Evergreen Wealth Advisors

Form ADV Part 2A - Wrap Fee Brochure Form ADV Part 2A - Wrap Fee Program Brochure For: Evergreen Wealth Advisors Corporation www.evergreenwealth.com Office Addresses: 1 Glenwood Ave Office 04-113 Raleigh, NC 27603 120 NE 27th St., Suite 100, Miami, FL 33137 Telephone: +1 (888) 884-0557 Mailing Address: 5540 Centerview Dr., Ste 204 PMB #48153 Raleigh, NC 27606 August 18, 2026 This Brochure provides information about the qualifications and business practices of Evergreen Wealth Advisors Corporation ("Evergreen Wealth Advisors" or "Evergreen" or the "Advisor") and the Evergreen Wrap Fee Program. If you have any questions about the contents of this Brochure, please contact the Advisor at the telephone number or addresses listed above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. Evergreen is a registered investment adviser with the SEC. Registration of an investment adviser does not imply any certain level of skill or training. information about Evergreen is available on the SEC's website Additional www.adviserinfo.sec.gov. 1  Form ADV Part 2A - Wrap Fee Brochure Item 2 – Material Changes This Brochure provides Clients with a summary of the Evergreen Wrap Fee Program, including fees, services, brokerage practices, and related conflicts of interest. This Item summarizes new and updated information. Annual Update: The Advisor is required to update certain information at least annually, within 90 days of the Advisor’s fiscal year end (“FYE”) of December 31. The Advisor will provide Clients with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of the Advisor’s FYE or will provide each Client with a revised Brochure with a summary of those changes in this Item. Material Changes: Should a material change in the Advisor’s operations occur, depending on its nature the Advisor will promptly communicate this change to Clients (and it will be summarized in this Item). ● Evergreen has moved its Raleigh office location and its new address is reflected above 2  Form ADV Part 2A - Wrap Fee Brochure Item 3 – Table of Contents Item 2 – Material Changes...........................................................................................................................2 Item 3 – Table of Contents.......................................................................................................................... 4 Item 4 – Services, Fees, and Compensation............................................................................................. 5 Item 5: Account Requirements and Types of Clients............................................................................... 7 Item 6: Portfolio Manager Selection and Evaluation................................................................................ 8 Item 7: Client Information Provided to Portfolio Managers..................................................................... 9 Item 8: Client Contact with Portfolio Managers........................................................................................ 9 Item 9: Additional Information.................................................................................................................... 9 3  Form ADV Part 2A - Wrap Fee Brochure Item 4 – Services, Fees, and Compensation A. Services Evergreen Wealth Advisors Corporation (“Evergreen,” “we,” or the “Advisor”) sponsors the Evergreen Wrap Fee Program (the “Program”). Under the Program, Evergreen provides ongoing, fully discretionary portfolio management and related investment advisory services. We monitor client accounts on an ongoing basis and make investment changes as needed to keep accounts aligned with each client’s investment objectives, risk tolerance, time horizon, and financial circumstances. This Wrap Fee Program Brochure is a supplement to Evergreen’s Form ADV Part 2A Disclosure Brochure. Together, these documents describe Evergreen’s advisory services, business practices, and fees. Evergreen also provides financial planning and consulting services to Program clients at no additional charge as part of the Wrap Fee. These services may include investment planning, tax-aware planning considerations, and general financial goal-setting. Portfolio Management Evergreen provides fully discretionary portfolio management to all Program clients. Portfolios are tailored to each client’s investment objectives, risk tolerance, time horizon, and financial circumstances based on Evergreen’s suitability and risk-assessment process. Portfolios are generally constructed using diversified holdings such as equities, exchange-traded funds, fixed income instruments, money market mutual funds, and government securities. Evergreen’s investment management may include tax-loss harvesting, gain deferral, asset location across taxable and tax-advantaged accounts, and periodic rebalancing. Evergreen monitors accounts on an ongoing basis and adjusts portfolios in response to market conditions, changes in client circumstances, cash flows, or drift from target allocations. Wrap Fee Schedule Clients pay a single asset-based wrap fee (the “Wrap Fee”) for services provided under the Program. The Wrap Fee covers Evergreen’s investment advisory and portfolio management services, as well as brokerage and transaction costs, custodial costs, and certain administrative expenses associated with managing client accounts. Fees are assessed monthly based on the average daily balance of assets under management during the billing period, including any cash and cash equivalents held within the portfolio. The applicable fee rate is determined by aggregating total assets across all of a Client's Investment Accounts, as follows: 4  Form ADV Part 2A - Wrap Fee Brochure Management Fee Based on Account Type(s) Held by Client Account Type Value of Assets Monthly AUM Fee Annual AUM Fee First $1,000,000 .0325% .39% Investment Accounts .0242% .29% Next $4,000,000 (over $1M up to $5M) Assets over $5,000,000 .0158% .19% Evergreen may, in its sole discretion, reduce, waive, or negotiate fees for certain clients or groups of clients based on factors such as account size, length of relationship, affiliation with Evergreen, or participation in a promotional or testing program. Portion of the Wrap Fee Paid to the Portfolio Manager Evergreen serves as the sponsor of the Program and the sole portfolio manager for all Program accounts. Evergreen does not use unaffiliated sub-advisers or third-party portfolio managers. After payment of brokerage, clearing, transaction, and custodial costs, the remaining portion of the Wrap Fee is retained by Evergreen as compensation for portfolio management services. Depending on trading activity and account-related costs, Evergreen may retain all, a portion, or only a small portion of the Wrap Fee. No portion of the Wrap Fee is paid to any third-party portfolio manager. B. Program Costs Participation in the Evergreen Wrap Fee Program may cost a client more or less than purchasing investment advisory services and brokerage services separately. Under the Program, clients pay a single asset-based Wrap Fee that includes Evergreen’s advisory services as well as brokerage and transaction costs. If those services were purchased separately, a client would typically pay an advisory fee in addition to transaction-based brokerage charges. Whether the Program is more or less expensive depends primarily on the client’s expected trading activity and account size. Because the Wrap Fee is charged regardless of the number of transactions in the account, clients with higher trading activity may pay less under the Program than they would under a separate advisory and brokerage arrangement. Clients with lower trading activity may pay more under the Program because they pay the Wrap Fee whether or not significant transaction costs are incurred. The total cost of the Program also increases as account assets increase because the Wrap Fee is based on assets under management. Clients should consider the Wrap Fee in light of their anticipated account size, trading frequency, and the nature of Evergreen’s investment approach, which may involve ongoing tax-loss harvesting, rebalancing, and other tax-aware portfolio management techniques that can increase trading activity. Clients are encouraged to discuss with Evergreen whether the Wrap Fee Program is appropriate for their circumstances. 5  Form ADV Part 2A - Wrap Fee Brochure C. Fees and Expenses in Addition to the Wrap Fee In addition to the Wrap Fee, clients may incur certain other fees and expenses in connection with Evergreen’s advisory services. Clients who invest in exchange-traded funds (“ETFs”), money market mutual funds, mutual funds, or other pooled investment vehicles will bear their proportionate share of the fees and expenses charged by those vehicles, including internal management fees and operating expenses. These expenses are separate from, and in addition to, the Wrap Fee. Evergreen does not receive these fees. Clients may also incur markups, markdowns, or bid-ask spreads when purchasing or selling certain fixed income securities, including bonds and other securities traded in principal transactions. These costs are embedded in the transaction price, are not paid to Evergreen, and are in addition to the Wrap Fee. Clients should review applicable account agreements, confirmations, and fund prospectuses for additional information regarding these fees and expenses. D. Compensation to the Person Recommending the Wrap Fee Program Evergreen’s advisory personnel do not receive any separate commission, referral fee, finder’s fee, or other incremental compensation as a result of a client’s enrollment in or continued participation in the Evergreen Wrap Fee Program. Advisory personnel are compensated under Evergreen’s regular employment arrangements, which may include salary and discretionary compensation, but no component of that compensation is directly tied to recommending the Program. Evergreen’s entire advisory business is conducted through a single Wrap Fee Program, and clients do not have the option to participate in a separate non-wrap advisory program sponsored by Evergreen. As a result, Evergreen’s personnel do not receive more compensation for recommending the Program over another advisory program offered by Evergreen. Neither Evergreen nor its personnel receive compensation from clearing brokers, ETF sponsors, mutual funds, or other third parties in connection with recommending the Program or investments held in Program accounts. Evergreen’s sole compensation is the advisory fee paid by clients. Like other asset-based advisory firms, Evergreen has a financial incentive to encourage clients to maintain and increase assets in accounts managed by Evergreen because its fees increase as assets under management increase. Evergreen addresses this conflict through its fiduciary duty and its suitability and account-monitoring processes. Item 5: Account Requirements and Types of Clients Evergreen generally provides advisory services under the Program to individuals, high-net-worth individuals, and corporations. Evergreen has a $100,000 minimum balance requirement to establish a relationship, which may be changed at the firm's discretion. Evergreen reserves the right to decline or discontinue engagements at its sole discretion if it is determined that the relationship is not appropriate or aligned with its service. 6  Form ADV Part 2A - Wrap Fee Brochure Item 6: Portfolio Manager Selection and Evaluation A. Portfolio Manager Selection and Evaluation Evergreen is the sponsor of the Evergreen Wrap Fee Program and the sole portfolio manager for all Program accounts. Evergreen does not select, recommend, or retain unaffiliated sub-advisers or third-party portfolio managers. Accordingly, clients are not assigned among multiple portfolio managers, and Evergreen does not maintain a process for selecting or replacing portfolio managers within the Program. Because Evergreen is the only portfolio manager, all Program accounts are managed through Evergreen’s investment process and are subject to Evergreen’s supervisory, compliance, and account review procedures. Accounts are managed on a fully discretionary basis in light of each client’s investment objectives, risk tolerance, time horizon, financial circumstances, tax considerations, and any applicable account restrictions. Evergreen has a financial interest in managing Program assets itself and retaining the Wrap Fee, which creates a conflict of interest. Evergreen addresses this conflict through its fiduciary duty, suitability process, ongoing account monitoring, and compliance oversight. B. Related Persons Acting as Portfolio Manager Evergreen, as a related person and the sponsor of the Program, has a financial interest in managing Program assets itself and retaining the Wrap Fee. This creates a conflict of interest because Evergreen has an incentive to recommend and maintain client assets in the Program. Evergreen addresses this conflict through its fiduciary duty, suitability process, ongoing account monitoring, and compliance oversight. Evergreen does not use composite or other portfolio manager performance information to select among multiple portfolio managers for the Program, and no third party reviews portfolio manager performance for that purpose, because no multiple-manager selection process exists. Evergreen does not charge performance-based fees. Although Evergreen manages multiple client accounts, its policies and procedures are designed to ensure investment decisions and trade allocations are made fairly and equitably across accounts. C. Standard of Conduct for Portfolio Managers Evergreen’s investment approach is based on each client’s investment objectives, risk tolerance, time horizon, financial circumstances, and tax considerations. Evergreen generally constructs diversified portfolios using equities, fixed income instruments, cash equivalents, ETFs, money market mutual funds, and government securities, and may employ tax-loss harvesting, gain deferral, asset location, and rebalancing. Investing in securities involves risk of loss that clients should be prepared to bear. Please refer to additional information found in the following Items of ADV Part 2A, which accompanies this Wrap Brochure: Item 4 – Advisory Business; Item 6 – Performance-Based Fees and Side-By-Side Management; Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss; and Item 17 – Voting Client Securities. 7  Form ADV Part 2A - Wrap Fee Brochure Item 7: Client Information Provided to Portfolio Managers Evergreen is the sponsor and sole portfolio manager for the Wrap Fee Program. Because Evergreen does not use third-party or unaffiliated portfolio managers, it does not provide client information to any outside portfolio manager. In managing Program accounts, Evergreen uses the client information it obtains through the account opening process and throughout the advisory relationship, including the client’s investment objectives, risk tolerance, time horizon, financial circumstances, tax considerations, account characteristics, and any reasonable account restrictions communicated by the client. Evergreen updates this information as needed based on information provided by the client, periodic reviews, and other communications or changes in the client’s circumstances. Item 8: Client Contact with Portfolio Managers Evergreen is the sponsor and sole portfolio manager for the Evergreen Wrap Fee Program. Clients may contact and consult directly with Evergreen regarding the management of their accounts. Evergreen does not place any restrictions on a client’s ability to contact or consult with Evergreen as portfolio manager. Item 9: Additional Information A. Disciplinary and Other Financial Industry Activities and Affiliations Evergreen and its management persons have not been a party to any legal or disciplinary event that would be material to a client’s or prospective client’s evaluation of Evergreen’s advisory business or the integrity of its management. Neither Evergreen nor its management persons are registered as a broker-dealer, broker-dealer representative, futures commission merchant, commodity pool operator, or commodity trading adviser. Evergreen is a wholly owned subsidiary of Evergreen Wealth Corporation, which provides certain technology, marketing, and administrative support services and also offers Evergreen.ai, a separate affiliated product. These relationships create potential conflicts of interest because Evergreen may have an incentive to use affiliate services, which Evergreen addresses through its fiduciary obligations and oversight of those arrangements. B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Evergreen has adopted a code of ethics under Rule 204A-1 designed to promote compliance with securities laws and Evergreen’s fiduciary duty to clients. The code addresses matters such as confidentiality, insider trading, gifts and entertainment, outside business activities, pre-clearance of employee securities transactions and political contributions, and reporting of personal holdings, transactions, and brokerage accounts. Because Evergreen employees may buy or sell securities for their own accounts that are the same as, or different from, securities recommended to clients, conflicts of interest can arise, and Evergreen addresses those conflicts through its code of ethics and related supervisory procedures. A copy of the code of ethics is available to clients and prospective clients upon request. 8  Form ADV Part 2A - Wrap Fee Brochure Program accounts are monitored at least monthly for consistency with each client’s strategy and investment objectives, and formal comprehensive reviews are conducted at least annually by Evergreen’s investment professionals. Additional reviews may occur in response to significant market, economic, or political developments or when large deposits or withdrawals materially affect an account’s allocation. Clients receive account statements from the clearing broker and should review those statements carefully. Evergreen does not receive economic benefits from third parties in connection with the investment advice it provides to clients. Evergreen does, however, pay certain unaffiliated third parties flat fees for lead-generation access or introductions to prospective clients. These payments are not contingent on whether a prospect becomes a client or on the amount of assets invested. Evergreen has no financial commitment that impairs its ability to meet its contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy petition. 9 

Form ADV Part 2A - Wrap Fee Brochure Form ADV Part 2A - Wrap Fee Program Brochure For: Evergreen Wealth Advisors Corporation www.evergreenwealth.com Office Addresses: 1 Glenwood Ave Office 04-113 Raleigh, NC 27603 120 NE 27th St., Suite 100, Miami, FL 33137 Telephone: +1 (888) 884-0557 Mailing Address: 5540 Centerview Dr., Ste 204 PMB #48153 Raleigh, NC 27606 August 18, 2026 This Brochure provides information about the qualifications and business practices of Evergreen Wealth Advisors Corporation ("Evergreen Wealth Advisors" or "Evergreen" or the "Advisor") and the Evergreen Wrap Fee Program. If you have any questions about the contents of this Brochure, please contact the Advisor at the telephone number or addresses listed above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. Evergreen is a registered investment adviser with the SEC. Registration of an investment adviser does not imply any certain level of skill or training. information about Evergreen is available on the SEC's website Additional www.adviserinfo.sec.gov. 1  Form ADV Part 2A - Wrap Fee Brochure Item 2 – Material Changes This Brochure provides Clients with a summary of the Evergreen Wrap Fee Program, including fees, services, brokerage practices, and related conflicts of interest. This Item summarizes new and updated information. Annual Update: The Advisor is required to update certain information at least annually, within 90 days of the Advisor’s fiscal year end (“FYE”) of December 31. The Advisor will provide Clients with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of the Advisor’s FYE or will provide each Client with a revised Brochure with a summary of those changes in this Item. Material Changes: Should a material change in the Advisor’s operations occur, depending on its nature the Advisor will promptly communicate this change to Clients (and it will be summarized in this Item). ● Evergreen has moved its Raleigh office location and its new address is reflected above 2  Form ADV Part 2A - Wrap Fee Brochure Item 3 – Table of Contents Item 2 – Material Changes...........................................................................................................................2 Item 3 – Table of Contents.......................................................................................................................... 4 Item 4 – Services, Fees, and Compensation............................................................................................. 5 Item 5: Account Requirements and Types of Clients............................................................................... 7 Item 6: Portfolio Manager Selection and Evaluation................................................................................ 8 Item 7: Client Information Provided to Portfolio Managers..................................................................... 9 Item 8: Client Contact with Portfolio Managers........................................................................................ 9 Item 9: Additional Information.................................................................................................................... 9 3  Form ADV Part 2A - Wrap Fee Brochure Item 4 – Services, Fees, and Compensation A. Services Evergreen Wealth Advisors Corporation (“Evergreen,” “we,” or the “Advisor”) sponsors the Evergreen Wrap Fee Program (the “Program”). Under the Program, Evergreen provides ongoing, fully discretionary portfolio management and related investment advisory services. We monitor client accounts on an ongoing basis and make investment changes as needed to keep accounts aligned with each client’s investment objectives, risk tolerance, time horizon, and financial circumstances. This Wrap Fee Program Brochure is a supplement to Evergreen’s Form ADV Part 2A Disclosure Brochure. Together, these documents describe Evergreen’s advisory services, business practices, and fees. Evergreen also provides financial planning and consulting services to Program clients at no additional charge as part of the Wrap Fee. These services may include investment planning, tax-aware planning considerations, and general financial goal-setting. Portfolio Management Evergreen provides fully discretionary portfolio management to all Program clients. Portfolios are tailored to each client’s investment objectives, risk tolerance, time horizon, and financial circumstances based on Evergreen’s suitability and risk-assessment process. Portfolios are generally constructed using diversified holdings such as equities, exchange-traded funds, fixed income instruments, money market mutual funds, and government securities. Evergreen’s investment management may include tax-loss harvesting, gain deferral, asset location across taxable and tax-advantaged accounts, and periodic rebalancing. Evergreen monitors accounts on an ongoing basis and adjusts portfolios in response to market conditions, changes in client circumstances, cash flows, or drift from target allocations. Wrap Fee Schedule Clients pay a single asset-based wrap fee (the “Wrap Fee”) for services provided under the Program. The Wrap Fee covers Evergreen’s investment advisory and portfolio management services, as well as brokerage and transaction costs, custodial costs, and certain administrative expenses associated with managing client accounts. Fees are assessed monthly based on the average daily balance of assets under management during the billing period, including any cash and cash equivalents held within the portfolio. The applicable fee rate is determined by aggregating total assets across all of a Client's Investment Accounts, as follows: 4  Form ADV Part 2A - Wrap Fee Brochure Management Fee Based on Account Type(s) Held by Client Account Type Value of Assets Monthly AUM Fee Annual AUM Fee First $1,000,000 .0325% .39% Investment Accounts .0242% .29% Next $4,000,000 (over $1M up to $5M) Assets over $5,000,000 .0158% .19% Evergreen may, in its sole discretion, reduce, waive, or negotiate fees for certain clients or groups of clients based on factors such as account size, length of relationship, affiliation with Evergreen, or participation in a promotional or testing program. Portion of the Wrap Fee Paid to the Portfolio Manager Evergreen serves as the sponsor of the Program and the sole portfolio manager for all Program accounts. Evergreen does not use unaffiliated sub-advisers or third-party portfolio managers. After payment of brokerage, clearing, transaction, and custodial costs, the remaining portion of the Wrap Fee is retained by Evergreen as compensation for portfolio management services. Depending on trading activity and account-related costs, Evergreen may retain all, a portion, or only a small portion of the Wrap Fee. No portion of the Wrap Fee is paid to any third-party portfolio manager. B. Program Costs Participation in the Evergreen Wrap Fee Program may cost a client more or less than purchasing investment advisory services and brokerage services separately. Under the Program, clients pay a single asset-based Wrap Fee that includes Evergreen’s advisory services as well as brokerage and transaction costs. If those services were purchased separately, a client would typically pay an advisory fee in addition to transaction-based brokerage charges. Whether the Program is more or less expensive depends primarily on the client’s expected trading activity and account size. Because the Wrap Fee is charged regardless of the number of transactions in the account, clients with higher trading activity may pay less under the Program than they would under a separate advisory and brokerage arrangement. Clients with lower trading activity may pay more under the Program because they pay the Wrap Fee whether or not significant transaction costs are incurred. The total cost of the Program also increases as account assets increase because the Wrap Fee is based on assets under management. Clients should consider the Wrap Fee in light of their anticipated account size, trading frequency, and the nature of Evergreen’s investment approach, which may involve ongoing tax-loss harvesting, rebalancing, and other tax-aware portfolio management techniques that can increase trading activity. Clients are encouraged to discuss with Evergreen whether the Wrap Fee Program is appropriate for their circumstances. 5  Form ADV Part 2A - Wrap Fee Brochure C. Fees and Expenses in Addition to the Wrap Fee In addition to the Wrap Fee, clients may incur certain other fees and expenses in connection with Evergreen’s advisory services. Clients who invest in exchange-traded funds (“ETFs”), money market mutual funds, mutual funds, or other pooled investment vehicles will bear their proportionate share of the fees and expenses charged by those vehicles, including internal management fees and operating expenses. These expenses are separate from, and in addition to, the Wrap Fee. Evergreen does not receive these fees. Clients may also incur markups, markdowns, or bid-ask spreads when purchasing or selling certain fixed income securities, including bonds and other securities traded in principal transactions. These costs are embedded in the transaction price, are not paid to Evergreen, and are in addition to the Wrap Fee. Clients should review applicable account agreements, confirmations, and fund prospectuses for additional information regarding these fees and expenses. D. Compensation to the Person Recommending the Wrap Fee Program Evergreen’s advisory personnel do not receive any separate commission, referral fee, finder’s fee, or other incremental compensation as a result of a client’s enrollment in or continued participation in the Evergreen Wrap Fee Program. Advisory personnel are compensated under Evergreen’s regular employment arrangements, which may include salary and discretionary compensation, but no component of that compensation is directly tied to recommending the Program. Evergreen’s entire advisory business is conducted through a single Wrap Fee Program, and clients do not have the option to participate in a separate non-wrap advisory program sponsored by Evergreen. As a result, Evergreen’s personnel do not receive more compensation for recommending the Program over another advisory program offered by Evergreen. Neither Evergreen nor its personnel receive compensation from clearing brokers, ETF sponsors, mutual funds, or other third parties in connection with recommending the Program or investments held in Program accounts. Evergreen’s sole compensation is the advisory fee paid by clients. Like other asset-based advisory firms, Evergreen has a financial incentive to encourage clients to maintain and increase assets in accounts managed by Evergreen because its fees increase as assets under management increase. Evergreen addresses this conflict through its fiduciary duty and its suitability and account-monitoring processes. Item 5: Account Requirements and Types of Clients Evergreen generally provides advisory services under the Program to individuals, high-net-worth individuals, and corporations. Evergreen has a $100,000 minimum balance requirement to establish a relationship, which may be changed at the firm's discretion. Evergreen reserves the right to decline or discontinue engagements at its sole discretion if it is determined that the relationship is not appropriate or aligned with its service. 6  Form ADV Part 2A - Wrap Fee Brochure Item 6: Portfolio Manager Selection and Evaluation A. Portfolio Manager Selection and Evaluation Evergreen is the sponsor of the Evergreen Wrap Fee Program and the sole portfolio manager for all Program accounts. Evergreen does not select, recommend, or retain unaffiliated sub-advisers or third-party portfolio managers. Accordingly, clients are not assigned among multiple portfolio managers, and Evergreen does not maintain a process for selecting or replacing portfolio managers within the Program. Because Evergreen is the only portfolio manager, all Program accounts are managed through Evergreen’s investment process and are subject to Evergreen’s supervisory, compliance, and account review procedures. Accounts are managed on a fully discretionary basis in light of each client’s investment objectives, risk tolerance, time horizon, financial circumstances, tax considerations, and any applicable account restrictions. Evergreen has a financial interest in managing Program assets itself and retaining the Wrap Fee, which creates a conflict of interest. Evergreen addresses this conflict through its fiduciary duty, suitability process, ongoing account monitoring, and compliance oversight. B. Related Persons Acting as Portfolio Manager Evergreen, as a related person and the sponsor of the Program, has a financial interest in managing Program assets itself and retaining the Wrap Fee. This creates a conflict of interest because Evergreen has an incentive to recommend and maintain client assets in the Program. Evergreen addresses this conflict through its fiduciary duty, suitability process, ongoing account monitoring, and compliance oversight. Evergreen does not use composite or other portfolio manager performance information to select among multiple portfolio managers for the Program, and no third party reviews portfolio manager performance for that purpose, because no multiple-manager selection process exists. Evergreen does not charge performance-based fees. Although Evergreen manages multiple client accounts, its policies and procedures are designed to ensure investment decisions and trade allocations are made fairly and equitably across accounts. C. Standard of Conduct for Portfolio Managers Evergreen’s investment approach is based on each client’s investment objectives, risk tolerance, time horizon, financial circumstances, and tax considerations. Evergreen generally constructs diversified portfolios using equities, fixed income instruments, cash equivalents, ETFs, money market mutual funds, and government securities, and may employ tax-loss harvesting, gain deferral, asset location, and rebalancing. Investing in securities involves risk of loss that clients should be prepared to bear. Please refer to additional information found in the following Items of ADV Part 2A, which accompanies this Wrap Brochure: Item 4 – Advisory Business; Item 6 – Performance-Based Fees and Side-By-Side Management; Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss; and Item 17 – Voting Client Securities. 7  Form ADV Part 2A - Wrap Fee Brochure Item 7: Client Information Provided to Portfolio Managers Evergreen is the sponsor and sole portfolio manager for the Wrap Fee Program. Because Evergreen does not use third-party or unaffiliated portfolio managers, it does not provide client information to any outside portfolio manager. In managing Program accounts, Evergreen uses the client information it obtains through the account opening process and throughout the advisory relationship, including the client’s investment objectives, risk tolerance, time horizon, financial circumstances, tax considerations, account characteristics, and any reasonable account restrictions communicated by the client. Evergreen updates this information as needed based on information provided by the client, periodic reviews, and other communications or changes in the client’s circumstances. Item 8: Client Contact with Portfolio Managers Evergreen is the sponsor and sole portfolio manager for the Evergreen Wrap Fee Program. Clients may contact and consult directly with Evergreen regarding the management of their accounts. Evergreen does not place any restrictions on a client’s ability to contact or consult with Evergreen as portfolio manager. Item 9: Additional Information A. Disciplinary and Other Financial Industry Activities and Affiliations Evergreen and its management persons have not been a party to any legal or disciplinary event that would be material to a client’s or prospective client’s evaluation of Evergreen’s advisory business or the integrity of its management. Neither Evergreen nor its management persons are registered as a broker-dealer, broker-dealer representative, futures commission merchant, commodity pool operator, or commodity trading adviser. Evergreen is a wholly owned subsidiary of Evergreen Wealth Corporation, which provides certain technology, marketing, and administrative support services and also offers Evergreen.ai, a separate affiliated product. These relationships create potential conflicts of interest because Evergreen may have an incentive to use affiliate services, which Evergreen addresses through its fiduciary obligations and oversight of those arrangements. B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Evergreen has adopted a code of ethics under Rule 204A-1 designed to promote compliance with securities laws and Evergreen’s fiduciary duty to clients. The code addresses matters such as confidentiality, insider trading, gifts and entertainment, outside business activities, pre-clearance of employee securities transactions and political contributions, and reporting of personal holdings, transactions, and brokerage accounts. Because Evergreen employees may buy or sell securities for their own accounts that are the same as, or different from, securities recommended to clients, conflicts of interest can arise, and Evergreen addresses those conflicts through its code of ethics and related supervisory procedures. A copy of the code of ethics is available to clients and prospective clients upon request. 8  Form ADV Part 2A - Wrap Fee Brochure Program accounts are monitored at least monthly for consistency with each client’s strategy and investment objectives, and formal comprehensive reviews are conducted at least annually by Evergreen’s investment professionals. Additional reviews may occur in response to significant market, economic, or political developments or when large deposits or withdrawals materially affect an account’s allocation. Clients receive account statements from the clearing broker and should review those statements carefully. Evergreen does not receive economic benefits from third parties in connection with the investment advice it provides to clients. Evergreen does, however, pay certain unaffiliated third parties flat fees for lead-generation access or introductions to prospective clients. These payments are not contingent on whether a prospect becomes a client or on the amount of assets invested. Evergreen has no financial commitment that impairs its ability to meet its contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy petition. 9