Axiom Financial Strategies Group, LLC

Axiom Financial Strategies Group LLC Form ADV Part 2A – Disclosure Brochure Effective: September 28, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Axiom Financial Strategies Group LLC (“Axiom” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (812) 913-7701 or by email at contactus@axiomfsg.com. Axiom is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Axiom to assist you in determining whether to retain the Advisor. Additional information about Axiom and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 306618. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Axiom. Axiom believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Axiom encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes No material changes have been made to this Disclosure Brochure since the annual amendment filing on March 31, 2026. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 306618. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (812) 913-7701 or by email at contactus@axiomsfg.com. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Advisory Services ................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................................................. 4 C. Client Account Management .......................................................................................................................................... 6 D. Wrap Fee Programs ....................................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................................ 6 Item 5 – Fees and Compensation ......................................................................................................................... 6 A. Fees for Advisory Services ............................................................................................................................................. 7 B. Fee Billing ....................................................................................................................................................................... 7 C. Other Fees and Expenses ............................................................................................................................................. 8 D. Advance Payment of Fees and Termination .................................................................................................................. 8 E. Compensation for Sales of Securities ............................................................................................................................ 9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9 Item 7 – Types of Clients ..................................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10 A. Methods of Analysis ..................................................................................................................................................... 10 B. Risk of Loss .................................................................................................................................................................. 10 Item 9 – Disciplinary Information ....................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12 A. Code of Ethics .............................................................................................................................................................. 12 B. Personal Trading with Material Interest ........................................................................................................................ 13 C. Personal Trading in Same Securities as Clients .......................................................................................................... 13 D. Personal Trading at Same Time as Client ................................................................................................................... 13 Item 12 – Brokerage Practices ............................................................................................................................ 13 A. Recommendation of Custodian[s] ................................................................................................................................ 13 B. Aggregating and Allocating Trades .............................................................................................................................. 14 Item 13 – Review of Accounts ............................................................................................................................ 15 A. Frequency of Reviews .................................................................................................................................................. 15 B. Causes for Reviews ..................................................................................................................................................... 15 C. Review Reports ............................................................................................................................................................ 15 Item 14 – Client Referrals and Other Compensation ........................................................................................ 15 A. Compensation Received by Axiom .............................................................................................................................. 15 B. Compensation for Client Referrals ............................................................................................................................... 16 Item 15 – Custody ................................................................................................................................................ 16 Item 16 – Investment Discretion ......................................................................................................................... 16 Item 17 – Voting Client Securities ...................................................................................................................... 17 Item 18 – Financial Information .......................................................................................................................... 17 Privacy Policy ...................................................................................................................................................... 18 Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 3  Item 4 – Advisory Services A. Firm Information Axiom Financial Strategies Group LLC (“Axiom” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Indiana. Axiom was founded in November 2019 and is owned and operated by David V. Scott Jr. (“Vaughan”) Managing Partner, Chief Compliance Officer. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Axiom. B. Advisory Services Offered Axiom offers investment advisory services to individuals, high net worth individuals, trusts, and estates (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Axiom's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Axiom provides Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with discretionary and in limited circumstances non-discretionary management of investment portfolios. These services are described below. Investment Management Services: Axiom provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and in very limited circumstances non-discretionary investment management and related advisory services. Axiom works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Axiom will create, analyze, strategize, and implement goal-oriented investment solutions. These solutions become our client’s investment policy. Axiom will then construct an investment portfolio, consisting of diversified mutual funds and/or low-cost exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Axiom’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Axiom will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Axiom evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Axiom may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Axiom may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Axiom may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Under certain circumstances, Axiom may accept or maintain custody of Client’s funds or securities. Please see Item 15 – Custody for more information. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 4  Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest or at the client’s request, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers Axiom in certain situations will recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure each Independent Manager’s strategies and target allocations remain aligned with the Client’s investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Financial Planning Services Axiom will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, business succession planning, cash flow forecasting, trust and estate planning, financial planning, investment consulting, insurance planning, business strategy & transition planning, liability management, risk management, charitable planning, distribution planning, tax planning, retirement plan consulting, family strategy & transition planning. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Axiom may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Axiom provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 5  Sponsor in meeting its fiduciary obligation to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services include both fiduciary and non-fiduciary services to the Plan Sponsor and the Plan Participants. Advisory services are negotiated based on the needs of the Plan and the direction and engagement by the Plan Sponsor and are included in the terms of a retirement plan advisory agreement. Axiom typically provides the following Plan Fiduciary Services pursuant to the scope and terms of Axiom’s agreement with each Plan Sponsor: • Plan Participant Enrollment and Education Tracking • Investment Policy Statement (“IPS”) Design and Monitoring • Investment Oversight Services (ERISA 3(21) • Performance Reporting • ERISA 404(c) Assistance These services are provided by Axiom serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Axiom’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Axiom to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Axiom, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Axiom will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Axiom will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Axiom will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Axiom includes transaction fees (herein “Covered Costs”) together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Axiom Financial Strategies Group Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2025, Axiom manages $404,117,800 in Client assets, $404,029,969 of which is managed on a discretionary basis, and $87,830 of which is managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 6  A. Fees for Advisory Services Wealth Management Services Wealth management and investment advisory fees are paid monthly in advance based on the fair market value of portfolio assets under management in the Account[s] at the end of the prior month. Investment advisory fees are based on the following schedule: Total Assets Under Management (By Family) ($) First $1,000,000 Greater than $1,000,000 – Less than or equal to $5,000,000 Greater than $5,000,000 – Less than or equal to $10,000,000 Greater than $10,000,000 Annual Rate (%) Up to 1.50% Up to 1.25% Up to 1.00% Up to 0.75% The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Axiom will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers As noted in Item 4, the Advisor in certain situations will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Financial Planning Services Axiom offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly fees range from $100 to $1,000 per hour. Fixed fees will be based on the estimated number of hours necessary to complete the engagement. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Retirement Plan Advisory Services Retirement plan advisory fees are paid in advance or in arrears and either monthly or quarterly pursuant to the terms of the retirement plan advisory agreement . and/or according to the plan providers payment practices. Fees are generally based on the market value of assets in the Plan at the end of the prior calendar quarter and charged at an annual rate ranging from 0.25% to 1.00% of Plan assets. Fees may also be billed at a fixed annual rate. B. Fee Billing Wealth Management and Investment Management Services Wealth management and investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective month end date. The amount due is calculated based on the fair market value of portfolio assets under management in the Account[s] at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 7  statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Axiom to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or deducted from the Client’s account[s] with the respective manager and a portion of the investment advisory fee may be provided to Axiom. Financial Planning Services Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s]. Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Retirement Plan Advisory Services Fees may be directly invoiced to the Plan Sponsor or deducted from the account of each Plan Participant, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Axiom, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees to clients; however, the Custodian does charge the Advisor an annual platform fee which is not passed along to clients. In addition, all fees paid to Axiom for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Axiom, but would not receive the services provided by Axiom which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Axiom to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Axiom is compensated for its investment advisory services at the beginning of the month, in advance of investment advisory services being rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five- day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Adviser will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and that Independent Manager. Axiom will assist the Client with the termination and transition as appropriate. Financial Planning Services Axiom is compensated for its financial planning services upon completion of the engagement deliverable[s]. Axiom may require an advance deposit as described above. Either party may terminate the financial planning agreement, at Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 8  any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination to the end of the engagement. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Axiom is compensated for its retirement plan advisory services in advance of the quarter or the month in which services are rendered or in arrears at the end of the quarter or month, as agreed upon in the investment advisory agreement and/or according to the plan providers payment practices. Either party may request to terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for advisory fees up to and including the effective date of termination. Upon termination, Axiom will promptly refund any unearned, prepaid fees to the Client. The Client’s investment advisory agreement with Axiom is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Axiom does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Broker-Dealer Affiliations Certain Advisory Persons of Axiom are also be registered representatives of Integrity Alliance, LLC ("Integrity Alliance"), a securities broker-dealer, and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). In one’s separate capacity as a registered representative of Integrity Alliance, an Advisory Person will implement securities transactions under Integrity Alliance and not through Axiom. In such instances, an Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by an Advisory Person in one’s capacity as a registered representative is separate and in addition to Axiom’s advisory fees. This practice presents a conflict of interest because Advisory Persons who are registered representatives have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on Client needs. The Advisor mitigates this conflict in two ways. First, Clients are under no obligation, contractually or otherwise, to purchase securities products through one of Axiom’s Advisory Persons. Second, the Advisor will not charge an ongoing investment advisory fee on any assets implemented in the separate capacity of one of the Advisory Persons. Please see Item 10 – Other Financial Industry Activities and Affiliations. Insurance Agency Affiliations The Advisor is affiliated through common control and ownership with Spring Street Solutions, LLC, a licensed insurance agency. Certain Advisory Persons are also licensed insurance professionals of Spring Street Solutions, LLC. Spring Street Solutions, LLC and Advisory Persons will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by an Advisory Person are separate and in addition to advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of the Advisor who are insurance agents have an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations. Item 6 – Performance-Based Fees and Side-By-Side Management Axiom does not charge performance-based fees for its investment advisory services. The fees charged by Axiom are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 9  Axiom does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Axiom offers investment advisory services to individuals, high net worth individuals, trusts, and estates. Axiom generally requires a minimum account size of $250,000 to effectively implement its investment process. The Advisor in its sole discretion may wave the minimum account size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Axiom will carefully construct a tax-efficient and cost-effective asset allocation strategy based on a client’s unique cash flow needs, stated return and risk profile. Security selection is based on qualitative, quantitative, technical, and relative strength metrics. Portfolio holdings are constantly monitored and adjusted as market conditions and our clients’ circumstances dictate. Clients may hold or retain other types of assets as well, and Axiom may offer advice regarding those various assets as part of its services. Advice regarding such assets will generally not involve asset management services but may help to more generally assist the client. Axiom predominantly allocates client assets to a combination of active and passive (tax-efficient and cost effective) strategies, utilizing combinations of publicly traded securities such as stocks, bonds, ETFs, mutual funds, and/or separately managed portfolios. Nevertheless, individual client circumstances may dictate the use of other types of securities, actively managed portfolios, or alternative investments. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Axiom will be able to accurately predict such a reoccurrence. Qualitative analysis involves analysis that uses subjective judgment based on unquantifiable information, such as management expertise, industry cycles, strength of research and development. Qualitative analysis contrasts with quantitative analysis, which focuses on numbers such as the firm’s financials and prospectus or offering memorandums. Both techniques are often used together in order to examine a company’s operations and evaluate its potential as an investment opportunity. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. As noted above, Axiom generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Axiom will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Axiom may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Axiom will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 10  While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 11  There are no legal, regulatory or disciplinary events involving Axiom or its owner [OR] management persons. Axiom values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 306618. Item 10 – Other Financial Industry Activities and Affiliations Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. The Advisor does not receive any compensation nor does this present a material conflict of interest. The Advisor will only earn its investment advisory fee as described in Item 5.A. Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons of Axiom are also registered representatives of Integrity Alliance. In an Advisory Person’s separate capacity as a registered representative, an Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person of Axiom. Neither Axiom nor an Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a registered representative. Under supervision by Integrity Alliance, Integrity Alliance may have access to certain confidential information of the Client, including, but not limited to financial information, investment objectives, transactions and holdings information. Please see the Advisor’s Privacy Policy, which is included with this Disclosure Brochure. Insurance Agency Affiliations As noted in Item 5, the Advisor is affiliated with Spring Street Solutions, LLC and certain Advisory Persons serve as licensed insurance professionals under Spring Street Solutions, LLC. Implementations of insurance recommendations are separate and apart from an Advisory Person's role with the Advisor. Advisory Persons and Spring Street Solutions, LLC will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor. Additionally, Axiom is affiliated with Spring Street Solutions, LLC, which is owned and operated by Mr. Scott and Ms. Konkle. This creates a conflict of interest because there is a financial incentive for Axiom to refer clients to Spring Street Solutions, LLC for their insurance needs. Axiom clients are under no obligation to do business with Spring Street Solutions, LLC. As a result of common control and ownership, Axiom is affiliated with Next Chapter Institute, LLC. Next Chapter Institute, LLC is a business consulting firm for businesses, non-profit organizations, families, and family enterprises on the topics of leadership, succession, and transition planning and personnel development by providing advice and best practices on how they can leverage their time, talent, and treasure to evaluate, improve, and optimize their human, social, intellectual, and spiritual capital. Clients of Axiom may be referred to Next Chapter Institute, LLC for business consulting services which would be deemed a conflict of interest due to the financial compensation received by Mr. Scott, owner. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Axiom has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Axiom (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Axiom and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Axiom’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 12  principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (812) 913-7701 or via email at contactus@axiomfsg.com. B. Personal Trading with Material Interest Axiom allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Axiom does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Axiom does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Axiom allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Axiom requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate/OR by conducting a coordinated review of personal accounts and the accounts of the Clients. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Axiom allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Axiom, or any Supervised Person of Axiom, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Axiom has the discretionary authority to select brokers and to negotiate commissions on behalf of clients. Axiom will endeavor to select those brokers or dealers which will provide the best services at the lowest commission rates possible. The reasonableness of commissions is based on the broker's ability to provide professional services, competitive commission rates, research and other services which will help Axiom in providing investment management services to clients. Axiom may select a broker(s) who provides useful research and securities transaction services even though a lower commission may be charged by a broker who offers no research services and minimal securities transaction assistance. Axiom utilizes Trade-PMR, Inc. (“Trade-PMR”) for brokerage and trade execution services. Trade-PMR clears trades and custodies assets with First Clearing, FINRA member broker-dealers. First Clearing is a trade name used by Wells Fargo Clearing Services, LLC., a non-bank affiliate of Wells Fargo & Company. Trade-PMR acts as an introducing broker dealer on a fully disclosed basis. Trade-PMR and First Clearing are members of SIPC and are unaffiliated registered broker dealers and FINRA members. The brokerage commissions and/or transaction fees charged by Trade-PMR or any other designated broker-dealer are exclusive of and in addition to Axiom’s fee. Axiom regularly reviews these programs to seek to ensure that its recommendation is consistent with its fiduciary duty. Factors which Axiom considers in recommending Trade-PMR and First Clearing or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research, and service. The commissions and/or transaction fees charged by these brokers may be higher or lower than those charged by other broker-dealers. In addition, Trade-PMR provides Axiom with access to its institutional trading and custody services, which are typically not available to retail investors. These brokerage services include the execution of securities transactions, Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 13  research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Additionally, Axiom may receive the following benefits from Trade-PMR: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its participants; access to block trading which provides the ability to aggregate securities transactions and then allocates the appropriate shares to client accounts; and access to an electronic communication network for client order entry and account information. Additionally, Axiom may recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. Axiom maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. The commissions paid by Axiom’s clients are intended to be consistent with Axiom’s duty to obtain “best execution.” However, a client may pay a commission that is higher than what another qualified broker dealer might charge to affect the same transaction when Axiom determines, in good faith, that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealers’ services, including among others, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while Axiom will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client transactions. Transactions for each client will generally be affected independently. For certain trades, Axiom will block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading allows Axiom to execute equity or fixed income trades in a timely, equitable manner and to reduce overall commission charges to clients. Again, clients who do not provide Axiom with brokerage discretion will not participate in block trades, and their trades in similar securities will be placed with brokers after trades for discretionary accounts. As registered representatives of Integrity Alliance, the Advisor may be limited in using other broker- dealers/custodians as Integrity Alliance must approve the use of any outside broker-dealer/custodian. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Axiom does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Axiom does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Axiom will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Axiom will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 14  The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Axiom will execute its transactions through the Custodian as authorized by the Client. Axiom may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Vaughan Scott, Chief Compliance Officer of Axiom. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Axiom if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Axiom Axiom is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Axiom does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Axiom may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Axiom may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform- Trade-PMR As noted in Item 12, Axiom will receive additional benefits from Trade-PMR which includes electronic systems that assist in the management of Axiom client accounts, access to research, the ability to directly debit client fees, software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), pricing information and other market data, assist with back-office functions, recordkeeping and client reporting. Participation in Institutional Advisor Platform- Schwab Axiom has also established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Axiom. As a registered investment advisor participating on the Schwab Advisor Services platform, Axiom receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 15  the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. However, Axiom’ commitment to its clients and the policies and procedures it has adopted are designed to limit any interference with Axiom independent decision-making process when choosing the most appropriate investments or custodian for our clients. Finally, we are committed to utilizing whatever benefits we may receive under this arrangement to enhance our services to you. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Axiom that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Axiom believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Axiom’ commitment to its clients and the policies and procedures it has adopted are designed to limit any interference with Axiom independent decision-making process when choosing the most appropriate investments or custodian for our clients. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor and shall not result in any additional charge to the Client. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Axiom generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Axiom. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 16  Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Axiom will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities As a matter of firm policy and practice, advisory clients can choose to have Axiom vote proxies on behalf of their managed accounts through Proxy Edge by Broadridge. Proxy Edge allows Axiom to vote proxies electronically on a client’s behalf for their shares managed in accounts by Axiom on a discretionary authority. Axiom will only take authority to vote proxies on behalf of clients for investments Axiom has provided investment discretion. Axiom will not vote proxies for client’s legacy positions that the client maintains in their portfolios. Axiom seeks to identify any material conflicts of interest and to ensure that any such conflicts do not interfere with voting in clients’ best interests. Clients may obtain a copy of Axiom’s complete voting policies and procedures and information about how Axiom voted a client’s proxies by contacting the Chief Compliance Officer. Item 18 – Financial Information Neither Axiom, nor its management, have any adverse financial situations that would reasonably impair the ability of Axiom to meet all obligations to its Clients. Neither Axiom, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Axiom is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 17  Privacy Policy Effective: September 28, 2026 Our Commitment to You Axiom Financial Strategies Group LLC (“Axiom” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Axiom (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Axiom does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 18  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Axiom shares Client information with Integrity Alliance, LLC (“Integrity Alliance”) due to the oversight Integrity Alliance has over Supervised Persons of the Advisor. You may also contact us at any time for a copy of the Integrity Alliance Privacy Policy. Marketing Purposes Axiom does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Axiom or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Axiom does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting the Advisor at (812) 913-7701 or via email at contactus@axiomsfg.com. Axiom Financial Strategies Group LLC 101 W. Spring Street, 5th Floor, New Albany, IN 47150 Phone: (812) 913-7701 * Fax: (812) 913-7702 www.axiomfsg.com Page 19