GLADSTONE WRAP BROCHURE

Gladstone Wealth Partners - Wrap Fee 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, Appendix 1, Wrap Fee 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,”). If you have any questions about the contents of this brochure, please contact us at (908) 719-1313. 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. Additional information about Gladstone and its investment adviser representatives (“IARs” or “representatives”) is available on the SEC’s website by searching our name or CRD No. 250787 at https://adviserinfo.sec.gov/. Item 2. Material Changes Gladstone Wealth Partners (“Gladstone”) filed its last annual update and distribution for its last Form ADV Part 2A – Appendix 1 Wrap Fee Brochure (“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 amendment. • • • • • Item 4 was revised to streamline and clarify the Wrap Fee Programs, including client onboarding; account, program, sub-adviser, and model-portfolio selection; the factors affecting whether a wrap program is cost- effective; client-imposed investment restrictions; treatment of transferred and unbillable positions; and the discretionary nature of Gladstone-sponsored wrap accounts. Item 4 was revised to clarify investment-management fees and billing practices. The revisions disclose that certain fees may be calculated as a percentage of assets under management subject to a stated maximum dollar amount; clarify the applicable percentage, cap, billing period, and treatment of deposits, withdrawals, partial periods, and termination refunds; and update the description of LPL billing practices and related- account group-fee arrangements. Item 4 and Item 9 were revised to clarify the Gladstone Capital Management Program and Gladstone’s compensation arrangement with Kessler Investment Group, LLC. Clients do not pay a separate portfolio- manager or platform fee to KIG; Gladstone pays KIG 0.15% (15 basis points) of assets managed, prorated quarterly, from Gladstone’s advisory fee; and representatives earn the same compensation regardless of the GCM strategy offered. Item 4 was revised to state expressly that Gladstone does not charge performance-based fees. Item 6 was revised to clarify Gladstone’s methods of analysis, platform-level and GCM-specific due diligence, and model-portfolio practices, and to 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. Page 1 of 28  • • • • • Item 9 was revised to clarify that Gladstone provides non-discretionary retirement plan consulting services under ERISA Section 3(21), while any discretionary ERISA Section 3(38) services are provided separately through LPL by appropriately affiliated representatives under separate LPL agreements and supervision. Item 9 was revised to clarify that Gladstone pays LPL a 10 basis point oversight fee on applicable assets held at non-LPL custodians and managed by LPL-registered representatives, subject to applicable account-type exclusions, and to clarify the related incentive to recommend LPL as custodian. Item 9 was revised to clarify the review of wrap accounts, including the continued appropriateness of the selected account type, program, third-party manager, model portfolio, investment strategy, and fee arrangement. Item 9 was revised to clarify client-imposed investment restrictions, the limitations that may apply to model portfolios, indexed products, funds, exchange-traded products, sub-advisers, variable annuity subaccounts, and retirement plan investment lineups, and the circumstances in which a restriction may require a different program or termination of the advisory relationship. Item 9 was revised to clarify Gladstone’s approved-custodian and directed-brokerage practices, the potential limitations on execution and available investments or share classes, and Gladstone’s evaluation of approved custodians. • The Brochure was revised throughout to correct the name of Gladstone’s parent company to Integrity Wealth, LLC; remove duplicative or stale disclosures; improve cross-references; and correct drafting and typographical errors. Item 3. Table of Contents Item 1. Cover Page ............................................................................................................................................................... 1 Item 2. Material Changes ..................................................................................................................................................... 1 Item 3. Table of Contents .................................................................................................................................................... 1 Item 4. Service, Fees, and Compensation ......................................................................................................................... 2 Item 5. Account Requirements and Types of Clients ..................................................................................................... 11 Item 6. Portfolio Manager Selection and Evaluation ..................................................................................................... 11 Item 7. Client Information Provided to Portfolio Managers ......................................................................................... 19 Item 8. Client Contact with Portfolio Managers ............................................................................................................. 19 Item 9. Additional Information ......................................................................................................................................... 19 Item 4. Service, Fees, and Compensation 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 offices located in Palm Beach Gardens, Florida. Gladstone was established in 2015 and is principally owned by Integrity Wealth, LLC. Gladstone primarily provides investment 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 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 (“IAR,” or “representative”) 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. Advisory Services Offered We offer investment advisory services primarily to retail investors. These services include portfolio management Page 2 of 28  services through wrap fee programs, including accounts managed directly by your Gladstone representative and/or a sub-adviser. The maximum advisory fee Gladstone will charge is 2%. Gladstone also offers advisory services on non-wrap accounts, including accounts held at custodians that Gladstone has agreements with, third- party retirement accounts, financial planning and investment consulting, and retirement consulting services. Information about these services is described in Gladstone’s firm brochure (Form ADV, Part 2A, Firm Disclosure Brochure) that will be delivered to the client, as applicable. 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. 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. In certain programs, as appropriate, the representative can recommend a portion of your portfolio be 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 in their discretion. Portfolio weighting among various investments, sub- advisors, and market sectors will be determined by each client’s individual needs and circumstances. 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. Clients can impose reasonable written restrictions on the management of accounts. However, restrictions can Page 3 of 28  be unavailable or impracticable for certain model portfolios, sub-advisers, variable annuity subaccounts, retirement plan accounts, indexed products, funds, and ETPs. 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. In addition to Gladstone Wealth Partners’ disclosures, clients should carefully review the Form ADV, Part 2A Firm Brochure, and Form CRS for any recommended sub-adviser and program for important additional information regarding the sub-adviser’s services, fees, conflicts of interest and other important information. Depending on client preference, Gladstone may retain discretionary authority to hire and fire sub-advisers, as necessary, to better service our clients’ accounts. Wrap Fee Programs A wrap fee program is an advisory program under which a client is charged a specified “bundled” fee or fees for investment management and trade execution and is not based directly upon transactions in a client’s account. In other words, transactions in a client’s wrap fee account are generally effected without separate commission charge to the client and a portion of the wrap fee is generally considered as being in lieu of commissions. It is important to understand that the more assets under management or advisement with Gladstone, the more you will pay in fees. We receive a portion of the wrap fee for our services. Depending on the program, wrap fee clients will incur certain additional costs, such as custodial fees, odd-lot differentials, step-out fees (when trades are placed with a broker other than the custodying broker), fees and expenses charged by mutual funds and exchange traded products (ETPs) to their shareholders, exchange fees, transfer taxes, wire transfer and electronic fund fees and certain administrative fees charged in connection with wire transfers or certificate issue. In general, a wrap fee account is more cost effective for the client when periodic trading activity is anticipated, though a wrap fee account may be more expensive than a non-wrap fee account when trading activity is low. Each wrap fee program offered by Gladstone is described below. A firm brochure will also be provided for any third-party investment adviser that provides advisory services to a client as part of the wrap fee program. A wrap fee program may cost you more or less than purchasing investment advisory, brokerage, custody, and other services separately. The relative cost of a wrap fee program depends on several factors, including: (i) the frequency of trading activity in your account (wrap fee programs are generally more cost-effective for accounts with higher trading activity, while accounts with lower trading activity may pay more under a wrap fee arrangement than they would if charged separately for each transaction); (ii) the size of your account (larger accounts may benefit from economies of scale in separately priced arrangements); (iii) the types of securities held in your account (certain securities, such as mutual funds and ETPs, have internal expenses that are charged regardless of whether the account is in a wrap fee program); (iv) the level of advisory services provided; and (v) the availability and cost of comparable services from other providers. 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 Page 4 of 28  period. You should consider these factors and discuss them with your representative to determine whether a wrap fee program is appropriate for your circumstances. Each account is managed by one or more representative who serves as the primary point of contact between the Firm and the client and who determines which available resources to utilize in connection with providing individualized investment advisory services. Some representatives choose to incorporate more available resources in their provision of investment advisory services than others. Investment strategies utilized by representatives can vary greatly as warranted by individual circumstances. Not all services are available to all clients, through all representatives, or in all jurisdictions. Recommendations presented to clients by representatives and the implementation of such recommendations are dependent upon the information provided by the client to build the client’s financial profile, which outlines each client’s current situation (e.g., income, investment objectives, and risk tolerance levels) and is used to construct a client specific action plan to aid in the selection of an investment program, portfolio and, as appropriate, a sub-adviser, that matches their restrictions, needs, and targets. Gladstone encourages clients to notify their representative promptly if they experience any material change in their financial circumstances or investment goals. Gladstone Sponsored Wrap Programs Gladstone Wrap Program Gladstone sponsors a wrap fee program in which we provide continuous and regular supervisory or management services. In this program the Advisor acts as the portfolio manager and tailors advisory services to the individual needs of the client. Depending on the investment strategy, securities used in these programs include equities, fixed income securities, mutual funds, ETPs, and alternative investments, but can include other securities and products available on the platform. If structured products or alternative investments, or annuities are utilized as part of the account’s investment strategy, the assets will be reported on custodian’s account statements, but the actual securities are typically held with and valued by the specific issuer. With limited exception for certain clients, accounts are managed on a discretionary basis. A discretionary account is an account that gives the representative the authority to make individual trade without the consent of the client. A non-discretionary account is an account where the client ultimately decides whether or not to make a trade. Clients can choose to custody their assets at Charles Schwab & Co., Inc. (“Schwab”) on the Charles Schwab Institutional platform, Fidelity Investments (“Fidelity”) on the Fidelity Institutional Wealth Services platform, or LPL Financial on the SWM Platform. The custodian selected by the client provides clearing, custody, or other brokerage services to the client. The custodian is not an investment adviser to the client and has no authority or responsibility for investment decisions made for the account. This program was previously referred to separately by the custodian’s platform name (Charles Schwab Institutional, Fidelity Wealth Services, LPL SWM II). Clients should refer to the pricing guide/fee schedule of the custodian at which the account is held for specific information regarding services that have associated fees which are separate from and in addition to the fees the client pays us. Gladstone Capital Management The Gladstone Capital Management program (“GCM”) is a Gladstone-sponsored wrap fee program that provides clients with access to investment strategies managed by Kessler Investment Group, LLC (“KIG”), an independent Page 5 of 28  SEC-registered investment adviser that serves as sub-adviser to GCM accounts. KIG manages client assets on a discretionary basis. Gladstone charges the client the annual asset-based advisory fee specified in the advisory agreement. Clients do not pay a separate portfolio manager or platform fee to KIG. Gladstone pays KIG 0.15% (15 basis points) of assets managed, prorated quarterly, for portfolio management services. Representatives earn the same compensation regardless of the GCM strategy offered. The representative assists the client in selecting an appropriate KIG strategy, provides initial and ongoing assistance regarding strategy selection, and serves as the point of contact regarding changes to the client’s investment objectives, financial circumstances, and investment restrictions. Typically, equities, fixed-income securities, mutual funds, and ETPs are used to implement the strategies, although other securities may be used. Clients may impose reasonable restrictions as provided in the applicable agreement. A separate account is established for each selected investment strategy, and each account is managed independently of the client’s other accounts. When utilizing the GCM program, clients can select Schwab or Fidelity to serve as custodian and executing broker for assets in the account. Minimum account values range from $10,000 to $100,000 depending on the investment strategy selected; however, in certain instances, the minimum account value may be lower or higher. Clients should refer to their account application package and KIG brochure for specific information on fees imposed by third parties which are separate from and in addition to the fees the client pays to us. Turnkey Asset Management Program (“TAMP”) The TAMP Program provides clients with access to the investment advisory services of portfolio management firms offered through Envestnet Asset Management, Inc. The Gladstone representative provides initial and ongoing supervisory and investment management services including initial selection of an independent manager, periodic review of the account, and serving as the point of contact between the client and the independent manager. When utilizing the TAMP program, clients can select Schwab or Fidelity to serve as custodian and executing broker for assets in the account. Account minimums range from $2,000 to $100,000 but can be more or less depending on the manager and/or model strategy selected. Investment Management Fees for Wrap Programs A wrap fee program is a program where a client is charged a specified “bundled” fee (generally, a percentage of assets under management) for discretionary or non-discretionary investment management services and trade execution costs and sometimes other services such as custody, record keeping and reporting. Gladstone receives a portion of the wrap fee for our services and, in most instances, representatives receive a portion of the fee paid to Gladstone for their services. Our Advisory fee is an annual percentage fee of up to 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, cap, billing period, and treatment of deposits, withdrawals, and partial periods will be stated in the client’s written agreement. Fees are assessed on all asset types, including securities, cash, and cash equivalents. Fees are paid quarterly in advance, are negotiable, and are established in writing in our investment management agreement or broker/custodian agreement with you prior to our working together. The fee that you negotiate with your representative may be more or less than the fees charged by other representatives or consultants at Gladstone or other firms for similar services. Representatives take various factors into consideration when establishing their fee including, but not limited to, the complexity of the Page 6 of 28  engagement, market value of assets, the level and scope of the overall investment management and/or consulting services to be rendered, and other objective and subjective factors. Representatives have a conflict of interest in establishing their fee in that the higher the fee is to you, the more profitable their business is. By signing our investment management agreement, our billing agreement, or an LPL account application, you authorize us to deduct fees quarterly and in advance from your account. We will have no other authority to deduct monies from your account, except to request the custodian disburse funds directly to you or your agents upon your specific written instructions. Either you or we may terminate the agreements at any time. In the event of termination, you are responsible for monitoring the securities in your account, and we as the investment adviser will have no further obligation to act or advise with respect to that account. If the agreement is terminated prior to the last day of the calendar quarter, a prorated portion of the fee previously paid for that quarter based on the number of calendar days remaining will be refunded to you or your account. Since Gladstone began providing these services, it has had other fee structures in effect, which may have been lower or higher or different than that described above. As new fee structures are put into effect, they are generally made applicable only to new clients, and fees to existing clients are generally not affected. Accounts custodied at LPL: LPL calculates and deducts the investment management fee as described in LPL’s account agreement, unless other arrangements are made in writing. A client who wishes to be billed rather than have the fee deducted directly from the account must submit the request to LPL through the representative. LPL deducts the account fee quarterly in advance. If the agreement is terminated before the end of the quarterly period, LPL generally pays the client a prorated refund of prepaid investment management fees based on the number of days remaining after the termination date, subject to LPL’s account terms. Payment of fees may result in the liquidation of securities if there is insufficient cash in the account. Clients receive an account statement from LPL at least quarterly showing fees debited or credited pursuant to written authorization. Upon written request, LPL may permit eligible related accounts to use a group-fee arrangement under which accounts are billed using a flat fee or a blended tiered fee based on aggregated account values. Accounts custodied at Schwab or Fidelity: Wrap fees are due and payable in advance and are based upon the ending account values as of the close of business on the last day of the previous calendar quarter. Fees are deducted from the account by the qualified custodian. Fees for the initial quarter are adjusted pro rata based upon the number of calendar days in the quarter that the Investment Advisory Agreement goes into effect. If assets are deposited into or withdrawn from an account after inception of a billing period in an amount equal to or greater than $5,000, the fee payable with respect to such assets is prorated to reflect the change in portfolio value. Payment of fees may result in the liquidation of a client’s securities if there is insufficient cash in the account. Gladstone’s process to value client holdings and assess fees based on those valuations are based on the market value assessed by the qualified custodians of the assets. Gladstone neither participates in the valuation nor adjusts those valuations. Cash balances, such as money market funds, are considered an asset class and are included in client’s asset-based fee calculation. If an account is closed withing the first six months by the client or as a result of withdrawals that bring the account value below the required minimum, we reserve the right to retain the pre-paid quarterly account fee for the current quarter in order to cover the administrative costs of establishing the account. Please refer to your sub-adviser’s disclosure documents for their termination policies. Unless stated otherwise in the applicable agreement, Gladstone or the client may terminate the agreement for portfolio 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 of advisory services, we, the broker/custodian, or the sub-adviser will determine the amount of any outstanding fees due to/from the client. Transactions in progress will be completed in the normal course of business. Page 7 of 28  The client receives a pro rata refund of any pre-paid unearned advisory fees based on the number of days remaining in the quarter after the termination date. Clients receive an account statement from the qualified custodian at least quarterly. The statement includes the amount of any fees debited or credited from the client’s account pursuant to written authorization. Other Fees and Expenses You Pay in Connection with Investment Management Gladstone offers wrap program options to its advisory clients. In most circumstances, our broker/custodians do not charge separately for custody, trade execution, clearance, and settlement of transactions but are compensated by charging Gladstone an asset-based fee (see the “Asset-Based Pricing” section below). Each of our broker/custodian’s asset-based fee arrangements are independently negotiated and are based on the condition that the Firm collectively maintains a minimum dollar amount of assets at the broker/custodian. Certain types of accounts, such as Personal Choice Retirement Accounts (PCRA),Retirement Plan Services (RPS), Stock Plan Services (SPS), Health Savings Brokerage Accounts (HSBA), and Managed Account Services, as well as asset types, such as unit investment trusts (UITs), American depository receipts (ADRs), alternative investments (AI), and other non-standard assets are exempt from asset-based pricing and subject to separate custody and/or commission charges by the broker/custodian that the client is responsible for paying. The broker/custodian does not share commission or ticket charges with Gladstone or its representatives. Clients should also be aware that they are responsible for paying all other applicable fees, including custodian fees, mutual fund expenses, 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 fees 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. 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 may 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, the Firm 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 Page 8 of 28  trading policy, the policy can limit a client’s transactions in shares of the fund. Many funds available in Gladstone’s advisory programs may 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’s 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 particular 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 may also be subject to brokerage fees. Third-Party Manager Fees: Clients with assets in third-party portfolio manager programs are subject to a portfolio manager fee and platform fee. 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 and in addition to the advisory fee you pay us and are disclosed on separate disclosure documents provided to the client 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 assets managed, prorated quarterly. This payment is made from Gladstone’s advisory fee and does not increase the fee stated in the client’s advisory agreement. Representatives earn the same compensation regardless of the GCM strategy offered. 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 investment management fees you pay us. Gladstone’s representatives do not “step out” trades; however, some of the 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 the 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. 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, expense, and administration charges (M&E&A charges.) Other riders or annuity expenses may 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. loan balance. The total amount of compensation 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 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 particular 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 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 Page 9 of 28  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 may apply. You will find these fees disclosed in the broker/custodian’s account application paperwork provided to you associated with these accounts. Investors may 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 may also apply. Withdrawal options, required minimum distributions, tax treatment (particularly with reference to employer stock) may 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 protections 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 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 Page 10 of 28  arrangements may 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. 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 5. 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) may waive minimum initial investment requirements at its discretion. Item 6. Portfolio Manager Selection and Evaluation Each representative independently determines based on his own investment strategies, methods of analysis, and preferences, in conjunction with each client’s specific profile and financial circumstances, which services and products to recommend. Accounts are managed independently, and representatives are under no obligation or requirement to buy or sell the same investments for accounts, even when the investment strategy may be similar. Your representative, working with you, provides personalized and individualized investment advice and can employ a variety of investment strategies based on a client’s investment objectives, financial circumstances, risk tolerance, financial needs, and specific circumstances. Such strategies typically include long-term and/or short-term purchases and sales of securities. Representatives must meet certain selection, review, and qualification criteria prior to becoming associated with the Firm 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 your Representative’s training, skill and experience, your representative has access to various technical research, due diligence materials, and publications to evaluate the performance of securities, third- party managers, as well as to make investment decisions on your behalf. Some Representatives choose to incorporate more of the Firm’s available resources in their provision of advisory services to their clients than others do. Representatives are under no obligation or requirement to utilize the same methods of analysis, investment strategies, or buy or sell the same investments or select the same third-party portfolio managers for all accounts, even when the investment strategy may be similar. Your representative will purchase or sell securities in your account based on your (i) investment objective, (ii) risk tolerance, (iii) liquidity needs, (iv) time horizon, and (v) other factors. Representatives conduct additional screenings and analysis to identify products, professional third-party portfolio managers, and investment strategies that are suitable for a particular client’s financial circumstances, investment guidelines, and preferences. Page 11 of 28  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 to validate their business models, costs, research and due diligence processes, and ability to identify and access attractive products and professional third-party portfolio managers that offer a variety of investment strategies and risk exposures. Gladstone does not conduct due diligence, calculate, or review the performance for each security, product, or third-party portfolio manager available on the third-party service provider’s platform; but rather, relies heavily on the rigorous quantitative and/or qualitative due diligence and research conducted by the wealth management platform’s professional research and portfolio management consultants. 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. Gladstone’s Investment Committee conducts initial research, due diligence and ongoing monitoring of portfolio managers and investment strategies offered under the GCM program. The Committee conducts a multi-factor quantitative and qualitative evaluation of the third-party manager’s investment philosophy and process, personnel quality, and firm stability through interviews with investment professionals, on-site visits, and/or conference calls. The Committee will also conduct return analysis, and holdings-based analysis and attribution. Managers undergo continued due diligence, including regular monitoring of performance versus benchmarks, material changes to personnel, processes, and the overall firm. Risk of Loss Clients should understand that all investments involve 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 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. Past performance of any investment is not indicative of future performance. Representatives and third-party portfolio managers invest in many different 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. Investing in securities involves risk of loss of principal that the client should be prepared to bear. An offering’s prospectus, or other disclosure document, will outline the terms of the investment including specific risk factors. Clients are strongly encouraged to review all prospectuses and other offering documents to fully understand risks associated with any investment prior to investing. Clients are advised that the risk factors listed below are not a complete description of all risks associated with investment strategies or investment vehicles utilized. Additional risks are detailed in each fund prospectus or disclosure memorandum that should be carefully considered before investing. Market Risk: This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. Page 12 of 28  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. Model Portfolio Risk: Model portfolios are designed for categories of investors and are not tailored security-by- security to each client. A model provider may 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 may 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. 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 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 Page 13 of 28  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 rsonal 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 likely 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 may be subject to loss and/or change in market value. Money market instruments may temporarily suspend your ability to sell shares if the fund’s liquidity falls below required minimums because of market conditions or other factors. The Firm 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 have been, and may continue in the future to be, lower than the aggregate fees and expenses charged for a client’s participation in an advisory program. This may result in a client experiencing a negative overall return with 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 may not be 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 Page 14 of 28  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 may be an additional cost to investors who redeem before holding shares for a specified amount of time. The repurchase offer program may 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 may trade at prices above or below their net asset value (“NAV”). As a result, investors in ETPs may purchase fund shares at process 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 may 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 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” pr “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 may 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 may 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 may have higher expense Page 15 of 28  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 case, the security may be called away and 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, may 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 may 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 may 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. Page 16 of 28  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 may 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 may 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 may experience significant delays (including, potentially, indefinite delays) to exit the investment. In addition, share redemption programs may 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 may constitute a return of capital and reduce the amount of capital available to make investments. In some cases, there may be an additional cost to investors who redeem before holding the shares for a specified number of years. 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 may 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 may fund distributions from offering proceeds or borrowings, which may 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 may repurchase shares at a price below net asset value. The repurchase program may 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 may involve complex tax structures and delays in distributing important tax information. At the discretion of the issuer of the fund, there may 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 may be an additional cost to investors who redeem before Page 17 of 28  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 may 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 may invest in a number of private hedge funds, funds of funds also hear 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 increase 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 may demand immediate payment of all or any portion of the outstanding obligations, or require additional cash or 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. 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. 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 Page 18 of 28  into its vendor due diligence program to review and monitor the use of AI by service controls providers. Technology based processes involve uncertainties and are not viewed as a substitute for Gladstone’s professional judgment and oversight. Terrorism, Disease Epidemics and Other Catastrophic Risks: These are the risks of loss that may 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. 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 may have been injured as a result of actions, misconduct or negligence by corporate management of issuers whose securities are held by clients. Item 7. Client Information Provided to Portfolio Managers The representative will request information from the client regarding the client’s financial circumstances including income, net worth, time horizon, liquidity needs, investment objectives, preferences, among other things, in determining whether a wrap fee account is appropriate for and in the best interest of the client. The representative will contact the client periodically to determine if there have been any changes in the client’s financial circumstances so that the investment strategy of the account can be adjusted accordingly. The information provided by the client will be shared among Gladstone, the representative, the selected broker/custodian, third-party managers (if any), and will be used in formulating recommendations and strategies in managing the client’s assets. Clients should promptly contact their representative any time the client’s financial circumstances or investment objectives change, or if any of the information previously provided to the representative has materially changed. The representative can then determine whether the wrap fee account and its investments continue to remain appropriate, or if changes should be recommended. Item 8. Client Contact with Portfolio Managers 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 may 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. Item 9. Additional Information Disciplinary Information Gladstone has no legal or disciplinary information to disclose. 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 representatives is available on FINRA’s BrokerCheck® website https://brokercheck.finra.org and the SEC’s website www.adviserinfo.sec.gov Page 19 of 28  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 LPL-registered representatives who manage assets at a broker-dealer or custodian other than LPL Financial. For applicable accounts, Gladstone pays LPL an oversight fee of 10 basis points on assets under management held at the non-LPL custodian; certain account types are excluded from the calculation. The payment is deducted from the portion of the advisory fee that otherwise would be paid to the representative. This creates an incentive for the representative to recommend that clients maintain assets at LPL rather than another custodian. Gladstone and its representatives will recommend a custodian only when they believe the recommendation is in the client’s best interest. Gladstone provides non-discretionary retirement plan consulting services as an investment adviser under Section 3(21) of ERISA when specified in the applicable agreement. In that capacity, Gladstone assists plan fiduciaries with matters such as plan design, investment selection and monitoring, and participant education, but the plan fiduciary retains final decision-making authority. Gladstone does not provide discretionary investment-management services to qualified retirement plans as an ERISA Section 3(38) investment manager. In limited circumstances, certain Gladstone representatives are separately associated with LPL as investment adviser representatives and may provide discretionary ERISA Section 3(38) services to plan sponsors solely in their capacity as representatives of LPL. Those services are provided under separate LPL agreements, are supervised by LPL, and are not services of Gladstone. Kessler Investment Group, LLC (“KIG”): Gladstone maintains a material relationship with Kessler Investment Group, LLC (“KIG”), an SEC-registered investment adviser (CRD No. 153696; SEC No. 801-71393). KIG serves as sub-adviser to investment strategies offered to individual separate accounts under the GCM Program. Gladstone charges clients the annual asset- based advisory fee specified in the advisory agreement and pays KIG 0.15% (15 basis points) of assets managed, prorated quarterly, for portfolio management services. Clients do not pay a separate KIG fee, and representatives earn the same compensation regardless of the GCM strategy offered. A material conflict of interest exists when a representative is dually registered with Gladstone and KIG and uses KIG as sub-adviser because KIG receives compensation for managing the account. 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 Page 20 of 28  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 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. Outside business activities that create a material conflict of interest or that provide a substantial source of the Supervised Person’s income or time are disclosed in the Supervised Person’s brochure supplement. 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 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 Page 21 of 28  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 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. 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 the Firm seeks to observe. Gladstone personnel are required to conduct themselves with integrity and follow the principles and policies detailed in the Firm’s code of ethics. A copy of the code of ethics is available upon request by contacting the Firm at (908) 719-1313. Gladstone’s code of ethics addresses conflicts of interest the Firm has 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 may 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 may 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 an 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 Page 22 of 28  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 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 act may provide clients in GCM program accounts with a better trading price than clients in the SWM program. Review of Accounts Representatives review wrap fee accounts on an ongoing basis and complete a review of each client account at least annually to determine the continued appropriateness of the account and if it remains in the client’s best interest. An Representative’s underlying premise for the continued suitability of a wrap account is based on the totality of services provided, not on any single service or component of the overall fee. The Representative will contact the client periodically to determine if there have been any changes in the client’s financial situation or investment objectives so that the investment strategy of the account may be adjusted accordingly. Additional contact may be triggered at the client’s request, or by material market, economic, or political events, or by 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 may 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 may 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. 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 can not 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. Page 23 of 28  Other Compensation these programs incentivize Representatives to base Gladstone representatives who 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. Because Representatives who participate in LPL’s inventive programs are rewarded with their cash and/or non-cash compensation, recommendations on their own financial interest rather than the client’s best interest. Portions of these programs are subsidized by other vendors and issuers which creates an inventive to promote the products of these vendors and issuers. Gladstone does not directly or indirectly receive cash or non-cash compensation from LPL. Gladstone representatives who are also a registered representative with LPL may 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 may 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 may 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 an Representative has a financial incentive to recommend that a client custody assets 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 other compensation from product sponsors. However, such compensation may not be tied to the sales of any products. Compensation includes such items as gifts with a de minimis annual value, an occasional dinner or ticket to an entertainment event, reimbursement in connection with an educational meeting, business consulting, client events, or marketing initiatives. Product sponsors also pay for, or reimburse Gladstone for the costs associated with, Gladstone-sponsored training conferences and events. 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. Investment Discretion It is our customary procedure to have full discretionary authority in order to supervise and direct the investments Page 24 of 28  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: • Execution of Gladstone Wealth Partner’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 Wealth Partners with trading authorization and discretionary authority on the new account forms that are 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 may impose reasonable restrictions, in writing, on investing in certain securities or types of securities in accordance with their values and beliefs. Gladstone Wealth Partners will make every effort to comply with the wishes of the client but cannot guarantee absolute adherence due to our use of indexed products, funds, and ETPs that may hold or trade securities sought to be restricted. Any limitations to the trading authorization will be added to Gladstone’s investment management agreement in writing. 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. 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. 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 investment management program accounts. Gladstone does not have discretionary authority to select the broker/custodian for custody and execution services. While Gladstone’s Representative s may 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 to 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, the representative may not be permitted to use a custodian other than LPL. Whether the representative may use another custodian is determined by Gladstone and LPL based on the representative’s experience, production level, and other factors. Page 25 of 28  When a client selects a non-LPL custodian and the representative is registered with LPL, Gladstone pays LPL an oversight fee of 10 basis points on the value of applicable assets under management held at that custodian; certain account types are excluded from the calculation. The payment is deducted from the portion of the advisory fee that otherwise would be paid to the representative, creating a financial incentive to recommend LPL as custodian. Gladstone and its representatives will recommend a custodian only when they believe the recommendation is in the client’s best interest. Certain clients may negotiate with their representative to designate specific positions held at custodians such as Charles Schwab or Fidelity as “unbillable,” meaning those positions are excluded from fee calculations. Gladstone does not monitor, supervise, or provide advisory services with respect to unbillable positions. This practice creates a conflict of interest for clients whose assets are custodied at LPL Financial because 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 a custodian. Gladstone addresses this conflict by disclosing it to clients and allowing them to select their preferred approved custodian, subject to the custodian’s policies. Asset-Based Pricing Representatives pay a platform fee (“asset-based fee” aka “asset-based pricing”) to Gladstone which it passes 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 may arise with individual ticket/transaction charges that can influence an Representative’s decision whether or not to trade an account. Depending on the broker/custodian, charges for asset-based pricing may 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 may 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 may arise that can influence an Representative recommending a particular broker/custodian or utilizing specific assets. We believe this fee structure mitigates conflicts of interest and financial incentive for an Representative to utilize any specific asset type. Clients are advised that while Gladstone endeavors to use the lowest-cost mutual fund 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, the Firm cannot ensure that all clients will hold the lowest cost shares available on the broker/custodian’s platform at any given time. 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. Page 26 of 28  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 may be 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 clients to select one of the Firm’s approved broker-dealer custodians—LPL Financial LLC, Charles Schwab & Co., Inc., or Fidelity Institutional—to maintain account assets and execute securities transactions. As a condition of opening and maintaining an account, clients direct Gladstone to execute all transactions through the selected 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 Gladstone were permitted to select the executing broker. The requirement to use an approved custodian also may limit the investment products or share classes available to the account. Gladstone selects and evaluates its approved custodians based on factors including execution quality, service standards, operational efficiency, financial stability, reputation, and overall cost, but the arrangement may not result in the most favorable execution in every circumstance. Aggregation of Orders Purchases, sales, and other orders made for your account may 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 may 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 Page 27 of 28  and individualized advisory services and take action with respect to other clients that may 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 may 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 may be reconciled within Gladstone’s custodian firm account and Gladstone may retain the net gains and losses. 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. An Representative’s performance reports may 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. Page 28 of 28