in any of the offered wrap programs listed above. Therefore, none of our personnel receive revenues based on commissions from the purchase or sale of securities for those accounts. Pershing will apply a markup or markdown to fixed income trades. This markup or markdown is in addition to the wrap fee you pay to Stephens. See Item 4.C (“Advisory Services”) for further discussion. For mutual fund investments, fees are also charged by the mutual fund as more fully described in the mutual fund’s prospectus. Some of the fees charged by the mutual funds are paid to Stephens by the mutual fund. See Item 5.C for further discussion. Generally outside managers in the MAP program either provide Pershing with their model portfolio or direct their trading to Pershing for execution. In both of these situations, Pershing executes these trades at no additional charge to the clients because execution charges are included in the wrap fee the client pays Stephens. The number of managers in the MAP program that direct trades to other broker dealers can change as managers are added or removed from the program. The following equity/balanced strategies in the program have the ability to send trades for execution to broker-dealers other than Pershing, and trades executed away from Pershing will result in commission charges to Stephens’ clients in addition to the wrap fee the client paid to Stephens. These additional charges affect the net performance for the clients’ accounts. In the MAP program, certain third party managers can trade away from Pershing or Stephens in order to achieve best execution or other reasons. When the manager trades away this results in additional transaction charges being incurred by your account which are in addition to the advisory wrap fee you pay Stephens. The Managers/strategies which traded away from Stephens or Pershing in the last two years are:

Franklin Templeton All Cap Blend Balanced Portfolios (MDA0-Balanced) Franklin Templeton Appreciation Balanced Portfolios Franklin Templeton Appreciation Balanced Tax-Favored Portfolios Franklin Templeton Balanced Income Portfolios Legg Mason Balanced Income Taxable (70/30) Legg Mason Balanced Income with Municipals Legg Mason Balanced Income with Municipals (70/30) Franklin Templeton All Cap Growth Balanced Portfolios Franklin Templeton Custom MDA Portfolios Franklin Templeton Global All Cap Blend Balanced Portfolios (MDA8-Balanced) Franklin Templeton Large Cap Growth Balanced Portfolios Nuveen Preferred Securities The average cost of the execution charges during this period was $0.00 to $0.05 per share. Generally, Sub-Advisors in the UMA program either provide Pershing with their model portfolio or direct their trading to Pershing for execution. In both of these situations, Pershing executes these trades at no additional charge to the clients because execution charges are included in the wrap fee the client pays Stephens. However, to achieve best execution and for other reasons, Non-Model Sub-Advisors have the ability to trade away from Pershing. When NonModel Sub-Advisors trade away from Pershing, clients will incur additional costs for fixed income securities. The additional fees are per bond or on a per transaction basis which are embedded in the net price you receive. The number of Non-Model Sub-Advisors in the UMA program that direct trades to other broker-dealers can change as Non-Model Sub-Advisors are added or removed from the program.

Stephens only enters into performance fee arrangements with certain clients which are eligible to enter into these arrangements as defined in Rule 205-3 under the Investment Advisers Act of 1940 and in accordance with the requirements set forth in the applicable laws, rules and regulations, and these arrangements are negotiated with the client on an individualized basis. The performance fee arrangement could create an incentive for Stephens to seek to maximize the investment return by making investments that are subject to greater risk, or are more speculative, than would be the case if Stephens’ compensation were not based upon the investment return or could create an incentive for Stephens to seek to limit investment returns by pursuing investments with reduced risk. With a performance fee arrangement Stephens’ fee is, in part, contingent upon the returns on the client’s assets, which is computed based upon unrealized and realized appreciation or depreciation of client’s assets. This gives Stephens an incentive to favor performance fee accounts with investment opportunities and therefore creates a conflict of interest for Stephens. Accounts participating in a performance fee arrangement may pay Stephens more compensation, or less compensation, when compared to standard fee rates. Performance fee arrangements may not be available for all investment accounts and must be approved by Stephens on a case-by-case basis. Performance fee rates are negotiable. A client may negotiate a base fee rate, performance fee rates, an index to be used to calculate the performance fee, or the use of no index in calculating the performance fee.

Any performance fee that Stephens charges is intended to comply with Rule 205-3 and other applicable requirements under the Investment Advisers Act of 1940 (the “Adviser’s Act”). Stephens has an incentive to favor accounts which it charges a performance fee over other types of client accounts by allocating more profitable investments to performance fee accounts or by devoting more resources toward the accounts’ management. Stephens seeks to mitigate the potential conflicts of interest which arise from managing accounts that bear a performance fee through its policies and procedures, including those related to investment allocation, and by complying with the provisions of Rule 205-3 as stated above. Stephens has discretion not to accept these arrangements.

The sponsor establishes a minimum account size for each program, and you should refer to the sponsor’s wrap fee brochure for a discussion of minimum account sizes and whether the minimum account size can be waived. Only those clients whom we, in our discretion, deem suitable will be accepted into these programs.

Investment Strategies Stephens offers many investment strategies through our programs sponsored through SCM, SFIM and PCG. Our investment advisory services seek to tailor an investment program for the unique financial circumstances and objectives of a particular client. When we are engaged as an investment advisor, the client typically pursues one or more of our investment strategies. Clients may impose investment restrictions on their accounts, such as restrictions on investing in particular securities or types of securities or restrictions on investing in particular industries. All of the programs are more fully described in Item 4.D. and their respective ADV Part 2A, Appendix 1. SCM services discretionary and non-discretionary portfolios of equity, fixed income and alternative asset classes and provides asset allocation advice to clients. SCM's IARs take into account both our clients' unique situations and the changing financial markets in developing investment strategies tailored to meet our clients' financial goals. PCG provides investment advisory services for discretionary and non-discretionary portfolios. Stephens has the flexibility to adapt strategies to a changing financial environment while keeping your goals and objectives in mind.

A Range of Investment Solutions As a full-service financial services firm, Stephens offers access to an array of financial solutions designed to help you achieve your investment goals and objectives. Stephens can assist you in selecting and managing investment solutions that best fit your wealth management goals. These investment solutions can include: • Investment management and advisory services • Wealth management • Corporate executive services • Individual equities, mutual funds and exchange traded funds • Taxable and tax-exempt fixed income securities • Alternative investments • Insurance and annuities C. Risk of Loss The material risks associated with our strategies are: Alternative Investments -- Investing in alternative investments can be highly illiquid, is speculative and not suitable for all investors. Certain alternative investment products place substantial limits on liquidity and the redemption rights of investors, including only permitting withdrawals on a limited periodic basis and with a significant period of notice and may impose early withdrawal fees. Investing in alternative investments is intended for experienced and sophisticated investors only who are willing to bear the high economic risks of the investment. Investors should carefully review and consider potential risks before investing. Certain of these risks include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative practices; lack of liquidity, in that there may be no secondary market for the fund and none expected to develop; volatility of returns; restrictions on transferring interests; potential lack of diversification and resulting higher risk due to concentration of trading authority when a single advisor is utilized; absence of information regarding valuations and pricing; complex tax structures and delays in tax reporting; less regulation and higher fees than mutual funds; and advisor risk. Alternative investment products typically have higher fees (including multiple layers of fees) compared to other types of investments. Individual funds will have specific risks related to their investment programs that will vary from fund to fund. Debt Obligations - Investing in debt (bond) obligations entails additional risks, including interest rate risk such that when interest rates rise, the prices of bonds and the value of bond funds shares can decrease, and the investor can lose principal value. Equity Market Risk - Overall stock market risks affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Foreign Debt Obligations - Investing in foreign debt obligations entails additional risks, including those related to regulatory, market or economic developments, foreign taxation and less stringent investor protection and disclosure standards. Foreign Securities - Investing in foreign securities presents certain risks that are not present in domestic securities. For example, investments in foreign and emerging markets present special risks including currency fluctuation, the potential for diplomatic and political instability, regulatory and liquidity risks, foreign taxation and differences in auditing and other financial standards. In addition to the greater exposure to the risks of foreign investing, emerging markets present considerable additional risks, including potential instability of emerging market countries and the increased susceptibility of emerging market economies to financial, economic and market events. Money Market Risk - An investment in a Money Market Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund. Yields will vary. Yield quotations more closely reflect the current earnings of the fund than the total return.

Management Risk - Our judgments about the attractiveness and potential appreciation of a particular asset class, mutual fund or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The price of an individual security can be more volatile than the market as a whole and our investment thesis on a particular stock may fail to produce the intended results. Options Risk - Options involve risk and are not suitable for all investors. Small Cap and Mid Cap Company Risk - Investing in small cap and mid cap issuers involves a significantly greater risk than investing in larger, more established companies. The daily trading volume for Small Cap and Mid Cap issuers can be much lower than for more widely held, established companies. There may be periods when it is difficult to invest in or liquidate portfolio investments for our various investment strategies. This is particularly the case when breaking news on a company occurs or when significant market forces and events occur. In addition, small and midcap companies are more vulnerable to economic, market and industry changes. Because smaller companies often have limited product lines, markets or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. Investors should only invest a portion of their total portfolios in these securities, and investors should be prepared to lose their entire investments. Certain Risks Associated with Cybersecurity With the increased use of technologies to conduct business, investment advisers, including Stephens, rely in part on digital and network technologies (collectively, “cyber networks”). These cyber networks are susceptible to operational, information security and related risks and can be at risk of cyber-attacks. Cyber-attacks could seek unauthorized access to cyber networks for the purpose of misappropriating sensitive information, corrupting data, or causing operational disruptions. Cyber-attacks can potentially be carried out against the issuers of securities you have invested in, against third party service providers, or against Stephens itself by persons using techniques that range from efforts to circumvent network security, overwhelm websites, and gather intelligence through the use of social media in order to obtain information necessary to gain access to cyber networks. Although cyber-attacks potentially could occur, Stephens and Pershing maintain an information technology security policy and technical and physical safeguards intended to protect the confidentiality of internal data. Risks Associated with Artificial Intelligence Stephens can be expected to utilize enterprise tools and systems that include or incorporate artificial intelligence (“AI”), machine learning, probabilistic modeling, and other data science technologies (collectively, “AI Tools”) to assist in formulating commentary, research materials, investment insights, investment advice, or client communications. The use of AI Tools is only supportive of the advisor’s investment-advice process and does not replace the professional judgment of the advisor. Stephens does not use AI Tools to automate investment decisions, select securities, or determine portfolio constructions. All investment decisions are made by human investment professionals. Stephens’ policies require all AI Tool-assisted outputs, including those used in assisting with the investment advice process, to be reviewed by a human before such outputs inform recommendations or investment decisions or are otherwise disseminated. AI Tools depend on the collection and analysis of large amounts of data and are highly complex. While reasonable efforts are made to verify the accuracy of information presented, AI Tools can produce outputs that contain incomplete, inaccurate, outdated, or misleading information. Stephens is not in a position to control the manner in which third-party AI Tools are developed or maintained. However, Stephens has implemented policies and procedures designed to mitigate these risks by requiring employees to take training on the proper use of AI Tools; requiring human review prior to dissemination of AI-generated or AI-assisted content; and prohibiting the use of publicly available AI Tools. The use of AI Tools is subject to Stephens’ vendor approval policies and procedures, including risk-based review and oversight prior to deployment. Stephens requires its employees to use enterprise versions of AI Tools, or other approved

AI Tools, that are designed to prevent data or information entered into the AI Tool from becoming public or being used to “train” the AI Tool. However, Stephens is unable to eliminate or mitigate all risks associated with the use of AI Tools. The legal and regulatory environment relating to AI is uncertain and could rapidly evolve. This may impact how Stephens uses AI, increase compliance costs, and increase the risk of non-compliance. Any of these risks could adversely affect Stephens as well as the models, platforms, and accounts advised by Stephens. There is also risk exposure arising from the use of AI by bad actors to commit fraud, misappropriate funds, or facilitate cyberattacks. Bank Sweep Program If you have on deposit through the Bank Sweep Program an amount of cash that exceeds the number of Banks multiplied by $250,000, the balances in excess of this amount will not be insured by the FDIC. In the event of a failure of a bank participating in the Bank Sweep Program, there may be a time period during which you may not be able to access your cash. If you have cash at a bank outside the Bank Sweep Program, this may negatively impact the availability of FDIC insurance for the total amount of your funds held within and outside the Bank Sweep Program. You are responsible for monitoring the total amount of deposits that you hold with any one Bank, directly or through an intermediary, in order to determine the extent of FDIC insurance coverage available to you on your deposits, including the Deposit Accounts. Nothing obligates you to participate in the Bank Sweep Program. You may receive a higher rate of return through products offered outside the Bank Sweep Program, including Money Market Funds offered through your account with Stephens and Pershing. Each Deposit Account constitutes a direct obligation of the Bank and is not directly or indirectly an obligation of Stephens or Pershing. Stephens and Pershing do not guarantee in any way the financial condition of the Banks or the accuracy of any publicly available financial information concerning such Banks. Stephens and Pershing are not responsible for any insured or uninsured portion of a Deposit Account.

The Order directed Stephens to Cease and Desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940 and ordered that Stephens be censured and pay disgorgement and prejudgment interest to advisory clients who held these more expensive mutual funds share classes in their advisory accounts. (IA Release No. 40-5196) In its capacity as a broker/dealer, Stephens has been subject to legal or disciplinary events in the ordinary course of its business, such as regulatory sanctions relating to compliance with broker/dealer trade reporting requirements and other regulatory actions.

from its broker/dealer and investment banking activities than it derives from its investment advisor activities. Affiliates of Stephens are also separately engaged in financial services businesses, including merchant banking, insurance and investment advisory businesses. C. Affiliations 1. Affiliated Mutual Funds Stephens may from time to time engage in transactions on behalf of clients with Hotchkis & Wiley Capital Management LLC (“H&W”) or with mutual funds advised by H&W. H&W is an investment adviser registered with the SEC in which entities under common control with Stephens hold an ownership interest. H&W provides investment advisory services to corporate, pension, public, endowment, foundation, mutual fund and other clients, and H&W also advises its own family of mutual funds. Stephens may also from time to time engage in transactions on behalf of clients with Stephens Investment Management Group LLC (“SIMG”) or with mutual funds advised by SIMG. SIMG is an investment adviser registered with the SEC in which members of the Stephens family are the beneficial owners of 100 percent of voting interests. SIMG provides investment advisory services for separate account clients and for mutual funds known as the American Beacon Stephens Funds® or other funds which may be added from time to time. Additionally, SIMG serves as one of the investment advisors to the following multi-manager mutual funds using its SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; and • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF (MMSC) H&W advised mutual funds and SIMG advised mutual funds are offered through Stephens’ broker dealer services and/or investment advisory services as part of an investment program. Clients that invest in H&W advised mutual funds or in SIMG advised mutual funds would bear a proportionate share of the fees and expenses of those funds including the management fees or other fees paid to H&W or SIMG. These fees and expenses include commissions or fees, if any, paid to Stephens in connection with portfolio transactions. Please refer to each mutual fund’s prospectus for a full discussion of the fees and expenses of each mutual fund. 2. Stephens Sponsored Wrap Fee Program Stephens sponsors the Stephens Small-Mid Cap Core (“SMID Core”) Growth Program which is a wrap fee program sub-advised by SIMG that follows its SMID Core Growth Model. FCs or IARs are not financially incentivized to place clients in the SMID Core Growth Program versus any other wrap program or platform available at Stephens. However, a portion of the SMID Core account fees, generally representing twenty to fifty percent (20%-50%) of SMID Core fees, will be paid to SIMG for its portfolio management services, pursuant to a sub-advisory agreement between Stephens and SIMG. SIMG and Stephens share common ownership which benefits from the compensation generated to SIMG as the result of a client investing in the SMID Core Growth Program. Depending on the level of trading, the value of the account, and types of securities purchased or sold, clients may be able to obtain transaction execution at a higher or lower cost if purchased separately at Stephens or SIMG than through this wrap fee program. 3. Affiliated Investment Management Activities Certain investment strategies offered by SIMG have been selected for inclusion in the Private Client Group’s (“PCG”) Managed Assets Program (“MAP”). Sub-Advisors and strategies may only participate in MAP if they have been approved by the MAP Investment Committee. The MAP Investment Committee employs a process for evaluating investment managers that includes both qualitative and quantitative factors. SIMG strategies participating in MAP are subject to the same due diligence and evaluation processes as sub-advisors or strategies that have no affiliation with Stephens. FCs are not financially incentivized to favor selecting SIMG strategies over non-affiliated sub-advisors or strategies. However, selection of an SIMG strategy in MAP generates compensation to SIMG, which shares common

ownership with Stephens. 4. Other Affiliations Certain entities affiliated with Stephens or under common control with Stephens hold an ownership interest in ABR Capital Partners, LLC (formerly Alex Brown Realty, LLC), a registered investment adviser. From time to time, Stephens offers to its clients securities sponsored by ABR Capital Partners, LLC. Stephens sometimes refers clients to Stephens Insurance, LLC, an affiliated insurance agency under common control with Stephens, for advice pertaining to products that are provided through Stephens Insurance, LLC, and FCs and IARs may be eligible, subject to regulatory and legal requirements, to receive referral fees for insurance business referred. Stephens Insurance, LLC, may refer prospects seeking investment advisory services to Stephens. If the referral results in a new account relationship, then a portion of the net revenue from such account may be paid to Stephens as a referral fee. This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. For further information that pertains to related persons of Stephens, please refer to “Other Potential Conflicts of Interest” following Item 18 below. D. Arrangements with Related Investment Advisers or Investment Companies From time to time, Stephens and its FCs and/or IARs may recommend that clients invest in investment products that are affiliated with Stephens. Such arrangements are described in greater detail in Item 10.C above. Such a recommendation of affiliated investment products creates a potential conflict of interest because Stephens, its affiliates, and their beneficial owners may receive higher aggregate compensation than if clients invest in unaffiliated investment products. Stephens addresses this potential conflict through disclosure, including in this Brochure. Additionally, when acting as fiduciaries, Stephens FCs and IARs are required to recommend affiliated investment products only when they determine it is in the client’s best interest to do so. FCs or IARs are not financially incentivized to recommend Stephensaffiliated products over any other investment product available at Stephens. In no case are you under any obligation to purchase any products or services sold by us or our affiliates.

Any personal securities transaction, which would be detrimental or potentially detrimental to any client account and any personal securities transaction, which is designed to profit by the market effect of any client account, must be avoided. 2. All personal securities transactions should be conducted in such a manner as to be consistent with the Code and to avoid actual or potential conflicts of interest or abuse of a Stephens’ employee’s knowledge of client information or client transactions. 3. Investment adviser personnel should not take inappropriate advantage of their positions. Information concerning the identity of security holdings and financial circumstances of clients is confidential. 4. Independence in the investment decision-making process is paramount.

Accordingly, there are certain standards of conduct which Stephens investment advisory employees follow to reduce potential conflicts with the interests of our clients. Stephens will provide a copy of the Code to any client or prospective client upon request. B. Conflicts of Interest Ownership Pursuant to Section 206(3) of the Investment Advisers Act, Stephens, acting as a principal for its own account, will not knowingly sell any security to or purchase any security from an advisory client, without obtaining the client’s prior consent to each such transaction and disclosing: 1) the capacity in which it is acting; and 2) the quantity and dollar amount of the securities being purchased or sold. As a practical matter, the above requirements may impose delays on the time at which principal transactions may be effected for advisory accounts, and thereby may impair the execution quality of such transactions for advisory clients. Accordingly, transactions are generally executed on an agency basis. If Stephens is acting as a market-maker or otherwise as a principal, Stephens has the potential for profit or loss on securities it sells to or buys from a client. For additional information, please see the discussion Advisory Services in Item 4.C above. American Beacon Stephens Funds® and Hotchkis & Wiley Funds (“Affiliated Funds”) are funds managed by affiliates of Stephens and/or advisors in which affiliates of Stephens have a substantial ownership interest. ERISA accounts and IRA accounts are generally prohibited from investing in these Funds. Other advisory accounts may invest in the Affiliated Funds in an appropriate amount if: (1) the manager and the client determine that the investment is suitable for the account, and (2) the client signs an Affiliate Funds Consent Letter (“Consent Letter”) prior to directing the purchase of the affiliated fund shares. Hotchkis and Wiley Limited (“HW-UK”), a wholly-owned subsidiary of H&W, is a private limited company incorporated in England and Wales. HW-UK is an appointed representative and tied agent of Arlington Group Asset Management Limited (AGAM) since March 1, 2016. AGAM is authorized by the Financial Conduct Authority to carry out regulated activities. The Chief Executive of HW-UK is also an appointed representative of AGAM and may carry on certain regulated activities in Europe. For further discussion on Affiliated Funds, see 10C and 10D. C. Stephens Personal Trading Stephens’ personnel may not participate in IPOs. All employees are required to maintain their personal accounts and accounts in which they have a beneficial interest at Stephens unless the account has been specifically exempt in writing from this requirement. Stephens’ employees are required to provide copies of all of their trade confirmations and brokerage account statements to Stephens’ Compliance Department in order to permit the monitoring of compliance with personal trading policies and restrictions. Additionally, employees are required to report all personal securities transactions no less than quarterly. Stephens’ Code requires employees to report violations of the Code to Stephens Chief Compliance Officer. D. Conflict of Interest with Personal Trading and Client Trades To minimize potential conflicts of interest, advisory personnel who determine or approve what recommendations will be made for client accounts will not participate in Stephens’ trading activities and will not know what trading strategies are employed for its proprietary accounts. It should be noted, however, that Stephens allows purchases to be made in the marketplace by its employees of securities owned by any client account, provided that such purchases are made in amounts consistent with the normal investment practice of the person involved. Such purchases must be made after the investment advisory accounts managed by such employee (or in the management of which such employee participates) has completed its transactions in such securities.

In such event, all commissions and other charges of the other broker-dealers will be borne by the account or the client and will not be borne by Stephens. 1. Research and Other Soft Dollar Benefits Stephens does not enter into arrangements with other broker-dealers whereby it receives free research in exchange for the placement of a specified amount of client trades. 2. Brokerage for Client Referrals Stephens typically does not recommend other broker-dealers to our clients. Stephens’s client accounts typically trade through Pershing. In most of Stephens’ investment advisory programs, brokerage commissions for trades executed by Pershing for investment advisory accounts are included in the investment advisory fee and no separate brokerage commissions are charged by Pershing or Stephens for the execution of such trades. Pershing adds markups and markdowns to fixed income transactions. See the discussion of Advisory Services in Item 4.C above for additional information. Clients may arrange to execute transactions in their accounts through other broker-dealers. In such event, all commissions and other charges of the other broker-dealers will be borne by the account or the client and will not be borne by Stephens. 3. Directed Brokerage Investment advisory clients will be advised that they have the option of seeking execution through broker/dealers other than through Stephens with Pershing. From time to time, some of Stephens’ clients may wish to direct Stephens to route their entire portfolio transactions through a particular broker-dealer at a rate agreed upon between the client and such broker-dealer. In such cases, Stephens typically does not negotiate commission rates with such broker-dealers. Clients are free to choose or change broker-dealers at their discretion unless there is reason to believe the chosen brokerage firm cannot offer adequate service. In such an event, Stephens might be unable to accept management of the account. A client who directs Stephens to use a particular broker-dealer should carefully consider whether such a directed brokerage arrangement could result in additional costs or disadvantages to it. These costs and disadvantages may include paying higher commissions and receiving less favorable executions. Accordingly, the client should satisfy itself that the broker-dealer it directs us to route their trades to can provide adequate price and execution of transactions. All commissions and other charges of the directed broker-dealers will be borne by the account or the client and will not be borne by Stephens. A client that directs us to use a particular broker-dealer may also be subject to certain disadvantages regarding allocation of new issues and aggregation of orders. See below. Accounts custodied at brokerage firms that do not permit Stephens to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In determining whether to direct Stephens to use a particular broker-dealer, the client may wish to compare the possible costs or disadvantages of such an arrangement. B. Aggregation of Client Transactions Stephens may determine in particular circumstances that, while it would be both desirable and suitable that a particular security or other investment be purchased or sold for the account of more than one of Stephens’ client accounts, there is a limited supply or demand for the security or other investment. Under such circumstances, Stephens will seek to allocate the opportunity to purchase or sell that security or other investment among those accounts on an equitable basis; and Stephens will not be required to assure equality of treatment among all of its clients (including that the opportunity to purchase or sell that security or other investment will be proportionally allocated among those clients according to any particular or predetermined standards or criteria) or to undertake to make investment opportunities offered or

provided to clients of other divisions of Stephens or to clients of other representatives of Stephens available to Stephens or to clients of the representative assigned to client’s account, including client. Stephens may aggregate purchase or sale orders in a particular security for client’s account with orders for other clients’ accounts when appropriate. However, Stephens is under no obligation to aggregate orders. Where, because of prevailing market conditions, it is not possible to obtain the same price or time of execution for all of the securities or other investments purchased or sold for client’s account in an aggregated order, Stephens may average the various execution prices and charge or credit client’s account with the average price.

Stephens will periodically review client portfolio holdings to determine whether advisory clients who hold mutual fund positions are invested in appropriate share classes for the mutual fund positions in their accounts. In the event 12b-1 fees are received on client advisory holdings, these will be rebated to the advisory client. When Stephens executes a transaction for you through Pershing’s order execution system, you will receive a written or electronic confirmation of the transaction, which provides information regarding the transaction. You will also receive a written monthly account statement if you had activity in your account that is custodied by Pershing during the month, which will detail the activity and the positions in your account. If you have not had any activity during the month and you have positions in your account, you will receive a written quarterly account statement, which details the positions in your account. You may waive the receipt of account statements or confirmations after each trade in favor of edelivery via https://stephensaccess.netxinvestor.com/nxi/welcome. You may also receive mutual fund prospectuses, where appropriate. In addition, we provide account reports and/or statements for client accounts reflecting account holdings and account performance on a quarterly basis.

Such arrangements are conducted in accordance with the Marketing Rule, as applicable, and the Advisers Act generally. FCs and IARs are eligible to receive referral fees for referring eligible clients to the Stephens Investment Banking division. For eligible investment banking referrals, referring parties are eligible to receive compensation as a percentage of net income earned by Investment Banking. Therefore, FCs and IARs are incentivized to refer clients to the Investment Banking division. Any such compensation to the FC or IAR is at the discretion of the Firm. FCs who join Stephens are eligible to receive a financial incentive package. The incentive package is designed to discourage FCs from leaving Stephens and transferring client accounts to another firm during their tenure. The amount of the financial incentive package is determined by Stephens’ assessment of the FC’s perceived value as a new hire.

There are no formal revenue or production requirements, nor are there specific requirements regarding the transfer of a set number of client accounts or assets. However, all FCs are expected to maintain good standing with the firm, which entails among other things properly servicing client accounts, recruiting new business, and upholding a clean compliance record. Apart from Stephens’ investment advisory services to its advisory clients, Stephens’ Investment Banking business receives compensation from sponsors and investment advisers to private funds in exchange for placement agent, referral or other fundraising services.

By selecting Stephens as your brokerage/advisory firm, Stephens will open a custodial account with Pershing as the clearing firm, a subsidiary of the Bank of New York Mellon Corporation, One Pershing Plaza, 4th Flr – Jersey City, NJ 07399. Your assets will be held in this account. Pershing will send your account statements, which you should carefully review. In addition to the account statements Pershing sends you, we may send you a quarterly performance report which among other things lists your account holdings and performance. You should compare our report to the account statements you receive from Pershing. In the event of any discrepancy between our report and any statement you receive from Pershing regarding the same investment, you should rely on the statement from Pershing. The information contained in your account statements and reports is obtained from sources believed to be reliable but have not been independently verified. Only the statement of the custodian of the account assets should be considered the official record of account assets, and only the statement of the custodian of the account assets should be relied upon for tax reporting purposes. If Pershing is not the custodian of assets, statements or reports may not be provided unless requested. If Pershing is the custodian of the account assets, then your Pershing brokerage account statement is the custodial statement for the account assets. Please notify us promptly if you do not receive an account statement on at least a quarterly basis from the custodian(s) of all account assets. You should only use the cost basis information provided on your custodial account statements for tax reporting purposes. For IRA and other retirement accounts, Pershing may charge termination fees pursuant to an adoption agreement you enter into with Pershing, which authorizes Pershing to act as the IRA custodian for Internal Revenue Service purposes. Pershing may resign at any time as the IRA custodian and then you have the right to appoint a successor IRA custodian (Successor).

Stephens’ proxy voting policy is to vote in favor of actions recommended by the issuer’s Board of Directors, unless the FC or Stephens disagrees with the proposed action and elects to vote the shares against the recommendation of the Board of Directors. If there is not a Board of Directors recommendation on a proposed action, then the FC or Stephens will determine whether to vote for, against or abstain. If the client chooses to have their securities custodied away from Stephens, it will be the responsibility of the client to vote or to arrange for the voting of their proxies. Stephens will make available information of the firm’s proxy voting policy and procedures including information regarding how Stephens voted proxies, if requested. In response to any request as to how the client’s proxies were voted, the Chief Compliance Officer – Investment Advisory would provide the information to the client. Procedures Stephens’ procedures to implement the Firm’s proxy voting policy are as follows: a. Voting Procedures • Proxy materials are received on behalf of clients in Stephens’ Reorganization Department (“Reorg. Department”); • A Proxy Voting Notice which includes a link to the proxy voting materials is sent by the Reorg Department via e-mail to the respective advisory area. This proxy Voting Notice will be used to instruct the Reorg Department as to how to vote the shares; • Stephens will vote the proxy through the Reorg Department in accordance with applicable voting guidelines, either by electronically voting or by mailing the proxy in a timely and appropriate manner. • Unless the responsible FC, IAR or Stephens loses confidence in management of the issuer or the client directs the vote, Stephens will vote the shares as recommended by the Board of Directors of the issuer; • If there is not a Board of Directors recommendation on a proposed action, then the FC or IAR will determine whether to vote for, against or abstain. b. Proxy Voting Guidelines • Stephens, if custodied at Pershing, is responsible for voting proxies. • If securities are custodied elsewhere the client or custodian is responsible for voting. • In a Non-Model Sub-Advisory relationship the Non-Model Sub-Advisor is responsible for voting the client’s proxies. c. Conflicts of Interest • On an annual basis Stephens will disclose to affected clients any identified potential material conflicts of interest by providing a list of said conflicts electronically or by mail. • Where Stephens has identified a specific potential material conflict of interest relating to one or more matters to be voted on by shareholders, Stephens: (1) will notify affected clients of the potential conflict of interest, (2) will disclose how the proxy will be voted absent a voting direction from the client, and (3) will give affected clients the opportunity to vote the proxy themselves. • Stephens will maintain a record of the voting resolution of any conflict of interest.

From time to time there may also be a variety of corporate actions or other matters for which shareholder action is required or solicited and with respect to which Stephens may take action that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the client. These actions include, for example and without limitation, responding to tender offers or exchanges, bankruptcy proceedings and proposed class action settlements. However, Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Stephens Advisor, Stephens Retirement Access, Stephens Retirement Solutions and the Stephens Capital Management Non-Discretionary Program Proxy Procedures Stephens will not take any action with respect to the voting of proxies solicited by or with respect to the issuers of securities in which assets of the client may be invested from time to time, except to provide proxy materials to Client. Stephens will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets.

a) Client account assets can be invested in interests of money market funds, mutual funds, other investment companies, privately offered investment funds and other collective vehicles (collectively, “Fund Vehicle”) for which Stephens or its affiliates acts as investment advisor, sponsor, administrator, distributor, selling agent, or in other capacities (“Affiliated Funds”). In addition, client account assets can be invested in interests of Fund Vehicles for which Stephens or its affiliates do not act as investment adviser, sponsor, and administrator or in other capacities. Stephens or its affiliates receive fees for services provided to such Fund Vehicles, which often include (but are not limited to) fees payable under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (“12b-1 fees”) and fees paid to compensate Stephens for providing administrative services, distribution services, shareholder services, investment advisory services or other services to or for the benefit of such Fund Vehicles. Stephens as a dually-registered broker-dealer is paid the retail 12b-1 fees for brokerage mutual fund investments. Where 12b-1 fees are received in advisory accounts, these fees are rebated to the client’s advisory account. b) From time to time, client account assets are invested in transactions that involve or constitute a purchase, sale or other dealings with securities or other instruments for which (i) Stephens, (ii) an affiliate or employee of Stephens, (iii) an entity in which Stephens or an affiliate has a direct or indirect interest, or (iv) another member of a syndicate or other intermediary (where an entity referred to in (i), (ii), or (iii), above is or was a member of the syndicate), has acted, now acts, or in the future may act as an underwriter, syndicate member, market maker, dealer, broker, principal, agent, research analyst or in any other similar capacity, whether the purchase, sale or dealing occurs during the life of the syndicate or after the close of the syndicate. Stephens has an incentive to favor the securities of issuers for which it

provides such services over the securities of issuers for which Stephens does not provide such services. Your FC or IAR also receives more money if you buy these investments. Although underwriting initial public offerings (“IPOs”) on behalf of corporate and other types of issuer clients is a regular part of Stephens’ investment banking business, the frequency, share price, number of shares available, and other characteristics of such offerings vary widely over time. For example, in some years Stephens may not participate as an underwriter, or in only a few, IPOs. For factors that limit IPO product availability to clients through Stephens see Item 5(C) ‘Other types of Fees and Expenses Clients May Pay’ – specifically the ‘IPO Related Conflicts of Interest’ discussions - for more detail. c) Stephens, or any other broker-dealer that is or may become affiliated with Stephens (the “Affiliated Brokers”), is expected to act as broker or dealer to execute transactions on behalf of client’s account. Client will not be charged a separate fee for brokerage services provided to the Account by Affiliated Brokers. d) Stephens or its affiliates sometimes effect transactions for the client’s account with other accounts for which Stephens or an affiliate provides investment advisory services (“Cross Trades”). Such Cross Trades are intended to enable Stephens to purchase or sell a block of securities at a set price and possibly avoid an unfavorable price movement that may be created through entrance into the market with such purchase or sell order. Stephens typically receives compensation from other accounts involved in a Cross Trade. e) Subject to applicable regulations, Stephens or its affiliates sometimes execute “Agency Cross Transactions” for the client’s account. Agency Cross Transactions are transactions where Stephens, or any affiliate of Stephens, acts as broker for both the Client’s account and the other party to the transaction. In such transactions, Stephens, or any of Stephens’s affiliates acting as broker, receives commissions from the other party to such transaction, to the extent permitted by law, in addition to its customary investment management or advisory fee for the client’s account. f) Clients of other divisions of Stephens or clients of other advisory representatives of Stephens or Stephens, its principals, employees, affiliates and their family members, sometimes hold, and sometimes engage in transactions in, securities purchased or sold for the client or about which Stephens gives or has given client advice. The client’s account may purchase as investments securities of companies with which Stephens or its affiliates maintain investment banking relationships or other relationships or securities of companies in which Stephens or its affiliates have an ownership or other investment interest. g) Subject to applicable law, Stephens sometimes pays fees to, and/or shares revenues with, affiliates or non-affiliates in connection with referrals for investment advisory accounts. For additional information regarding referral fees, please see Item 14 above. h) Stephens, or its affiliates, may provide more than one type of service to the client (or a related organization), including (but not limited to), investment management services, investment advisory services, financial advisory services, underwriting services, placement agency services, investment banking services, securities brokerage services, securities custodial services, insurance agency services, insurance brokerage services, administrative services or other services, or any combination of services, all on such terms as may be agreed between Stephens (or its affiliate) and the client (or its related organization). i) Other divisions and other advisory representatives of Stephens perform investment advisory services for clients other than the client and such other divisions or other advisory representatives of Stephens give advice or take action with respect to other clients that is similar to or different from the advice given or action taken for the client’s account, in terms of securities, timing, nature of transactions and other factors. Stephens will, to the extent practicable, attempt in good faith to allocate investment opportunities among its clients, including the client, on a fair and equitable basis. However, other divisions and other advisory representatives of Stephens will not undertake to make any recommendation or communication to client with respect to any security which such other divisions or advisory representatives may purchase or sell (either as principal or for any other client’s account) or recommend to any other client, or in which such other divisions or advisory representatives, or their respective principals, employees, affiliates or their family members, may engage in transactions.

j) Both advisory and brokerage clients of Stephens have the ability to borrow money against the collateral value of their accounts with non-purpose loans arranged through Stephens with third party banks. Stephens receives a fee which is paid by third party banks in an amount which varies but can be up to 1.35% of the monthly outstanding balance of the client’s loan. Part of the administrative fee is passed along to Stephens Financial Consultants, and this can create a conflict of interest. Since Stephens has not compared rates available elsewhere, clients may be able to obtain lower interest rates on their loans through other banks. k) Stephens and Pershing and IntraFi receive fees and benefits for services provided in connection with the Bank Sweep Program. Stephens offers the Bank Sweep Program as a service and is not obligated to offer you this or any sweep product or to make available to you a sweep product that offers a rate of return that is equal to or greater than other comparable products or investments. Stephens has an economic incentive to make available to our clients sweep options that are more profitable to us than other sweep options. Each Bank will pay Stephens a fee equal to a percentage of the average daily deposit balance in your Deposit Accounts at the Bank. Because the Banks pay different amounts, the compensation paid to Stephens will vary from Bank to Bank. Because the interest rates paid to clients are subject to tiers based on the aggregate value of accounts with the client’s Household Balance, Stephens’s compensation rate is higher on client’s cash in lower interest rate tiers and lower on client’s cash balances in higher rate tiers. Stephens may reduce its fee and may vary the amount of the reductions between clients. The interest rate applicable to your Deposit Accounts is determined by the amount of interest participating banks are willing to pay on the aggregate balance of the deposits minus (i) the fees paid to Intrafi Network, LLC, as administrator, (ii) the fees paid to Pershing for its services, and (iii) the fees paid to Stephens. Stephens retains and exercises the right to negotiate its own fee and may reduce or increase its fee. Because an increase in fees to Stephens reduces the effective amount of the interest rate that is ultimately paid to customers, Stephens has a conflict of interest with regard to the Bank Sweep Program. The rate tier applicable to your Deposit Accounts is determined based on your Household Balance as of the first business day following the fifteenth (15th) of the month. Stephens charges advisory accounts an investment advisory fee based on a percentage of client assets. In computing your investment advisory fee, cash balances in the Bank Sweep Program are included in the assets of your account when calculating the investment advisory fee earned by Stephens for management of your account. Therefore, Stephens is paid both its fee from the Banks on the Bank Sweep Program balance in your account, and, in addition, Stephens earns an investment advisory fee for your total balances in your account, including your balance in the Bank Sweep Program. This creates a conflict of interest, as Stephens earns more from Bank Sweep Program balances in investment advisory accounts than it would if such balances were held outside of the Bank Sweep Program or outside of the investment advisory account entirely, creating an economic incentive for Stephens to retain advisory assets in cash in the Bank Sweep Program. Your Financial Consultant does not receive a portion of the fee paid to Stephens by the Banks. l) The Stephens Investment Banking department may introduce its clients, prospective clients, or affiliates thereof, to Stephens Financial Consultants. This introduction is done in Stephens’s capacity as a registered broker-dealer, and not as a registered investment adviser. If the introduction results in a new account relationship, then for a period of years a portion of the net revenue from such account is allocated to the Investment Banking department as a referral fee. Such revenue is considered, along with other factors, in the determination of compensation for the introducing investment banker(s). This arrangement is disclosed to the client and does not result in any additional fees or charges to the client. For more detailed information regarding PCG programs, SCM programs, SMID, SC, and the SFIM Program, please see the ADV Part 2A Appendix 1 for each program. The Part 2A for the Equity Research Advisory Program is also available.

Who to Contact We are pleased to have an opportunity to serve as your investment adviser. If you have any questions about the information contained in this brochure or about any aspect of the services we provide, please do not hesitate to call Stephens at (877-891-0095). Clients often receive this information by electronic delivery. The Stephens ADV and additional brochures are now available at www.stephens.com/investmentdisclosures/. To access your FC or IAR’s SEC Advisor Biography, go to www.stephens.com , use the search bar in the top right corner of the home page and search by your FC or IAR’s name. SEC Advisor Biographies are also available in the "Our People" section and are there for your review.