HORIZON ADVISORY SERVICES, INC.

5582 West Henrietta Road West Henrietta, New York 14586 (585) 334-3600 http://www.horizonfinancial.net BROCHURE July 23, 2025 This Brochure provides information about the qualifications and business practices of Horizon Advisory Services, Inc., doing business as Horizon Financial. If you have any questions about the contents of this Brochure, please contact us at (585) 334-3600 or send an email to mrcongdon@horizonfinancial.net. 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. Horizon Advisory Services, Inc. is an investment adviser registered with the SEC. Registration does not imply a certain level of skill or training. Additional information about Horizon Advisory Services, Inc., also is available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number. The CRD number for Horizon Advisory Services, Inc., is 305239.  ITEM 2 - MATERIAL CHANGES Since the last annual update of the Firm's Brochures, dated March 25, 2025, we have updated Items 5 and 12 to describe more fully the asset-based fee charged by Charles Schwab & Co., Inc. We do not regard this as a material change. We encourage all clients and prospective clients to read this Brochure in full and contact us with any questions. Horizon Financial / Brochure / July 23, 2025 Page 2 of 22  ITEM 3 - TABLE OF CONTENTS Item 2 - Material Changes ............................................................................................. 2 Item 3 - Table of Contents ............................................................................................ 3 Item 4 - Advisory Business ........................................................................................... 4 Types of Advisory Services ............................................................................................................. 4 Assets Under Management ............................................................................................................. 5 Fiduciary Status for Retirement Investment Advice ........................................................................ 5 Item 5 - Fees and Compensation ................................................................................... 6 Investment Supervisory or Management Services ........................................................................... 6 Other Fees ...................................................................................................................................... 7 Compensation for the Sale of Securities or Other Investment Products .......................................... 7 General Information on Advisory Services and Fees ....................................................................... 8 Item 6 - Performance-Based Fees and Side-by-Side Management ................................. 9 Item 7 - Types of Clients ............................................................................................... 9 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss ........................ 10 Methods Of Analysis ..................................................................................................................... 10 Investment Strategies ................................................................................................................... 10 Risk of Loss .................................................................................................................................. 11 Client Obligations ......................................................................................................................... 12 Item 9 - Disciplinary Information ............................................................................... 12 Item 10 - Other Financial Industry Activities and Affiliations ...................................... 12 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................................................................................... 13 Item 12 - Brokerage Practices .................................................................................... 14 The Custodians And Brokers We Use ............................................................................................ 14 How We Select Brokers/Custodians ............................................................................................. 15 Your Brokerage and Custody Costs ............................................................................................... 15 Products and Services Available to Us from QCs. ......................................................................... 16 Trade Errors ................................................................................................................................. 18 Block Trading and Trade Allocations............................................................................................. 18 Directed Brokerage ....................................................................................................................... 18 Item 13 - Review of Accounts ..................................................................................... 19 Item 14 - Client Referrals and Other Compensation ................................................... 20 Item 15 - Custody ....................................................................................................... 20 Item 16 - Investment Discretion ................................................................................. 21 Item 17 - Voting Client Securities ............................................................................... 21 Item 18 - Financial Information .................................................................................. 22 Horizon Financial / Brochure / July 23, 2025 Page 3 of 22  ITEM 4 - ADVISORY BUSINESS Horizon Advisory Services, Inc. (“Horizon”, the “firm”, “we”, or “our”) has been in business since 1998. It became registered as an investment adviser in 2019. The firm’s principal owner is Mark Congdon, with Susan Congdon and Michael Congdon as voting minority shareholders. The firm conducts business under the name “Horizon Financial.” Types of Advisory Services We provide ongoing investment advice and portfolio management services on a discretionary basis, meaning clients authorize us to make investment decisions, including the selection and timing of securities transactions, without prior approval for each trade. We generally do not offer non-discretionary portfolio management services. Our advisory process begins with a comprehensive understanding of each client’s financial circumstances, including their goals, investment objectives, cash flow needs, tax considerations, risk tolerance, and time horizon. Based on this information, we recommend and implement an investment strategy tailored to the client’s needs. Our firm maintains a suite of model portfolios that are developed, monitored, and maintained by our internal investment management team. These models reflect a range of asset allocation strategies and are constructed using various investment types, including mutual funds, exchange-traded funds (ETFs), individual stocks and bonds, and other securities as appropriate. The investment team is responsible for the selection and ongoing oversight of investments within each model. Our Investment Adviser Representatives (IARs) work directly with clients to recommend one or more of the firm’s model portfolios - or, in some cases, to combine or adjust models - based on each client’s individual situation. For clients with more complex financial profiles or unique planning considerations, portfolios may be further tailored within the scope of the firm’s internal capabilities. IARs also serve as the primary point of contact for clients, providing ongoing advice, financial planning guidance, and regular portfolio reviews. While most clients are invested in our standardized models, we may accommodate reasonable investment restrictions on a case-by-case basis. Clients must submit any restriction requests in writing. All requests are reviewed by the Investment Policy Committee to determine whether they can be reasonably implemented within our investment framework. We believe that appropriate portfolio diversification offers the greatest opportunity to achieve consistent, long-term investment results. A well-diversified portfolio helps Horizon Financial / Brochure / July 23, 2025 Page 4 of 22  manage risk by balancing exposure across multiple asset classes and investment types. While diversification does not guarantee a profit or protect against loss, we view it as a core principle of prudent portfolio construction. We provide financial planning services exclusively to clients who engage us for portfolio management. These services are tailored to the client’s specific needs and may include guidance on cash flow and net worth, education funding, retirement planning, tax and insurance considerations, estate planning, and risk management. Financial planning is integrated into our overall advisory relationship. The financial plan is not necessarily memorialized in a written report; often, the plan is delivered verbally through ongoing meetings and consultations. Assets Under Management As of December 31, 2024, we manage approximately $455,755,922 in regulatory assets under management, all of which is managed on a discretionary basis. We do not currently manage any assets on a non-discretionary basis. This figure is updated annually as part of our Form ADV filing. Fiduciary Status for Retirement Investment Advice When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Horizon Financial / Brochure / July 23, 2025 Page 5 of 22  ITEM 5 - FEES AND COMPENSATION Investment Supervisory or Management Services Our annual investment management fee is generally 1.00% of the value of the client’s assets under our management, although this fee is negotiable at the sole discretion of the firm. The specific fee applicable to each client is set forth in the client’s advisory agreement and generally applies to all assets within the client’s household or portfolio, as defined in the agreement. In addition to the investment management fee, each client account is charged a technology fee. Accounts with an average daily balance of $5,000 or more are assessed an annual technology fee of $40, charged quarterly at $10 per quarter. Accounts with an average daily balance below $5,000 are charged $20 annually, or $5 per quarter. Clients with multiple accounts are charged separately for each account. If an account is open for less than a full calendar quarter, the fee is prorated based on the number of days the account was active during that quarter. Both the investment management fee and the technology fee are combined and deducted as a single charge directly from the client’s account. Although these components are calculated separately, they are billed together as one combined fee for each applicable quarter. Investment management fees are calculated using the firm’s portfolio accounting system, based on the average daily account value over each calendar quarter. This method accounts for daily fluctuations in account value and is applied consistently across all managed accounts. Clients are required, as a condition of engagement, to authorize the custodian to deduct the total combined fee directly from their accounts. We do not accept clients who do not provide this authorization. Fees are billed quarterly in arrears, based on the average daily balance for the applicable calendar quarter. For clients who engage the firm mid-quarter, the initial fee is prorated from the account’s inception date through the end of that calendar quarter. If a client relationship terminates during a quarter, fees are prorated through and including the effective termination date. While we do not typically recommend the use of margin in client accounts, clients should be aware that investment management fees are calculated on the full gross value of assets in the account, including any margin balances. Clients using margin will also incur margin interest charges, which are separate from and in addition to our investment management fees. Horizon Financial / Brochure / July 23, 2025 Page 6 of 22  Other Fees In addition to the investment management and technology fees we charge, clients are responsible for any fees or expenses imposed by third parties in connection with managing their accounts. These third-party charges are not paid to Horizon and may include: • Custodial fees (including, for clients who maintain their accounts at Charles Schwab & Co., Inc., an asset-based fee of 5 basis points annually on Chargeable Assets, calculated and billed in accordance with its Asset-Based Pricing Addendum signed at account opening); transaction charges; account maintenance fees; and other service fees such as those for overnight check delivery, wire transfers, or special handling requests) IRA, qualified plan, or other account-type-specific fees • Trading or execution-related fees (such as commissions or ticket charges) • • Mutual fund and ETF expenses (e.g., management fees, operating expenses, 12b-1 fees) • Platform or clearing fees imposed by the custodian or broker-dealer These fees are typically described in the custodial agreement and may vary depending on the type of transaction (e.g., exchange vs. purchase), the method of placement (e.g., electronic vs. phone), and the specific investment vehicles used. Paper trade confirmations or mailed statements may also trigger additional charges. Mutual funds and ETFs incur their own internal expenses, which reduce the investment return to shareholders. These typically include fund management fees, administrative costs, and, in some cases, marketing or distribution expenses (such as 12b-1 fees). Investors should consult the fund’s prospectus and Statement of Additional Information to understand these fees before investing. The selection of a mutual fund share class can also affect the total cost to the investor. Different share classes carry different internal fees and may include redemption restrictions or back-end sales charges. We strive to use the lowest-cost share class available through the client’s custodian; however, not all custodians offer every available share class. We do not receive any portion of the third party fees described in this section. Compensation for the Sale of Securities or Other Investment Products Horizon Advisory Services, Inc. is primarily a fee-based investment advisory firm, and the majority of the firm’s compensation is derived from the investment management fees we charge for advisory services. Horizon Financial / Brochure / July 23, 2025 Page 7 of 22  However, certain supervised persons of the firm are also registered representatives of Private Client Services, Inc. (“PCS”), an SEC-registered broker-dealer and member of FINRA/SIPC. In this separate capacity, they may receive commissions, trails, 12b-1 fees, or other transaction-based compensation from the sale of securities or insurance products. These commissionable activities are generally limited to legacy brokerage accounts and previously issued insurance products, and they are separate from our investment advisory services. Clients are under no obligation, contractually or otherwise, to purchase investment or insurance products through PCS or through any Horizon-affiliated representative. When clients do engage in brokerage transactions through PCS, the affiliated representative may receive additional compensation. These arrangements create a potential conflict of interest, as they may create an incentive to recommend products that result in additional compensation. Neither Horizon Advisory Services nor its supervised persons, in their roles as registered representatives of PCS, monitor or manage brokerage accounts or brokerage-held investments on an ongoing basis. While we may provide hold or sell recommendations for positions in brokerage accounts, we generally do not make buy- side recommendations or actively allocate assets within those accounts. On occasion, when a client requests to add to an existing position or exchange within a brokerage account, we may accommodate the request; however, such activity is limited and must be reviewed and approved in advance by the firm’s Chief Compliance Officer (CCO). These transactions do not constitute ongoing investment management. Clients seeking active management or portfolio oversight must engage Horizon through a signed investment advisory agreement. We mitigate potential conflicts of interest through transparency, internal oversight, and by always prioritizing our fiduciary duty when providing investment advisory services. Recommendations made in our advisory capacity are based solely on what we believe to be in the best interest of the client. General Information on Advisory Services and Fees Our investment management and technology fees are negotiable at the sole discretion of the firm. As a result, clients with similar account sizes, service needs, or complexity may be charged different fee rates. The services we offer may also be available from other providers at lower cost. Clients and prospective clients should consider this when evaluating our services and fee structure. We typically do not recommend the use of margin in client accounts. However, if margin is used - whether at our recommendation or client request - clients should be aware that our investment management fee is calculated based on the full gross value Horizon Financial / Brochure / July 23, 2025 Page 8 of 22  of assets in the account, including assets purchased on margin. This creates a potential conflict of interest, as it may result in higher advisory fees. We address this conflict by rarely recommending margin, and only when we determine it is in the client’s best interest. Margin amplifies both potential gains and losses and may result in losses greater than the original investment. Clients should review all margin-related disclosures provided by the custodian before engaging in margin transactions. Advisory services may be terminated at any time by either party with written notice, or as otherwise provided in the advisory agreement. Upon termination, we will calculate and deduct any earned but unpaid fees through the effective termination date. If a client transfers assets to another firm without prior written notice - such as via an ACAT (Automated Customer Account Transfer) - and fees cannot be deducted from the account prior to transfer, the client will receive a final invoice for any earned, unpaid fees. Although we typically bill in arrears, if any fees were prepaid and unearned, we will refund the applicable portion. Any fees or charges imposed by custodians or other third parties—such as account closing fees, transaction charges, or administrative costs—are the responsibility of the client and will not be refunded by Horizon. Fees are calculated and billed quarterly in arrears based on the average daily account value during the calendar quarter. For clients who begin or terminate service mid- quarter, fees are prorated based on the number of days services were provided. Fee deductions are made directly from client accounts, and all fee activity is reported on custodial statements. Clients are encouraged to review all account statements carefully and contact us with any questions or concerns regarding fee calculations. ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Horizon does not charge performance-based fees. We do not assess fees based on capital gains or a percentage of profits in client accounts. All clients are charged asset- based fees according to the terms of their individual advisory agreements. Because we do not charge performance-based fees, we do not engage in side-by-side management of accounts with different fee structures. This helps to reduce the potential for conflicts of interest related to the allocation of investment opportunities, time, or resources among client accounts. ITEM 7 - TYPES OF CLIENTS Horizon Advisory Services, Inc. provides investment advisory services primarily to individuals and families, including taxable accounts, trusts, and retirement accounts. While we do not impose a firm-wide minimum account size, certain investment Horizon Financial / Brochure / July 23, 2025 Page 9 of 22  strategies or operational constraints may result in account minimums at the advisor's discretion. These minimums, if applicable, will be disclosed to the client in advance and included in the advisory agreement. ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Methods Of Analysis Horizon Advisory Services, Inc. uses a combination of fundamental and quantitative analysis to evaluate and select investments for our model portfolios. Our internal investment team analyzes factors such as fund expenses, historical performance, risk- adjusted returns, portfolio composition, manager tenure, and alignment with the intended role in the portfolio. Fundamental analysis involves reviewing financial statements, management track records, industry outlook, and other publicly available data to estimate a security’s intrinsic value. As with any analysis, there is a risk that our interpretation of the data may be incorrect or that market prices will not adjust as anticipated. Our primary source for investment research and data is YCharts, which provides analytical tools and comprehensive data for securities, funds, and economic indicators. We may also supplement our analysis with additional resources, including but not limited to: • Research provided through custodial platforms, including Schwab • Public SEC filings and company-specific disclosures • Financial publications such as The Wall Street Journal, Barron’s, and Bloomberg • Company websites, annual reports, earnings calls, and investor presentations • Financial data aggregators such as Yahoo! Finance and Google Finance We do not rely on technical analysis or short-term trading signals. Our focus is on long-term value and portfolio-level alignment with client goals. Investment Strategies Our investment philosophy is built on the principles of asset allocation and diversification. The firm’s Investment Committee develops and maintains a suite of model portfolios, each aligned with a specific investment objective and risk profile. These models typically include allocations to multiple asset classes—such as U.S. and Horizon Financial / Brochure / July 23, 2025 Page 10 of 22  international equities, fixed income, and cash equivalents—and are primarily implemented using mutual funds and exchange-traded funds (ETFs). We follow a top-down process, first determining the appropriate asset allocation, then selecting investment vehicles to fill each allocation. Models are reviewed regularly and updated based on our outlook for the economy and capital markets. For clients with sufficient account size or more complex needs, individual stocks and bonds may be used in place of pooled investment vehicles. All portfolios are tailored using the firm’s core model framework, and each client’s representative recommends an allocation that reflects the client’s goals, risk tolerance, and overall financial profile. We manage portfolios using a long-term, buy-and-hold strategy, and rebalance periodically or as needed to maintain alignment with the target allocation. While we monitor economic and market trends, we do not engage in frequent trading or short- term market timing. Risk of Loss Investing in securities involves risk, including the potential for loss of principal. The value of a client’s portfolio may fluctuate due to market conditions, economic events, interest rate movements, geopolitical factors, and issuer-specific developments. Clients should be prepared to bear the risk of loss associated with investing. While diversification and strategic asset allocation are core components of our investment approach, they do not guarantee a profit or protect against loss in declining markets. No investment strategy can eliminate all risk or assure future returns. Examples of common investment risks include, but are not limited to: • Market Risk – General market movements that affect the value of most investments • Interest Rate Risk – The potential for bond prices to decline as interest rates rise • Inflation Risk – The erosion of purchasing power over time due to rising prices • Currency Risk – Fluctuations in foreign exchange rates affecting international investments • Liquidity Risk – Difficulty selling an investment without significantly impacting its price • Reinvestment Risk – The chance of having to reinvest proceeds at lower interest rates • Business Risk – Risks specific to a company’s financial health or business model • Financial Risk – Risks associated with a company’s use of debt or leverage Horizon Financial / Brochure / July 23, 2025 Page 11 of 22  Additionally, there is a risk that the securities we select for a portfolio may underperform their peers, benchmarks, or the broader market. Past performance is not a guarantee of future results, and no assurance can be made that any investment strategy will achieve its objectives. Client Obligations The effectiveness of our investment advisory services depends on accurate and timely information from the client. We rely on each client to provide a complete and up-to- date picture of their financial circumstances, investment goals, cash flow needs, and risk tolerance. Clients are responsible for promptly notifying us of any material changes in their financial situation, investment objectives, or other relevant factors that may impact how we manage their accounts. Failure to provide such updates may result in a portfolio strategy that no longer aligns with the client’s needs. We are not required to verify the accuracy of information received from the client or from third-party professionals (e.g., attorneys, accountants), and we are expressly authorized to rely on that information in making investment decisions or recommendations. Clients should also regularly review account statements and performance reports, and contact us with any questions or concerns regarding their accounts or our services. ITEM 9 - DISCIPLINARY INFORMATION Horizon Advisory Services, Inc. has not been involved in any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management team. We are required to disclose any such events if they had occurred within the past ten years or are otherwise material. If that changes in the future, we will promptly update this Brochure and notify affected clients as required by law. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Certain supervised persons of Horizon Advisory Services, Inc. are also registered representatives of Private Client Services, Inc. (“PCS”), an SEC-registered broker- Horizon Financial / Brochure / July 23, 2025 Page 12 of 22  dealer and member of FINRA/SIPC. In this separate capacity, they may receive commissions or other transaction-based compensation from the sale of securities. Some of our supervised persons are also licensed insurance agents and may receive compensation for the sale of insurance products. Clients should be aware that this dual relationship creates a conflict of interest. We place our clients’ interests first as part of our fiduciary duty, and clients are under no obligation, contractually or otherwise, to execute securities or insurance transactions through PCS or through our personnel in their roles as registered representatives or insurance agents. Horizon Advisory Services is not owned by or affiliated with PCS or any insurance carrier. These relationships are based on the individual licensing or registration of our supervised persons. When acting in a brokerage or insurance capacity, these individuals are not acting as representatives of Horizon Advisory Services. We manage potential conflicts through clear disclosure, supervisory oversight, and by ensuring that all recommendations made in an advisory capacity are based solely on what we believe to be in the best interest of the client. ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Horizon Advisory Services, Inc. has adopted a Code of Ethics (the “Code”) in compliance with SEC Rule 204A-1 under the Investment Advisers Act of 1940. The Code sets forth the professional and ethical standards expected of all supervised persons of the firm. Its purpose is to protect client interests and ensure we meet our fiduciary obligations of honesty, good faith, and fair dealing—while also permitting employees to invest for their own accounts in a responsible and transparent manner. The Code includes policies related to the confidentiality of client information, a prohibition on insider trading, limits on the acceptance of gifts or business entertainment, and personal securities trading procedures, among other topics. All supervised persons are required to acknowledge the Code annually and upon any material amendments. Horizon’s supervised persons may invest in the same securities we recommend to clients. When this occurs, we require all personal trading to be conducted in accordance with the Code. Our policies are designed to ensure that employee trading activities do not interfere with our ability to make and implement decisions in the best Horizon Financial / Brochure / July 23, 2025 Page 13 of 22  interest of clients. Among other safeguards, the Code: • Requires pre-clearance of employee participation in initial public offerings, limited offerings and other personal securities transactions • Requires reporting and monitoring of personal securities transactions to prevent conflicts with client trading • Prohibits employees from using non-public information for personal gain • Requires ongoing reporting and monitoring of personal accounts Despite these controls, there is a possibility that an employee may benefit from market activity initiated by a client. To address this, the firm conducts regular reviews of employee trading to detect and prevent any actual or perceived conflicts of interest. We will provide a copy of our Code of Ethics to any client or prospective client upon request. ITEM 12 - BROKERAGE PRACTICES The Custodians And Brokers We Use Horizon Advisory Services, Inc. does not maintain physical custody of client assets. However, we are deemed to have constructive custody in certain situations—such as when clients authorize us to deduct advisory fees directly from their accounts. All client assets must be held with a qualified custodian, typically a FINRA-registered broker-dealer or a bank, which maintains possession of the account and provides clients with regular statements. We generally recommend that clients custody their assets with Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member of SIPC. Schwab provides custody, trade execution, and related services to independent investment advisers through its institutional platform. Horizon is independently owned and operated and is not affiliated with Schwab or any other custodian. Clients open their accounts by signing an account agreement directly with the qualified custodian. While we assist clients with the account-opening process, we do not open accounts on their behalf. The custodian holds client assets, processes deposits and withdrawals, and executes trades as instructed by Horizon. Clients who wish to use a custodian other than Schwab must obtain mutual agreement from Horizon. If we do not mutually agree on an acceptable custodian, we will not be able to provide investment advisory services for that account. While most trades are executed through the account’s custodian, we reserve the right to use other brokers for trade execution when we believe doing so is in the client’s Horizon Financial / Brochure / July 23, 2025 Page 14 of 22  best interest, as described further below. How We Select Brokers/Custodians When recommending a broker-dealer or custodian, Horizon Advisory Services, Inc. seeks to select firms that provide overall value and service quality for our clients. We consider a range of factors to determine whether a provider can deliver execution and custody services on terms we believe are in the best interests of our clients, considering both cost and service capabilities. Our evaluation includes, but is not limited to, the following considerations: • Integrated trade execution and custody services (typically with no separate custody fee) • Access to lowest-cost share classes of mutual funds where available • Capability to execute, clear, and settle transactions efficiently • Support for client-directed transactions, including wires, ACH transfers, check requests, and disbursements • Breadth of available investment products (e.g., stocks, bonds, mutual funds, ETFs) • Availability of institutional research, trading tools, and technology that assist us in serving clients • Quality and responsiveness of the firm’s client service team • Competitive pricing on trading, margin, and administrative services • Financial strength, reputation, and regulatory standing • Historical service experience with our firm and our clients • Access to other non-monetary services or benefits that support our advisory business (described in the following section) We do not consider these factors in isolation. Instead, we evaluate the overall balance of cost, capabilities, and service when determining whether a custodian or broker- dealer is appropriate for client use. Your Brokerage and Custody Costs The qualified custodian (“QC”) that holds your account is entitled to charge fees for custody and brokerage services in several ways. Depending on the custodian and account type, these fees can include: • An asset-based fee (such as the 5-basis-point fee that Charles Schwab & Co., Inc., charges annually on Chargeable Assets, calculated and billed in accordance with its Asset-Based Pricing Addendum signed at account opening) • Commissions or transaction fees on trades that are executed through the Horizon Financial / Brochure / July 23, 2025 Page 15 of 22  custodian or settle into your account • Payment for order flow or rebates, which the custodian receives from some trading venues when routing client orders In addition, if Horizon arranges for a trade to be executed by a broker-dealer other than your custodian—a practice known as a “trade away”—your QC may charge you a flat “trade away” or “prime broker” fee for settling the transaction into your account. These fees are separate from, and in addition to, any commission paid to the executing broker-dealer. Because trade away fees can increase your overall trading costs, we generally execute client trades directly through your custodian. We have determined that using the QC for most transactions is consistent with our obligation to seek best execution, which refers to obtaining the most favorable overall terms for your transactions, considering a range of factors including price, execution quality, costs, speed, and reliability. All such brokerage or custodial fees are charged by the custodian and are not retained by Horizon. Products and Services Available to Us from QCs. Qualified custodians (“QCs”) provide Horizon Advisory Services, Inc. and our clients with access to institutional brokerage and custody services, which are typically not available to retail investors. These services may include trade execution, custody of client assets, account reporting, and access to a broad range of investment products. In addition, QCs make available a variety of support services that help us manage client accounts and operate our business. These support services are generally offered unsolicited and at no direct charge to Horizon. Some of these services directly benefit you and your account; others benefit us by enhancing our operational infrastructure, even if they don’t have a direct effect on your account. Services That Benefit You - These services support the management of your portfolio and include: • A wide selection of investment products, including lower-cost share classes and institutional funds • Efficient trade execution and settlement • Secure custody of assets • Access to institutional-level tools and features that may not be available to retail investors • Streamlined account administration and operational support Horizon Financial / Brochure / July 23, 2025 Page 16 of 22  These services enhance our ability to provide you with a higher standard of investment management. Services That Indirectly Benefit You - QCs also provide us with access to investment research, portfolio management tools, and account administration technology. While these services may not directly benefit a particular client account, they support our ability to manage client portfolios effectively and consistently. Examples include: • Access to client account data (such as duplicate trade confirmations and account statements) • Trade execution and allocation tools for managing block orders • Market data and security pricing tools • Systems for fee billing, reporting, and recordkeeping These tools improve our firm’s efficiency and the consistency of service across all client accounts. Services That Benefit Horizon - In addition to custodial and portfolio management tools, QCs also offer services intended to help us grow and manage our business. These include: • Educational conferences, webinars, and practice management resources • Consulting services on compliance, operations, technology, and business planning • Publications and tools related to business succession and human capital support • Discounts or payments for third party services arranged by the custodian • Occasional business entertainment or non-cash benefits (e.g. meals, event invitations) These benefits are provided to Horizon, not to individual clients, and may create a potential conflict of interest. Our Interest in QC Services and Potential Conflicts of Interest - The availability of these products and services creates a potential conflict of interest. We are not required to pay for many of these resources as long as a minimum level of client assets are custodied with the QC. Although we do not receive direct compensation from QCs, the ability to access these services without cost provides us with an incentive to recommend custodians who offer them. We mitigate this conflict by selecting custodians based on what we believe is in the best interests of our clients. Our evaluation prioritizes the overall value, service quality, and cost of custody and execution—not the ancillary benefits made available to us as an adviser. We continue to believe that the custodians we recommend provide Horizon Financial / Brochure / July 23, 2025 Page 17 of 22  excellent value and service for our clients. Trade Errors Horizon Advisory Services, Inc. has procedures in place to identify and correct trade errors in a timely and equitable manner. If a trade error occurs in a client account and results in a loss, we will take appropriate steps to ensure that the client is made whole. Clients will not bear the cost of errors caused by the firm. Clients are not permitted to retain profits that result from trade errors. If a correction results in a gain, that profit is typically retained by the custodian, not by the client or by Horizon. Our firm does not keep any profits from trade errors. If an error causes a loss, Horizon is responsible for covering the loss and will be billed by the custodian accordingly. Our goal is to ensure that trade errors are handled consistently, fairly, and in a way that protects the interests of our clients. Block Trading and Trade Allocations When appropriate, Horizon Advisory Services, Inc. may aggregate, or “block,” orders to buy or sell the same security across multiple client accounts. This practice allows us to execute trades more efficiently and may help reduce transaction costs and improve execution quality. Block trading is typically used when we are executing trades in individual securities, such as stocks or exchange-traded funds (ETFs), for multiple clients at the same time. If multiple executions are required to complete a block trade, each participating account will receive the average execution price for the block, and transaction costs will be allocated pro rata based on the size of each client’s order. We use a pre-determined, non-discretionary allocation method to ensure that all participating accounts are treated fairly and equitably. No account is favored over another, and clients benefit equally from the average pricing and cost savings that may result from aggregating orders. Not all trades are executed as block trades. Whether a trade is aggregated depends on a variety of factors, including the type of security, client-specific timing requirements, and operational logistics. When block trading is not possible or practical, we execute client orders individually and continue to seek best execution on all trades. Directed Brokerage Horizon Advisory Services, Inc. does not typically permit clients to direct brokerage. We generally require that clients use the custodians and broker-dealers we Horizon Financial / Brochure / July 23, 2025 Page 18 of 22  recommend in order to maintain consistent trading practices, operational efficiency, and best execution standards. • In very limited or exceptional cases, we may consider accommodating a directed brokerage request. However, clients should understand that doing so may: • Limit our ability to aggregate orders or negotiate transaction costs • Prevent us from seeking best execution across platforms • Result in higher trading expenses or delayed execution Clients who request directed brokerage assume the risks associated with these limitations. Any such arrangement must be mutually agreed upon in writing and is subject to the firm’s discretion. ITEM 13 - REVIEW OF ACCOUNTS Horizon Advisory Services, Inc. reviews client accounts on both a scheduled and ongoing basis. At a minimum, each client is offered an annual review. Many clients receive two or more reviews per year, depending on their complexity, engagement preferences, or evolving financial needs. Reviews are conducted by the client’s Investment Adviser Representative (IAR), who evaluates changes in the client’s financial situation, goals, risk tolerance, or cash flow needs. IARs also conduct ad hoc reviews when made aware of material life events or at the client's request. Clients are encouraged to notify us of any significant changes that may affect their financial plan or investment strategy. In addition to advisor-led reviews, client portfolios are monitored on an ongoing basis by our internal investment management team. This team is responsible for: • Ensuring portfolios remain within acceptable drift ranges based on client- specific allocation targets • Reviewing and updating model portfolios to confirm each holding aligns with the intended mission of the model • Overseeing consistency and investment discipline across all client accounts Clients receive monthly or quarterly account statements directly from the qualified custodian, depending on account activity. Horizon also provides clients with access to Albridge, a secure client portal where they can view portfolio performance and account-level reporting at their discretion. Horizon does not deliver performance reports on a regular cadence, but clients may log in to access reports at any time. Clients should promptly notify us of any concerns or discrepancies they identify in Horizon Financial / Brochure / July 23, 2025 Page 19 of 22  custodial statements, investment holdings, or performance data. ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION Horizon Advisory Services, Inc. receives economic benefits from custodians and service providers in the form of support services, as described in Item 12: Brokerage Practices. These include access to technology platforms, investment research, practice management resources, and trading tools. While these services are not paid for directly by clients, they may create a conflict of interest, which we mitigate by making recommendations based on the best interests of each client. In addition, some of our supervised persons are also registered representatives of Private Client Services, Inc. (“PCS”), a registered broker-dealer, and/or licensed insurance agents. In these separate roles, they may receive commissions, trails, or other compensation from third parties for the sale of securities or insurance products. These activities are described in more detail in Items 5 and 10 of this Brochure. Clients are under no obligation, contractually or otherwise, to purchase investment or insurance products through these individuals. Horizon does not currently engage promoters (formerly called solicitors) to refer new clients to the firm. However, we previously maintained a relationship with a third- party promoter who no longer actively refers clients, but continues to receive compensation for legacy relationships established under that agreement. These arrangements were fully disclosed at the time and remain in place only for those specific clients. No new clients are being referred under that agreement. ITEM 15 - CUSTODY Under SEC rules, Horizon Advisory Services, Inc. is deemed to have custody of client assets in certain situations - most commonly when clients authorize us to deduct our advisory fees directly from their account held at a qualified custodian. We may also be deemed to have custody if a client grants us standing authority to transfer funds to a third party (e.g., via a standing letter of authorization or SLOA). While we may be deemed to have custody for regulatory purposes, Horizon does not maintain physical custody of client funds or securities. Client assets are held by a qualified custodian (“QC”), typically a FINRA-registered broker-dealer or a bank, which is responsible for safeguarding the assets and issuing account statements. Clients will receive statements directly from the custodian at least quarterly, sent to the email or mailing address on file with the custodian. These statements are the official record of the account and should be reviewed promptly. Horizon Financial / Brochure / July 23, 2025 Page 20 of 22  Clients are strongly encouraged to compare any reports or statements received from Horizon (such as performance or allocation summaries) with the statements issued by the custodian. Any discrepancies should be reported immediately to both Horizon and the custodian. ITEM 16 - INVESTMENT DISCRETION Horizon Advisory Services, Inc. provides investment advisory services on a discretionary basis only. This means that clients grant us the authority to determine the identity, amount, and timing of securities to be bought or sold in their accounts, without obtaining advance approval for each transaction. Discretionary authority is granted through the client’s execution of our Investment Management Agreement, which outlines the scope of our authority and the terms of the relationship. This discretionary authority allows us to manage portfolios efficiently in alignment with each client’s stated investment objectives and risk tolerance. Clients may request reasonable investment restrictions (e.g., excluding certain securities or industries). All such requests must be submitted in writing to the firm’s Chief Compliance Officer and are subject to review by the firm’s Investment Policy Committee to determine whether they can be reasonably implemented within the context of the client’s strategy and the firm’s investment framework. ITEM 17 - VOTING CLIENT SECURITIES Horizon Advisory Services, Inc. does not vote proxies on behalf of clients and does not provide advice about how clients should vote securities held in their accounts. Clients retain the authority and responsibility to vote all proxies and act on other shareholder matters. This is outlined in our Investment Management Agreement. Clients may contact us with questions about a particular proxy solicitation; however, we will not provide recommendations on how to vote. If a client needs assistance understanding the materials or accessing documentation, we may be able to help facilitate that access. In limited cases, a qualified custodian’s default account settings may incorrectly indicate that Horizon is responsible for proxy voting. In such instances, we will take no action on the client’s behalf other than to forward any proxy materials to the client or a third-party designated by the client. Horizon will not vote proxies under any circumstances, even if account documents suggest otherwise, unless we have entered into a specific written agreement stating otherwise. Horizon Financial / Brochure / July 23, 2025 Page 21 of 22  ITEM 18 - FINANCIAL INFORMATION Horizon Advisory Services, Inc. does not require or solicit prepayment of fees of more than $1,200 per client, six months or more in advance. The firm is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Horizon Advisory Services, Inc. has not been the subject of a bankruptcy petition at any time. 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