SHARIAPORTFOLIO WRAP BROCHURE 2026

WRAP FEE PROGRAM BROCHURE Form ADV Part 2A Appendix 1 March 31, 2026 ShariaPortfolio, Inc. 1331 S. International Parkway, Suite 2291 Lake Mary, Florida 32746 Phone: (321) 275-5125 Fax: (321) 275-5126 www.shariaportfolio.com This wrap fee program brochure provides information about the qualifications and business practice of ShariaPortfolio, Inc. If you have any questions about the contents of this brochure, please contact us at 321-275-5125 or info@shariaportfolio.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state security authority. Additional information about ShariaPortfolio, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. ShariaPortfolio, Inc. is a registered investment adviser with the United States Securities and Exchange Commission (“SEC”). Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of ShariaPortfolio, Inc. provides you with information about which you may use to determine to hire or retain ShariaPortfolio, Inc.  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 ITEM 2: MATERIAL CHANGES SEC Rule 204-3(b)(2) allows us to provide you with a summary page of Material Changes in lieu of sending out our entire Wrap Fee Program Brochure. If you are being offered this Material Change page as a separate piece from our Wrap Fee Program Brochure and you have questions about these summary disclosures or would like a current copy of our Wrap Fee Program Brochure to review, you may contact us and a current, complete Wrap Fee Program Brochure will be sent free of charge. Since our last update of this brochure in March 2025, the following material updates were made: • Enhanced disclosure of wrap fee program conflicts of interest • Clarification of fee structure and comparison to non-wrap services • Addition of digital platform and third-party technology risk disclosures • Clarification of the Firm’s proxy voting practices with respect to the private fund managed by the Firm • Clarification of the Firm’s role with respect to certain private funds that are operated by affiliated entities and/or their principals. The structure and allocation of responsibilities among these entities may vary and the Firm’s affiliates may participate in the investment and operational activities of such funds. Pursuant to State and SEC Rules, ShariaPortfolio, Inc. (“ShariaPortfolio” or the “Firm”) will ensure that clients receive a summary of any materials changes to this Brochure within 120 days of the close of ShariaPortfolio’s fiscal year. Additionally, as the firm experiences material changes in the future, we will send you a summary of our “Material Changes” under separate cover. For more information about the firm, please visit www.shariaportfolio.com. 2  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 ITEM 3: TABLE OF CONTENTS ITEM 4: SERVICES, FEES AND COMPENSATION ....................................................................................................................... 4 ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............................................................................................ 6 ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ....................................................................................... 6 ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ....................................................................... 8 ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................................. 8 ITEM 9: ADDITIONAL INFORMATION .......................................................................................................................................... 8 3  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 ITEM 4: SERVICES, FEES AND COMPENSATION Wrap Fee Program Overview ShariaPortfolio sponsors a wrap fee program (the “Express Program” or “Program”), through which clients pay a single asset-based fee for bundled advisory, brokerage, custody, and administrative services. The Program is offered through an online platform and provides discretionary portfolio management using model portfolios. The Firm determines suitability for participation based on client information. Services Provided Services include: • Portfolio management on a discretionary basis • Asset allocation and rebalancing • Ongoing monitoring of client accounts • Access to client service support via electronic and telephone communication Client Onboarding and Portfolio Selection As part of the onboarding process, the Firm collects information regarding a client’s financial situation, investment objectives, risk tolerance, time horizon, and other relevant factors through an online assessment and/or discussions with the client. This information is used to recommend an appropriate investment strategy and model portfolio. Clients are responsible for notifying the Firm of any material changes to their financial circumstances or investment objectives so that the Firm can update its recommendations and portfolio management approach as necessary. Charles Schwab & Co., Inc. (“Schwab”) serves as the qualified custodian and executes transactions. Fees Clients pay a single asset-based fee, billed quarterly in advance, which covers advisory services, custody, and most transaction costs. In addition to the wrap fee, clients will incur indirect expenses associated with investments held in their account, including ETF and mutual fund expense ratios and other investment-related costs. These expenses are in addition to the wrap fee and will reduce overall returns. The wrap fee does not include: • ETF and mutual fund expense ratios Internal fund fees and expenses • • Certain transaction costs (e.g., trades executed away from the custodian) • Wire fees, taxes, or other account-related expenses Wrap Fee vs. Non-Wrap Programs The wrap fee program may cost more than purchasing advisory and brokerage services separately, particularly in accounts with low trading activity or buy-and-hold strategies. Conversely, accounts 4  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 with higher trading activity may benefit from bundled pricing. Clients should consider expected trading frequency and account activity when evaluating whether the Program is appropriate. Conflicts of Interest – Wrap Fee Structure Because the Firm bears certain transaction costs associated with client accounts, the Firm has a financial incentive to reduce trading activity, select investments with lower transaction costs, or otherwise manage accounts in a manner that minimizes such costs. This may create a conflict of interest, as it could influence the Firm’s trading decisions. The Firm addresses this conflict by maintaining policies and procedures designed to ensure that investment decisions are made in the client’s best interest. Affiliated Investment Products The Firm may recommend or allocate client assets within the Program to ETFs or other investment products for which the Firm or its affiliates serve as investment adviser, sub-adviser, or otherwise receive economic benefits. The Firm also manages a private fund outside of the Program. The Firm is affiliated with SP Funds Management, LLC (“SP FM”), an entity involved in the operation of certain private funds. Although the Firm does not provide investment advisory services to certain of these funds, it may recommend that eligible clients invest in such funds from time to time. Due to the Firm’s ownership interest in SP FM and the involvement of shared personnel, the Firm may have indirect economic interests in these affiliated entities. These relationships create conflicts of interest, including an incentive to recommend investments in affiliated private funds. The Firm charges an asset-based fee for accounts in the Express Program, billed quarterly in advance, based on assets under management as follows: Assets Under Management 0 to $500,000 $500,000 to $1,000,000 $1,000,001 to $5,000,000 > $5,000,000 Mutual Fund/ETF Portfolios Annual Advisory .75% .60% .50% .40% .50% The wrap fee includes portfolio management, administration, and Schwab’s custody, trade execution, and related brokerage services. Clients should be aware that the wrap fee does not include certain costs, including ETF and mutual fund expense ratios, internal fund expenses, and other account-related fees, which will reduce overall returns. Additional Fee Considerations Clients funding Program accounts through the liquidation of investments outside the Program may incur tax consequences, redemption fees, or other costs. The total cost of the Program may be higher or lower than purchasing advisory and brokerage services separately. In particular: 5  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 • Accounts with low trading activity or buy-and-hold strategies may pay more in a wrap program • Accounts with higher trading activity may benefit from bundled pricing Because the Firm bears certain transaction costs in wrap accounts, the Firm has an incentive to reduce trading activity, which creates a conflict of interest. Lower fees for comparable services may be available from other providers. Fees may be negotiated at the Firm’s discretion. Billing and Termination Fees are billed quarterly in advance and are prorated for accounts opened or terminated during a billing period. Either party may terminate the advisory agreement upon written notice. Upon termination: • Fees are prorated through the termination date • Unearned fees are refunded • Any earned but unpaid fees are due Following termination, the Firm will cease management of the account, and clients will be responsible for investment decisions. The custodian may require additional time to transfer or liquidate assets. Asset Allocation Models The Program utilizes model portfolios with target allocation ranges across asset classes, including equity, Sukuk (income), cash, and real estate. Allocations may vary based on market conditions, and portfolios may temporarily deviate from target ranges when deemed appropriate. Wrap Fee Considerations The wrap fee is not based on the number of transactions in the account. The relative cost of the Program depends on factors such as account size, investment strategy, and trading activity. As a result, the Program may cost more or less than paying for advisory and brokerage services separately. The Program utilizes model portfolios with target allocations across asset classes, including equities, income (Sukuk), cash, and real estate. Allocations vary based on the selected investment strategy and may change over time. Under certain market conditions, portfolios may deviate from target allocations. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS The Program is available to individuals, IRAs, and certain trusts. The Program is generally not available to ERISA plans or institutional clients. While there is no strict minimum account size, the Firm may establish operational thresholds and investment limitations based on account size. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION Selection and Review of Portfolio Manager 6  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 ShariaPortfolio serves as the portfolio manager for Program accounts. Investment Adviser Representatives manage client accounts using model portfolios and are subject to internal oversight and review. The Firm conducts ongoing internal reviews of portfolio performance, consistency with model strategies, and adherence to client objectives. Performance-Based Fees The Program does not include performance-based fees. However, the Firm offers performance-based fee arrangements in other advisory programs, which may create differences in incentives across accounts. Investment Strategies and Risks Investment strategies are primarily based on diversified model portfolios utilizing ETFs and other securities. Risks include: Interest rate risk • Market risk • Liquidity risk • • Allocation risk Wrap Program-Specific Risks Additional risks include: • Reduced trading activity due to cost considerations • Higher overall costs for low-activity accounts • Reliance on model portfolios Digital Platform Risk The Program relies on third-party technology providers and digital platforms. Risks include system outages, cybersecurity incidents, data inaccuracies, vendor dependency, and service interruptions, any of which could impact account access, trading, or reporting. Voting Client Securities The Firm does not vote proxies for wrap program client accounts. Clients retain the responsibility for voting proxies for securities held in their accounts, and proxy materials are sent directly to clients by the custodian. The Firm may vote proxies with respect to certain private fund investments where it has been delegated such authority. 7  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 If the Firm receives proxy materials on behalf of a client, such materials will be promptly forwarded to the client. Upon request, the Firm may provide information to help clients understand proxy matters; however, the Firm does not provide advice or recommendations on how to vote. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Investment Adviser Representatives (“IARs”) manage client accounts within the Program. In connection with account onboarding, the Firm collects information regarding a client’s financial situation, investment objectives, and risk tolerance, which is used to determine an appropriate investment strategy and model portfolio. Ongoing account management is based on this information and any updates provided by the client. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS Clients may contact the Firm through electronic communication or telephone. There are no restrictions on client access. ITEM 9: ADDITIONAL INFORMATION Brokerage and Custodial Conflicts The Firm recommends Schwab as custodian and receives certain economic benefits from this relationship. These benefits create a conflict of interest, as they provide an incentive to recommend Schwab. Code of Ethics and Personal Trading The Firm maintains policies to address conflicts related to employee trading and client transactions. Review of Accounts Accounts are monitored on an ongoing basis and reviewed periodically to ensure consistency with client objectives. Client Referrals The Firm may compensate solicitors in accordance with applicable regulations. Financial Information The Firm does not require prepayment of fees exceeding regulatory thresholds and has no financial condition impairments. Disciplinary History Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of the Firm or the integrity of its management. The Firm has no such disciplinary events to disclose. 8  ShariaPortfolio, Inc. Form ADV Part 2A Appendix 1 Other Financial Industry Activities and Affiliations Naushad Virji, a principal and majority shareholder of the Firm serves as Chief Executive Officer of SP Funds Management, LLC (“SPFM”), an affiliated entity involved in certain private funds. Mr. Virji also serves as Chief Executive Officer of Virji Investments, Inc., an investment adviser registered in the State of Florida. Mr. Virji’s involvement with these entities may create potential conflicts of interest, including the allocation of time and resources among multiple business activities. In addition, due to the Firm’s affiliation with SPFM, the Firm may have an incentive to recommend that eligible clients invest in certain affiliated private funds. The Firm has adopted policies and procedures designed to address these conflicts and to ensure that advisory services are provided in the best interest of clients. . 9