GLADSTONE FORM ADV PART 2A, FIRM BROCHURE

Gladstone Wealth Partners - Firm Brochure Gladstone Wealth Partners 2000 PGA Blvd., Suite 4440 Palm Beach Gardens, FL 33408 (908) 719-1313 www.gladstonewealth.com September 22nd, 2026 Item 1. Cover Page This Form ADV Part 2A brochure (“Brochure” or “Disclosure Brochure”) provides information about the qualifications and business practices of Gladstone Institutional Advisory, LLC doing business as Gladstone Wealth Partners (referred to as “Gladstone,” “we," “our,” or “us,”). The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC” or “the Commission”) or by any state securities authority. Registration with the SEC does not imply any specific level of skill or training. information about Gladstone and investment adviser representatives Additional (“IARs,” or its “representatives”) is available on the SEC’s website by searching our name or our CRD No. 250787 at https://adviserinfo.sec.gov/. If you have any questions about the contents of this brochure, please contact us by phone at (908) 719-1313. Item 2. Material Changes Gladstone Wealth Partners (“Gladstone”) filed its last annual update and distribution for its last Form ADV Part 2A (“brochure”) on March 31, 2026. We urge you to carefully review the summary of material changes, as they contain important information, which can impact the advisory relationship between you and Gladstone. Material Changes Since the Last Annual Amendment The following is a summary of material changes made to this Brochure since our last annual updating amendment dated March 31, 2026. • • Item 4 was revised to streamline disclosures and clarify Gladstone’s advisory services, fiduciary roles, and program structures. The revisions distinguish Gladstone’s fiduciary obligations under the Investment Advisers Act of 1940 from its obligations under ERISA; clarify account, program, model portfolio, sub- adviser, and investment-selection practices; correct the name of Gladstone’s parent company to Integrity Wealth, LLC; clarify the scope of the Third-Party Retirement Account Program, including its participant- level ERISA Section 3(21) services and limited discretionary authority; and clarify that new accounts in Gladstone-sponsored wrap programs are managed on a discretionary basis. Item 5 was revised to clarify fee structures, billing practices, and related conflicts of interest. The revisions disclose that certain investment management fees may be calculated as a percentage of assets under management subject to a stated maximum dollar amount; explain how that maximum applies; clarify that fees are assessed on billable assets and how deposits, withdrawals, partial periods, and termination refunds are treated; disclose that Third-Party Retirement Account Program fees are billed quarterly and charged to a separate non-qualified account, and that the technology fee includes a markup; provide the typical fee range for Financial Planning and Consulting services; disclose the maximum asset-based fee for Retirement Plan Consulting services; and revise the GCM Program disclosure to state that clients do not pay a separate KIG fee and that Gladstone pays KIG 0.15% (15 basis points) of assets managed, prorated quarterly. Item 6 was revised to clarify Gladstone does not charge performance-based fees. Item 8 was revised to clarify Gladstone’s methods of analysis, due diligence, and model-portfolio practices • • Page 1 of 30  • • • • • and to expand the discussion of investment risks. The revisions add or enhance disclosures regarding Model Portfolio Risk; Sector Risk; Tax-Managed Investing Risk; Direct Indexing; Values-Based and Environmental, Social and Governance Investing Risk; Unit Investment Trusts; Other Annuity Products; Other Complex Exchange Traded Products; Options; and Private Equity Funds. Item 10 was revised to clarify Gladstone’s compensation arrangement with KIG and clarifies disclosures regarding outside business entities and insurance activities. Items 10 and 12 were revised to clarify that LPL charges an oversight fee of up to 10 basis points on certain assets managed by LPL-registered representatives and held at a custodian other than LPL, and to disclose the resulting financial incentive to recommend LPL as custodian. Item 12 was revised to remove the statement that the Non-Wrap Investment Management Program is available only for at Charles Schwab & Co., Inc. Item 13 was revised to clarify factors considered in periodic account reviews, including continued appropriateness of account type, program, third-party manager, model portfolio, strategy, and fee arrangement. Item 14 was revised to enhance promoter disclosures to include digital marketing companies and clarify conflicts associated with non-cash compensation from product sponsors, managers, and model providers. Item 16 was revised to clarify application and consequences of client-imposed investment restrictions. • Item 3. Table of Contents Item 1. Cover Page ........................................................................................................................................................... 1 Item 2. Material Changes ................................................................................................................................................ 1 Item 3. Table of Contents ................................................................................................................................................ 1 Item 4. Advisory Business ............................................................................................................................................... 2 Item 5. Fees and Compensation .................................................................................................................................... 6 Item 6. Performance-Based Fees and Side-by-Side Management ......................................................................... 12 Item 7. Account Requirements and Types of Clients ............................................................................................... 12 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ................................................................... 12 Item 9. Disciplinary Information ................................................................................................................................. 20 Item 10. Other Financial Industry Activities and Affiliations ................................................................................... 20 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................ 23 Item 12. Brokerage Practices ....................................................................................................................................... 24 Item 13. Review of Accounts ........................................................................................................................................ 26 Item 14. Client Referrals and Other Compensation ................................................................................................. 27 Item 15. Custody ........................................................................................................................................................... 29 Item 16. Investment Discretion ................................................................................................................................... 29 Item 17. Voting Client Securities ................................................................................................................................. 30 Item 18. Financial Information .................................................................................................................................... 30 Item 4. Advisory Business Gladstone Institutional Advisory, LLC, doing business as Gladstone Wealth Partners (referred to as “Gladstone,” “we,” “us,” “our,” “Firm,” or “Adviser”), is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) with its principal office located in Palm Beach Gardens, Florida. Gladstone was established in 2015 and is principally owned by Integrity Wealth, LLC. Gladstone primarily provides asset management, retirement, financial planning, and consulting services to individuals, high-net worth individuals, corporations and other business entities, pension and profit-sharing plans, and charitable organizations (each referred to Page 2 of 30  as a “client” or collectively as “clients”) as described below. As of December 31, 2025, Gladstone has $5,683,810,587 regulatory assets under management of which $5,668,051,947 is managed on a discretionary basis and $15,758,640 is managed on a non-discretionary basis. Gladstone’s business model is based on a network of investment adviser representatives (“IARs,” or “representatives”) with offices located throughout the United States. Our representatives are primarily independent contractors and are subject to our supervision and oversight from a centralized location. Clients may engage Gladstone for one or more of the services set forth herein, which will be detailed in the client’s investment management agreement. It is important to understand that the more assets under management or advisement with Gladstone, the more you will pay in fees. Our representatives are paid a portion of those fees for delivering investment advisory services to you. The portion of fees that a representative receives is not incentive-based but can vary based on the specific agreement the representative negotiated with Gladstone. See Item 5 for additional information regarding fee structures and related conflicts of interest. Unless explicitly stated, Gladstone serves as a fiduciary to its investment advisory clients under the Investment Advisers Act of 1940 and applicable laws and regulations. As a fiduciary, Gladstone has a duty of care and a duty of loyalty and must act in the best interest of its clients, provide advice based on a reasonable understanding of each client's objectives, and make full and fair disclosure of material conflicts of interest. Client Onboarding and Account Type / Program Selection Advisory services are provided by one or more representatives who serve as the primary point of contact between you and Gladstone. Through personal discussions, questionnaires and/or requests for documentation, your representative will gather and analyze information regarding your current investments, goals, investment objectives, financial circumstances, investment experience, limitations, among other information. Gladstone encourages you to notify your representative promptly if you experience any material change in your financial circumstances or investment goals. Your representative will work with you to determine which of our services are appropriate based on your investment goals and objectives which may include one or more of the services described below. Representatives can offer different services and will use different resources, methods of analysis, and investment strategies based on individual client circumstances. Not all services are available to every client, through every representative, or in every jurisdiction. Representatives are required by applicable laws, rules, regulations, and Firm policies to obtain certain licenses or credentials and complete regular training to offer particular investments, products, and/or services. Your representative, depending on their licenses, affiliation, or training, may or may not be able to utilize certain custodians, products, sub-advisors, programs, or services. Please ask your representative whether any limitations apply. Investment Management Programs Client portfolios typically consist of one or more of the following: individual equities, bonds, mutual funds, exchange traded funds (ETFs), exchange traded products (ETPs), alternative assets, variable annuities, cash and cash equivalents, and/or other investment products. As appropriate, the representative can recommend that a portion of your portfolio be allocated to alternative investments. Clients will retain individual ownership of all securities held in their accounts and their advisory agreement will clearly define whether we are acting in a discretionary or non-discretionary capacity. In certain programs, as appropriate, the representative can recommend a portion of your portfolio be Page 3 of 30  managed by one or more sub-advisers subject to the representative’s supervision. Such sub-advisers may also engage third parties at their own expense and at their discretion. Portfolio weighting among various investments, sub-advisors, and market sectors will be determined by each client’s individual needs and circumstances. Given the long-term nature of many of the individual strategies employed by Gladstone, an account can have little or no trading activity during a given period. Certain programs provide access to model asset allocation portfolios managed in accordance with each portfolio’s stated strategy and objectives rather than the investment objectives of any particular client. Depending on the program, the models may be managed by your representative or by a third-party manager. Your representative is responsible for determining whether a model is appropriate based on your investment objectives, risk tolerance, liquidity needs, time horizon, financial circumstances, investment restrictions, and other relevant considerations. Model portfolios generally are not customized security-by-security for each client, and reasonable restrictions may limit the ability to implement or maintain a model. See Item 8 for information about our evaluation of model providers and related investment risks and Item 16 - Investment Discretion for limitations on investment restrictions. Clients can impose reasonable written restrictions on the management of accounts. However, restrictions can be unavailable or impracticable for certain model portfolios, sub-advisers, variable annuity subaccounts, retirement plan accounts, indexed products, funds, and ETPs. See Item 16 – Investment Discretion for the procedures, limitations, and potential consequences applicable to client restrictions. When transferring accounts for investment, existing positions will generally be liquidated. Liquidation of your account will likely have tax consequences, which you should discuss with your tax adviser. If there are certain securities you own that you do not want to liquidate, you must notify your representative in writing. At certain custodians positions can be transferred in-kind for custody only, but neither Gladstone nor the sub-adviser, as applicable, will advise on those positions. Any transaction costs incurred in the liquidation of transferred assets are the responsibility of the client. Investment management programs are detailed below and in separate disclosure brochures, as applicable. None of the services described herein are intended as, or meant to be, a substitute for legal, accounting, or tax advice. There can be no assurance that any advisory service or investment strategy will produce favorable results or will be successful in achieving a client’s investment goals and objectives. Gladstone Sponsored Wrap Programs Gladstone sponsors three wrap fee programs in which we provide continuous and regular supervisory or management services for accounts custodied at select broker/custodians: the Gladstone Wrap Program, in which the representative acts as portfolio manager; the Gladstone Capital Management Program (“GCM”); and the Turnkey Asset Management Program (“TAMP”). GCM and TAMP provide access to third-party managers, model providers, and portfolio strategists. Minimum account values range from $0 to $100,000 depending on the program and investment strategy selected. New accounts in this program are managed on a discretionary basis. Each wrap fee program sponsored by Gladstone is described in detail in Gladstone’s Form ADV, Part 2A, Appendix 1, Wrap Fee Brochure that will be delivered to the client, as applicable. LPL Sponsored Wrap Programs Gladstone makes available wrap programs sponsored by LPL Financial, including the Manager Asset Select (“MAS”), Model Wealth Portfolios (“MWP”), Optimum Market Portfolios (“OMP”) and the Guided Wealth Portfolios (“GWP”) programs. Account minimums vary by program and money manager, ranging from $1,000 for the OMP program to $50,000 for the MAS program. Page 4 of 30  Gladstone is unaffiliated with LPL and any third-party portfolio management firms utilized under these programs. Depending on the program, Gladstone can retain discretionary authority to hire and fire sub- advisers. If you are invested in one of these programs, you will receive applicable disclosure documents for the wrap program sponsor, wrap program adviser, and/or sub-adviser, including a Form ADV Part 2A Appendix 1 Wrap Fee Brochure and Form CRS, as applicable. Those documents describe the program’s services, fees, investment approach, model-provider or sub-adviser arrangements, conflicts of interest, and risks. Non-Wrap Investment Management Program Gladstone provides investment management on a discretionary basis for accounts at certain broker-dealers and annuity issuers selected by the client. There is no minimum account size for non-wrap accounts. In a non-wrap account, you will separately incur commissions and/or other transaction charges for each trade placed in their account in addition to investment advisory fees, and other costs Clients invested in a non-wrap account should be aware that the same services are available in the Gladstone Wrap Program. Representatives pay an asset-based-pricing fee to cover transaction charges in wrap accounts whereas clients in non-wrap accounts are responsible for paying these charges. This creates an incentive for the representative to recommend a non-wrap account where they don’t have to pay the asset-based-pricing fee. See Item 12 – Brokerage Practices in this brochure for more information on “asset-based pricing”. Third-Party Retirement Account Program Gladstone provides investment advisory services to qualified retirement plan participants, including 401(k), 403(b), and other ERISA-covered accounts, through third-party technology platforms that enables us to access and manage held-away accounts on a non-custodial basis. Services are provided as an investment adviser under Section 3(21) of ERISA. You provide authorization for Gladstone and your representative to access your account through the third- party technology platform by entering your account credentials. If permitted, the representative implements trades on your behalf, subject to the terms of the advisory agreement. This limited discretionary authority is to select and manage investments from the plan’s investment options determined by the plan fiduciary, or an unrelated ERISA Section 3(38) investment manager. The third-party technology platforms do not offer investment advice or act in a fiduciary capacity. All investment advice and decisions are made solely by us, not by the platform provider. Planning and Consulting Services Financial Planning and Consulting Financial planning and consulting services are based on a flat rate or as a percentage of the asset under advisement as negotiated between the client and representative and documented in the corresponding Agreement. Financial planning and consulting services can vary depending on the client’s specific situation and can include estate planning, college/education planning, retirement planning, charitable giving, business succession planning, and portfolio analysis. Gladstone representatives do not advise on business value analysis, business liquidations or provide tax, accounting, or legal advice to clients, but these components can be referred to third parties. Representatives may recommend their own services, including products and services offered through Gladstone and in their individual capacities as insurance agents, as registered representatives of LPL, and/or other professionals to implement recommendations. Clients are free to implement none, some, or all recommendations and can do so through us or through other providers of such services. Charges can be lower or higher if recommendations are implemented away from your Gladstone representative. Page 5 of 30  In circumstances where a Gladstone representative recommends specific investments and is otherwise involved in implementing the plan or recommendations, the opportunity for the representative to receive additional compensation because of such recommendations creates a material conflict between the client’s interests and those of the representative. In addition, if a client separately purchases a product or service recommended by the representative to implement a recommendation, the client will be charged commissions or fees in connection with those transactions and services that are separate from and in addition to the fees charged by Gladstone for financial planning and consulting services. Retirement Plan Consulting Gladstone offers non-discretionary consulting services to qualified retirement plans including, as appropriate: assisting plan fiduciaries with plan design, selection of suitable investments, periodic monitoring of those investments, and general education to plan participants (“3(21) services”). Gladstone does not provide discretionary investment management of plan assets offered withing qualified retirement plans (“3(38) services”). Retirement plan consulting fees can be based on a percentage of the assets held in the Plan, or on a flat rate basis, as negotiated between the plan sponsor and representative and documented in the Retirement Plan Consulting Agreement. These services are provided in accordance with the fiduciary standards applicable under ERISA, including acting solely in the interests of plan participants and beneficiaries and exercising the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use. Gladstone is not a custodian to plan assets. The plan sponsor is responsible for selecting a qualified custodian for plan assets. The custodian for plan assets is responsible for providing the plan with periodic confirmations and statements. Agreements can be terminated at any time upon written notice given by either party to the other. Item 5. Fees and Compensation Advisory fees are negotiable and established in writing prior to the commencement of services through an investment management agreement, billing agreement, or applicable custodian or carrier documentation. The advisory fee negotiated with your representative may differ from fees charged to other clients or by other representatives based on factors such as account size, complexity, scope of services, fee structure, and other relevant considerations. Investment Management Fees The maximum investment management fee charged by Gladstone is 2.00% of assets under management. Advisory fees for certain investment management programs can be structured as a percentage of assets under management, on a tiered basis with reduced percentage rates at specified asset thresholds, or as a percentage of assets under management subject to a stated maximum dollar amount. The applicable percentage, maximum dollar amount, billing period, and treatment of deposits, withdrawals, and partial periods will be stated in the client’s written agreement. ‑ Non-wrap clients pay applicable custody, execution, and transaction charges directly while these costs are generally covered by the representative in wrap accounts through an “asset-based pricing” arrangement. This creates a conflict of interest, as representatives may have a financial incentive to recommend non wrap accounts even when clients may incur higher overall costs. See Item 10 and Item 12 for information regarding the asset-based pricing fees. In wrap fee programs, most transaction costs are bundled into the single asset based fee; however, clients may still incur certain additional expenses such as step-out charges, underlying investment expenses, and other costs described below. Whether a wrap or non-wrap program is ‑ Page 6 of 30  more cost-effective depends on factors such as trading activity, services provided, and overall account structure. Fees for the initial quarter are adjusted pro rata based on the number of calendar days in the quarter that the Investment Advisory Agreement is in effect. If assets of $5,000 or more are deposited into or withdrawn from an account after the beginning of a billing period, the fee attributable to those assets is prorated to reflect the change in portfolio value. Fees are calculated using asset values reported by the qualified custodian; Gladstone does not participate in or adjust those valuations. Payment of fees can result in the liquidation of securities if insufficient cash is available. Fees are assessed on all billable asset types, including securities, cash, and cash equivalents, and are generally billed quarterly in advance. Except for annuities linked to LPL SWM accounts, advisory fees for annuities are billed directly by the insurance issuer and may follow a billing cycle different from Gladstone’s standard quarterly billing practices. Depending on the program and custodian, clients can designate specific positions as unbillable, meaning those positions are excluded from fee calculations. Gladstone does not monitor, supervise, or provide advisory services with respect to unbillable positions. For a fee subject to a maximum dollar amount, the percentage-based calculation, applicable cap, and any prorated adjustment are applied as specified in the client’s written agreement and the custodian’s billing capabilities. Unless the agreement provides otherwise, the cap limits only Gladstone’s advisory fee and does not limit transaction charges, custodian fees, platform fees, product expenses, or other fees described in this Brochure. An asset-based fee creates an incentive to increase or retain assets in a client’s account because higher billable assets generally increase compensation to the representative and Gladstone until any applicable dollar cap is reached. After a capped fee reaches its stated maximum, additional assets subject to the same cap do not increase that advisory fee, although other fees and expenses can still apply. ‑ dealer commission costs during Clients should understand that advisory fees may exceed comparable broker periods of limited trading activity. Clients are not required to implement investment recommendations through Gladstone or its representatives and may do so through unaffiliated brokers or agents. For accounts managed under the Third-Party Retirement Account Program, the advisory fee charged is based on a percentage of assets under management accessed via third-party technology platforms. Fees are billed either quarterly, in advance or arrears, as specified in your agreement and are charged to a separate non- qualified account specified in the advisory agreement or separate billing agreement. The third-party technology platforms charge Gladstone a technology fee which the Firm passes on to the client. The amount charged to offset the third-party technology platform’s cost includes a markup, resulting in a profit to our firm creating a financial incentive to recommend the use of third-party technology platforms or to include more accounts on the platform. Representatives are only compensated for a percentage of the advisory fees and do not receive separate incentives to promote the third-party technology platforms. Unless stated otherwise in the applicable agreement, Gladstone or the client can terminate the agreement for investment management services for any reason within thirty (30) days’ written notice to the other party. The date of receipt of the written notice will be the effective date of termination. • Upon termination, clients receive a prorated refund of any unearned prepaid advisory fees based on the number of days remaining in the billing period, subject to applicable custodian or platform terms. Clients are responsible for monitoring their accounts following termination and may incur commissions or other transaction related charges in addition to advisory fees. • Upon termination of advisory services, we, the broker/custodian, or the sub-adviser will determine the ‑ Page 7 of 30  amount of any outstanding fees due to/from the client. Transactions in progress will be completed in the normal course of business. Please refer to your sub-advisers’ disclosure documents for their termination policies. Financial Planning and Consulting Fees Financial planning and consulting fees typically range from $200 to $5,000. Fees are negotiable and will be determined based on the nature and extent of the services being provided, the complexity of the client’s circumstances, as well as other aspects of the client’s current and historical relationship with Gladstone. Any changes made to a financial plan or consulting services will be discussed with the client in advance, and a new agreement will be signed to reflect the changes. Agreements can be terminated at any time upon advanced written notice given by either party to the other. Fees for financial planning and consulting services are typically a flat fee and are agreed upon prior to entering into an agreement. Clients have the option of paying the fixed fee either one time or in an installment frequency (e.g., quarterly, or semi-annual). Gladstone will not charge more than $1,200 six or more months in advance of delivering the financial plan. Agreements can be terminated at any time upon written notice given by either party to the other. Fees for financial planning and consulting services are payable to Gladstone and a portion of the fee is paid to the representative. Fees are payable by check or credit card/debit card. Payments made by credit card/debit card are processed through a third-party payment processor. The payment processor does not give Gladstone the ability to withdraw client funds. The client approves or denies the payment request directly with the payment processor. Gladstone never sees client banking or credit card information because clients enter that information themselves on the third-party payment processor's client portal. After a client authorizes the amount and frequency of the credit card/debit card payment, their representative is charged transaction fees, typically an ACH fee of 1.5% or credit card fee of 3.5% + $0.30/transaction. Transaction fees are charged by the payment processor and are subject to change. We believe that this presents a material conflict of interest in that a representative has an incentive to charge clients a higher fee when utilizing a third-party payment processor to offset the transaction charges that he/she is charged. Retirement Plan Consulting Fees Fees for retirement plan investment advisory services are negotiable and paid in the form of an annual percentage fee of assets held in the plan up to 1% or a flat dollar rate as negotiated between the plan sponsor and representative. Fees are assessed on all assets under Firm management, including securities, cash, and money market balances. Clients should understand that the negotiated fee may be higher or lower than the fees charged by other representatives or consultants for similar services. Fees will be payable to Gladstone in advance or in arrears on the frequency agreed upon by the plan sponsor and Gladstone. Gladstone will pay a portion of the fee to the representative. If asset-based fees are negotiated, payment generally will be based on the value of the plan assets as of the close of business on the last business day of the period as valued by the custodian of the assets. However, if the fee is paid by the plan or the client through a third-party service provider, such fee will be calculated as determined by the provider. Depending on the capabilities and requirements of the plan’s record-keeper or custodian, fees can be automatically calculated by the record- keeper and charged as a deduction from plan assets or ERISA budget account based on the plan’s authorization. Plans are subject to fees and charges imposed by third parties other than Gladstone in connection with recommended investments. These third-party fees can include fund or annuity subaccount management fees, 12b-1 fees, administrative servicing fees, plan recordkeeping and other service provider fees. These fees are separate and in addition to retirement plan consulting fees paid to us. Further information regarding charges and fees assessed by a fund or annuity are available in the appropriate prospectus and should be Page 8 of 30  considered by the plan before making the investment. No third-party payments will be received by Gladstone in connection with the services provided, such as commissions or 12b-1 fees. Gladstone can receive additional non-cash compensation from service providers to facilitate training and education meetings for Gladstone’s representatives. Non-cash compensation is not dependent on a plan’s investment in any fund, product, or custodian. Other Fees and Expenses Clients should be aware that they are responsible for paying all other applicable transaction costs, custodian fees, mutual fund expenses, brokerage commissions, third-party manager fees, administrative fees, and other miscellaneous fees, charges, or expenses associated with their account. This includes, but is not limited to, charges the fees outlined below. These provide an overview of the most common fees but does not include a description of every potential additional fee or expense applicable to client accounts; rather, this is a general description of the most common fees inherent to the types of accounts and transactions we offer. As noted throughout this brochure, clients should refer to applicable account opening documents, broker/custodian fee schedules, prospectuses, third-party portfolio manager brochures, and any other disclosure documents for specific details regarding applicable fees and expenses in connection with your account, product, transaction type, or third-party manager. Execution Charges: Clients who pay execution charges, including non-wrap program clients, will do so at rates determined by the custodian/broker-dealer. “Execution charges” means charges for executing transactions, including but not limited to commissions, commission equivalents, mark-ups, mark-downs or spreads. These rates may be negotiated, and clients may pay more or less in execution charges than similar clients for identical transactions. Execution charges paid by similar clients may differ depending on the circumstances of the client, including the size of the relationship and required service levels. The custodian/broker-dealer generally charges clients commissions according to the commission schedules set forth in the custodian agreement and/or account governing paperwork. However, there may be circumstances where charges commissions for investments or transactions that are not covered by the commission schedule. Commissions and mark-ups/mark-downs may be waived for certain clients or investment strategies. Clients may also pay spreads, and mark-ups/markdowns. However, third-party custodians reserve the right to charge fees in addition to what is described below including trade away fees and fees related to specific investments such as mutual funds and alternative investments. For a complete list of transaction fees that may apply to their account, clients should review their customer agreements with the applicable custodian. Third-Party Manager, Model Provider, Strategist, and Platform Fees: Clients with assets in programs that provide access to third-party portfolio managers, model providers, or portfolio strategists can incur portfolio manager and platform fees. These fees typically range from 15 to 100 basis points (“bps”) of account assets per year but can be higher or lower. These fees are separate from and in addition to the advisory fee paid to Gladstone and are described in the applicable program, manager, strategist, or model-provider disclosure documents. Under the GCM Program, clients pay Gladstone the annual asset-based advisory fee specified in their advisory agreement and do not pay a separate portfolio manager or platform fee to KIG. Gladstone pays KIG 0.15% (15 basis points) of the assets managed, prorated quarterly. Item 10 provides additional information regarding Gladstone’s relationship with KIG and the compensation KIG receives. Step-Out Trades: Broker/custodians will charge you a flat dollar amount or commission as a “prime broker” or “step-out” fee for each trade that is executed by a different broker-dealer but where the securities bought or the funds from the securities sold are settled into your account. These fees are in addition to the asset management fees you pay us. Gladstone’s representatives do not “step out” trades; however, some of the Page 9 of 30  professional third-party portfolio managers do step out trades at the portfolio manager’s discretion, subject to their best execution obligations. Step-out trading practices differ from Manager to Manager. Some third- party Managers do not engage in step-out trading while others do. Clients should review the firm brochure for any third-party portfolio manager selected prior to investing for more information regarding their step- out trade practices including additional costs that will be incurred by the client. Mutual Fund Share Class Fees: Gladstone has available for purchase through its broker/custodian platforms, mutual funds which are no- load or load-waived share classes. Most mutual fund share classes charge marketing and distribution fees (i.e., 12b-1 fees) which are paid to the broker/custodian and not directly or indirectly paid to Gladstone or its representatives. 12b-1 fees are not credited back to client accounts. Clients should also be aware that advisory assets can be held in a mutual fund share class that charges higher 12-b1 fee when a lower-cost share class is available on the broker/custodian’s platform for the same fund. While Gladstone endeavors to use the lowest-cost share class available and periodically reviews its fund holdings to convert higher cost shares to lower cost shares in accordance with its duty of best execution, Gladstone cannot ensure that all clients will hold the lowest cost shares available on the broker/custodian’s platform at any given time. Further, some third-party money managers and algorithm-driven strategists are more careful about utilizing the lowest cost share class than others. In many cases, a particular broker/custodian’s platform will not make available the least expensive share class that the mutual fund company offers. Share classes are selected by broker/custodians to be available on their platforms in most cases because the share class pays the broker-dealer compensation for the administrative and record keeping services the broker-dealer provides to the mutual fund. Gladstone is not paid revenue sharing compensation paid by mutual fund distributors to broker-dealers for these services. If a client transfers into an investment advisory account a previously purchased mutual fund and there is an applicable contingent deferred sales charge (“CDSC”) on the fund, client will pay that charge when the mutual fund is sold. If the account is invested in a mutual fund that charges a fee if a redemption is made within a specific time period after the investment, the client will be charged a redemption fee. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund. Many funds available in Gladstone’s advisory programs can be purchased by clients directly from the fund company. Therefore, clients could generally avoid an additional layer of fees by not using the advisory services of Gladstone and by making their own decisions regarding the investment. Gladstone encourages all clients to closely review the investment prospectus or offering documents for all such investments with their representative and to consider aggregate costs. Clients should contact their representative with any questions about any product’s fees and expenses. Exchange Traded Product Fees: Exchange traded products (ETPs) have internal operational expenses and fees that vary considerably. Operational expenses are typically deducted from the fund assets and investors do not pay fees directly to a fund manager. Since ETPs are traded on an exchange like stocks, they are also subject to brokerage fees. Insurance Product Fees: Insurance companies impose internal fees and expenses including, but not limited to, policy fees, contingent deferred sales charges, early redemption fees, fees for guaranteed income riders, underlying investment fees, and mortality, expenses, and administration charges (M&E&A charges.) Other riders or annuity expenses can apply. These fees are in addition to the management fees you pay us. Complete details of annuity internal expenses are specified and disclosed in each insurance company’s prospectus. Margin Loans and Collateralized Lending: If you enter into a margin loan, the broker/custodian will receive interest charged on your outstanding margin loan balance. The amount of interest paid to the Page 10 of 30  broker/custodian will vary depending on the outstanding loan balance and other factors that will affect the interest rate charged to you for the margin loan. We encourage clients to read their broker dealer’s Margin Interest Rate Disclosure for more information regarding applicable charges on debit and credit balances. With collateralized lending, in most instances the broker/custodian will be compensated by receiving payments from the lender based on the amount of your outstanding loan balance. The total amount of compensation received by the broker/custodian can vary depending on the terms of the agreement including the interest rate charged to you by the lender. Gladstone is not affiliated with any lender or broker /custodian and does not receive compensation directly in connection with a margin loan or pledged asset line of credit. Clients are strongly encouraged to review the lender's agreements and disclosure documents to understand the fees and expenses they are paying. Your representative has an incentive to recommend that you use a margin loan and/or pledged asset line of credit for liquidity purposes rather than liquidating your holdings or using other sources of liquidity. Your representative will benefit from your margin loan or collateralized loan because you do not have to liquidate assets in your account to pay for things with cash, which would diminish the assets held in the account and the potential fees that could be earned by your representative from holding or engaging in future transactions with those assets. IRA and Qualified Retirement Plan Fees and Rollover Expenses: There are additional fees relating to IRA and qualified retirement plan accounts that you normally incur such as annual maintenance fees, fees for loans processed, and retirement account closeout fees. These fees are in addition to underlying investment fees, and the management fees you pay us. Other fees can apply. You will find these fees disclosed in the broker/custodian’s account application paperwork provided to you associated with these accounts. Investors face increased fees and expenses when they rollover assets from an employer-sponsored retirement plan, transfer an IRA to an IRA, or convert to a Roth IRA managed by Gladstone. Investors should be aware that even if there are no costs associated with the rollover or transfer itself, there will be costs associated with account administration and investment management. In addition to the management fees charged by Gladstone or another adviser, some underlying investment products charge additional internal fees and expenses. Custodial and transaction fees can also apply. Withdrawal options, required minimum distributions, tax treatment (particularly with reference to employer stock) can differ. We do not receive payments in the form of commissions, 12b-1 fees, sales loads, revenue sharing payments, or mark ups or mark downs in exchange for rendering fiduciary investment advice. You should also be aware that your representative has a financial incentive to rollover your account or plan because the representative will be paid on those assets. If you are considering rolling over assets from an existing employer-sponsored retirement plan, you should understand that Gladstone’s representatives will provide you with general education regarding the pros and cons of available options to transfer or rollover tax qualified assets and will not recommend one option over the other. Your decision to rollover assets from an employer-sponsored retirement plan should be based on your individual financial circumstances, needs and goals and understanding of the options available to you including: (I) remaining invested in the plan; (ii) rolling over plan assets to a plan of a new employer (if applicable); (iii) rolling over assets to an IRA with a financial institution; or (iv) receiving a cash distribution (which may be fully taxable). If you decide to rollover assets from an employer-sponsored plan into an IRA account, assets will no longer be subject to protection of ERISA or different types of protection from creditors and legal judgments. We strongly encourage you to consult an independent tax or legal advisor prior to rolling over qualified plan assets. Securities held in a retirement plan can often not be transferred into an IRA and commissions and sales charges are typically charged by the plan’s broker when liquidating such securities in the plan prior to Page 11 of 30  the transfer of assets. These fees are in addition to commissions and sales charges previously paid on transactions in the plan. You should understand that you are making an independent decision regarding your rollover options, including any decision to roll out of your current employer-sponsored plan. Your representative will speak with you regarding the pros and cons of available rollover options as detailed in the IRA Adoption Application and other applicable disclosures in the account application packet. Representatives will not provide you with advisory services in connection with a rollover of employer-sponsored plan assets prior to you making an independent decision to roll assets into an account with us. Cash Sweep Arrangement Fees: Gladstone makes available through unaffiliated broker/custodians for cash in an account to be automatically swept to an interest-bearing Federal Deposit Insurance Corporation (FDIC) insured deposit account and, for certain types of accounts, a money market fund. We do not receive a separate fee or compensation for cash sweep arrangements. Clients should understand that interest rates available in these arrangements can be lower than interest rates available if the client makes deposits directly with a bank or other depository institution outside of these arrangements or invests in a money market fund or other cash equivalent. Clients should compare terms, interest rates, required minimum amounts and other features of these arrangements with other types of accounts and investments for cash. Account Termination Fees: Fees to terminate an account are a one-time fee charged to an account holder if he/she terminates or transfers an account. The termination fee is levied and retained by the financial institution that custodies the client’s assets. Termination fees are spelled out in the client agreement with the broker/custodian that is entered into when the account is opened. Item 6. Performance-Based Fees and Side-by-Side Management Performance-Based Fees Performance-based fees are based on a share of the capital gains or capital appreciation of the assets of a client. Gladstone does not charge performance-based fees. Side-By-Side Management Side-by-side management typically refers to a situation in which the same adviser manages accounts that are billed based only on a percentage of assets under management and at the same time manages other accounts for which fees are performance-based, which can give rise to certain conflicts of interest. Gladstone Wealth Partners does not provide side-by-side management. Item 7. Account Requirements and Types of Clients Gladstone’s service offerings currently extend to individuals, high net worth individuals, trusts, corporations, businesses, pension and profit-sharing plans, and charitable organizations. Gladstone requires a minimum initial investment of $0 to $100,000, depending on the program or third-party money manager utilized. Gladstone and the third-party money manager (if any) can waive minimum initial investment requirements at its discretion. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Gladstone offers the same suite of services to all clients; however, each representative independently determines which methods of analysis and investment strategies to use based on the client’s specific profile and financial circumstances. Accounts are managed independently, and representatives are not required to buy or sell the same investments for accounts with similar investment strategies. Strategies typically include long-term and/or short-term purchases and sales of securities. See Item 4 for information regarding Page 12 of 30  individualized account, program, manager, model portfolio, product, and service selection. Representatives must meet certain selection, review, and qualification criteria prior to becoming associated with Gladstone and must successfully complete ongoing training. For more information about the education and background of the representative managing your account you should refer to the representative’s brochure supplement provided to you when you opened your account. In addition to each representative’s training, skill, and experience, representatives have access to technical research, due diligence materials, and publications that can be used to evaluate securities and third-party managers and to support investment decisions. Representatives can use different resources, methods of analysis, and investment strategies based on individual client circumstances and are not required to purchase or sell the same investments or select the same third-party portfolio managers for accounts with similar strategies. See Item 4 for the factors considered in selecting services, programs, managers, model portfolios, products, and investment strategies for a particular client. Gladstone does not calculate or review the performance record of representatives; however, through its custodians, provides clients with individual quarterly performance information on a time-weighted basis. Performance information is intended to inform clients as to how their investments have performed for a given period, both on an absolute basis and compared to leading investment indices. Portfolio Manager Analysis and Evaluation Gladstone’s Investment Committee conducts initial and ongoing due diligence on wealth management platforms and wrap program sponsors, including review of their business models, costs, research and due diligence processes, and ability to identify and provide access to products, professional third-party portfolio managers, model providers, and investment strategies with varying risk exposures. Gladstone does not independently conduct due diligence on, calculate, or review the performance of every security, product, manager, model, or strategy available through a third-party platform. Instead, Gladstone relies substantially on the quantitative and qualitative research and due diligence performed by the platform’s professional research and portfolio management consultants. Your representative remains responsible for determining whether a particular program, manager, model, or strategy is appropriate for you as described in Item 4.For portfolio managers and investment strategies offered through the GCM Program, Gladstone’s Investment Committee conducts initial research and due diligence and performs ongoing monitoring. The Committee’s multi-factor quantitative and qualitative evaluation includes the manager’s investment philosophy and process, personnel quality, firm stability, return and holdings-based analysis, attribution, performance relative to benchmarks, and material changes to personnel, processes, or the firm. The Committee can conduct interviews with investment professionals, on-site visits, and conference calls as part of this review. This GCM-specific review is distinct from Gladstone’s platform-level diligence described above. Ultimately, Gladstone’s representatives are responsible for conducting additional screenings and analysis to identify products, investment strategies, and third-party portfolio managers that are suitable for a particular client’s financial circumstances, investment guidelines, and individual preferences. Risk of Loss Clients should understand that all investments involve the risk of loss of principal and clients should be prepared to bear the loss of some or all assets invested. The investment performance and the success of any account or particular investment cannot be predicted or guaranteed, and the value of a client’s investments will fluctuate due to market conditions and other factors. The investment decisions and recommendations made, and the actions taken are subject to various market, liquidity, currency, economic, and political risks, and will not necessarily be profitable. It should be expected that the types of risks to which an account is subject, and the degree to which any particular risks impact an account, will change over time Page 13 of 30  depending on various factors, including investment objective, investment techniques and asset classes utilized by the representative or third-party portfolio manager, the timing of the account’s investments, prevailing market and economic conditions, reputational considerations, and the occurrence of adverse social, political, regulatory, or other developments. The past performance of any investment is not indicative of future performance. Representatives and third-party portfolio managers invest in many types of securities, including mutual funds, ETPs, listed and non-listed equities, investment-grade and non-investment-grade fixed income, closed-end funds, options, annuities, and alternative investments. The prospectus, offering memorandum, or other disclosure document for an investment describes its terms and specific risks. Clients are strongly encouraged to review those documents before investing. The risk factors below are not a complete description of all risks associated with the investment strategies and vehicles used in client accounts. Model Portfolio Risk: Model portfolios are designed for categories of investors and are not tailored security-by- security to each client. A model provider can change allocations, securities, or implementation instructions without considering an individual client’s tax circumstances, cash needs, legacy positions, or investment restrictions. Differences in account funding, cash flows, custodian processing, trade timing, restrictions, and implementation can cause a client’s holdings, execution prices, and performance to differ from the model and from other accounts following the same model. Use of a model does not assure that investment objectives will be achieved or that losses will be avoided. Market Risk: This is the risk that the value of securities owned by an investor can go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. Interest Rate Risk: This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. Credit Risk: This is the risk that an investor could lose money if the issuer or grantor of a fixed income security is unable or unwilling to meet its financial obligations. Liquidity Risk: This is the risk that an investor would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than equities, fixed income securities, mutual funds, or ETPs. Concentration Risk: To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country, or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry, or such government could be considerably greater than if they did not concentrate their investments to such an extent. Sector Risk: To the extent a client account invests more heavily in particular sectors, industries, or sub-sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub-sectors. An individual sector, industry, or sub-sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub-sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. Tax-Managed Investing Risk: Investment strategies that seek to enhance after-tax performance might be unable to fully realize strategic gains or harvest losses due to various factors. Market conditions could limit the ability to generate tax losses. A tax-managed strategy could cause a client portfolio to hold a security to achieve Page 14 of 30  more favorable tax treatment or to sell a security in order to create tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. There is no guarantee that securities submitted for exchange will be accepted by a fund that utilizes a tax-managed strategy (e.g., an “exchange fund”), and exchange funds may accept “out-of-benchmark” securities at the sole discretion of portfolio managers. Although third-party managers of these strategies seek to avoid “wash sales” whenever possible and temporarily restrict securities they have sold at a loss to prevent them, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the third-party manager. A wash sale can also be triggered by the third-party manager when it has sold a security for loss harvesting and shortly thereafter the firm is directed by the client to invest a substantial amount of cash resulting in a repurchase of the security. Changes to the tax code and other policy changes could result in unfavorable tax treatment for investors in tax-managed strategies. Direct Indexing: Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing may provide a more tax efficient means of investing, and may allow for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if you don’t take advantage of tax planning or impose account restrictions, such as account level security or sector- based restrictions or customizations based on your specific tax, ESG or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of your account and the number of securities in the index your account seeks to replicate also limit the ability of your account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index into your account and can cause your portfolio to underperform the index, including as a result of customization. Gladstone cannot guarantee that the dividend yield in your portfolio will accurately track a market index. Values-Based and Environmental, Social and Governance (ESG) Investing Risk: Values-based investing or ESG investing, also known as “socially responsible investing,” “sustainable investing,” or “impact investing,” focuses on the social values or environmental, social, and governance standards or the sustainability factors of an investment. Some values-based investing strategies focus on factors relating to an individual investor’s personal or religious values, such as “biblical investing,” while other strategies focus on issues like environmental impact. Some values-based investment strategies use values-based criteria to supplement financial analysis when considering a particular issuer or security, while others affirmatively select “socially responsible” investments or screen out or exclude investments in companies that engage in certain activities. Values-based investing may limit the type and number of investments available in a strategy and cause the strategy to underperform other strategies without a values-based focus or with a focus that involves a different type of focus or screening methodology. Values-based strategies may underperform the market as a whole. Companies and issuers selected in a values-based strategy may not or may not continue to demonstrate values-based characteristics. Different investors are likely to have different opinions about what types of investments are socially responsible. Money Market Instruments: Money market instruments are generally considered low risk but are not guaranteed and be subject to loss and/or change in market value. Money market instruments can temporarily suspend your ability to sell shares if the fund’s liquidity falls below required minimums because of market conditions or other factors. Gladstone considers money market instruments an asset class and charges an asset-based fee on these positions. Depending on interest rates and other market factors, investments in money market instruments can be lower than the aggregate fees and expenses charged for a client’s participation in an advisory program. This can result in a client experiencing a negative overall return with Page 15 of 30  respect to cash reserves invested in money market instruments. Variable Annuities: Annuities are insurance products not designed for short-term investing. Their performance can approximate that of equities and fixed income. Common risks include insurer insolvency, inflation exceeding a guaranteed rate, limited access to funds, and surrender penalties for early withdrawals. Certain riders purchased with a variable annuity can also limit available investment options and the ability to manage subaccounts. Other Annuity Products: If client invests in other annuity products, client should be aware of the specific risks and limitations of such products. If client purchases an annuity product that is part of the program, client will receive a prospectus with respect to the terms and conditions of the annuity product. Some products may charge a recapture or redemption fee for contracts or benefits not held for a specified period of time or that do not follow stated withdrawal terms. Registered Index Linked Annuities (RILAs) are insurance products tied to the performance of a market index, offering the positive returns of the index up to a cap and providing a buffer for a certain level of negative returns. RILAs are subject to risks associated with other investment products, including market risk, and the total loss of principal is possible. Alternative Strategy Mutual Funds: Certain mutual funds available invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies is not appropriate for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. Closed-End/Interval Funds: Clients should be aware that closed-end funds may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time-to-time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an “interval fund”). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. In some cases, there can be an additional cost to investors who redeem before holding shares for a specified amount of time. The repurchase offer program can also be suspended under certain circumstances. Exchange Traded Products: Exchange Traded Funds (“ETFs”) and Exchange Traded Notes (“ETNs,”) (collectively Exchange Traded Products (“ETPs,”) are investment funds traded on stock exchanges. Investing in ETPs carry the risk of capital loss. Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest, illiquidity, poor trade execution in adverse market conditions. While ETPs often provide diversification, the fund can be concentrated in a particular asset category or class within a category. A fund’s risk can depend on how closely its return is coupled with given indexes, the riskiness of each index and how closely the indexes tend to move together. In addition, because ETPs are traded on exchanges, they can trade at prices above or below their net asset value (“NAV”). As a result, investors in ETPs may purchase fund shares at prices above their NAV or sell shares at prices below their NAV. Although many ETPs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETPs, in particular those that invest in commodities, are not registered as an investment company. ETPs can be closed and liquidated at the discretion of the issuing company. Unit Investment Trusts (UITs): UITs are investment companies that generally offer a fixed portfolio of stocks and Page 16 of 30  bonds as redeemable units to investors for a specified period of time. Like a mutual fund, UITs typically issue redeemable units. However, UITs differ from mutual funds in that UITs have stated expiration dates and are not actively traded. As a consequence, UITs will not be sold to take advantage of market conditions and their value may fluctuate, sometimes rapidly or unpredictably, due to factors affecting securities markets or particular industries. Upon the stated expiration date of a UIT, there is no assurance that the value of the UIT will be equal to or higher than the original price. Leveraged and Inverse ETPs and Mutual Funds: Leveraged ETPs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETPs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as a tracking error. Continual resetting of returns within the product can add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions can be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products can have higher expense ratios and be less tax-efficient than more traditional ETPs and mutual funds. Other Complex Exchange Traded Products (ETPs): Certain clients meeting qualification standards may also purchase other complex ETPs, which may be structured as ETFs, ETNs or as other types of securities. Similar to leveraged and inverse products, these other complex products differ, often significantly, from traditional ETFs, ETNs and mutual funds and can be significantly more speculative and volatile. Other complex ETPs are often not designed to be held long term. These products include, for example, single-inverse ETPs (Single Inverse ETPs), futures-linked ETPs (Futures Linked ETPs) and cryptocurrency-related ETPs (Cryptocurrency ETPs). Single Inverse ETPs are complex financial instruments that seek investment results that are the opposite of the performance of an index for a stated trading period (or “reset frequency”), often a single day. When a Single Inverse ETP with a shorter reset frequency is held for a longer period, significantly different returns from the investment objective or returns of the underlying assets may result, including potential realized and unrealized losses. A Single Inverse ETP that resets each day is typically inappropriate as an intermediate or long-term investment unless it is recommended as part of a sophisticated trading or hedging strategy that will be closely monitored. Futures Linked ETPs are intended to provide exposure to reference assets like commodities. However, Futures Linked ETPs are not designed to track the spot price of the referenced asset, but instead track the price of futures contracts. The performance of a Futures Linked ETP may deviate significantly from the performance of the spot price of the reference asset, especially over longer periods. Cryptocurrency ETPs are exposed to cryptocurrency, decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Certain Futures Linked ETPs invest in cryptocurrency futures, which could magnify the risks described above. Options: Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such cases, the security can be called away and Page 17 of 30  the account will no longer hold the security. When purchasing options there is the risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (i.e., “writing”) options, the risk of loss can be much greater if the options are written uncovered (i.e., “naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. Structured Products: Structured products are securities derived from another asset, such as a security or basket of securities, an index, a commodity, a debt issuance, or foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. The credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, can be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors will typically be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities can be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by FDIC are subject to applicable FDIC limits. High-Yield Debt: High-yield debt is issued by companies or municipalities that do not qualify for “investment grade” ratings by one or more rating agencies. The below investment grade designation is based on the rating agency’s opinion of an issuer that it has a greater risk to repay both principal and interest and a greater risk of default than those issuers rated investment grade. High yield debt carries greater risk than investment grade debt. There is the risk that the potential deterioration of an issuer’s financial health and subsequent downgrade in its rating will result in a decline in market value or default. Because of the potential inability of an issuer to make interest and principal payments, an investor may receive back less than originally invested. There is also the risk that the bond’s market value will decline as interest rates rise and that an investor will not be able to liquidate a bond before maturity. Business Development Companies (BDCs): BDCs are types of closed-end investment companies. Generally, BDCs invest primarily in the debt and equity of private and/or small U.S. companies and typically offer distribution rates generated through potentially significant credit and liquidity risk exposures amplified through leverage. As with other high-yield investments, such as floating-rate/leveraged loan funds, private REITs and limited partnerships, investors are exposed to significant market, credit, interest rate, and liquidity risks. In addition, BDCs run the risk of over-leveraging their relatively illiquid portfolios. Due to the illiquid nature of non-traded BDCs, investors’ exit opportunities can be limited to only periodic share repurchases by the BDC. A tender offer pursuant to a share redemption program may be oversubscribed so that the BDC accepts only a pro rata portion of the shares a client tenders during a redemption program. In such cases, a client can experience significant delays (including, potentially, indefinite delays) to exit the investment. In addition, share redemption programs can be shut down at any time at the discretion of the issuer’s board. Also, BDCs may fund distributions from offering proceeds or borrowings, which can constitute a return of capital and reduce the amount of capital available to make investments. In some cases, there is an additional cost to investors who redeem before holding the shares for a specified number of years. Page 18 of 30  Real Estate Investment Trusts (“REITs”): Investments in real estate funds and REITs face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles of performance. Revenues and cash flows can be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the credit and equity markets; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; and the impact of present and future environmental legislation and compliance with environmental laws. Non-Traded REITs are not required to provide annual valuations until two years and 150 days after reaching the minimum capital raise required to begin purchasing properties. Non-Traded REITs can fund distributions from offering proceeds or borrowings, which can constitute a return of capital and reduce the amount of capital available to invest in new assets. Clients should be aware that these securities may not be liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the security, there may be certain repurchase offers made from time-to-time. However, there is no guarantee that the client will be able to redeem the security during the repurchase offer. Issuers can repurchase shares at a price below net asset value. The repurchase program can also be suspended under certain circumstances. Hedge Funds and Non-Traded Managed Futures: Investing in these funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices, currency and interest rate risk, lack of liquidity, and performance volatility. In addition, these funds are not required to provide periodic pricing or valuation information to investors and involve complex tax structures and delays in distributing important tax information. At the discretion of the issuer of the fund, there can be certain repurchase offers made; however, there is no guarantee that an investor will be able to redeem the fund during the repurchase offer. In some cases, there will be an additional cost to investors who redeem before holding shares for a specified amount of time. Issuers typically accept redemption requests only periodically (monthly or quarterly) and often have discretion to suspend redemptions in times of market stress. Even after a redemption request is accepted, the redemption proceeds may not be available for a significant period of time following the effective date of the redemption. A portion of the redemption proceeds can also be withheld to account for potential future adjustments to the valuation of the security. Funds of hedge funds are pooled investments in several hedge funds. Expenses in funds of hedge funds are typically higher than mutual funds. Because they can invest in a number of private hedge funds, funds of funds also earn a part of the fees and expenses of those underlying hedge funds. Private Equity Funds: Private equity investments are speculative and involve significant risks. It is possible that investors may lose some or all of their investment. The risks associated with private equity include: limited diversification, the use of leverage, and limited liquidity. The investment timeline for private equity can be a decade or more. Some issuers or general partners may penalize limited partners who redeem before holding units for a specified amount of time, or may disallow redemptions entirely. Margin Accounts: Clients should be aware that margin borrowing involves additional risks. Margin borrowing will result in increased gain if the value of the securities in the account go up, but will result in increased losses if the value of the securities in the account goes down. The client’s broker/custodian acts as the client’s creditor and has the authority to liquidate all or part of the account to repay any portion of the margin loan, even if timing would be disadvantageous to the client. Pledged Asset Lines of Credit: Entering into a pledged asset line and pledging securities as collateral involves a high degree of risk. At any time, including in the event that the loan value of collateral is insufficient to satisfy the minimum loan value of collateral or to support the outstanding loans, the lending institution can demand immediate payment of all or any portion of the outstanding obligations, or require additional cash or Page 19 of 30  securities to be added to the pledged account. Donor advised funds ("DAFs"): DAFs are available only to clients in select states. DAFs allow clients to make an irrevocable charitable contribution, receive an immediate tax deduction, and recommend grants from the fund over time. The sponsoring organizations maintain ultimate control over all contributions and grant recommendations. Clients should consult with their tax advisor regarding the tax implications of contributions to DAFs. Artificial Intelligence Risks: Gladstone does not use artificial intelligence (“AI”) to construct portfolios or to make recommendations. Certain third-party vendors may use artificial intelligence within their own systems, and the use of this technology involves risks that clients should understand. AI tools may rely on data that is incomplete or inaccurate, which can result in errors withing supporting processes. These tools may not perform as expected and can be affected by model limitations, system interruptions, and other factors. Gladstone has incorporated controls into its vendor due diligence program to review and monitor the use of AI by service providers. Technology based processes involve uncertainties and are not viewed as a substitute for Gladstone’s professional judgment and oversight. Reliance on Outside Data Providers: We receive all account and transactional data and other information regarding account valuation from unaffiliated custodians (outside data providers.) The inherent risk is that we have no independent means to ensure that such data is error-free or discover that such data is in other ways incomplete or inaccurate. Technology and Cyber Security Risks: Clients should be aware of the risk of actual and attempted cyber- attacks, including denial of service attacks, harm to technology infrastructure and data from misappropriation or corruption, and reputational harm. Due to Gladstone’s interconnectivity with service providers, client accounts could be adversely impacted and subject to identity theft and fraud if any service provider is subject to a cyber- attack or other information security event. Although Gladstone takes risk management and security measures against cyber security breaches, systems could be subject to physical or electronic breaches resulting in a failure to maintain the security and confidentiality of data assets. Technology failures or cyber security breaches, deliberate or unintentional, could delay or disrupt our ability to do business or service our clients. Terrorism, Disease Epidemics and Other Catastrophic Risks: These are the risks of loss that can be incurred, indirectly, due to the occurrence of various events, including hurricanes, earthquakes, and other natural disasters, terrorism, and other catastrophic events such as a pandemic. These catastrophic risks of loss can be substantial and could have a material adverse effect on Gladstone’s business and on the performance of your account. Item 9. Disciplinary Information Neither Gladstone nor any of its management persons have legal or disciplinary events to disclose that are material to a client's or prospective client's evaluation of our advisory business or integrity of our management. Item 10. Other Financial Industry Activities and Affiliations LPL Financial (“LPL”): Most Gladstone Wealth Partners Representatives are associated with LPL Financial (“LPL”) as broker dealer registered representatives (“Dually Registered Persons”).1 LPL is an unaffiliated SEC-registered investment 1 Additional information about LPL Financial (CRD#: 6431/SEC#: 801-10970, 8-17668) and its registered representatives is available on FINRA’s BrokerCheck® Website at https://brokercheck.finra.org and the SEC’s Investment Adviser Public Disclosure Website www.adviserinfo.sec.gov. Page 20 of 30  adviser and FINRA member broker-dealer. Clients can choose to engage Dually Registered Persons in their individual capacities as registered representatives of LPL to execute investment recommendations on a commission basis. In this capacity, a Dually Registered Person’s recommendation that a client purchase securities in a brokerage account presents a material conflict of interest, as the receipt of commissions provides an incentive for the Dually Registered Person to recommend investment products based on commissions, 12b-1 fees from mutual fund sales, and other forms of remuneration rather than on a particular client’s need. In some cases, clients may pay higher commissions and transaction costs for executing transactions through LPL than through other broker-dealers and in most cases, than through a discount broker-dealer. Clients are under no obligation to purchase brokerage products from Gladstone’s Representatives. Clients are reminded that they can purchase investment products recommended by Gladstone Representatives through other, non-affiliated broker-dealers or insurance agents. LPL Financial is responsible for supervising certain activities of these representatives to the extent they manage assets at a broker/dealer and custodian other than LPL Financial. LPL Financial charges a fee of up to 10 basis points to the representative for this oversight. This creates a conflict of interest as it creates an incentive for the representative to recommend that you maintain your account with LPL Financial rather than another custodian. Clients should be aware that Gladstone shares confidential client information about these accounts with LPL Financial, including account information, transactions and holdings. In limited circumstances, certain Representatives of Gladstone are also associated with LPL as dually registered investment advisory representatives to provide advisory services as an investment manager under Section 3(38) of ERISA. When acting in this capacity, Representatives offer discretionary retirement planning services to plan sponsors for a fee as representatives of LPL. Kessler Investment Group, LLC (“KIG”): Gladstone maintains a material relationship with Kessler Investment Group, LLC (“KIG”), an SEC registered investment adviser (CRD#: 153696/SEC#: 801-71393), where KIG serves as sub-adviser to investment strategies offered to individual separate accounts under the GCM program. In return for portfolio management services, Gladstone charges clients an annual asset-based fee and pays 0.15% (15 basis points) to KIG prorated on a quarterly basis. Clients do not pay more for portfolio management services under this fee arrangement and Representatives earn the same compensation regardless of which strategy they offer. A material conflict of interest exists where certain representatives are dually registered representatives of Gladstone and KIG and utilize KIG as the sub-adviser for accounts in the GCM program where KIG will earn related compensation. Outside Business Activities (“OBAs”): Many of our representatives engage in outside business activities that create conflicts of interest when providing client recommendations. Further information about the representative managing your account, as well as potential conflicts that can impact their recommendations, are outlined in your representative’s Form ADV, Part 2B, Brochure Supplement provided to you when you opened your advisory account. Contact your representative or us at (908) 719-1313 if you need an additional copy. Certain representatives of the firm conduct advisory business through a personal legal entity (such as an LLC or S-Corporation) for branding, tax, or administrative purposes. In such cases, the representatives may direct the payment of advisory fees to the representative’s approved personal entity. These entities are wholly Page 21 of 30  owned and controlled by the relevant representative and used solely as a compensation conduit; they do not themselves provide investment advisory services, custody client assets, or hold themselves out to the public as independent advisory firms. The use of such entities does not change the advisory relationship between the client and Gladstone. All representatives, regardless of any personal entity used for compensation, remain individually registered and subject to the firm’s compliance policies, supervision, and regulatory oversight Certain Representatives of Gladstone have their own legal business entities including, but not limited to, accounting and legal firms. Supervised Persons must disclose outside business activities to Gladstone before undertaking any such activity so that a determination may be made that the activities do not interfere with any of the individual’s responsibilities with the representative and any conflicts of interests may be addressed. Clients should understand that outside businesses are legal entities of the Representative and not Gladstone. Gladstone does not endorse or recommend the services of any Representative outside of their role as a Supervised Person of Gladstone. No client is under any obligation to purchase any products or services from Gladstone’s representatives in their individual business capacities. Gladstone does not recommend, monitor, or evaluate fixed insurance products purchased by clients. When clients request insurance products, such purchases are made solely through representatives acting in their capacity as licensed insurance agents, which constitutes an OBA and is separate from Gladstone. Even where a client requests that fixed insurance products be included in consolidated reports or hypothetical illustrations, such products are reflected only as provided by the client or the issuing company. Gladstone does not recommend, review, monitor, or evaluate such fixed insurance products, and clients are solely responsible for determining whether those products continue to meet their financial needs. Gladstone does not assess advisory fees on these insurance products because it does not provide advisory services with respect to these products. Additionally, variable insurance products may be held in an account managed by Gladstone or in an outside account. Variable products held in an outside account are purchased through representatives acting in their capacity as licensed insurance agents and registered representatives of LPL Financial and treated as an OBA and are not managed by Gladstone. By contrast, for variable insurance products held within advisory accounts we manage, Gladstone provides ongoing advice and monitoring, consistent with our fiduciary responsibilities under the Investment Advisers Act. Certain of these variable products are purchased through an outside insurance desk to the extent permitted by the insurance carrier. For such products, Gladstone receives compensation for the variable products in two forms: (1) a fee for purchasing certain variable annuity products through the outside insurance desk, and (2) an ongoing management fee for managing these assets within advisory accounts. As a result, clients may pay more for variable insurance products held in accounts managed by Gladstone. When Gladstone is unable to purchase the variable annuity through the outside insurance desk, its compensation related to such variable annuities is limited to an ongoing management fee for managing the variable annuities within the advisory account. This compensation structure creates a conflict of interest because Gladstone and its representatives have a financial incentive to recommend variable insurance products-and to retain these assets under management-even when comparable non-insurance investment options may be available at lower cost to the client. To mitigate this conflict, Gladstone requires all representatives to adhere to their fiduciary obligations when recommending variable insurance products, including evaluating whether such products are suitable and in the client’s best interest. Clients should understand the important distinction between: (a) variable insurance products held in advisory accounts, which are subject to Gladstone’ fiduciary management and ongoing monitoring; and (b) fixed Page 22 of 30  insurance products and other outside holdings, which may appear in consolidated reports for reporting purposes only but are not managed, monitored, or evaluated by Gladstone. Clients bear sole responsibility for evaluating whether fixed insurance products and other outside holdings continue to meet their financial objectives. Clients should also be aware that because commissions and other benefits may be higher when representatives sell fixed insurance products through Gladstone-affiliated agencies, representatives generally have a greater financial incentive to recommend affiliated products over comparable products available from non-affiliated insurance agencies. This creates an additional conflict of interest, as the representative may benefit financially from recommending affiliated products even if non-affiliated products offer comparable or better terms. Clients are under no obligation to purchase any insurance product recommended or offered by a representative, and clients are free to purchase comparable insurance products through any other licensed insurance agent or agency of their choosing. Clients should carefully consider these potential conflicts of interest when evaluating any insurance recommendation made by a representative. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Gladstone has adopted a code of ethics that emphasizes the high standards of conduct we seek to observe. Gladstone personnel are required to conduct themselves with integrity and follow the principles and policies detailed in our code of ethics. A copy of the code of ethics is available upon request by contacting us at (908) 719-1313. Gladstone’s code of ethics addresses conflicts of interest that have been identified or that could likely arise specific to its business activities and service model. Firm personnel are required to follow guidelines governing their conduct in areas including, but not limited to conflicts of interest, compliance with state and federal statutes, laws and regulations, personal trading activities, and possession of and actions with regard to material nonpublic information. Gladstone’s code of ethics requires, among other things, “Access Persons” (as defined by the SEC) to periodically report their personal securities transactions and holdings to the Firm for review. Gladstone does not maintain “restricted lists,” implement “blackout periods” or require prior written approval (“pre-clearance”) for personal securities transactions other than participation in private placements or initial public offerings (“IPOs”). Gladstone does not participate in allocations of IPOs. Gladstone does not hold or trade securities in proprietary accounts. From time to time, representatives trade in securities for their own accounts that they also trade in client accounts, and they also trade in different securities that they do not feel are appropriate for certain clients. The conflict presented in this practice could lead to a client not participating in the appreciation of a particular security, or the representative purchasing or selling a security and receiving a better price than the client. Representatives can aggregate transactions for a client with other clients to improve the quality of execution. Clients should be aware that the representative’s personal accounts (including related accounts, such as those of family members) can be included in such a block order. Although the same average price would be applied to client accounts and the representative’s personal accounts, the inclusion of a representative’s personal account(s) in a block order can present a conflict of interest. It is possible that the inclusion of the personal account could negatively impact the price of the security or result in the client being allocated less of an order. If a partially filled order is allocated on a random basis, the inclusion of the personal account could make it less probable that a client account is randomly selected, and the representative’s personal account could be randomly selected instead of a client account. Gladstone addresses this conflict by disclosing it to you. Please ask your representative if you would like more information on the representative’s trading practices in this Page 23 of 30  respect. Craig Kessler is a dually registered investment adviser representative of Gladstone and KIG, an unaffiliated institutional money manager where KIG serves as sub-adviser to accounts in the GCM program. SWM Accounts that are in whole or in part managed by Craig Kessler are independently managed and often include the same or similar securities and allocations as GCM investment strategies. Clients are advised that in instances where the same securities are purchased or sold in SWM accounts as those in GCM accounts, SWM account transactions will occur after KIG trades the GCM accounts. This may provide clients in GCM program accounts with a better trading price than clients in the SWM program. Item 12. Brokerage Practices Recommendation of Broker/Custodians Gladstone has entered a relationship with LPL Financial, Fidelity, and Charles Schwab to serve as executing broker- dealer and qualified custodian for asset management program accounts. Gladstone does not have discretionary authority to select the broker/custodian for custody and execution services. While Gladstone’s representatives can make a recommendation as to the selection of a broker/custodian, it is ultimately the client’s decision to select and direct the custodian as the sole and exclusive broker-dealer to execute, clear, and settle transactions for program accounts and authorize Gladstone to buy and sell securities when we instruct them to. Clients should be aware that if a representative is also a registered representative of LPL, he/she may not be permitted to use a custodian other than LPL. Whether or not the representative is able to use a custodian other than LPL is determined by Gladstone and LPL and is based on the experience and production level of the representative, among other factors. In cases where a custodian other than LPL is selected by the client and the representative is a registered representative of LPL, Gladstone will pay 10 bps of the value of assets under management held at said custodian to LPL as an oversight fee. Certain account types are exempt from the calculation. This payment comes from the portion of the advisory fee that would otherwise be paid to the representative creating a financial incentive to recommend LPL as a custodian. Notwithstanding, Gladstone and its representatives will recommend a custodian to clients only if it believes it is in the client’s best interest. Asset-Based Pricing for Wrap Accounts Representatives pay a platform fee (“asset-based fee” aka “asset-based pricing”) to Gladstone which it passed in part to the broker/custodian to cover transaction and execution costs (commissions/ticket charges) on a calculation based on the representative’s aggregate assets under management. Representatives pay an asset- based fee regardless of how much or little they trade client accounts. We believe that an asset-based fee structure reduces potential conflicts of interest that can arise with individual ticket/transaction charges that can influence a representative’s decision whether or not to trade an account. Depending on the broker/custodian, charges for asset-based pricing can exclude certain account and asset types, such as non-transaction fee (“NTF”) mutual funds and ETPs. To mitigate any financial incentive for representatives to select NTF funds over other funds that can have lower internal fees, representatives pay a platform fee to Gladstone based on their total assets under management regardless of asset type (e.g., the asset-based fee does not exclude NTF funds). We believe this fee structure further reduces conflicts of interest which can arise that can influence a representative recommending a particular broker/custodian or utilizing specific assets. We believe this fee structure mitigates conflicts of interest and financial incentive for a representative to utilize any specific asset type. Clients are advised that while Gladstone endeavors to use the lowest-cost mutual fund share class available, Page 24 of 30  the Firm cannot ensure that all clients will hold the lowest cost shares available on the broker/custodian’s platform at any given time. See "Item 5 - Fees and Compensation" for more information on mutual fund share class fees. Best Execution Gladstone recognizes that there are areas that represent potential conflicts of interest when considering its duty to obtain best execution of client trades. To this end, Gladstone has negotiated asset-based pricing arrangements with broker/custodians where transactions are executed without commissions or transaction fees (see “Asset-Based Pricing” above). Through evaluation of a list of quantitative and qualitative factors, Gladstone believes that the broker/custodians that it makes available on its platform offer the most comprehensive package and best balance of costs, accuracy and speed of execution, access to markets and liquidity, quality of services, financial stability, and reputation. Gladstone regularly evaluates these factors as part of its duty to secure best execution of client trades. Clients should be aware that while Gladstone reviews to ensure that available broker/custodians have execution procedures that are reasonably designed to obtain the best execution possible, there can be no assurance that best execution will be achieved. Research and Other Soft Dollar Benefits Gladstone receives products and services from broker/custodians, many of which assist Gladstone to better monitor and service client accounts. Products and services are received without cost, at a discount, and/or at a negotiated rate, and can include investment-related research, pricing information and market data, software and other technology that provide access to client account data, consulting services, attendance at conferences, meetings, and other educational and/or social events, marketing support, computer software, and other products and services used by Gladstone in furtherance of its investment advisory business operations. Products and services are provided to Gladstone based on the overall relationship between Gladstone and the broker/custodian and not the result of soft dollar arrangements or any other express arrangements that involve the execution of client transactions as a condition to the receipt of such products and services. Gladstone will continue to receive products and services regardless of the volume of client transactions executed with a particular broker/custodian. Clients do not pay more because we receive these benefits. There is no corresponding commitment made by Gladstone to a broker/custodian or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of these arrangements. Brokerage for Client Referrals Gladstone and its related persons do not receive client referrals for recommending broker-dealers. Directed Brokerage Gladstone requires that clients select one of the Firm’s approved broker-dealer custodians for account custody and execution. The Firm currently maintains relationships with LPL Financial LLC, Charles Schwab & Co., Inc, and Fidelity Institutional. Clients must designate one of these custodians to maintain their assets and execute securities transactions. Clients may negotiate with their representative to designate specific positions held at some custodians such as Charles Schwab or Fidelity as “unbillable,” meaning those positions are excluded from fee calculations. This practice creates a conflict of interest for clients whose assets are custodied at LPL Financial, as LPL does not permit positions to be designated as unbillable. As a result, clients custodied at LPL may incur advisory fees on all positions, whereas clients at other custodians may have the ability to exclude certain positions from billing. This difference in treatment could influence a client’s choice of custodian or the adviser’s recommendation of custodians. We address this conflict by disclosing it to clients and allowing them to select their preferred Page 25 of 30  custodian, subject to the custodian’s policies. As a condition of opening and maintaining an account with Gladstone, clients direct the Firm to execute all transactions through their chosen custodian. This arrangement is referred to as “directed brokerage”. By directing brokerage, clients acknowledge that they may not receive the most favorable execution in terms of price, speed or other factors that might be available if the Firm were permitted to select the executing broker. Gladstone does not receive any soft dollar benefits, research, or other compensation from custodians in exchange for directing client transactions. While Gladstone believes that its custodian relationships provide overall benefit to its clients, the Firm’s requirement that clients select a specific custodian can create a conflict of interest. The Firm’s selection of custodians is based on factors such as execution quality, service standards, and operational efficiency. Clients should understand that this arrangement may not result in the most favorable trade execution in every circumstance. Aggregation of Orders Purchases, sales, and other orders made for your account can be aggregated with purchase, sales, and other orders in the same investments for other clients. When transactions are aggregated, the actual prices applicable to the aggregated orders will be averaged, and the account will be deemed to have purchased or sold its proportionate share of the investments involved at the average price obtained. Occasionally, an aggregated order can only be partially filled. Under such circumstances, the investments are allocated, to the extent feasible, among the applicable clients on a pro rata basis. Representatives may determine not to aggregate transactions, for example, based on the size of the trades, the liquidity of the securities, and the discretionary or non-discretionary nature of the trades. If orders are not aggregated, some clients purchasing securities around the same time may receive a less favorable price than other clients. Clients are encouraged to refer to the agreements they enter into as well as the disclosure brochure for any third-party manager utilized for information on the third-party manager’s trade aggregation practices. Allocation of Investments Representatives engage in an investment advisory business apart from managing your account. This creates a conflict of interest with the representative’s time devoted to managing your account and the allocation of time and investment opportunities among other client accounts managed by the representative. The representative will attempt to resolve such conflicts in a manner That is fair to all clients. Representatives provide personalized and individualized advisory services and take action with respect to other clients that can differ from advice given or the timing or nature of action taken with respect to your account. Representatives are not obligated to purchase or sell any security that the representative can acquire for their own account or for the account of any other client, if in the absolute discretion of the representative, it is not practical or desirable to acquire a position in such security for the account. Principal Transactions and Cross Transactions Gladstone does not engage in principal transactions or cross transactions. Trade Errors Gladstone reimburses accounts for losses resulting from Gladstone’s trade errors but does not credit accounts for such errors resulting in market gains. The gains and losses can be reconciled within Gladstone’s custodian firm account and Gladstone can retain the net gains and losses. Item 13. Review of Accounts Representatives review non-wrap and wrap fee accounts on an ongoing basis and complete a review of each Page 26 of 30  client account at least annually to determine whether the account remains in the client’s best interest and whether the selected account type, program, third-party manager, model portfolio, investment strategy, and fee arrangement continue to be appropriate. The review considers the totality of the services provided and the client’s current investment objectives, risk tolerance, liquidity needs, time horizon, financial circumstances, and restrictions, rather than any single service or component of the overall fee. See Item 4 for information regarding initial account, program, and model selection and Item 5 for fee structures and billing practices. The representative will contact the client periodically to determine whether there have been changes in the client’s financial situation, investment objectives, risk tolerance, liquidity needs, time horizon, or investment restrictions that warrant an adjustment to the account, program, model portfolio, or investment strategy. Additional reviews or contact can be triggered by a client request, a material change in the client’s circumstances, or significant market, economic, political, regulatory, or other events. Once an advisory relationship is established, there are no restrictions on a client’s ability to contact Gladstone or the representative. Under certain circumstances, the client can request direct contact with Gladstone, a third-party manager, or a strategist. However, these consultations will occur at the sole discretion of Gladstone or the applicable third-party manager or strategist. Each client will receive written reports directly from the broker/custodian that detail the client’s positions and activity. Many representatives also provide their clients with periodic performance reports, which can show performance across multiple accounts within a household. Clients are advised that these are not official account records and to always compare those reports to the ones provided by the qualified custodians, which are the official records of the accounts. Program accounts are subject to a risk-based exception reporting system that flags client accounts or households based on Firm-specified criteria, including, but not limited to, trading inactivity and/or missing annual review reports. The exception reporting identifies accounts or households where additional analysis by a Gladstone supervisor may be appropriate. Item 14. Client Referrals and Other Compensation Client Referrals Third-Party Referrals to Gladstone: Gladstone maintains investment advisory referral arrangements with unaffiliated third parties, including but not limited to, individual professionals, professional firms, corporate institutions, and digital marketing companies. For each such referral arrangement a solicitor or “promoter” will receive compensation in the form of a flat fee, or as a percentage of advisory fees received from the referred client when the client elects to utilize Gladstone for investment advisory services. Because Gladstone is engaged by and compensates the third-party promoter for the referral, it presents a conflict of interest. Referral arrangements are pursuant to a written agreement between Gladstone and the third- party in accordance with the requirements set forth in Rule 206(4)-1 under the Advisers Act. Under the written agreement, the promoter is responsible for delivering to the referred Client, at the time the solicitation was presented, certain disclosures with regard to (i) whether the promoter is a client of Gladstone, (ii) compensation provided for the referral and a description of the compensation arrangement, and (iii) any other material conflicts of interest the promoter may have that results from the promoter’s relationship with Gladstone or with the Gladstone representative. Gladstone Referrals to Third-Party Investment Advisors: Gladstone has relationships with various third-party investment advisers that provide various types of advisory services. Gladstone representatives can introduce clients to such services in which case the representative will not be providing continuous and regular Page 27 of 30  supervisory or management services or have discretionary authority over assets with respect to individual security selection. Gladstone representatives obtain information from the client regarding their financial situation, investment objective and any reasonable restrictions, assist the client in selecting a suitable investment solution, and agree to meet with the client at least annually to determine if the Client’s financial situation, investment objective or Account restrictions, if any, have changed. Clients will receive a separate firm brochure for the third-party investment advisor selected and a disclosure describing the nature of our relationship, the terms of our compensation, including a description of the compensation that Gladstone will receive. Gladstone Referrals for Lending Services: Gladstone established relationships with lenders and lending platforms to help facilitate client access to unsecured (personal) loans, residential real estate loans, and securities-backed loans. Clients should understand that any such referral made by a Gladstone representative is an ancillary service, and it is not an, nor it is part of, any advisory program or advisory service. Gladstone representatives act as an intermediary but do not act as a fiduciary to the client when making such a referral and will not provide advice or oversee any lending arrangement between the client and lender. Clients cannot use proceeds from a loan to purchase securities. For unsecured loans and securities-based loans, Gladstone is eligible to receive a one-time compensation payment based on a certain percentage of the loan amount for each loan that Gladstone representatives refer to the lender or lending platform. This compensation rate does not vary between lenders. Gladstone representatives are not compensated for these referrals. Other Compensation Most of Gladstone’s representatives are also registered representatives of LPL and are eligible to participate in incentive programs offered through LPL where cash and non-cash compensation is received such as production bonuses, deferred compensation, stock options to purchase shares of LPL’s parent company, and other things of value, such as free or reduced-cost attendance at LPL’s national sales conference or top producer forums and events. Such compensation is typically based on overall business produced and/or on the amount of assets placed through LPL. To this end, there is a financial incentive for many representatives to recommend that you establish and maintain an account at LPL. Representatives will recommend that clients establish and maintain their account at LPL only if they believe it is in the client’s best interest. Gladstone representatives who are also a registered representative with LPL can receive payments from LPL in connection with his/her transition to LPL as a registered representative. Registered representatives often receive an initial loan and/or transition payment from LPL to assist with the costs associated with transitioning client assets to LPL’s custodial platform (“Transition Assistance”). The amount of Transition Assistance that LPL pays to any registered representative can vary greatly but is typically between 5 – 15 bps of verified or unverified assets. Transition Assistance can also be provided by LPL, at its discretion, to Dually Registered Persons for investment advisory assets custodied at LPL where Gladstone is Adviser. Transition Assistance is paid to the registered representative to assist with the costs associated with the transition, such as moving expenses, leasing space, furniture, staff, and termination fees associated with moving accounts; however, there is no verification to confirm the use of these payments for such transition costs. These payments can be in the form of loans to the registered representative, which are repayable to LPL or forgiven by LPL based on years of service with LPL and/or the scope of business engaged in with LPL, including the amount of assets custodied at LPL. The receipt of these payments is a conflict of interest in that a representative has a financial incentive to recommend that a client custody asset at LPL in order for the loan to be forgiven. However, to the extent we recommend you establish or maintain an account with Gladstone and custody at LPL, it is because we believe it is in your best interest to do so based on your financial circumstances, goals, and objectives, as well as the services offered. Gladstone and its representatives receive limited non-cash compensation from product sponsors, third-party managers, and model providers, including gifts with a de minimis annual value, Page 28 of 30  occasional meals or entertainment, reimbursement associated with educational meetings, business consulting, client events, marketing initiatives, and support for Gladstone-sponsored training conferences and events. This compensation is not tied to the sale of any product. These benefits create an incentive to favor providers that furnish them; however, Gladstone and its representatives are required to recommend providers and strategies based on the client’s best interest. See Items 4 and 8 for information regarding program selection and evaluation of third-party managers, strategies, and platforms. Gladstone utilizes Envestnet Financial Technologies, Inc. (“Envestnet”) to access various third-party investment managers for the TAMP Program and alternative investments through Envestnet’s “Alternatives Exchange” in conjunction with Institutional iCapital Network, Inc. (“iCapital”) and UBS Financial Services, Inc. (“UBS”). Gladstone accesses Envestnet through LibertyFi, LLC, a middle-office Envestnet consulting solution. By utilizing such service providers to access advisory products and services, Gladstone is eligible to receive preferred (lower) pricing on transition support, technology, and other related administrative, operational, and consulting support and services. Gladstone believes that the scope and nature of these services best service the interests and needs of its clients. Envestnet, LibertyFi, iCapital and UBS are not affiliated with Gladstone and Gladstone does not receive revenue sharing or any portion of fees paid directly to these service providers. Item 15. Custody Client assets are housed in unaffiliated and nationally recognized brokerage firms, otherwise known as custodians. Gladstone does not take custody except under the following two conditions, which are considered by the SEC to be custody because of the Firm’s ability to transfer/access funds: 1. Gladstone has the authority to ask the custodian to pay investment adviser fees from client accounts and give payment directly to Gladstone (direct debit). Clients will be sent monthly and/or quarterly written summary account statements directly from the custodian that holds and maintains their assets at least quarterly. Any funds being deposited for investment must be payable to the custodian where the account is held. Custodial statements will reflect the account holdings, transactions for the period reported, and any additions and withdrawals from the account, including the custodian’s withdrawal of Gladstone’s adviser fees. Clients are urged to carefully review the custodian’s statements and compare these official custodial records to any performance reports that the client’s representative provides. A representative’s performance reports can vary from the custodial statements based on systems, accounting procedures, or reporting dates. Clients should notify their representative of any report discrepancies as soon as possible. 2. Clients can establish a standing letter of authorization (“SLOA”) to direct Gladstone to transfer funds or securities from the client’s account to a specified third-party. The client’s SLOA gives Gladstone the authorization to change the timing and/or the amount of the transfer; however, not the ability to change the third-party recipient without the client’s written authorization. Clients receive account statements directly from the custodian at least quarterly. Statements will be sent to the email or postal mailing address you provided to the custodian. You should carefully review those statements promptly when you receive them. You should also compare your custodial account statements with any performance reports you may receive from your representative and contact us immediately should there be any discrepancies or concerns. Item 16. Investment Discretion It is our customary procedure to have full discretionary authority in order to supervise and direct the investments of our clients’ accounts and retain sub-advisers. This authority is for the purpose of making and implementing investment decisions, including the hiring and firing of sub-advisers, without the client’s prior consultation. All investment decisions are made in accordance with the client’s stated investment objectives. Clients grant discretionary authority to Gladstone Wealth Partners by completing the following items: Page 29 of 30  • Execution of Gladstone’s investment management agreement, which designates the authority for us to implement investment decisions and, as applicable, to select sub-advisers on your behalf. • Provide Gladstone with trading authorization and discretionary authority on the new account forms submitted to the broker-dealer acting as custodian for the client’s account(s). Other than advisory fees due to Gladstone, which the Firm will receive directly from the custodian, Gladstone’s discretionary authority does not grant us the authority to take or have possession of any assets in the client’s account. Clients can impose reasonable written restrictions on investments in particular securities or types of securities based on their values and beliefs. Gladstone will make reasonable efforts to comply with those restrictions but cannot guarantee complete adherence when an account uses a model portfolio, indexed product, fund, ETP, sub-adviser, variable annuity subaccount, or retirement plan investment lineup that can hold securities the client seeks to restrict. A restriction that prevents Gladstone from managing the account consistently with the selected program or strategy can require selection of a different program or termination of the advisory relationship. Any limitation on trading authority will be documented in Gladstone’s investment management agreement. See Item 4 for information regarding account, program, and model selection. Item 17. Voting Client Securities Gladstone will not request or accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the Custodian. Clients should direct all proxy questions to the issuer of the security. For client accounts managed by a third-party portfolio manager, clients should refer to the separate agreement they entered into with the portfolio manager and that portfolio manger’s specific proxy voting policies and procedures. In addition, Gladstone and its representatives do not accept authority to take action with respect to legal proceedings relating to securities held in the account. Class Action Lawsuits From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Gladstone Wealth Partners has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. Furthermore, we have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who have been injured as a result of actions, misconduct or negligence by corporate management of issuers whose securities are held by clients. Item 18. Financial Information Balance Sheet Requirement Gladstone does not require or solicit prepayment of more than $1,200 in fees per client, six (6) months or more in advance, we are not required to deliver our balance sheet along with the Disclosure Brochure. Financial Condition Gladstone does not have any financial condition that would reasonably be likely to impair its ability to meet its contractual commitments to clients. Bankruptcy Petition Gladstone has not been the subject of a bankruptcy petition at any time during the last ten (10) years. Page 30 of 30