OXINAS PARTNERS WEALTH MANAGEMENT

Oxinas Partners, LLC dba Oxinas Partners Wealth Management Form ADV Part 2A – Disclosure Brochure Effective: February 11, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Oxinas Partners, LLC dba Oxinas Partners Wealth Management (“Oxinas Partners” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (812) 725- 8649. Oxinas Partners is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Oxinas Partners to assist you in determining whether to retain the Advisor. Additional information about Oxinas Partners and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 297462. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Oxinas Partners and is included as a separate document from this brochure. Oxinas Partners believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Oxinas Partners encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 18, 2025: • The Advisor had a change in ownership. Please see Item 4 for more information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 297462. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (812) 725-8649. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................. 1 Item 2 – Material Changes ....................................................................................................................... 2 Item 3 – Table of Contents ....................................................................................................................... 3 Item 4 – Advisory Services ...................................................................................................................... 4 A. Firm Information .......................................................................................................................................... 4 B. Advisory Services Offered............................................................................................................................ 4 C. Client Account Management ........................................................................................................................ 6 D. Wrap Fee Programs .................................................................................................................................... 7 E. Assets Under Management .......................................................................................................................... 7 Item 5 – Fees and Compensation ............................................................................................................ 7 A. Fees for Advisory Services .......................................................................................................................... 7 B. Fee Billing ................................................................................................................................................... 8 C. Other Fees and Expenses ........................................................................................................................... 8 D. Advance Payment of Fees and Termination ................................................................................................. 9 E. Compensation for Sales of Securities ........................................................................................................... 9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................... 10 Item 7 – Types of Clients ....................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ............................................ 10 A. Methods of Analysis................................................................................................................................... 10 B. Risk of Loss ............................................................................................................................................... 11 Item 9 – Disciplinary Information .......................................................................................................... 13 Item 10 – Other Financial Industry Activities and Affiliations ............................................................. 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ... 14 A. Code of Ethics ........................................................................................................................................... 14 B. Personal Trading with Material Interest ...................................................................................................... 14 C. Personal Trading in Same Securities as Clients ......................................................................................... 14 D. Personal Trading at Same Time as Client .................................................................................................. 14 Item 12 – Brokerage Practices............................................................................................................... 14 A. Recommendation of Custodian[s] .............................................................................................................. 14 B. Aggregating and Allocating Trades ............................................................................................................ 15 Item 13 – Review of Accounts ............................................................................................................... 15 A. Frequency of Reviews ............................................................................................................................... 15 B. Causes for Reviews ................................................................................................................................... 15 C. Review Reports ......................................................................................................................................... 16 Item 14 – Client Referrals and Other Compensation ............................................................................ 16 A. Compensation Received by Oxinas Partners.............................................................................................. 16 B. Compensation for Client Referrals ............................................................................................................. 16 Item 15 – Custody .................................................................................................................................. 16 Item 16 – Investment Discretion ............................................................................................................ 17 Item 17 – Voting Client Securities ......................................................................................................... 17 Item 18 – Financial Information ............................................................................................................. 17 Privacy Policy ......................................................................................................................................... 18 Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 3  Item 4 – Advisory Services A. Firm Information Oxinas Partners, LLC dba Oxinas Partners Wealth Management (“Oxinas Partners” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Indiana. Oxinas Partners was founded in January 2018 and is owned M. T. Wagner, LLC and B. C. Coxon, LLC. Oxinas Partners is operated by Brian Coxon (Partner), and Matthew Wagner (Partner and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by Oxinas Partners. Oxinas Partners offers services through the Advisor’s network of investment advisor representatives (“IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The Client should understand that the businesses are legal entities of the IAR and not of Oxinas Partners. The IARs are under the supervision of the Advisor, and the advisory services of the IAR are provided through Oxinas Partners. The Advisor has the arrangement described above with the following IAR, Samuel Gurvitch – Brand Name: SDG Asset Management. B. Advisory Services Offered Oxinas Partners offers investment advisory services to individuals, high net worth individuals, trusts, estates, small businesses, charitable organizations, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith toward each Client and seeks to mitigate potential conflicts of interest. Oxinas Partners’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Oxinas Partners provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and nondiscretionary investment management and related advisory services. Oxinas Partners works closely with each Client to identify their investment goals and objectives, as well as risk tolerance and financial situation, in order to create a portfolio strategy. Oxinas Partners will then construct an investment portfolio consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, real estate investment trusts (“REITs”), private investments, leveraged and inverse ETFs, business development companies (“BDCs”), margin, and/or options contracts to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Oxinas Partners’ investment approach is primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Oxinas Partners will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Oxinas Partners evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Oxinas Partners may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Oxinas Partners may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Oxinas Partners may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, changes in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 4  Oxinas Partners selects, recommends, and/or retains mutual funds on a fund-by-fund basis and seeks to use non- retail or institutional classes when possible. Due to specific custodial or mutual fund company constraints, material tax considerations, and/or systematic investment plans, Oxinas Partners may select, recommend, and/or retain a mutual fund share class that has a higher expense ratio than an equivalent share class. Oxinas Partners will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and state investment guidelines. At no time will Oxinas Partners accept or maintain custody of a Client’s funds or securities except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Use of Independent Managers – Oxinas Partners may recommend that a Client utilizes one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with the Client’s investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager’s Form ADV Part 2A – Disclosure Brochure (or a brochure that makes the appropriate disclosures). Adhesion Wealth – Among other Independent Managers, the Advisor may utilize the turn-key asset management portfolio and practice management software platform ("TAMP Platform") of Adhesion Wealth Advisor Solutions, Inc. ("Adhesion Wealth"). Adhesion Wealth has developed a customized single-source managed account solution that it makes available to its clients and the clients of third-party investment advisers such as the Advisor. The TAMP Platform assists investment advisers with highly intuitive tools to provide separately managed accounts (“SMAs”) and unified managed accounts (“UMAs”) portfolios, bringing an increased scale and flexible wealth management solutions to assist in providing better outcomes. Adhesion Wealth will provide, as appropriate, personalized portfolio management, the ability to create low-cost, index-based portfolio solutions, trade order management, order aggregation, and other administrative and operational services. Trading by independent managers on the Adhesion Wealth TAMP Platform is executed through Charles Schwab & Co., Inc. (“Schwab”). Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to the Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction, including rollovers from one ERISA-sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Third-Party Access Platforms – The Advisor may use third-party platforms to access, aggregate, or manage certain client accounts that are held away from the Advisor’s primary custodians, such as employer-sponsored retirement plans or other externally maintained accounts. These platforms allow clients to grant the Advisor authorized access to account information and, where permitted, limited account management capabilities. Access to such accounts is provided solely at the client’s direction and subject to the permissions granted by the client through the third-party platform. Recommendations to have assets managed through a third-party platform pose a conflict between the interests of the Advisor and the interests of the Client. Assets managed through a third-party platform increases the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to have the Advisor manage held-away assets by the Advisor. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 5  Financial Planning Services Oxinas Partners will typically provide a variety of financial planning and consulting services to Clients, either as a component of investment management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to investment planning, retirement planning, insurance needs, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, and establish education savings and/or charitable giving programs. Oxinas Partners may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Oxinas Partners provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services may include: • Vendor Analysis • Plan Participant Enrollment and Education Tracking Investment Oversight Services (ERISA 3(21)) • • Ongoing Investment Recommendations and Assistance These services are provided by Oxinas Partners serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Oxinas Partners’ fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Oxinas Partners to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Oxinas Partners, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Oxinas Partners will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance of risk for each Client. • Portfolio Construction – Oxinas Partners will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 6  • Investment Management and Supervision – Oxinas Partners will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Oxinas Partners does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Oxinas Partners. E. Assets Under Management As of December 31, 2025, Oxinas Partners manages $390,977,057 in Client assets, $388,163,843 of which is managed on a discretionary basis and $2,813,214 on a nondiscretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid monthly, in advance of each month, pursuant to the terms of the agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior month. Investment advisory fees range up to 2.40% annually based on several factors, including the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions, and other complexities may be charged a higher fee. The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Oxinas Partners will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations to ensure accurate billing. Clients may make additions to and withdrawals from their account[s] at any time. However, reconciliations are performed every month to capture if, on any given day, assets are deposited into or withdrawn from an account after the start of the monthly billing period. An adjustment will be made in the form of a credit or debit the following month to reflect the interim change in portfolio value from the date of the deposit/withdrawal until the end of the month. The Advisor’s fee is exclusive of, and in addition to, any applicable securities transaction and custody fees and other related costs and expenses described in Item 5.C. below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment management fee as described above. The Client will pay a separate fee to the applicable Independent Manager. For Clients who enter into contracts directly with Independent Managers, the terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule that will reduce the fee with an increased level of assets placed under management with an Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.50% annually. Adhesion Wealth – The Client may be required to enter into a separate agreement with Adhesion Wealth regarding the assets allocated to Independent Managers on Adhesion Wealth’s TAMP Platform. The Client will pay a Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 7  separate fee for services based on Adhesion Wealth’s disclosure brochure and applicable contract[s] with Adhesion Wealth. Services offered through Adhesion Wealth are detailed in Item 4.B. above. Third Party Access Platforms – For assets managed through a third-party platform, the Client is not charged any additional platform fees. The Advisor bears the cost of the platform in order to service these Client assets. Advisory fees apply to assets accessed and managed through the platform as part of the Client’s assets under management, as disclosed above. Financial Planning Services Oxinas Partners offers standalone financial planning services on an hourly or fixed-fee basis. Hourly fees range up to $250 per hour. Fixed fee engagements will be based on the expected hours to complete the engagement at the hourly rate. Financial planning fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and overall costs will be provided to the Client prior to engaging for these services. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.50%, billed monthly or quarterly in advance of each month or calendar quarter, pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the prior month. Fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] by the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective month. The amount due is calculated by applying the monthly rate [(annual rate divided by the number of days in the year), multiplied by the number of days in the month] to the total assets under management with Oxinas Partners at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement, as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Oxinas Partners directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees may include Oxinas Partners’ investment management fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Financial Planning Services Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed-upon deliverable[s]. Retirement Plan Advisory Services Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients of Oxinas Partners will be assessed an annual administrative fee of $45 per account which may be prorated based on the account opening date. Additionally, Clients may incur certain fees or charges imposed by third parties other than Oxinas Partners in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client accounts but typically charges for mutual funds and other types of investments. The fees charged by Oxinas Partners are separate and distinct from these custody and execution fees. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 8  As mentioned in Item 4.B. above, the Client may be invested into share classes of a mutual fund that have a higher expense ratio than a different share class, including but not limited to 12b-1 fees. This may result in Clients paying higher expense ratio[s]. For a complete discussion of expenses related to each mutual fund, please read a copy of the prospectus issued by that particular fund. In addition, all fees paid to Oxinas Partners for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Oxinas Partners, but would not receive the services provided by Oxinas Partners, which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Oxinas Partners to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Oxinas Partners is compensated for its services in advance of the month in which investment management services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the month. The Client’s investment advisory agreement with the Advisor is non- transferable without the Client’s prior consent. Use of Independent Managers In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest, or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager. Oxinas Partners will assist the Client with the termination and transition as appropriate. Financial Planning Services Oxinas Partners may be compensated for its services upon completion of the engagement deliverable[s]. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Oxinas Partners is compensated for its retirement plan advisory services in advance of the month or quarter in which services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the retirement plan advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the month. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Oxinas Partners does not buy or sell securities and does not receive any compensation in any Client account other than the investment advisory fees noted above. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 9  Broker-Dealer Affiliations Certain Supervised Persons are also registered representatives of M.S. Howells & Co. (“M.S. Howells”). M.S. Howells is a registered broker-dealer (CRD# 104100) and a member of FINRA/SIPC. In one’s separate capacity as a registered representative of M.S. Howells, a Supervised Person implements securities transactions under M.S. Howells and not through Oxinas Partners. In such instances, Supervised Persons will receive commission- based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by a Supervised Person in one’s capacity as a registered representative is separate and in addition to Oxinas Partners’ advisory fees. This practice presents a conflict of interest because the Supervised Person, who is a registered representative, has an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client. Clients are not obligated to implement any recommendation provided by the Advisor or Supervised Persons. Neither the Advisor nor a Supervised Person will earn ongoing investment advisory fees in connection with any products or services implemented in one’s separate capacity as a registered representative. Please see Item 10 – Other Financial Industry Activities and Affiliations. Insurance Agency Affiliations Oxinas Partners is also a licensed insurance agency, and Advisory Persons, in their separate capacities, are licensed insurance professionals. As insurance professionals, Advisory Persons and Oxinas Partners earn commission-based compensation for selling insurance products, including insurance products sold to Clients. Insurance commissions earned by Advisory Persons and Oxinas Partners are separate and in addition to Oxinas Partners’ advisory fees. This practice presents a conflict of interest because the person providing investment advice on behalf of Oxinas Partners, who is an insurance agent, has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on the Client’s needs. However, Clients are under no obligation to purchase insurance products through Oxinas Partners, or any Advisory Person affiliated with Oxinas Partners. Please see Item 10 – Other Financial Industry Activities and Affiliations. Item 6 – Performance-Based Fees and Side-By-Side Management Oxinas Partners does not charge performance-based fees for its investment advisory services. The fees charged by Oxinas Partners are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Oxinas Partners does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Oxinas Partners offers investment advisory services to individuals, high-net-worth individuals, trusts, estates, small businesses, charitable organizations, and retirement plans. Oxinas Partners generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis Oxinas Partners employs fundamental, technical, cyclical, and charting analysis, as well as model signals, in developing investment strategies for its Clients. The Advisor may also employ cyclical and charting analysis in order to achieve the Client’s objective. Research and analysis from Oxinas Partners are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and reviews of company activities, including annual reports, prospectuses, press releases, and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria generally consist of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 10  monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Oxinas Partners will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level rather than the overall fundamental analysis of the health of the particular company that Oxinas Partners is recommending. The risks with cyclical analysis are similar to those of technical analysis. Charting analysis utilizes various market indicators as investment selection criteria. These criteria are generally pricing trends that may indicate movement in the markets. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the technical and charting analysis may lose value and may have negative investment performance. The Advisor monitors these market indicators to determine if adjustments to strategic allocations are appropriate. As noted above, Oxinas Partners generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Oxinas Partners will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Oxinas Partners may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Oxinas Partners will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing in the Client’s accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. The following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 11  ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices will fall if interest rates rise, and vice versa; the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e., the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Options contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call," pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Real Estate Investment Trusts Investing in REITs involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers, and self-liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). Business Development Companies Investing in BDCs is subject to various risk factors, Including, but not limited to, the following: (1) liquidity risk, i.e., the risk that a financial asset cannot be sold quickly enough without impacting the market price. (2) interest rate risks, i.e., changes in interest rate policy, can dramatically impact the margin between borrowing and lending costs and the amount the BDC is able to distribute. (3) leverage risk, i.e., BDCs commonly borrow money to make investments, which may have a negative effect on the BDC’s net asset value if the value of the borrowed assets deteriorates. (4) diversification risk, i.e., BDCs have a concentration of assets held in small to mid-size companies that may have similar characteristics in regard to their ability to pay back loans or weather an economic downturn. (5) structural risk, i.e., BDCs often have high fees and expenses that are deducted from their net assets for purposes of determining net asset values that can put pressure on the company to make investments that are able to generate sufficient returns and cover such expenses. BDCs also often pay incentive compensation to their investment professionals, which may incentivize them to make riskier investments for higher individual compensation. (6) key personnel risk, i.e., BDC investment decisions are often undertaken by a small team of Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 12  managers; therefore, if any one of the managers leaves the BDC, there may be a resulting adverse effect on the company. Private Funds Risks Private investment funds generally involve various risk factors, including, but not limited to, the potential for complete loss of principal, liquidity constraints, and lack of transparency. A complete discussion of these risks is set forth in each fund’s respective offering documents, which will be provided to each Client for review and consideration. Unlike liquid investments that a Client may maintain, private investment funds do not provide daily liquidity or pricing. Leveraged and Inverse ETFs Leveraged and Inverse ETFs are not suitable for all investors and should be utilized only by sophisticated investors who understand the leverage risk consequences of seeking daily leveraged investment results and intend to actively monitor and manage their investments. Leverage ETFs are not designed to track the underlying index over periods longer than one trading day. The use of leverage increases the level of investment risk. Leverage will magnify gains or losses on those investments. Inverse ETFs lose value when the underlying investments rise in value. The investments have the risk of not meeting their stated daily investment objectives over a long-term period. The Advisor does not actively include these investments in Client portfolios. Certain Clients may have legacy positions in these investments. The Advisor will work closely with the Client to determine whether to retain these investments. Digital Assets Risks Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable for Clients with a high-risk tolerance. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information Oxinas Partners values the trust Clients place in the Advisor. The Advisor encourages all Clients to perform the requisite due diligence on any advisor or service provider with whom the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 297462. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. In July 2010, The State of Indiana alleged that from approximately January 29, 2009, through February 24, 2009, Mr. Gary G. Bouch Jr. transacted business in the State of Indiana as an agent of Ameriprise Advisor Services, Inc., although he was not registered or exempted from registration during that time. The matter was resolved through a Consent Order where Mr. Bouch paid a monetary penalty of $500 plus an administrative penalty of $1,500. Clients may independently view the background of Mr. Bouch on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his name or his individual CRD# 1807688. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5.E., certain Supervised Persons are also registered representatives of M.S. Howells. In one’s separate capacity as a registered representative, a Supervised Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by a Supervised Person. Neither the Advisor nor its Supervised Persons will earn Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 13  ongoing investment advisory fees in connection with any products or services implemented in one’s separate capacity as a registered representative. Insurance Agency Affiliations As noted in Item 5.E., Oxinas Partners is also a licensed insurance agency, and Advisory Persons, in their separate capacities, are licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Oxinas Partners. As insurance professionals, Advisory Persons and Oxinas Partners will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Person or Oxinas Partners. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics Oxinas Partners has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Oxinas Partners (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Oxinas Partners and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of Oxinas Partners’ Supervised Persons to adhere not only to the specific provisions of the Code but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (812) 725- 8649. B. Personal Trading with Material Interest Oxinas Partners allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Oxinas Partners does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Oxinas Partners does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Oxinas Partners allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material nonpublic information controls), gifts and entertainment, outside business activities, and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades or by trading based on material nonpublic information. This risk is mitigated by Oxinas Partners requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, nonpublic information. D. Personal Trading at Same Time as Client While Oxinas Partners allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Oxinas Partners, or any Supervised Person of Oxinas Partners, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Oxinas Partners does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Oxinas Partners to direct trades to the Custodian as agreed upon in the investment Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 14  advisory agreement. Further, Oxinas Partners does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Oxinas Partners does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Oxinas Partners. However, if the recommended Custodian is not engaged, the Advisor may be limited in the services it can provide. Oxinas Partners may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the Custodian’s offices. Oxinas Partners will generally recommend that Clients establish their account[s] at Schwab, a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian.” Oxinas Partners maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Oxinas Partners does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – Oxinas Partners does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis,” where Oxinas Partners will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Oxinas Partners will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Oxinas Partners will execute its transactions through the Custodian as authorized by the Client. Oxinas Partners may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts on the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons and periodically by Matthew T. Wagner, CCO of Oxinas Partners. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 15  as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Oxinas Partners if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Oxinas Partners Oxinas Partners may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Oxinas Partners may receive non-compensated referrals of new Clients from various third parties. Participation in the Institutional Advisor Platform Oxinas Partners has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Oxinas Partners. As a registered investment advisor participating on the Schwab Advisor Services platform, Oxinas Partners receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor, and many, but not all, services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of the Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts, and other services. In addition, the Advisor receives duplicate statements for Client accounts and the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Oxinas Partners that may not benefit the Client, including educational conferences and events, financial start-up support, consulting services, and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Oxinas Partners believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Oxinas Partners does not compensate, either directly or indirectly, any persons who are not supervised persons for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 16  securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Oxinas Partners typically has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Oxinas Partners. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Oxinas Partners will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Oxinas Partners does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies; however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Oxinas Partners nor its management has any adverse financial situations that would reasonably impair the ability of Oxinas Partners to meet all obligations to its Clients. Neither Oxinas Partners nor any of its Advisory Persons have been subject to a bankruptcy or financial compromise. Oxinas Partners is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 17  Privacy Policy Effective: February 11, 2026 Our Commitment to You Oxinas Partners, LLC dba Oxinas Partners Wealth Management (“Oxinas Partners” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Oxinas Partners (also referred to as "we," "our," and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Oxinas Partners does not sell your nonpublic, personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal, nonpublic information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address, and phone number[s] Income and expenses Email address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage, and advisory agreements Account applications and forms Other advisory agreements and legal documents Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service the account How do we protect your information? To safeguard your personal information from unauthorized access and use, we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Clients’ personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 18  How do we share your information? An RIA shares Clients’ personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share nonpublic, personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, and other financial institutions) as necessary for us to provide agreed-upon services to you, consistent with applicable law, including but not limited to processing transactions, general account maintenance, responding to regulators or legal investigations, and credit reporting. No Not Shared Yes Yes We share Client information with M.S. Howells & Co. (“MS Howells”). This sharing is due to the oversight MS Howells has over certain Supervised Persons of our firm. You may also contact us at any time for a copy of MS Howells’ Privacy Policy. Marketing Purposes Oxinas Partners does not disclose and does not intend to disclose personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Oxinas Partners or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your nonpublic, personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Oxinas Partners does not disclose and does not intend to disclose nonpublic, personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume that accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically, we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of nonpublic, personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (812) 725-8649. Oxinas Partners, LLC dba Oxinas Partners Wealth Management 607 N. Shore Drive, Suite 101, Jeffersonville, IN 47130 Phone: (812) 725-8649 | Fax: (812) 920-0862 www.oxinaspartners.com Page 19