Overview

Assets Under Management: $900 million
Headquarters: WAYNE, PA
High-Net-Worth Clients: 225
Average Client Assets: $0.4 million

Frequently Asked Questions

AXIOM ASSET MANAGEMENT is a fee-based investment advisor. Detailed fee schedules are available in their SEC Form ADV filing.

Yes. As an SEC-registered investment advisor (CRD #145186), AXIOM ASSET MANAGEMENT is subject to fiduciary duty under federal law.

AXIOM ASSET MANAGEMENT is headquartered in WAYNE, PA.

AXIOM ASSET MANAGEMENT serves 225 high-net-worth clients according to their SEC filing dated March 30, 2026. View client details ↓

According to their SEC Form ADV, AXIOM ASSET MANAGEMENT offers financial planning, portfolio management for individuals, pension consulting services, and selection of other advisors. View all service details ↓

AXIOM ASSET MANAGEMENT manages $900 million in client assets according to their SEC filing dated March 30, 2026.

According to their SEC Form ADV, AXIOM ASSET MANAGEMENT serves high-net-worth individuals and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Clients

Number of High-Net-Worth Clients: 225
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 10.28%
Average Client Assets: $0.4 million
Total Client Accounts: 614
Discretionary Accounts: 323
Non-Discretionary Accounts: 291

Regulatory Filings

CRD Number: 145186
Filing ID: 2053486
Last Filing Date: 2026-03-30 18:05:53

Form ADV Documents

Primary Brochure: AXIOM ASSET MANAGEMENT FORM ADV PART 2A MARCH 31, 2026 (2026-03-30)

View Document Text
550 E Swedesford Road, Suite 110 Wayne PA 19087 610-688-0050 877 294-6699 (toll-free) www.axiomasset.com Form ADV Part 2A March 31, 2026 This brochure provides information about the qualifications and business practices of WealthTrust Axiom, LLC (“Axiom Asset Management” - also referred to throughout this document as “Axiom”). If you have any questions about the contents of this brochure, please contact David Webster at 610-688-0050. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Additional details about Axiom Asset Management are also available on the SEC’s website at www.adviserinfo.sec.gov. Axiom Asset Management is a registered investment adviser with the SEC. The registration of an Investment Adviser does not imply any level of skill or training. Our oral and written communications will provide you with the information about us you need to fully understand Axiom Asset Management and its investment advisory role in managing our client’s assets. Axiom Asset Management 1 March 2026 Item 2: Material Changes This section only discusses any material changes to our Form ADV Part 2A disclosure document from the date of our last 2024 annual update (Sent March 2025) to this brochure, January 1, 2025, through the date of our 2025 yearly update, March 31, 2026. During this period, Jake Cohen joined Axiom Asset Management in September 2025 as Vice -President and Investment Adviser. Below are more details about Jake’s education and work history under Form ADV Part 2B - Item 2 -Educational Background and Business Experience. Item 3: Table of Contents Item 2: Material Changes ............................................................................................................................................................................. 2 Item 3: Table of Contents ........................................................................................................................................................................... 2 Item 4: Advisory Business ........................................................................................................................................................................... 3 Item 5: Fees and Compensation ................................................................................................................................................................. 5 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................ 7 Item 7: Types of Clients ............................................................................................................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ............................................................................................... 7 Item 9: Disciplinary Information ............................................................................................................................................................... 9 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................. 10 Item 11: Code of Ethics, Participation in Transactions, Personal Trading ........................................................................................... 11 Item 12: Brokerage Practices..................................................................................................................................................................... 12 Item 13: Review of Accounts .................................................................................................................................................................... 13 Item 14: Client Referrals and Other Compensation ............................................................................................................................. 13 Item 15: Custody ......................................................................................................................................................................................... 13 Item 16: Investment Discretion................................................................................................................................................................ 14 Item 17: Voting Client Securities .............................................................................................................................................................. 14 Item 18: Financial Information................................................................................................................................................................. 14 Axiom Asset Management 2 March 2026 Item 4: Advisory Business History Axiom Asset Management (“Axiom”) was formed in 2003 by Michael C. Heaberg, Chief Executive Officer; Robert Loreaux, Executive Vice President; and Albert Matt, President. In 2007, WealthTrust LLC bought a financial stake in Axiom Asset Management. WealthTrust LLC was a Scottsdale, Arizona- based holding company. On May 31, 2017, WealthTrust LLC sold its financial stake to Hightower Holding LLC. Hightower is a strategic financial partner for U.S.-based investment management firms that provides comprehensive wealth management services to individuals and families. Hightower strengthens each affiliate by providing support in compliance and back-office services. Axiom's principal owners are Hightower Advisors, LLC, Michael Heaberg, Craig Rose, and David Webster. Unchanged throughout our history, Axiom was formed to provide investors with a distinctive investment approach. In our view, most investment firms are plagued by competing agendas that sap energy and creativity that should be directed toward solving problems and building wealth for clients. Axiom is structured to allow a single-minded approach to our client’s success. Business WealthTrust Axiom, also known as Axiom Asset Management, has the principal business of furnishing “investment advisory services” to clients. Axiom is structured to allow a single-minded focus on our clients’ success. This activity includes providing continuous advice concerning the investment of monies consistent with each client's circumstances, preferences, and objectives. The investment management process includes an assessment of each client’s objectives, needs, restrictions, and portfolio holdings. We attempt to structure each client’s investment portfolio in the context of these considerations. Axiom Asset Management’s investment philosophy: • Customized and Personal—Our relationships begin with profiling each client’s investment attitudes and objectives. We build and manage a family’s household of assets according to their unique balance of growth, income, and tax objectives. The client may restrict specific investments or strategies at their preference. Axiom’s clients have direct access to our experienced portfolio managers for ongoing discussions of their changing needs and portfolio allocations. • Value, Growth, Contrarian, and Opportunistic - We seek to find attractively valued investments and minimize risk in our client’s portfolios via asset allocation and security selection through research and analysis. Opportunistically, Axiom will also invest in “out of favor” companies and/or industry sectors and use cash as a hedge when warranted. Focusing on company and industry fundamentals, we believe this approach has been successful in meeting our client’s return expectations in rising markets while providing downside protection in a declining market environment. • Experienced Personnel—In our view, there is no substitute for investment experience. Our investment and operational staff average over 20 years of working with individuals and families to achieve investment success. Axiom’s investment advisory services are generally executed through discretionary management of investment portfolios in accordance with the client's investment objective(s) and subject to any investment restrictions imposed or added by the client and applicable regulatory restrictions. Clients may also engage our investment advisory services on a non-discretionary basis at their request. However, this may impact the level of service we can provide you. We make investment and reinvestment decisions on behalf of the client using equity, fixed income (from short-term to long- term), and cash instruments. If mutual funds are used, Axiom does not receive fee compensation through front-end loads or 12b-1 fees for RIA fee business. Where appropriate for a client’s investment objectives, Axiom may engage a third-party investment manager on a sub-advisory basis to provide investment management services in asset classes such as fixed income. These third-party investment management services are subject to the firm's review. Axiom Asset Management 3 March 2026 Financial Planning: Axiom may provide consulting services on investment-related matters for which we may or may not receive additional compensation. Such planning may or may not include: Insurance and Risk Management Planning • Retirement Planning • Education Planning • • Asset Allocation and Portfolio Analysis • Cash Flow Analysis • Estate Planning in coordination with a client’s attorney and/or CPA. Axiom does not provide tax or legal advice or prepare such related documents. Axiom may provide employer-sponsored retirement consulting services to employee benefit plans and their fiduciaries by providing education and an analysis of the needs of the plan, including the type of securities or investments that may be included as investment options for the plan participants. Axiom will also assist in performance monitoring and general plan communication. Services generally include client assistance with developing long-term financial objectives, determining risk tolerances, and educational advice in selecting asset allocations. Axiom does not act as a Plan Sponsor or Administrator of retirement plans. Axiom’s role is as an advisor to the plan trustees or Plan Sponsor. The dollar amount of client assets we manage on a discretionary basis as of: 12/31/2025 = $697,501,376 The dollar amount of client assets we manage on a non-discretionary basis as of 12/31/2025 = $202,054,578 Axiom Asset Management 4 March 2026 Item 5: Fees and Compensation Axiom is only compensated for its investment advisory services by charging the client a management fee based on the market value of the client’s assets under our management and based upon the fee schedule set forth below or agreed upon. Should a Sub-Advisor be used, their fee is incorporated into the Axiom Asset Management fee. Axiom will pay the Sub-Advisor on your behalf from the fees charged to the client’s account using the fee schedule described below. If the client decides to engage Axiom to provide investment advisory services (discretionary or non-discretionary), this will be fee-only. If engaged, Axiom shall charge an annual fee based upon a percentage of the market value of the assets managed by Axiom Asset Management. Axiom’s annual fee shall be charged quarterly, in arrears, based on the market value of the assets on the last business day of the previous quarter. The investment vehicles Axiom uses are traded on public exchanges with daily valuations. The portfolio valuations are retrieved from our custodians (Fidelity Investments or American Funds for 529 plans, if applicable). The annual fee shall vary depending upon the market value of the assets under management and the type of investment management services to be rendered, as follows: Fee Schedule Value of Household Portfolio Annual Fee Equity Portfolios Assets below $250,000 Up to 1.25% Assets below $2,500,000 Up to 1% Assets above $2,500,000 Negotiable Fixed Income Portfolios Assets over $100,000 Up to .70% The first quarter’s fees shall be calculated pro rata for the initial quarter of investment advisory services. The Management Agreement (Agreement) between Axiom Asset Management and the client will continue in effect until terminated by either party according to the terms of the Agreement. Axiom’s annual fee shall be prorated through the termination date and charged to the client immediately. Axiom does not impose an account minimum for starting or maintaining an account. Axiom’, in its sole discretion, may waive, negotiate, or charge a reduced management fee based upon specific criteria (i.e., anticipated future earning capacity, anticipated future additional assets, the dollar amount of assets to be managed, related accounts, account composition, pre-existing client, pro bono activities, high cash balances during the building of new portfolios, etc.) for clients. Employees may also receive services for a reduced or no fee. Axiom has always considered the accuracy of client fees extremely important. The client fee amount is calculated by multiplying the agreed-upon percentage of the closing quarter-end portfolio value. We utilize an eight-step procedure to calculate the fees every quarter. This includes multiple levels of review by various personnel, including compliance, operations, and investment managers. Axiom Asset Management 5 March 2026 Highlights of 8-Step Fee Calculation 1. Receive quarter-end values from Fidelity Investments or American Funds (529 plans) 2. Multiply agreed upon annual fee amount percent and divide by 4 (quarter) 3. Cross-check for any pro-rata billings and adjustments 4. Advisors will review households for accuracy 5. Spot-check random accounts with hand calculation 6. Confirm available cash balance for deductions or send out invoices for accounts paying by check 7. Outside manager fees included if applicable 8. Deduct the quarterly fee from the Fidelity account or send an invoice to those paying by check. Other Costs: The above-referenced fee schedule does not include custody fees or other costs or charges associated with securities transactions with or through a broker-dealer, including dealer mark-ups or mark-downs in principal transactions, stock exchange fees (domestic or international for both investment advisor or brokerage), transfer taxes, or other charges mandated by law, all of which will be separately charged to the client by our custodian. Please refer to the Item 12 Brokerage Practices section for more information on our brokerage practices. Axiom Asset Management’s investment management fee generally includes any investment-related consulting services. However, Axiom may charge a separate fee for investment-related consulting services for non-investment management clients and investment management clients who require a disproportionate amount of consulting services. The fees shall be agreed upon before rendering the consulting services in these limited circumstances. Clients should understand that, in addition to the annual fee charged by Axiom, any mutual funds, including exchange-traded funds, in which assets are invested will incur separate investment management fees and other operating expenses (as described in each fund’s prospectus, typically referred to as “management expense ratio”) for which the client will incur a proportionate share. Agreement Terms: Axiom Asset Management’s Agreement authorizes Axiom, through our custodian, to debit the client’s account for the amount of Axiom Asset Management’s fee and to directly remit that management fee to Axiom in accordance with applicable custody rules. However, as an accommodation for clients who wish to pay their fee from personal funds, we will invoice them so they may send a check. You will receive a periodic statement from your custodian, including the amount of the Management Fee sent to us. It is essential that you confirm the accuracy of our Management Fee calculation upon receipt of your custodian’s statement. Axiom’s clients are advised to promptly notify us if there are ever any changes in their financial situation or investment objectives or if they wish to impose reasonable restrictions upon our management services. To more thoroughly assist clients with managing their portfolios, it would be prudent for the client to share their total financial picture and detail their objectives for each portfolio should the individual parts have objectives and constraints that may differ from the whole. Axiom seeks to manage based on the complete financial list of assets, familial circumstances, and personal goals. Axiom Asset Management 6 March 2026 Item 6: Performance-Based Fees and Side-By-Side Management Axiom does not accept performance-based fees of any kind. Item 7: Types of Clients Axiom provides portfolio management services to individuals, high-net-worth individuals, corporate pension and retirement plans, trusts, estates, corporations, and other business entities other than those listed above. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Our primary analysis methods include fundamental, technical, cyclical, and quantitative analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and the analysis of management and competitive advantages. This information is used to forecast trends in areas such as earnings per share and revenue growth. There is no guarantee that past financial trends will continue in the future. Technical analysis involves analyzing past market data, primarily price and volume, for trends and market accumulation/distribution, primarily by large financial institutions. Past or present trends may or may not persist. Cyclical analysis involves analyzing business cycles to find favorable conditions for buying and/or selling a security. Cyclical stock’s performance and profitability are generally highly sensitive to economic cycles or seasonality. Some examples of cyclical industries are consumer discretionary, travel and leisure, construction and real estate, and manufacturing and industrials. There are times when cycles may be repeated. Quantitative analysis involves mathematical and statistical analysis, looking for correlations to the market or peers, or valuation analysis using ratios based on historical ratios or comparisons to peers. The effectiveness of these measures may change over time as correlations change or are impacted by external market events. Axiom Asset Management 7 March 2026 Market Risks Portfolios are exposed to Market Risk. The price of an equity security, bond, exchange-traded fund, or mutual fund may drop due to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s underlying circumstances. Geopolitical Risk—This involves risk related to political and social events such as a terrorist attack, war, pandemic, or elections that could impact financial markets. Such events, whether actual or anticipated, can affect investor attitudes and outlooks, resulting in system-wide fluctuations in stock prices. Country Risk — The risk of events in the country where an investment is made could impact general market sentiment. This can occur when a country overhauls its government, changes policies, or experiences social unrest or war. Currency Risk — Any change in the exchange rate between two relevant currencies can increase or reduce your investment return. Interest Rate Risk — This is the risk that the value of a security can fluctuate due to changes in interest rates. Interest rate changes directly affect bonds — as interest rates rise, the price of a previously issued bond falls; conversely, when interest rates fall, bond prices increase. The rationale is that a bond promises a future stream of payments; an investor will offer less for a bond that pays out at a rate lower than the rates provided in the current market. The opposite also is true. Interest rates can also impact the cost of borrowing, which can help or hinder growth opportunities within companies. Higher rates can also increase equities’ competition with bonds. Inflation Risk (or Purchasing Power Risk) — Inflation risks money's purchasing power and investment values. When the general price level of goods and services increases, money buys less, reducing purchasing power. Inflation also tends to lead to higher interest rates, negatively impacting economic growth and corporate profits. During periods of low inflation, new bonds may offer lower interest rates, causing investors to turn to higher-risk bonds with higher rates. However, as inflation rises, so do interest rates, which can slow economic growth and reduce corporate profits. For example, in the 1970s, the United States experienced a period of high inflation, which led to a sharp increase in interest rates, causing a recession in the early 1980s. Liquidity Risk — The risk that you won't be able to buy or sell investments quickly for a price that tracks the true underlying value of the asset or that you won't be able to sell the investment at all because of a lack of buyers in the market. Legal Remedies Risk — If you have a problem with your investment, you may not have adequate legal means to resolve it. When investing in an international market, you often have to rely on the legal measures available in that country to resolve problems. These measures may differ from those you may be used to in the US. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Portfolio Management Process Axiom conducts its portfolio management process based on the completed "Client Household Profile," which is sent to clients annually. The profiles are sent out for client review for changes or confirmation. If there are changes, the client will send back the marked-up changes. If there are no changes, the client can send back the form noted as no change or exercise negative consent. This means that if Axiom Asset Management is not notified or the profile is not sent back, it is agreed as current and accurate until further notice. These profiles consist of annual household income, tax bracket, total net worth, investment experience, time horizon, income needs and sources, risk attitude, and financial objectives. These profiles and general conversations throughout the year help the advisors build and adjust portfolios based on the factors listed above. Our client portfolios factor in the personal profiles, market conditions, liquidity of individually traded securities, client cash flow needs, and tax implications. Tax implications are based on one’s tax bracket and could consist of one or more of the following: balancing the withdrawal of funds used from retirement accounts taxed as ordinary income tax rates as opposed to Axiom Asset Management 8 March 2026 capital gains or the taxation of bonds (corporate, municipal, or US Treasurys, or certificates of deposit) at the Federal, State & Local levels. For those clients to whom Axiom provides investment management services with a Sub-Advisor, account reviews are conducted annually according to a client’s investment profile. Selection of Sub-Advisers When using a sub-advisor, Axiom will gather information about the client’s financial situation, investment objectives, and risk tolerance; we will make recommendations regarding the suitability of the investment style of a particular third-party investment adviser, or more than one and, if acceptable, the client will then engage the services of the third-party investment adviser directly. Following the selection of the particular third-party investment adviser, we will monitor their performance so that their style and performance remain aligned with the investment goals and objectives of the client. Retirement Rollovers–No Obligation Clients or future clients have several options when managing their previous 401(K) plans, IRAs, or other qualified accounts. If permitted, they may leave their 401(K) plans with a previous employer, roll it over to the new employer, or roll it over into a new or existing IRA account. There may or may not be advantages to an employer's plan. Below are possible situations to consider: • Whether lower investment costs (e.g., whether there is advantageous share class, institutional pricing at either current provider or Fidelity Investments) • Whether the employer covers administrative fees • Whether greater creditor protection • Whether Age 55 exception to early distribution policy if the client is under 59 1/2 • Delayed RMD availability in the plan if the client is employed after 73 • Loan availability • Brokerage window • Company stock tax treatment Service/functionality advantages of an IRA to take into consideration: • Wider range of investment options • Availability of discretionary management • Asset allocation advice • Retirement income and holistic financial planning services • Distribution payout options (for self or beneficiary) • Beneficiary designation options Additional considerations, if applicable: • Fees and expenses of an employer's plan versus an IRA • Suitability ‐ must consider the customer's investment profile, including the customer's age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs, risk tolerance, and any other disclosed information Item 9: Disciplinary Information As noted on Form ADV Part 1, Item 11, two of Hightower’s advisory affiliates, under common ownership, reported disclosures in 2024. AXIOM does not have material relationships with Hightower Affiliates. AXIOM and its employees do Axiom Asset Management 9 March 2026 not have any legal or disciplinary events. You should visit investor.gov/CRS for a free and simple search tool to research our firm and financial advisors. Item 10: Other Financial Industry Activities and Affiliations Insurance Affiliations Our employee, David Webster, is independently licensed to sell insurance products to clients of Axiom Asset Management. When acting as an insurance agent, Axiom Asset Management will receive a fee for selling insurance products and, as such, may be incentivized to recommend such insurance products based on their receipt of remuneration rather than the client’s best interest. However, Axiom Asset Management believes any such conflict of interest with our advisory clients is resolved by his fiduciary obligation to act in the best interest of our clients and by disclosure of this conflict. Affiliated Firms Axiom Asset Management is affiliated through common ownership with Hightower Advisors, LLC (“Hightower”), an investment adviser registered with the Securities and Exchange Commission, and Hightower Securities, LLC, a broker-dealer registered with the Securities and Exchange Commission. Hightower Securities, LLC is also a licensed general insurance broker. It is a member of FINRA and SIPC and is registered in various states as required. Hightower primarily provides Axiom with back-office support such as payroll and benefits management and, in some cases, leverages their volume discounts with vendors. Through Hightower’s partial ownership and services provided, Hightower Advisors, LLC receives compensation as part of its ownership stake. The following firms are also affiliated with Axiom Asset Management based on a shared ownership interest through our majority owner, Hightower Advisors, LLC: Entity Name CRD SEC # Delta Asset Management 113688 801-60492 Duncker Streett 110828 801-58224 GMS Surgent Advisors, LLC not registered as an investment adviser Grant Tanai Barash & Altman LLC 319128 801-127101 Harvey Investment Company 110482 801-58031 Hightower Advisors 145323 801-69625 Hightower Securities 116681 801-53560 Hightower Trust Services LTA CIK Number = 1090413 Kanawha Capital Management 118458 801-60800 Madison Avenue Financial Solutions, LLC 307461 801-118936 NEPC, LLC 110562 801-37227 Hightower Trust Company of Illinois, LLC 145323 801-69625 However, Axiom does not have a relationship or arrangement with any affiliated firms that are material to our business or clients. Axiom Asset Management 10 March 2026 Item 11: Code of Ethics, Participation in Transactions, Personal Trading Axiom has adopted a written Code of Ethics. All of our employees are obligated to comply with certain trading restrictions in their personal accounts to avoid conflicts of interest with transactions conducted in client accounts. Axiom and its employees are subject to the following specific fiduciary obligations when dealing with clients: • The duty to have a reasonable, independent basis for the investment advice provided • The duty to obtain the best execution for a client’s transactions where Axiom is in a position to direct brokerage transactions for the client • The duty to ensure that investment advice is suitable for meeting the client’s objectives, needs, and circumstances • A duty to be loyal to clients Our employees may buy or sell the same securities that we recommend to our clients or that we purchase or sell at the request of our clients. This presents a conflict of interest between our employees’ own financial interests and the best interests of our clients. We have addressed this conflict of interest by imposing trading restrictions under Axiom’s Code of Ethics, which include restrictions on our employees’ personal trading based upon investment activity occurring in, or being contemplated for, our clients’ accounts. Axiom employees are generally obligated to buy or sell securities in their personal accounts simultaneously with, or after completion, the purchase or sale of the same security in our clients’ accounts, subject to certain exceptions. Many trades are implemented as a block, which averages the price paid across all allocations. The Code of Ethics also requires that all of Axiom’s personnel (called “Supervised Persons”) report their personal securities holdings and transactions to the Chief Compliance Officer and obtain pre-approval of specific investments such as initial public and limited offerings. Axiom has adopted the following principles governing personal investment activities by supervised persons: • Axiom’s policy and practice do not engage in principal transactions. • Clients may contact Axiom to request a copy of its Code of Ethics. • Axiom’s written Code of Ethics covers the following areas: Interested Transactions o Standards of Business Conduct o o Prohibition Against Insider Trading o Personal Securities Transactions o Gifts and Entertainment o Protecting the Confidentiality of Client Information o Compliance Procedures o Certification o Record retention and security o Reporting Violations and Sanctions o Use of block trades to manage best execution Axiom Asset Management 11 March 2026 Item 12: Brokerage Practices Axiom considers the following factors in selecting or recommending brokerage firms for our clients’ transactions and in determining the reasonableness of the compensation or other remuneration paid to the brokerage firms: • Quality of Support Services and Technology Provided • Trade Implementation Costs • Value of Various Information Provided • Market Liquidity • Confidentiality of Trading Intentions • Client Oriented Culture • Financial Stability • Ability to Execute Difficult Trades We periodically review our brokerage practices and the reasonableness of compensation and other remuneration paid to brokerage firms and monitor our efforts to seek the best execution of client transactions. Fidelity Investments enables Axiom to obtain many mutual funds without transaction charges and other securities at zero to nominal transaction charges. The commissions and transaction fees charged by Fidelity Investments may be higher or lower than those charged by other broker-dealers. Software and Support Provided by Fidelity Investments Axiom has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity or Fidelity Investments") through which Fidelity Investments provides Axiom with "institutional platform services." The institutional platform services include, among others, brokerage, custody, and other related services. Fidelity's institutional platform services assist us in managing and administering our clients' accounts and include software and other technology through Fidelity.com that (i) provide access to client account data (such as trade confirmations and account statements), (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing, and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping, and client reporting. Fidelity Investments offers other services to assist Axiom in managing and developing its advisory practice. Such services include, but are not limited to, third-party research and publications, access to educational conferences, roundtables, and webinars, practice management resources, and access to consultants and other third-party service providers who provide a wide array of business-related services and technology with whom we may contract directly. Axiom is independently operated, owned, and not affiliated with Fidelity Investments. Fidelity generally does not charge its advisor clients separately for custody services but is compensated by account holders through, at times, commissions and other transaction-related or asset-based fees for securities trades that are executed through Fidelity or that settle into Fidelity accounts (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions – i.e., international). Fidelity provides access to many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Fidelity provides Axiom with certain brokerage and research products and services that qualify as "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934 ("Exchange Act"). Block Orders Axiom may group orders for the same security across multiple client accounts. This is what is known as a “block transaction.” This process creates trading efficiencies and can improve price execution. The block transaction may be executed at various prices throughout the trading day but is averaged as one price. Personal transactions of our employees are included in such block transactions when both client and Axiom employees are transacting in the same security on the same day. This helps to ensure the best execution for the client. Axiom Asset Management 12 March 2026 Cross Trades Axiom does not execute them. Directed Brokerage Axiom does not permit clients to direct brokerage transactions to a specific brokerage firm. Trade Errors As fiduciaries, investment advisers must put their client’s interests ahead of their own. This duty is especially evident when correcting errors when placing trades for client accounts. 1. Advisers know the following restrictions on trading errors: When an adviser makes and corrects a mistake, the client must not be disadvantaged; the client must be "made whole." 2. Advisers must review their supervisory procedures to ensure that procedures for correcting trading errors are in place. In addition, trading practices should periodically be reviewed to determine that the firm's procedures are being followed. To this end, the Chief Compliance Officer (CCO) maintains a file documenting the correction of trading errors. The creation of such a file allows the CCO to periodically review all trading errors for a particular period to ensure they were handled quickly and correctly. The suitability of a trade error also factors into its resolution. Unsuitable trades must always be resolved in the client's favor, with the client being made whole and errors being determined on a case-by-case basis. Errors may also include compensating a client for any loss on a mistake. Neither the client nor Axiom will benefit from the error. Any gains are donated to charity, and Axiom absorbs the losses. Item 13: Review of Accounts For clients receiving investment management services from Axiom, account reviews are conducted by the investment adviser (account manager) responsible for managing that particular client’s accounts. As an ongoing process, Axiom actively engages with the accounts through general trading activities and other miscellaneous actions, such as phone calls, mailings, and notifications from the custodian or those required to meet obligations compliance. Concerning trading activity, Axiom mainly uses individual securities in its portfolios. This strategy may necessitate more frequent reviews of clients’ portfolios due to the heightened trading activity. Axiom does not, as a general policy, provide our clients with regular or periodic written reports regarding their accounts. However, upon request, our clients will receive a written report that may include relevant account and market-related information, such as an inventory of account holdings. Much of this account information is expected to be supplied by the custodian (Fidelity Investments) (see information under Item: 15 Custody for further details). All investment advisory clients are encouraged to regularly inform Axiom of changes to their needs, goals, and objectives. Item 14: Client Referrals and Other Compensation Axiom does not compensate or receive compensation for client referrals, attorneys, accountants, business valuation companies, etc. For more information on other economic benefits we receive from a non-client, please refer to the section on Brokerage Practices contained herein. Item 15: Custody All financial assets, including stocks, bonds, and cash, are held by a custodian. Fidelity Investments, a qualified custodian, is our primary custodian; others are used on a situation-specific basis. In addition to any account information you may receive from us as described above in the section on Review of Accounts, you should expect to receive account statements directly from Axiom Asset Management 13 March 2026 your custodian on at least a quarterly basis. However, you may receive them every month. You should carefully review these statements for any discrepancies. It would be best to remember that the statements you receive from your custodian are the official record of your accounts and assets for tax purposes. Axiom Asset Management’s Agreement authorizes Axiom, through our custodian Fidelity Investments, to debit the client’s account for the amount equal to Axiom Asset Management’s fee agreement with the client and to directly remit that management fee to Axiom in accordance with applicable custody rules. Item 16: Investment Discretion Axiom offers investment advisory accounts on either a discretionary or non-discretionary basis. Our management and financial planning of your account is guided by your objectives (e.g., maximum capital appreciation, growth, income, or growth and income) and tax considerations. For our clients who provide us with discretionary authority, we buy and sell securities and continuously monitor them on your behalf. For non-discretionary clients, you make the ultimate decision regarding the purchase or sale of investments. Our investment advice will cover a limited selection of investments, i.e., no direct real estate. Other firms could advise on a broader range of choices, some of which might have lower costs. We will accept discretionary investment authority over your assets if you agree to such an arrangement, as stated in Item 4, Advisory Business. This is typically accomplished by executing a limited trading authority in your client agreement with us. You can limit the extent of discretionary investment authority to be granted to us. However, this may impact the level of service we can provide you. For further details about our services, please see www.axiomasset.com. Item 17: Voting Client Securities Axiom does not accept the authority to vote for client securities on behalf of its clients and does not provide advice on how to vote for them. Clients will receive proxies directly from the security issuer or our custodian. We will not take any action or advise on investments in your accounts that become subject to class actions, related litigation, or other matters such as mergers, acquisitions, tender offers, bankruptcy proceedings, or other similar events. However, we may provide you limited assistance upon request on an informal basis. Item 18: Financial Information Axiom has no financial commitment that will impair its ability to meet client contractual and fiduciary obligations and has not been the subject of a bankruptcy proceeding. Axiom Asset Management 14 March 2026 Axiom Asset Management 550 E Swedesford Road, Suite 110 Wayne PA 19087 610 688-0050 877 294-6699 (toll-free) www.axiomasset.com Form ADV Part 2B March 31, 6 This information about the supervised persons listed below supplements our ADV Part 2A, the Axiom Asset Management “Firm Brochure.” Please contact David Webster at 610-688-0050 if you did not receive Axiom Asset Management’s firm brochure or have any questions about the supplement's contents. “Supervised Persons” within Axiom Asset Management covered by this brochure supplement are identified as persons who (i) formulate investment advice for clients and have direct client contact or (ii) make discretionary investment decisions for clients’ assets, even if the supervised person has no direct client contact. Karin Braack-Cannon 610-688-0085 Vice-President Jake Cohen 610-688-0025 Vice President Michael C. Heaberg 610-688-0053 Managing Director, Chief Executive Officer Craig Rose 610-688-0054 Managing Director David Webster 610-688-0089 Managing Director, Chief Compliance Officer Additional information about each supervised person is available on the SEC’s website at www.adviserinfo.sec.gov. Axiom Asset Management 15 March 2026 Form ADV Part 2B - Item 2 -Educational Background and Business Experience Supervised person: Karin A. Braack-Cannon, Post-Secondary Education: Born 1979 The Catholic University of America – 2001, BA Recent Business Background: WealthTrust Axiom, LLC, Vice-President, 3/2024 – Present DuPont Capital Management, 5/2013 – 9/2023 Ashford Capital Management, 3/2002 – 4/2013 Form ADV Part 2B - Item 3 - Disciplinary Information There are no legal or disciplinary actions to report for Karin Braack-Cannon. Form ADV Part 2B - Item 4 - Other Business Activities Karin A. Braack-Cannon is currently not actively engaged in any other investment-related business. Form ADV Part 2B - Item 5 - Additional Compensation Karin A. Braack-Cannon receives compensation for providing advisory services solely from her responsibilities at Axiom Asset Management. She gets no additional economic benefit from third parties that offer advisory services. Form ADV Part 2B - Item 6 - Supervision Our firm has written supervisory procedures, including annual account reviews by the firm’s supervised persons. These procedures are reasonably designed to detect and prevent violations of the securities laws, rules, and regulations and to monitor the advice provided to the firm’s clients. Karin reports to Michael C. Heaberg. He can be contacted at the phone number listed at the beginning of Form ADV Part 2B. Supervised person: Jake Cohen, Post-Secondary Education: Born 1990 Davidson College – 2013, BA Economics ISDE Barcelona - 2024 – Masters Global Sports Management Recent Background Professional Basketball & Union Representative (2013-2025): WealthTrust Axiom, LLC, Vice-President, 9/2025 – Present Professional Basketball Player: Maccabi Tel Aviv (Israel) – 2013-2015, 2017-2020, 2021-2025 Aris Thessaloniki (Greece) - 2015-2016 Maccabi Ashdod (Israel) - 2016-2017 Obradoiro (Spain) - 2020-2021 EuroLeague Players Association (ELPA) Team Representative – 2018-2025 ELPA Vice-President – 2019-2020 Axiom Asset Management 16 March 2026 Form ADV Part 2B - Item 3 - Disciplinary Information There are no legal or disciplinary actions to report for Jake Cohen. Form ADV Part 2B - Item 4 - Other Business Activities Jake Cohen is currently not actively engaged in any other investment-related business. Form ADV Part 2B - Item 5 - Additional Compensation Jake Cohen receives compensation for providing advisory services solely from his responsibilities at Axiom Asset Management. He gets no additional economic benefit from third parties that offer advisory services. Form ADV Part 2B - Item 6 - Supervision Our firm has written supervisory procedures, including annual account reviews by the firm’s supervised persons. These procedures are reasonably designed to detect and prevent violations of the securities laws, rules, and regulations and to monitor the advice provided to the firm’s clients. Jake reports to Michael C. Heaberg. He can be contacted at the phone number listed at the beginning of Form ADV Part 2B. Form ADV Part 2B - Item 2 -Educational Background and Business Experience Supervised person: MICHAEL C. HEABERG Post-Secondary Education: Born 1958 Vanderbilt University – 1980, BS Recent Business Background: WealthTrust Axiom, LLC, CEO, 11/2007 - Present Purshe Kaplan Sterling Invest, Registered Representative, 06/2003 – 12/2024 Axiom Asset Management, LLC, Managing Director, 06/2003 – 10/2007 PaineWebber Incorporated/UBS, Vice President, 05/1995 – 06/2003 Form ADV Part 2B - Item 3 - Disciplinary Information There are no legal or disciplinary actions to report for Michael C. Heaberg. Form ADV Part 2B - Item 5 - Additional Compensation Michael C. Heaberg receives compensation for providing advisory services solely from his responsibilities at Axiom Asset Management. He does not receive any additional economic benefit from third parties for providing advisory services other than those described above. Axiom Asset Management 17 March 2026 Form ADV Part 2B - Item 6 - Supervision Our firm has in place written supervisory procedures, which include annual account reviews by the firm’s supervised persons that are reasonably designed to detect and prevent violations of the securities laws, rules, and regulations and to monitor the advice being provided to the firm’s clients. Michael is a Principal Owner. Each principal of the firm is subject to the supervision of, and is mutually accountable to, all other principals. Form ADV Part 2B - Item 2 -Educational Background and Business Experience Born 1974 West Virginia University - 1996, BA Supervised person: CRAIG A ROSE Post-Secondary Education Recent Business Background WealthTrust Axiom, LLC, Investment Adviser Representative, 11/2007 – Present Axiom Asset Management, LLC, Investment Adviser Representative, 06/2003 – 10/2007 Purshe Kaplan Sterling Invest, Registered Representative, 06/2003 – 10/2021 PaineWebber Incorporated/UBS, Financial Advisor, 08/2000 – 06/2003 Olde Discount Corp, Registered Representative 8/1996 - 8/2000 Form ADV Part 2B - Item 3 - Disciplinary Information There are no legal or disciplinary actions to report for Craig A Rose. Form ADV Part 2B - Item 4 - Additional Compensation Craig Rose receives compensation for providing advisory services solely from his responsibilities at Axiom Asset Management. He does not receive any additional economic benefit from third parties for providing advisory services other than those described above. Form ADV Part 2B - Item 5 - Supervision Our firm has written supervisory procedures, including annual account reviews by the firm’s supervised persons. These procedures are reasonably designed to detect and prevent violations of the securities laws, rules, and regulations and to monitor the advice provided to the firm’s clients. Craig is a Principal Owner. Each principal of the firm is subject to the supervision of, and is mutually accountable to, all other principals. Form ADV Part 2B - Item 2 -Educational Background and Business Experience Supervised person: DAVID WEBSTER Post-Secondary Education Born 1964 University of Alabama - 1987, BA Recent Business Background WealthTrust Axiom, LLC, Investment Adviser Representative, 04/2013 – Present Purshe Kaplan Sterling Invest, Registered Representative, 04/2013 – 12/2024 Wells Fargo Advisors, Financial Consultant, 05/2009 – 04/2013 Axiom Asset Management 18 March 2026 Goldman Sachs, 07/2007 – 01/2009 Form ADV Part 2B - Item 3 - Disciplinary Information There are no legal or disciplinary actions to report for David Webster. Form ADV Part 2B - Item 4 - Other Business Activities David Webster is licensed to sell insurance products to clients of Axiom Asset Management through various insurance companies where appointed. When acting in his capacity as an insurance agent, Axiom will receive commissions for selling insurance products and, as such, may have an incentive to recommend such insurance products based on his receipt of remuneration rather than the client’s best interest. However, Management believes any such conflict of interest with our advisory clients is resolved by his fiduciary obligation to act in the best interest of our clients and by disclosure of this conflict. For more information on these arrangements, please refer to the section on Other Financial Industry Activities and Affiliations (Item 10) in the firm’s Form ADV 2A. Form ADV Part 2B - Item 5 - Additional Compensation David Webster receives compensation for providing advisory services solely from his responsibilities at Axiom Asset Management. He does not receive any additional economic benefit from third parties for providing advisory services other than those described above. Form ADV Part 2B - Item 6 - Supervision Our firm has in place written supervisory procedures, which include annual account reviews by the firm’s supervised persons that are reasonably designed to detect and prevent violations of the securities laws, rules, and regulations and to monitor the advice being provided to the firm’s clients. David is a Principal Owner. Each principal of the firm is subject to the supervision of, and is mutually accountable to, all other principals. Axiom Asset Management 19 March 2026