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AZZAD ASSET MANAGEMENT, INC.
FIRM BROCHURE (FORM ADV PART 2A)
For clients and prospective clients of Azzad Asset Management
JANUARY 30, 2026
Azzad Asset Management, Inc.
3141 Fairview Park Drive, Suite 355
Falls Church, VA 22042
Phone: (888) 862-9923
www.azzadasset.com
hello@azzadasset.com
1. Cover page
This brochure provides information about the qualifications and business practices of Azzad Asset
Management, Inc. (“Azzad”). If you have any questions about the contents of this brochure, please
contact our Chief Compliance Officer, Lejeana Love, at (202) 750-9093 or by email at
llove@kbc.team. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority.
Azzad is a Registered Investment Adviser. Registration with the United States Securities and
Exchange Commission or any state securities authority does not imply any level of skill or training.
The oral and written communications of an Adviser provide you with information you can use to
determine whether to hire or retain an Adviser.
Additional information about Azzad Asset Management, Inc. is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by using a unique identifying number known as
a “CRD number.” Our firm’s CRD number is 111291.
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2. Material Changes
The following material changes have been made since our last filing:
•
Item 4 to update the firm’s assets under management as of December 31, 2025 and
expanded disclosure regarding recommendations of qualified rollovers.
• Lejeana Love has assumed the role of Chief Compliance Officer.
Azzad may, at any time, update this brochure and either: (1) send you a copy without charge; or
(2) provide a summary of the material changes and offer to send you a copy of the ADV Part 2
without charge, provided the offer is accompanied by certain contact information. Pursuant to SEC
Rules, we will ensure that you receive a summary of any material changes to this and subsequent
Brochures within 120 days of the close of our business’ fiscal year. We may further provide other
ongoing disclosure information about material changes, as necessary.
A copy of Azzad’s Brochure may be requested by contacting the Chief Compliance Officer,
Lejeana Love, at 202.750.9093 or llove@kbc.team.
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3. Table of Contents
1. Cover page ............................................................................................................................................ 1
2. Material Changes .................................................................................................................................. 2
3. Table of Contents .................................................................................................................................. 3
4. Advisory Business ................................................................................................................................ 5
A. Ownership/Adviser History .............................................................................................................. 5
B. Advisory Services Offered ................................................................................................................ 6
C. Tailored Services .............................................................................................................................. 9
D. Wrap Program ................................................................................................................................... 9
E. Clients Assets Managed .................................................................................................................... 9
5. Fees and Compensation ........................................................................................................................ 9
A. Ethical Wrap Program ....................................................................................................................... 9
B. Azzad Funds Advisory Services ..................................................................................................... 13
6. Performance-Based Fees and Side by Side Management ................................................................... 13
7. Types of Clients .................................................................................................................................. 13
A. Types of Clients .............................................................................................................................. 13
B. Account Minimums ........................................................................................................................ 13
8. Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 14
A. Methods of Analysis and Investment Strategies ............................................................................. 14
B.
Investment Risks ............................................................................................................................. 16
C. Other Investment Risks ................................................................................................................... 17
9. Disciplinary Information ..................................................................................................................... 19
10.
Other Financial Industry Activities and Affiliations ...................................................................... 19
11.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 20
A. Description ...................................................................................................................................... 20
B. Material Interest in Securities ......................................................................................................... 20
C.
Investing or Recommending in the Same Securities ....................................................................... 20
12.
Brokerage Practices ....................................................................................................................... 21
A. Recommendation Criteria ............................................................................................................... 21
B. Research and Other Soft Dollar Benefits ........................................................................................ 22
C. Brokerage for Client Referrals ........................................................................................................ 23
D. Directed Brokerage ......................................................................................................................... 23
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E. Trade Aggregation .......................................................................................................................... 24
13.
Review of Accounts ....................................................................................................................... 24
A. Periodic Reviews ............................................................................................................................ 24
B. Other Reviews ................................................................................................................................. 25
C. Reports ............................................................................................................................................ 25
14.
Client Referrals and Other Compensation ..................................................................................... 25
A. Other Compensation ....................................................................................................................... 25
B. Client Referrals ............................................................................................................................... 26
15.
Custody .......................................................................................................................................... 27
16.
Investment Discretion .................................................................................................................... 27
17.
Voting Client Securities ................................................................................................................. 28
18.
Financial Information..................................................................................................................... 28
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4. Advisory Business
A. Ownership/Adviser History
Our History
Azzad Asset Management, Inc. (“Azzad,” “we” or the “firm”) has specialized in socially
responsible Islamic investing since our founding in 1997. Based in Northern Virginia, we have
earned a reputation for our ethical investment philosophy and our active equity strategies.
Azzad was formed as a Delaware corporation in 1997 and subsequently registered as an investment
adviser with the Securities and Exchange Commission on August 21, 2000.
Our Principles
We believe that sustainable companies operating responsibly and in ethical lines of business offer
the best opportunities for shareholder returns. We believe that such companies offer relatively less
business risk and are in a better position to thrive. We integrate our socially responsible Islamic
investment philosophy with our disciplined investment process to build portfolios that are in line
with our core values.
Our People
Azzad’s models, asset allocation strategies and managers are overseen by an Investment
Committee (the “Committee”) that meets regularly. The Committee reviews, analyzes and
discusses the various forces and factors that affect the financial markets and, in turn, the portfolios
we manage and oversee. The Committee’s review includes (but is not restricted to)
macroeconomic trends, risk/reward profiles for various markets, strategy allocations, portfolio
characteristics, and performance. The Investment Committee is assisted by Azzad’s independent
investment consulting firm.
Bashar Qasem, President & Senior Investment Adviser Representative
Mr. Qasem is the founder of our firm, the principal owner, the Chief Executive Officer, and Senior
Investment Adviser Representative. Mr. Qasem has extensive experience in the financial
investment world, particularly in Islamic finance, having spent over 25 years managing Azzad
Asset Management, Inc. and serving as Chairman of the Azzad Funds since their inception. He
holds Bachelor of Science degrees in electrical engineering, and previously held securities licenses
6, 63, & 26. He currently holds FINRA Series 65. He also earned the designation of Certified
Shari’ah Auditor & Adviser (C.S.A.A.) from Accounting and Auditing Organization of Islamic
Financial Institutions (AAOIFI) in 2009.
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B. Advisory Services Offered
Azzad offers the following services to its clients:
Ethical Wrap Program
We manage client accounts through a wrap program called the Azzad Ethical Wrap Program
(“Ethical Wrap Program” or “Program”) that we also sponsor. Prior to enrolling in the Ethical
Wrap Program, the client must execute a written Investment Advisory Agreement with Azzad that
defines the terms and conditions of a client participating in the Program. For a predetermined
“wrap” fee (based on a percentage of assets under management), the Program offers investment
management services (i.e., investment advisory, brokerage, custody) and financial planning. The
client will have access to an Azzad Investment Adviser Representative (“IAR”) whose fiduciary
duty is to assist in the overall management of the client’s account(s). The client’s IAR will assist
in determining his or her investor profile (this includes identifying their goals, objectives, risk
tolerance, and liquidity needs) and then selecting an appropriate asset allocation strategy. The IAR
is available for direct telephone conversations with clients at their request, and at least once a
quarter.
Specific services or features offered in the Ethical Wrap Program include an assessment of client
investment needs and objectives, account rebalancing, and continuing evaluation of investment
performance. Depending on market conditions, our views on the markets, and other factors, an
asset allocation model may change. Changes in our asset allocation models are conducted without
consulting our clients. Clients must notify their IAR of any changes to their financial situation.
Such changes may affect a client’s investor profile, which may necessitate a change in the strategy
assigned. For example, if a client anticipates retiring earlier than previously stated, he or she will
want to share that information with his or her advisor. An IAR may recommend changing a strategy
to reduce risk level (conversely, there may be other life situations where an advisor may
recommend increasing a client’s risk level to meet investment goals).
Under the Program, clients have access to a broad range of financial planning services which may
include tax-related and other non-investment related matters. The services provided by Azzad may
include developing a financial plan, tax planning, retirement planning, estate planning, education
planning, insurance planning and charitable planning. To perform its services, Azzad is not
required to verify any information received from the client or from the client’s other professionals
(e.g., attorney, accountant, etc.) and is expressly authorized to rely on information provided by the
client.
Azzad does not serve as a law firm, accounting firm, charity administrator or insurance agency,
and no portion of Azzad’s services should be construed as legal, accounting, charitable
administrator, or insurance implementation services. Accordingly, Azzad does not prepare estate
planning documents, tax returns, or sell insurance products. To the extent requested by a client,
Azzad may recommend the services of other professionals for certain non-investment
implementation purposes (i.e., attorneys, accountants, insurance agents, charity administrators,
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etc.). Clients are under no obligation to engage in the services of any such recommended
professional. The client retains absolute discretion over all such implementation decisions and is
free to accept or reject any recommendation made by Azzad or its representatives. However, if the
client engages any unaffiliated recommended professional, and a dispute arises thereafter relative
to such engagement, the client agrees to seek recourse exclusively from and against the engaged
professional.
Depending on the allocation chosen, client assets will be allocated among various portfolios
consisting of individual securities that comply with our investment philosophy. Each portfolio is
managed by independent and affiliated portfolio managers. In addition, assets may be allocated
into the Azzad Funds, for which Azzad Asset Management serves as investment adviser. Clients
are not charged a wrap program fee on assets that are invested in the Azzad Funds. Independent
managers are compensated a portion of the wrap fee pursuant to an agreement. We conduct
ongoing monitoring, due diligence, and continuing evaluation of investment performance for each
of our independent portfolio managers to ensure that they are a right fit for our Program.
All wrap accounts are maintained by a qualified and unaffiliated custodian and broker-dealer that
provides custodial, clearing and brokerage duties. We generally recommend that clients utilize the
custody, brokerage and clearing services of Goldman Sachs & Company, Charles Schwab & Co.,
Inc., or Fidelity Brokerage Services, LLC, members FINRA/SIPC. We do not have physical
custody of client assets. Custodial, brokerage and clearing services are included in your wrap fee.
Prior to becoming a client with our firm, clients must execute a written agreement with Azzad
which defines the terms and conditions of the program. Clients also must execute a separate
custodial/clearing/brokerage agreement with the custodian.
Advisory Services to the Azzad Funds
We provide investment management services as an adviser under an advisory agreement to the
following portfolios registered under the Investment Company Act of 1940: Azzad Ethical Fund
(ADJEX) and Azzad Wise Capital Fund (WISEX) (collectively, the “Funds”). These no-load
mutual funds are affiliated with Azzad, and their fees are based on assets under management. The
Funds are available through prospectus only; a prospectus is available free of charge by calling the
Funds’ transfer agent at 888-350-3369 or online at https://azzadasset.com/azzad-funds/.
Under the terms of the investment advisory agreement with the Funds, Azzad is responsible for
formulating the Funds’ investment program.
ADDITIONAL DISCLOSURES
ERISA / IRC Fiduciary Acknowledgment. When Azzad provides investment advice to a client
about the client’s retirement plan account or individual retirement account, it does so as a fiduciary
within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or
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the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts.
Because the way Azzad makes money creates certain conflicts with client interests, Azzad operates
under a special rule that requires it to act in the client’s best interest and not put its interests ahead
of the client’s. Under this special rule’s provisions, Azzad must: meet a professional standard of
care when making investment recommendations (give prudent advice); never put its financial
interests ahead of the client’s when making recommendations (give loyal advice); avoid
misleading statements about conflicts of interest, fees, and investments; follow policies and
procedures designed to ensure that Azzad gives advice that is in the client’s best interest; charge
no more than is reasonable for Azzad’s services; and give the client basic information about
conflicts of interest.
Retirement Plan Rollovers –: A client or prospective client leaving an employer typically has four
options regarding an existing retirement plan: (i) leave the money in the former employer’s plan,
if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers
are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the
account value (which could, depending upon the client’s age, result in adverse tax consequences).
Clients may engage in a combination of these options and each has advantages and disadvantages.
Before making a change we encourage you to speak with your CPA and/or tax attorney. If Azzad
recommends that a client roll over their retirement plan assets into an account to be managed by
Azzad, such a recommendation creates a conflict of interest if Azzad will earn an advisory fee on
the rolled over assets. No client is under any obligation to roll over retirement plan assets to an
account managed by Azzad.
As part of our investment advisory services to you, Azzad may recommend that you withdraw the
assets from your employer's retirement plan and roll the assets over to an individual retirement
account ("IRA") that Azzad will manage on your behalf. If you elect to roll the assets to an IRA
that is subject to Azzad management, we will charge you an asset-based fee as set forth in the
agreement you executed with our firm. We are fiduciaries under the Investment Advisers Act of
1940 and when we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. This practice presents a conflict of interest because persons
providing investment advice on our behalf have an incentive to recommend a rollover to you for
the purpose of generating fee-based compensation rather than solely based on your needs. As a
fiduciary, we are required to document the reason(s) for why the recommendation we made is in
your best interest. Azzad also mitigates this conflict by waiving program fees invested in the Azzad
Mutual Funds.
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C. Tailored Services
All Ethical Wrap Program and Financial Planning Services are individualized or tailored to each
client’s needs, goals, risk appetite, and objectives. Clients complete a risk assessment
questionnaire, financial planning questionnaire and/or interview used to create an Investment
Policy Statement tailored to meet client’s current situation. Clients may impose reasonable trade
restrictions, subject to approval by the Firm. However, if the restrictions prevent Azzad or its
representatives from properly servicing the account, or if the restrictions require Azzad to deviate
from its standard services, Azzad reserves the right to terminate the relationship. Additionally, at
your request, Azzad will remove the Azzad Funds from your Ethical Wrap Program account.
Clients are advised that it remains their responsibility to promptly notify Azzad if there is ever any
change in their financial situation, investment objectives, or if they wish to impose reasonable
the purpose of reviewing, evaluating, or revising Azzad’s previous
restrictions for
recommendations and/or services. In performing its services, Azzad shall not be required to verify
any information received from the client or from the client’s other professionals and is expressly
authorized to rely thereon.
D. Wrap Program
Azzad sponsors the Ethical Wrap Program that is described in Item 4.B, above. Additional
information about the Ethical Wrap Program can be found in Part 2A, Appendix 1 (the “Wrap Fee
Program Brochure”), which can be requested free of charge by calling 888.862.9923. Azzad does
not manage wrap accounts in a different fashion than non-wrap accounts. We manage all our
accounts according with our socially responsible Islamic investment philosophy. As further
described in the Wrap Fee Program Brochure, Azzad receives a portion of the wrap fee for its
services.
E. Clients Assets Managed
As of December 31, 2024, the Firm manages approximately $1,819,099,866 in discretionary assets
and approximately $18,094,059 in nondiscretionary assets.
5. Fees and Compensation
A. Ethical Wrap Program
The annual wrap fee is based on a percentage of assets under management and is paid monthly in
advance in accordance with the following fee schedule:
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Market Value
$0-$500,000
$500,001-$2,000,000
$2,000,001-$4,000,000
$4,000,001-$10,000,000
$10,000,001 and over
Annual Fee
1.75% on the first $500,000
1.5% on the next $1,500,000
1.4% on the next $2,000,000
1.3% on the next $6,000,000
1.2% on assets over $10 million
As mentioned previously, these fees are inclusive of brokerage, custodial, investment
management, and advisory services. A portion of the wrap fee is payable to your Azzad Investment
Adviser Representative. The custodian may charge clients special service charges such as wire
transfer and check fees (not included in the above wrap fee) but clients may use other payment
methods at no charge (such as electronic funds transfers). Clients may request a detailed
description of such fees from their representative.
In certain circumstances, clients whose advisory accounts are held at Fidelity Brokerage Services
(“Fidelity”) will incur additional transaction fees for trades executed via individual transaction
charges when choosing to receive paper delivery of their statements. These transaction fees are
separate from our firm’s wrap fees and will be charged by Fidelity. Clients may avoid these
transaction fees for U.S. listed equities and exchange traded funds by either opting into electronic
delivery of statements or maintaining at least $1 million in assets at Fidelity.
A client’s actual fees will depend on their allocation and total household assets under management
with Azzad. Depending on unique circumstances (another existing account relationship with a
client, expected dramatic account growth, account type, special conditions, etc.), fees may be
subject to negotiation. The specific way fees are charged by Azzad is established in a client’s
written agreement with us. We reserve the right to charge clients wrap fees that are lower than the
above fee schedule.
We provide “householding” billing for clients who maintain their accounts at Charles Schwab &
Co., Inc., or Fidelity Brokerage Services, LLC. In those cases, Azzad combines managed account
values for family members living in the same household at either custodian to increase the
managed asset total, and ultimately reduce the wrap fee based on the available breakpoints in the
fee schedule above. We provide limited “householding” for clients who maintain accounts at
Goldman Sachs. Only accounts opened with the same social security number or tax identification
number are “householded” in determining breakpoints in our fee schedule. In determining our fee,
we also do not “household” accounts held at Goldman Sachs with accounts held at Charles Schwab
& Co., Inc., or Fidelity Brokerage Services, LLC. For example, we would not combine the account
values for spouses sharing the same household who each own an account maintained at Goldman
Sachs to reduce the wrap fee based on the available breakpoints in the fee schedule above.
We reserve the right to lower your fees without obtaining your permission. However, we may not
increase your fees without thirty (30) days’ advance written notice.
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Clients who do not receive an Azzad Wrap Fee Program Brochure (Part 2A Appendix 1 of Form
ADV) prior to or at the time of opening a wrap account with Azzad, shall have the right to terminate
the wrap relationship without cost or penalty, within five (5) business days from the date of the
wrap agreement. Thereafter, in the event of the termination of our services, any unearned portion
of fees previously paid will be refunded. Clients may terminate their agreement with us at any time
by written notice delivered to Operations at Azzad Asset Management, 3141 Fairview Park Drive,
Suite 355, Falls Church, VA 22042.
How We are Paid
The annual wrap fee is generally based on a percentage of assets under management as determined
by the custodian and pursuant to the above standard fee schedule. Fees are paid in advance at the
beginning of each month. They are computed on the custodian’s reported valuation of assets under
management on the last day of the prior month and automatically debited from the client’s account.
Thereafter, if any prepayments of fees are made by advisory clients, such pre-payments are
prorated, and any unearned fees are refunded if services are terminated prior to the period for
which payments were to apply.
Other Fees You Should Understand
We are the investment adviser to the Azzad Funds. The Azzad Funds charge separate fees and
expenses not included in the above wrap fees (referred to as the Funds’ expense ratios). These
separate fees are described in the Funds’ prospectus and will generally include a management and
distribution fee.
A significant portion of our proprietary mutual fund sales are made through wrap accounts.
However, the wrap fees are waived on the portion of a client’s account that is invested in the Azzad
Funds. Although clients will not be charged a wrap fee on any assets invested in the Azzad Funds,
as noted previously, clients will still be charged separate fees and expenses associated with the
Funds. Clients should refer to the Azzad Funds’ prospectus https://azzadasset.com/azzad-funds/
for more information.
Clients may invest in the Azzad Funds directly outside of the Ethical Wrap Program. Clients who
choose to do so should review both the fees charged by the Funds and the wrap fees to fully
understand the total amount of fees and to evaluate the advisory services being provided. Clients
have full discretion to request the removal of the Azzad Funds from their wrap account.
Azzad is registered as an Investment Adviser under the Investment Advisers Act of 1940 and is
therefore qualified to be appointed an Investment Manager under section 402(c)(3) of ERISA. We
acknowledge that, regarding those clients for which we serve as an Investment Manager as defined
in section 3(38) of ERISA, we are a Fiduciary as defined in section 3(21)(A) of ERISA.
As Investment Adviser to the Azzad Funds, we are contractually obligated to waive all or a portion
of our management fees and to reimburse the Funds to the extent necessary to limit operating
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expenses to 0.99% of assets for the Azzad Ethical Fund and 0.89% for the Azzad Wise Capital
Fund. By increasing the assets in the Azzad Funds, we may be able to eliminate or reduce our
reimbursement obligation. Therefore, we have an incentive to allocate wrap assets into the Funds.
In addition, broker-dealers servicing our wrap accounts receive 12b-1 fees paid by investors
holding the Azzad Funds in their accounts.
For clients whose advisory accounts are held at Schwab, Schwab has eliminated commissions for
online trades of U.S. equities, ETFs, and options (subject to $0.65 per contract fee). This means
that, in most cases, when we buy and sell these types of securities on behalf of clients, clients will
not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to
compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee
arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could
exceed the cost of paying for brokerage and advisory services separately. However, our
investment portfolios are not available to clients outside the wrap fee program. As Azzad absorbs
certain transaction costs in wrap accounts, Azzad may have a financial incentive not to place
transaction orders in those accounts since doing so increases its transaction costs. Thus, an
incentive exists to place trades less frequently in a wrap fee arrangement.
Mutal Fund Share Class
In many instances, the custodian makes available mutual funds in various classes of shares,
including shares designated as Class A Shares and shares designed for advisory programs, which
can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,”
“administrative” share classes. The Class I Shares offered for a particular mutual fund in many
cases will not be the least expensive share class that the mutual fund makes available, and was
selected by the custodian in certain cases because the share class pays the custodian compensation
for the administrative and recordkeeping services the custodian provides to the mutual fund.
Clients should understand that another financial services firm may offer the same mutual fund at
a lower overall cost to the investor. In other instances, a mutual fund may offer only Class A
Shares, but another similar mutual fund may be available that offers Class I Shares. Class A Shares
typically pay the custodian a 12b-1 fee for providing shareholder services, distribution, and
marketing expenses (“brokerage- related services”) to the mutual funds. Class I Shares generally
are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes,
it is generally more expensive for a client to own Class A Shares than Class I Shares. An investor
in Class I Shares will pay lower fees over time, and keep more of his or her investment returns
than an investor who holds Class A Shares of the same fund. Other financial services firms may
offer the same mutual fund at a lower overall cost to the investor.
Azzad has a financial incentive to recommend Class A Shares in cases where both Class A and
Class I Shares are available. This is a conflict of interest which might incline Azzad, consciously
or unconsciously, to render advice that is not disinterested. Although the client will not be charged
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a transaction charge for transactions, Advisor pays the custodian a per transaction charge for
mutual fund purchases and sales in the account. Azzad generally does not pay transaction charges
for Class A Share mutual fund transactions accounts, but generally does pay transaction charges
for Class I mutual fund transactions. The cost to Azzad of transaction charges generally may be a
factor the Advisor considers when deciding which securities to select and whether or not to place
transactions in the account.
B. Azzad Funds Advisory Services
Azzad receives advisory fees under the terms of an investment advisory agreement with the Funds.
For its services, Azzad receives a fee at an annual rate of 0.80% (pursuant to a voluntary fee
waiver) of the Azzad Ethical Fund’s average daily net assets and 0.80% of the Azzad Wise Capital
Fund’s average daily net assets. Azzad has an agreement with the Funds to reimburse Azzad
Ethical Fund for expenses exceeding 0.99% of the Funds’ net assets in any given year and 0.89%
for Azzad Wise Capital Fund. Shareholders who wish to make redemptions from either fund may
do so by following its redemption procedures as outlined in the relevant prospectus.
6. Performance-Based Fees and Side by Side Managemen
Azzad does not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client).
7. Types of Clients
A. Types of Clients
We provide investment management services to individuals (including high-net worth
individuals), corporate pension and profit-sharing plans, charitable institutions, foundations,
endowments, registered mutual funds, trust programs, small businesses, and other institutions.
B. Account Minimums
Minimum Wrap Account Size
We require a minimum dollar amount of assets under management of $500,000 for wrap accounts.
Under certain circumstances, Azzad may treat affiliated accounts (e.g., accounts of different family
members or multiple accounts for the benefit of the same person or persons) as one account for
purposes of satisfying the minimum size requirements. We reserve the right to accept clients with
lower minimum investment requirements for normal business reasons and considerations. We also
reserve the right to resign from the management of any individual account that falls below our
required investment minimum.
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Minimum Mutual Funds Account Size
For mutual fund accounts, Azzad requires a minimum initial investment as outlined in each Fund’s
prospectus. Generally, clients may invest in the Azzad Ethical Fund (ADJEX) with a minimum
account size of $1,000 and in the Azzad Wise Capital Fund (WISEX) with a minimum account
size of $4,000.
8. Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis and Investment Strategies
Wrap accounts include portfolios consisting of securities selected by each respective portfolio’s
model manager (“Independent Manager”) or Azzad’s internal investment team (“Azzad
Investment Team”). To assist in the management of a client’s account, Azzad hires Independent
Managers to manage the funds and various model portfolios. A client’s relationship, however, is
solely with Azzad. There is no communication, including consultations between the Independent
Manager and the client. Azzad continues to advise the client regarding asset allocation and other
financial decisions in their accounts. The Azzad Investment Team may also manage various model
portfolios for clients. Azzad may recommend that a client invest in one or more portfolios that is
managed by the Azzad Investment Team.
Each Independent Manager, using various available sources of information, has developed a
method of analysis, style, or specialty that we believe is suitable for our wrap account clients.
Independent Managers begin their investment process with our investment philosophy (described
below). They generally do not have direct or indirect responsibility for client accounts, nor do they
communicate with clients. Their sole responsibility is to manage the model portfolios they are
assigned within the wrap account. They will normally only recommend securities for a model
portfolio but have no or limited authority to effect account transactions.
The Azzad Investment Team and Independent Managers may use the following methods of
analysis when managing client assets:
FUNDAMENTAL ANALYSIS. The intrinsic value of a security is analyzed by reviewing
economic and financial factors (including the overall economy, industry conditions, and the
financial conditions and management of the company itself) to determine if the company is
underpriced (suggesting it may be a good time to buy) or overpriced (suggesting it may be time to
sell). Fundamental analysis does not attempt to anticipate market movements. There is risk in the
fact that the price of a security moves up or down along with the overall market, regardless of the
economic and financial factors considered in evaluating the stock.
CYCLICAL ANALYSIS. In this type of technical analysis, the movements of a stock against the
overall market are analyzed to predict the price movement of the security.
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QUANTITATIVE ANALYSIS. Mathematical modeling is used to obtain more accurate
measurements of a company’s quantifiable data, such as the value of a share price or earnings per
share, and to predict changes to that data. A risk in using quantitative analysis is that the models
used may be based on assumptions that prove to be incorrect, including usage of historical data,
which may present certain limitations.
QUALITATIVE ANALYSIS. In this type of analysis, factors that are difficult to quantify (such
as quality of management and operations, labor/client relations, strength of research and
development factors, legal and reputational aspects, which are not readily subject to measurement)
are evaluated to predict changes to share price based on that data. A risk in using qualitative
analysis is that our subjective judgment may prove incorrect.
ASSET ALLOCATION. Rather than focusing primarily on securities selection, we attempt to
identify an appropriate ratio of securities and fixed income suitable to the client’s investment goals
and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases
in a security, industry, or market sector. Another risk is that the ratio of securities and fixed income
will change over time due to stock and market movements and, if not corrected, will no longer be
appropriate for the client’s goals. In addition, the fixed income portion of Azzad’s Ethical Wrap
Program is not diversified because it invests solely in a proprietary mutual fund, the Azzad Wise
Capital Fund (WISEX).
THIRD PARTY MODEL MANAGERS. A risk of investing with a third-party manager who has
been successful in the past is that he/she may not be able to replicate that success in the future. In
addition, we do not control the underlying investments in a third-party manager’s portfolio (other
than enforcing our socially responsible Islamic screens). There is a risk that a manager may deviate
from the stated investment mandate or strategy of the portfolio, making it a less suitable investment
for our clients. Moreover, as we do not control the manager’s daily business and compliance
operations, we may be unaware of the lack of internal controls necessary to prevent business,
regulatory, or reputational deficiencies. To mitigate these risks, Azzad conducts ongoing due
diligence on the managers it hires in the Ethical Wrap Program.
SOCIALLY RESPONSIBLE ISLAMIC INVESTMENT PHILOSOPHY. Our investment
approach incorporates socially responsible Islamic investment screens with our affiliated and
independent portfolio managers’ specific investment process to deliver a portfolio that we believe
is promising. These screens include avoiding companies that earn more than 5% of their revenue
from the following lines of business: alcohol, tobacco, pork, gambling, pornography, defense
companies, insurance, and interest lending arrangements (which means we avoid most banks and
financial services companies). In addition to the above qualitative screens, we also incorporate
financial screens in our investment philosophy such as avoiding companies with excessive debt.
To assist portfolio managers in choosing stocks that comply with our investment philosophy, we
created a proprietary software application. ISFA (Investment Screening Filtering Application)
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helps managers automatically screen their stock universe(s) for compliance with our investment
guidelines. Once a security passes, it must then pass the manager’s investment process to be
included in the portfolio. However, we recognize that companies are dynamic, and their balance
sheets and lines of business can change periodically. Therefore, we continue to monitor all our and
our managers’ holdings to ensure that they remain in compliance with our investment philosophy.
Our managers also refrain from using certain investment techniques we believe are contrary to our
investment philosophy. These include, but are not limited to, buying, and selling on margin, short
selling, hedging, and using options trading.
Investment Strategies
Client accounts are invested in one of five asset allocation strategies ranging from conservative to
aggressive. Clients may also choose to work with their Investment Adviser Representatives to
develop different variations of these five asset allocation strategies. The strategies vary in their
exposure to different equity categories (diversified among international, large/mid/small, REITs,
and others) and fixed income (as represented by the Azzad Wise Capital Fund). Due to Azzad’s
investment philosophy, the fixed income portion of the strategies is not diversified and limited to
the Adviser’s proprietary mutual fund.
B. Investment Risks
Although we work hard to preserve capital and achieve real growth of client wealth, all investments
bear different types and degrees of risk and investing in securities involves risk of loss (including
loss of principal) that clients should be prepared to bear. No investment strategy can protect
against the risk of loss in the stock markets. Our managers use various investment techniques and
strategies to try to control risk in the portfolios they manage. Still, some investments have
significantly greater risks than others. Obtaining higher rates of return on investments entails
accepting higher levels of risk. Recommended investment strategies seek to balance risks and
rewards to achieve investment objectives. Clients need to ask questions about risks they do not
understand. We would be pleased to discuss them. Ultimately, however, there is no guarantee that
your investments will not lose money. Clients should understand that they could lose some or all
their investment and should be prepared to bear the risk of such potential losses.
We strive to render our best judgment on behalf of our clients. Still, we cannot assure or guarantee
clients that investments will be profitable or assure them that no losses will occur in an investment
portfolio. Past performance is an important consideration with respect to any investment or
investment adviser but is not a reliable predictor of future performance. We continuously strive
to provide outstanding long-term investment performance, but many economic and market
variables beyond our control can affect the performance of an investment portfolio.
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C. Other Investment Risks
American Depository Receipts. We may invest in American Depository Receipts (“ADR”), also
known as American depositary shares. An ADR is a receipt for the shares of a foreign-based
corporation held in the vault of a U.S. bank and entitling the shareholder to all dividends and
capital gains. Instead of buying shares of foreign-based companies in overseas markets, Americans
can buy shares in the U.S. in the form of ADRs. ADRs are available for hundreds of stocks from
numerous companies. ADRs make trading foreign securities in the U.S. easier by eliminating
currency exchange, legal obstacles, foreign ownership transfers and the need to trade on a foreign
exchange. While an ADR removes direct foreign currency ownership, the value of the ADR share
is still impacted by changes in the U.S. dollar to foreign currency exchange rate.
ADRs can be created/canceled through a custodian depository bank. The bank usually charges a
fee for conversion. If the ordinary shares are bought in the foreign market, those shares are sent to
the depository custodian where they are converted from ordinary to ADR form. In the case of a
sale, the custodian cancels the ADR and delivers the ordinary shares. ADRs that are created in this
manner may have low trading liquidity on the U.S. exchanges. Selling a low liquidity ADR on a
US exchange may have excessive transaction costs. Thus, such shares may need to be sold in their
home foreign market and delivered through cancellation of their ADR.
Equity Securities. An account investing all its assets in common stocks bears the risk that the value
of the stocks it holds may decrease in response to the activities of an individual company or in
response to general market, business, and economic conditions. If this occurs, the account value
may also decrease.
Market Risk. This risk exists in all our accounts and means that the risk of the price of securities
in a market, a sector or an industry will fluctuate and that such movements might reduce an
investment’s value.
Concentration Risk. Concentrating investments in a country, region, market, and industry or asset
class means that performance will be more susceptible to loss due to adverse occurrences affecting
that country, region, market, and industry or asset class.
Non-Diversification Risk. Non-Diversification of investments means a portfolio may invest a large
percentage of its assets in securities issued by or representing a small number of issuers. Thus, the
portfolio’s performance may depend on the performance of a small number of issuers.
Small Companies. Typically, securities of small companies are less liquid than securities of large
companies. The stocks of small companies are generally more sensitive to purchase and sale
transactions and, therefore, the prices of such securities may be more volatile than those of larger
companies.
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Socially Responsible Islamic Investing Risks. We will invest in securities only if they meet both
our investment and socially responsible Islamic requirements, and as such, your return may be
lower than if we made decisions based solely on investment considerations. Moreover, our screens
typically exclude the stocks of most financial and utility companies. When these sectors are
outperforming, our portfolios may underperform their benchmarks. If we believe a company has
violated our socially responsible Islamic investment philosophy, then we will request that the
manager sell the security. This policy could result in the manager selling a security at an
inopportune time from a purely financial point of view. Moreover, it can create higher turnover
and lead to short-term tax consequences.
Tax Considerations. Our strategies and investments may have unique and significant tax
implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not
our primary consideration in the management of your assets. Regardless of your account size or
any other factors, we strongly recommend that you continuously consult with a tax professional
prior to and throughout the investing of your assets. Please note that decisions about cost basis
accounting methods will need to be made before trades settle, as the cost basis method cannot be
changed after settlement.
Cyber Security Risks and Disaster Recovery. Cybersecurity incidents and cyber-attacks have been
occurring globally at a more frequent and severe level and will likely continue to increase in
frequency in the future. Azzad and its service providers’ information and technology systems may
be vulnerable to damage or interruption from computer viruses or other malicious code, network
failures, computer and telecommunication failures, infiltration by unauthorized persons and
security breaches, usage errors by their respective professionals or service providers, power,
communications or other service outages and catastrophic events such as fires, tornadoes, floods,
hurricanes, and earthquakes. If unauthorized parties gain access to such information and
technology systems, they may be able to steal, publish, delete, or modify private and sensitive
information. Although Azzad has implemented, and service providers may implement or already
have implemented, various measures to manage risks relating to these types of events, such
systems could prove to be inadequate and, if compromised, could become inoperable for extended
periods of time, cease to function properly, or fail to adequately secure private information.
Breaches such as those involving covertly introduced malware, impersonation of unauthorized
users and industrial or other espionage may not be identified even with sophisticated prevention
and detection systems, potentially resulting in further hard and preventing it from being addressed
appropriately. The failure of these systems and/or disaster recovery plans for any reason could
cause interruptions in Azzad’s operations and result in a failure to maintain the security,
confidentiality, or privacy of sensitive information (including material non-public information in
connection with investments) and, potentially including personal information relating to clients, if
any.
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9. Disciplinary Information
On September 17, 2024, the SEC entered an Order Instituting Administrative and Cease-and-
Desist Proceedings, Making Findings and Imposing Remedial Sanctions and a Cease-and-Desist
Order (the “Order”). Specifically, the Order reflects the SEC’s finding that from the quarter ending
December 31, 2019, to the quarter ending September 30, 2023, Azzad had investment discretion
over at least $100 million of reportable 13F securities and was therefore obligated to file quarterly
Forms 13F beginning by at least February 2020. However, Azzad failed to file Forms 13F until
April 2024. In April 2024, Azzad filed fifty-two Forms 13F, which covered the period from the
quarter ending December 31, 2010, to the quarter ending September 30, 2023, inclusive. In
connection with the Order, Azzad agreed to: cease and desist from committing or causing any
violations of Section 13(f)(1) under the Securities Exchange Act of 1934 and Rule 13F-1
promulgated thereunder, the entry of a censure, and to pay a civil money penalty of $225,000. In
determining to accept Azzad’s offer of settlement, the SEC considered certain remedial acts
promptly undertaken by Azzad. Azzad consented to the entry of the Order without admitting or
denying the factual findings or conclusions of law. Additional details can be found at
https://www.sec.gov/files/litigation/admin/2024/34-101054.pdf. The Order and the underlying
settlement should not have any impact on client accounts or services received from Azzad.
10. Other Financial Industry Activities and Affiliations
Azzad sponsors and acts as Investment Adviser to the Azzad Funds family of no-load mutual funds
(investment companies) consisting of the Azzad Ethical Fund (ADJEX) and the Azzad Wise
Capital Fund (WISEX). We provide administration and investment management services to the
Azzad Funds. The portfolio manager of the Azzad Funds (overseen by an Investment Committee)
also manages various portfolios in our wrap accounts.
For the reasons above, we have an incentive to, and in fact may if we deem it suitable to, hold
shares of our affiliated mutual funds (Azzad Wise Capital Fund and/or Azzad Ethical Fund) in
client wrap accounts so that clients will have a complete picture of their assets. In such
circumstances, we will not charge our wrap program fee on these assets. However, clients should
understand that we will receive any fees paid by the Azzad Fund as disclosed in the applicable
prospectus for the Fund. That fee may be higher or lower than the fee a client may be paying on
other assets that we manage in the client’s wrap account.
Azzad does not select third party investment advisers for its clients. We only select independent
investment managers for our Ethical Wrap Program, which is described above under Item 4.B.
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11. Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Description
Azzad has adopted a Code of Ethics for all supervised persons of the firm describing its high
standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes
provisions relating to the confidentiality of client information, a prohibition on insider trading,
restrictions on the acceptance of significant gifts and the reporting of certain gifts and business
entertainment items, and personal securities trading procedures, among other things. All
supervised persons at Azzad must acknowledge the terms of the Code of Ethics annually, or as
amended.
A complete copy of Azzad’s current Code of Ethics is available by sending a written request to
Azzad Asset Management, Inc., Attn: Compliance, 3141 Fairview Park Dr. Suite 355, Falls
Church, VA 22042, or by contacting Lejeana Love, Chief Compliance Officer, at 202.750.9093.
B. Material Interest in Securities
When acting as a portfolio manager to the Ethical Wrap Program, Azzad may recommend
inclusion of the Azzad Funds, the Azzad Ethical Fund (ADJEX) and Azzad Wise Capital Fund
(WISEX). This causes a conflict of interest because Azzad acts as the Investment Advisor to the
mutual funds and receives a separate fee for this service. As a result of this conflict, Azzad has
created several policies and procedures to mitigate the conflict of interest.
It is Azzad’s policy that our Investment Adviser Representatives should only make the
recommendation to use Azzad Funds when it is consistent with the client’s investment objectives.
In addition to their fiduciary duty to the client, Azzad has adopted a Code of Ethics that binds its
Investment Adviser Representatives. Furthermore, Azzad waives the wrap program fee on assets
invested in the Azzad Funds but does receive a management fee on these assets. Finally, the
Program’s clients have full discretion to request the removal of Azzad Funds from their accounts.
C. Investing or Recommending in the Same Securities
Subject to satisfying this policy and applicable laws, officers, directors, and employees of Azzad
and its affiliates may trade for their own accounts in securities that are recommended to and/or
purchased for Azzad’s clients. The Code of Ethics is designed to assure that the personal securities
transactions, activities and interests of the employees of Azzad will not interfere with (i) making
decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the
same time, allowing employees to invest for their own accounts. Under the Code, certain classes
of securities have been designated as exempt transactions, based upon a determination that these
would materially not interfere with the best interests of our clients. In addition, the Code requires
pre-clearance of many transactions and restricts trading in close proximity to client trading activity.
Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest
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in the same securities as clients, there is a possibility that employees might benefit from market
activity by a client in a security held by an employee. Employee trading is continually monitored
under the Code of Ethics, and to reasonably prevent conflicts of interest between Azzad and its
clients.
It is our policy that the firm will not affect any principal or agency cross-securities transactions for
client accounts. We also do not conduct cross trades between client accounts. Principal
transactions are generally defined as transactions where an adviser, acting as principal for its own
account or the account of an affiliated broker-dealer, buys from or sells any security to any
advisory client. A principal transaction may also be deemed to have occurred if a security is
crossed between an affiliated hedge fund and another client account. An agency cross transaction
is defined as a transaction where a person acts as an investment adviser in relation to a transaction
in which the investment adviser, or any person controlled by or under common control with the
investment adviser, acts as broker for both the advisory client and for another person on the other
side of the transaction. Agency cross transactions may arise where an adviser is dually registered
as a broker-dealer or has an affiliated broker-dealer.
12. Brokerage Practices
A. Recommendation Criteria
Azzad does not place client trades with an affiliated broker-dealer since it does not conduct its own
brokerage activities, therefore we must utilize the brokerage and clearing services of Goldman
Sachs Company, Charles Schwab & Co., Inc., and/or Fidelity Brokerage Services, LLC, members
FINRA/SIPC. We are independently owned and operated and not affiliated with any broker-dealer.
Unless we receive specific directions from a client regarding the placement of brokerage business,
we select the broker-dealer to effect clients’ transactions. We consider various factors in selecting
a broker, including, but not limited to: the broker’s execution capability, custodial and other
services provided by the broker that are expected to enhance our general portfolio management
capabilities, sound financial condition, reputation and integrity and the broker’s knowledge of
market, securities, and industries, as well as the broker’s responsiveness. Commission rates paid
on securities transactions must also reflect comparative market rates. However, the lowest possible
commission cost alone does not determine brokerage selection. Another important consideration
is acceptable record keeping, e.g., timely and accurate written confirmations and statements.
As stated previously, wrap accounts are not charged a separate brokerage fee and do not incur
commission costs outside of the wrap fee. Azzad strives to execute each client’s securities
transactions in such a manner that the client’s total costs or proceeds in each transaction are the
most favorable under the circumstances. Schwab’s asset-based fees applicable to our client
accounts were negotiated based on our commitment to maintain $65 million of our clients’ assets
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in accounts at Schwab. This commitment benefits you because the overall asset-based fees you
pay are lower than they would be if we had not made this commitment.
Azzad periodically and systematically reviews its policies and procedures regarding its
recommendation of broker-dealers considering its duty to obtain best execution.
Azzad’s sub-advisers have discretion to determine which broker-dealer(s) they will use, and the
commission rates paid by Azzad Fund shareholders for the Azzad Funds. As the investment adviser
to the Azzad Funds, Azzad has implemented policies and procedures in place to oversee the Funds’
sub-advisers’ brokerage selection and review process.
B. Research and Other Soft Dollar Benefits
“Soft dollars” are defined as a form of payment investment firms can use to pay for goods and
services such as subscriptions or research. When an investment firm gives its business to a
brokerage firm, the brokerage firm in return can agree to use some of its revenue to pay for these
types of services. Azzad does not have arrangements to receive soft dollar benefits in connection
with securities transactions in the Azzad Funds. As stated above, each Fund sub-adviser has full
discretion to place buy and sell orders with or through such broker-dealers as it may deem
appropriate. It is the policy and practice of Azzad to strive for the best price and execution that are
competitive in relation to the value of the transaction (“best execution”).
Although Azzad does not have any arrangements to receive soft dollar benefits in connection with
client securities transactions for its wrap or other investment advisory accounts, it may be eligible
to receive certain economic benefits from the broker-dealer it selects for its clients. By selecting
Goldman Sachs, Azzad may be eligible to receive certain economic benefits that are typically not
available to retail clients. These benefits include the following products and services (either
without cost or at a discount): duplicate client statements and confirmations, the ability to have
advisory fees deducted directly from client accounts, access to an electronic communications
network for client order entry and account information, and consulting services. However, the
benefits received by Azzad through participation in the broker-dealer’s institutional program do
not depend on the amount of brokerage transactions directed to it.
Azzad may recommend that certain clients establish brokerage accounts with Schwab Advisor
Services (“Schwab”) a division of Charles Schwab & Co., Inc., to maintain custody of clients’
assets and to effect trades for their accounts. The final decision to custody assets with Schwab or
other broker-dealers is at the discretion of the client.
If clients choose to use Schwab, Azzad is required to disclose the economic benefits made available
to the Firm by Schwab. Azzad, however, may choose not to take advantage of these additional
economic benefits, while retaining the brokerage services of Schwab. Schwab Advisor Services
offers certain additional services to clients such as brokerage, execution of securities transactions,
custody, research, etc. For Azzad clients’ accounts maintained in Schwab’s custody, Schwab
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generally does not charge additional fees for custody services. Schwab is compensated by account
holders through commissions or other transaction-related, or asset-based fees for securities trades,
which are executed through them or that settle into their accounts.
Schwab also makes available to Azzad other products and services that may benefit the Firm but
may not directly benefit its clients’ accounts. Such benefits may include educational events
organized or sponsored by Schwab. Other potential benefits may include occasional business
entertainment of personnel of Azzad, such as invitations to sporting events, golf tournaments, and
other forms of entertainment, some of which may accompany educational opportunities.
Other products and services may assist Azzad in managing and administering clients’ accounts.
These include software and other technology (and related training) 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), provide research, pricing
information and other market data, facilitate payment of advisers’ fees from its clients’ accounts,
and assist with back-office training and support functions, recordkeeping and client reporting. If
the Firm chooses to take advantage of some of these offerings, these services may be used to
service Azzad clients’ accounts, including accounts not maintained at Schwab Advisor Services.
Schwab also makes available to Azzad other services intended to help the Firm manage and further
develop its business enterprise. These services may include professional compliance, and other
business operations services. Schwab may discount or waive fees it would otherwise charge for
some of these services or pay all or a part of the fees of a third-party providing these services to
advisers.
Clients should be aware, however, that the receipt of economic benefits by Azzad in and of itself
creates a potential conflict of interest and may indirectly influence Azzad’s selection for custody
and brokerage services. As a fiduciary, we endeavor to always act in our clients’ best interests.
Our recommendation that clients maintain their assets in accounts at a specific broker-dealer is
based solely on the nature, cost or quality of custody and brokerage services provided by the
broker-dealer regardless of any other products or services which may be provided to the Firm. We
are aware, however, that the availability of some of the foregoing products and services may create
a potential conflict of interest.
C. Brokerage for Client Referrals
Azzad does not have any arrangements to receive client referrals from any broker-dealer.
D. Directed Brokerage
Some clients may direct us in writing to a specific broker-dealer to execute securities transactions
for their accounts. When so directed, we may not be able to achieve the most favorable execution
of clients’ transactions. This can result in substantially higher fees, charges, or dealer concessions
in one or more transactions for the clients’ account because the Adviser cannot negotiate favorable
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prices. Subject to its duty of best execution, Azzad may decline a client’s request to direct
brokerage if, in Azzad’s sole discretion, such directed brokerage arrangements would result in
additional operational difficulties.
Azzad generally recommends that wrap clients open their accounts with Goldman Sachs Company,
Charles Schwab & Co., Inc., or Fidelity Brokerage Services, LLC, members FINRA/SIPC for
custody and brokerage services. If a client does not wish to place assets with these custodians, then
Azzad may not be able to manage the account as a wrap account.
E. Trade Aggregation
Azzad typically has complete discretion over the selection and quantity of securities to be brought
or sold without obtaining specific client consent. As noted above, Azzad seeks to obtain “best
execution” on each portfolio transaction for clients. As part of our effort to obtain best execution,
Azzad aggregates trades in individual securities for as many accounts as practicable, except where
subject to client direction constraints. Each account that participates in a block trade that is filled
at several different prices through multiple trades will receive the average share price.
When using Goldman Sachs to execute brokerage trades, Azzad conducts all its brokerage trades
through Window Trades. Instead of being executed immediately, Window orders are grouped
together by side and symbol, one or more times per day, and executed. The orders are collected
until each Window deadline. Orders placed after the last Window on any business day are generally
processed in the first Window of the next trading day. If a client wants to trade securities
immediately or requests to trade securities that cannot be traded through a Window, Azzad will
send a Direct Trade order immediately to the market for execution.
13. Review of Accounts
A. Periodic Reviews
Azzad strives to ensure compliance with each client’s investment guidelines, consistent with our
fiduciary responsibility to manage the account in a client’s best interests. We review our wrap
allocation models as well as the specific portfolios managed (by us and our independent managers)
frequently, with a specific review occurring monthly, and a more general review conducted at least
once a quarter. All portfolios are reviewed continuously rather than periodically. The portfolios
and allocation models are reviewed by the investment team and then overseen by an investment
committee that meets at least once a quarter (and more frequently when conditions warrant). The
Azzad Funds’ board of trustees, with Azzad’s assistance, also reviews the Azzad Funds’
portfolio(s) at least once a quarter.
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Investment Adviser Representatives also conduct reviews with their clients at least quarterly or
more frequently as warranted or requested by the client. Representatives meet with clients to
review their accounts and the advisory relationship.
B. Other Reviews
Additional reviews are conducted periodically depending on market conditions, economic or
political events, or by changes in a client’s financial situation, investment objectives and
guidelines, market conditions, reaching life milestones, and so forth.
C. Reports
Clients receive separate monthly account statements from their custodian detailing all cash and
asset transactions, activity, and holdings information. Statements are available electronically by
downloading them off the custodian’s website. Clients receive, by email, notifications that their
statements are ready for downloading. Clients may then log into their account(s) with a secure
username and password.
You may also access your performance information by using a portal maintained by an unaffiliated
company called Orion Advisor Services, LLC (“Orion”). Azzad has contracted with Orion to
utilize its technology platforms to support various administrative services including performance
reporting. Due to this arrangement, Orion will have access to client accounts, but Orion will not
serve as an investment advisor to Azzad clients. The portal may contain a client’s balance, initial
deposits, and other summarized information.
Clients investing directly in the Azzad Funds receive their account statements from the Funds’
transfer agent at least once a quarter. They will receive a variety of reports including semi-annual
and annual reports with respect to their shares, as required by the Investment Company Act of
1940. They may also access their account information online at
https://www.mutualss.net/azzad/login.aspx and log in with their investor number and password.
Investors may obtain their login information by calling the funds' transfer agent at 888-350-3369.
14. Client Referrals and Other Compensation
A. Other Compensation
Azzad and its IARs do not receive extra compensation or any other economic benefit for providing
investment advice or other advisory services to clients.
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B. Client Referrals
Azzad employees market services to clients on a direct basis in accordance with the new Marketing
Rule 206(4)-1. Azzad does not direct brokerage transactions to any third party in return for client
referrals. Azzad does not have any referral or solicitation arrangements with third parties.
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15. Custody
All client funds, securities and accounts are held by independent third-party custodians. Azzad
does not take possession of a client’s securities or funds. Clients will receive account statements
directly from their third-party custodians for the accounts and should carefully review these
statements. Clients should contact Azzad immediately if they do not receive account statements
from their custodian on at least a quarterly basis. As noted in Item 13, Azzad may provide clients
with separate reports or account statements providing information about their account. Clients
should compare these carefully to the account statements received from the custodian. Azzad’s
statements may vary slightly from custodial statements based on accounting procedures, reporting
dates, or valuation methodologies of certain securities. In the event of any discrepancies, you
should rely on the statement you receive from the custodian of your assets. If clients discover any
discrepancies, they should contact Azzad immediately.
16. Investment Discretion
For the Ethical Wrap Program, most of our other advisory relationships and Azzad Funds, we have
discretionary authority to make determinations regarding the securities that are purchased and sold,
as well as the quantities of such securities. Discretion over the account is obtained when the client
signs the investment advisory contract. Azzad exercises its investment discretion consistent with
its investment philosophy, ethical investment guidelines and any other restrictions imposed by the
client and accepted by Azzad. Any additional investment guidelines and restrictions must be
provided to Azzad in writing. If client is a profit-sharing plan, trust, estate, charitable organization
or other business entity, Azzad may comply with such limitations as may be imposed by the
individuals, board of directors or trustees of such entities and with the stated investment objectives
of such clients of the plans involved.
Azzad normally sells some or all the securities in a client’s account after the initial receipt of the
account or the deposit of additional securities into the account. Some securities may be retained in
the account to the extent that they are included in our normal holdings for such an account or at a
client’s request. The client is solely responsible for any tax liabilities that result from such
transactions. If a client makes a special request to hold or purchase securities, then they will be
held in a sub-account. The client is solely responsible for the management of any securities held
in a sub-account.
For the Azzad Funds (which are registered investment companies) Azzad’s authority to trade
securities may be limited by certain federal securities and tax laws that require diversification of
investments and favor the holding of investments once made.
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A non-discretionary investment account means the client retains full discretion to supervise,
manage, and direct the assets of the account. The client maintains full power and authority to
purchase, sell, invest, reinvest, exchange, convert, and trade the assets in the account in any manner
deemed appropriate and to place all orders for the purchase and sale of account assets with or
through brokers, dealers, or issuers selected by the client. The client is free to manage the account
with or without our recommendations and all with or without prior consultation with us.
17. Voting Client Securities
Unless directed by the client in writing, Azzad will vote proxies on behalf of our advisory accounts.
Azzad also votes proxies on behalf of the Azzad Funds. Azzad votes client securities in the best
interests of the clients and then in accordance with its ethical investment philosophy and
guidelines. In general, this entails voting client proxies with the objective of increasing the long-
term economic value of client assets. Azzad seeks to avoid the occurrence of actual or apparent
material conflicts of interest in the proxy voting process by voting in accordance with
predetermined voting guidelines. In all cases in which there is deemed to be a material conflict of
interest, Azzad will seek to resolve the conflict in the clients’ best interests. Clients may obtain a
copy of Azzad’s complete proxy voting policies and procedures upon request. Clients may also
obtain information from Azzad about how we voted proxies on behalf of their accounts(s). Please
contact our Chief Compliance Officer at 202.750.9093.
18. Financial Information
We have no financial condition that is reasonably likely to impair our ability to meet contractual
commitments to you and we have never been the subject of a bankruptcy proceeding. Azzad does
not require prepayment of more than $1,200 in fees per client, six months or more in advance.
Therefore, a balance sheet is not required and not attached.
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