Stewardship Advisors, LLC

Item 1 - Cover Page Stewardship Advisors, LLC 321 W. Main Street Mount Joy, PA 17552 Tel: (717) 492-4787 Fax: (717) 283-4049 www.mystewardshipadvisor.com Form ADV Part 2 Firm Brochure March 16, 2026 This brochure provides information about the qualifications and business practices of Stewardship Advisors, LLC. Please contact our Chief Compliance Officer, Mr. Mark Brinser, at (717) 492-4787 if you have any questions about the content of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or any state securities administrator. Additional information about Stewardship Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Click on the “Investment Adviser Search” link and then search for “Investment Adviser Firm” using the firm’s IARD (“CRD”) number, which is 277099. While the firm and its associates may be registered and/or licensed within a particular jurisdiction, that registration and/or licensing in itself does not imply an endorsement by any regulatory authority, nor does it imply a certain level of skill or training on the part of the firm or its associated personnel. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 1 of 21  Item 2 - Material Changes Since our previous amendment on March 17, 2025, there has been no material changes to Stewardship Advisors, LLC (“Stewardship” or “Firm”) ADV brochures. As with all firm documents, clients and prospective clients are encouraged to review this brochure in its entirety and as there may be other small changes not included here. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 2 of 21  Item 3 - Table of Contents Contents Item 1 - Cover Page ........................................................................................................................................................................... 1 Item 2 - Material Changes ................................................................................................................................................................. 2 Item 3 - Table of Contents ................................................................................................................................................................ 3 Item 4 - Advisory Business ................................................................................................................................................................ 4 Item 5 - Fees and Compensation ...................................................................................................................................................... 8 Item 6 - Performance-Based Fees and Side-By-Side Management .................................................................................................. 11 Item 7 - Types of Clients .................................................................................................................................................................. 11 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................................. 11 Item 9 - Disciplinary Information ..................................................................................................................................................... 14 Item 10 - Other Financial Industry Activities and Affiliations ........................................................................................................... 14 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................................... 15 Item 12 - Brokerage Practices ......................................................................................................................................................... 15 Item 13 - Review of Accounts ......................................................................................................................................................... 18 Item 14 - Client Referrals and Other Compensation ........................................................................................................................ 19 Item 15 - Custody ........................................................................................................................................................................... 20 Item 16 - Investment Discretion ...................................................................................................................................................... 20 Item 17 - Voting Client Securities .................................................................................................................................................... 21 Item 18 - Financial Information ....................................................................................................................................................... 21 CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 3 of 21  Item 4 - Advisory Business Description of the Firm Stewardship Advisors, LLC is a Pennsylvania domiciled limited liability company formed in November of 2011; initially created for general business purposes (e.g., operating expenses, etc.). The Firm initially registered as an investment advisor with the Commonwealth of Pennsylvania in October of 2015, followed by our SEC registration in July of 2016. The firm’s control person is W. Lee Shertzer. Description of Services Offered Stewardship Advisors, LLC provides financial planning services that focus on areas such as cash flow and budgeting, funding a college education, retirement planning, risk management, estate, or tax planning, among others. Ongoing and continuous supervision of clients’ portfolios are provided through our portfolio management services offering as well as engaging the services of institutional investment managers. We provide educational workshops involving a broad range of financial planning and investing topics. The firm also offers our services to retirement plan sponsors that are described in a separate brochure available on adviserinfo.sec.gov. Prior to engaging Stewardship Advisors, LLC for our services, you must first execute a written engagement agreement with our firm. Thereafter discussion and analysis will be conducted to determine your financial needs, goals, holdings, etc. Depending on the scope of the engagement, you may be asked to provide copies of the following documents early in the process: • Wills, codicils, and trusts • Insurance policies • Mortgage information • Tax returns • Student loans • Divorce decree or separation agreement • Current financial specifics including W-2s or 1099s • Information on current retirement plans and benefits provided by your employer • Statements reflecting current investments in retirement and non-retirement accounts • Employment or other business agreements you may have in place • Completed risk profile questionnaires or other forms provided by our firm It is important that you provide us with an adequate level of information and supporting documentation throughout the term of the engagement, including but not limited to: source of funds, income levels, and an account holder or their legal agent’s authority to act on behalf of the account, among other information that may be necessary. This helps us determine the appropriateness of our planning strategies and/or investment recommendations. The information and/or financial statements you provide needs to be accurate. It is also essential to keep us informed of significant issues that may call for an update to your plan. Events such as changes in employment or marital status, an unplanned windfall, etc., can have an impact on your circumstances and needs. We need to be aware of such events, so that we may make adjustments as necessary in order to keep you on track toward your goals. Financial Planning Services CRD # 277099 SEC # 801-108174 The incorporation of most or all of the following planning components allows for not only a thorough analysis but Stewardship Advisors, LLC Form ADV Part 2 - Page 4 of 21  also a refined focus of your goals and objectives. Your plan may be as broad-based or narrowly focused as you desire. Note that when our planning focuses only on certain areas of your interest or need, your overall situation or needs may not be fully addressed due to limitations you may have established. We will present you with a summary of our recommendations, guide you in the implementation of some or all of them per your decisions, as well as encourage ongoing reviews thereafter. You retain full discretion over all implementation decisions and are free to accept or reject any recommendation we make. Cash Flow Analysis and Debt Management A review of your income and expenses may be conducted to determine your current surplus or deficit. Based upon the results, we might recommend prioritizing how any surplus should be used, or how to reduce expenses if they exceed your income. In addition, advice on the prioritization of which debts to repay may be provided, based upon such factors as the debt’s interest rate and any income tax ramifications. Recommendations may also be made regarding the appropriate level of cash reserves for emergencies and other financial goals. These recommendations are based upon a review of cash accounts (such as money market funds) for such reserves and may include strategies to save desired reserve amounts. Risk Management A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”). Employee Benefits A review is conducted and analysis is made as to whether you, as an employee, are taking maximum advantage of your employee benefits. We will also offer guidance on your employer-sponsored retirement plan and/or stock options, along with other benefits that may be available to you. Personal Retirement Planning Retirement planning strategies typically include projections of your likelihood of achieving your financial goals, with financial independence usually the primary objective. For situations where projections show less than the desired results, a recommendation may include showing you the impact on those projections by making changes in certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. College Funding Advice involving college funding may include projecting the amount that will be needed to achieve post- secondary education funding goals, along with savings strategies and the “pros-and-cons” of various college savings vehicles that are available. We are also available to review your financial picture as it relates to eligibility for financial aid or the best way to contribute to family members, such as grandchildren, if appropriate. Tax Strategies Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, recommendations may be offered as to which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state, or local tax laws and rates that may impact your situation. Upon your request, we will assist you in preparing tax forms or data collection for your accountant’s review. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 5 of 21  Estate Planning Our review typically includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. We may assess ways to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your prior approval. Divorce Planning Separation or divorce can have a major impact on your goals and plans. We will work with you to help you gain an understanding of your unique situation and provide you with a realistic financial picture so that you are in a better situation to communicate with your legal counsel, mediator or soon to be ex-spouse. We can assist in the completion of cash flow and net worth projections, budget analysis, as well as help you to understand what the consequences and/or benefits of a settlement. Investment Consultation Our investment consultation component often involves providing information on the types of investment vehicles available, employee retirement plans and/or stock options, investment analysis and strategies, asset selection and portfolio design. The strategies and types of investments that may be recommended are further discussed in Item 8 of this brochure. Business Consultation We are available to assist small businesses in a variety of ways to include business strategy, debt management, general financial advice, risk management, as well as assisting you with matters involving coordination with your financial institution, retirement plan advisor, and attorney or accounting firm. Broad-Based v. Modular Financial Planning A broad-based plan is an endeavor that requires detail. Certain variables can affect the development of the plan, such as the quality of your own records, complexity and number of current investments, diversity of insurance products and employee benefits you currently hold, size of the potential estate, and special needs of the client or their dependents, among others. At your request, we may concentrate on reviewing only a specific area (modular or component planning), such as investment allocation at your employer’s retirement plan, funding an education, an estate planning issue, or simply evaluating the sufficiency of your current retirement plan. Note that when these services focus only on certain areas of your interest or need, your overall situation or needs may not be fully addressed due to limitations you may have established. Whether we have created a broad-based or modular plan, we will present you with a summary of our recommendations, guide you in the implementation of some or all of them per your decision, as well as offer you periodic reviews thereafter. In all instances involving our financial planning engagements, our clients retain full discretion over all implementation decisions and are free to accept or reject any recommendation that we make. Portfolio Management Services You may also engage our firm to implement investment strategies that we have recommended to you. Depending on your risk profile, goals and needs, among other considerations, your portfolio will involve the employment of one of our investment strategies as well as either a broad range or more narrowly focused choice of investment vehicles which are further discussed in Item 8 of this brochure. CRD # 277099 SEC # 801-108174 Where appropriate, we will prepare investment guidelines reflecting your objectives, time horizon, tolerance for Stewardship Advisors, LLC Form ADV Part 2 - Page 6 of 21  risk, as well as any reasonable account constraints you may have for the portfolio. These guidelines will be designed to be specific enough to provide future guidance while allowing flexibility to work with changing market conditions. Since this effort is the product of information and data you have provided, you may be asked to review it and provide your final approval. We will then develop a customized portfolio for you based on your unique situation, investment goals and tolerance for risk. We serve as your portfolio manager on a discretionary or nondiscretionary basis (defined in Item 16), and the engagement typically includes: • Determination of risk tolerance • Investment strategy • Investment guideline development • Asset allocation • Asset selection • Regular monitoring • Periodic rebalancing Following our review and/or plan development, we may recommend that you engage an institutional investment manager to serve your portfolio. Prior to recommending a sub-advisor or third-party investment manager, we will conduct what we believe to be an appropriate level of due diligence that includes ensuring that the investment manager is appropriately notice-filed within your state of residence. Clients may be required to maintain a minimum account size to be eligible for this service. Under this type of engagement, we will gather input from you about your financial situation, investment objectives, reasonable restrictions you may want to impose on the management of the account, and we will then provide this information to the investment manager to develop your portfolio. Sub-advisors and third- party investment managers will invest on behalf of a client account in accordance with the strategies set forth in their own disclosure documents which will be provided to you by our firm prior to your employing these strategies. The selected investment manager assumes typically discretionary authority over an account, and some of these programs may not be available for those clients who prefer an account to be managed under a nondiscretionary engagement or whom may have other unique account restrictions. At least annually thereafter a review will be performed from both a compliance and performance perspective to determine whether the selected investment manager remains an appropriate fit for your portfolio. Educational Workshops We provide periodic complimentary educational seminar sessions for those desiring information on personal finance and investing. Topics may include issues related to general financial planning, educational funding, estate planning, retirement strategies, implications involving changes in marital status, and various other current economic or investment topics. Our workshops are educational in nature and do not involve the sale of insurance or investment products. Wrap Fee Program We previously offered a wrap fee investment program for those investors with an account value of $250,000 or greater of investable assets that are managed by our firm, however, Stewardship is moving away from the wrap fee program and are no longer accepting participants into the program. Client Assets Under Management CRD # 277099 SEC # 801-108174 As of December 31, 2025, our firm managed approximately $538,071,393 in assets under management on a discretionary basis and $7,109,067 on a non-discretionary basis for total assets managed of approximately $545,180,460. Stewardship Advisors, LLC Form ADV Part 2 - Page 7 of 21  Item 5 - Fees and Compensation Forms of payment are based on the types of services being provided, term of service, etc., and will be stated in your engagement agreement with our firm. Fees are to be paid by check or draft from US-based financial institutions. With your prior authorization, payment may also be made through a qualified, unaffiliated PCI compliant third-party processor, or withdrawal from your investment account held at your custodian of record. Fees paid to our firm will be noted in your account statement you will receive from your custodian. Our fees are negotiable, with the final determination to be made by the firm. Method of Compensation and Fee Schedule Project-Based Engagements Our project-based financial planning services are designed for those who prefer a shorter-term engagement involving our financial planning services. We are compensated for project-based services via a fixed fee ranging from $1,000 to $10,000 per plan. The fee will be determined by the complexity of the engagement, the time involved developing the plan, number of accounts involved, etc. Half the quoted fee will be due upon execution of the engagement agreement, and the remaining portion upon plan delivery. Annual Consultation Arrangement Through our annual consultation engagement, we will assist you over the course of the year, creating your foundation and working with you to ensure various steps or action items are accomplished. We are available to help you in opening and maintaining an investment account at the custodian of your choice and we will provide portfolio allocation adjustments when necessary. The annual consultation fee is $100 to $1,000 per month, paid in equal monthly or quarterly installments per your preference, and takes into consideration factors such as the complexity of your financial profile and requirements, the time involved developing your plan and assisting you in its execution, assets that comprise your overall portfolio, as well as the number of individual accounts comprising your portfolio and where those accounts are maintained. The first period’s fee is due upon execution of the engagement agreement, which may require proration based on the days remaining in the billing cycle, and the remaining portion is paid in advance in equal installments thereafter until the end of the 12-month period. Note that the fee is due within the first 10 calendar days of each billing period. The agreed upon services will be rendered throughout the 12-month period; annual consultation fees are not to be extended or carried over into a subsequent period. The fee will remain in effect for successive 12-month periods unless the engagement is amended or terminated. Portfolio Management Services Fees - Internal Portfolio Management When we provide our portfolio management services, the account will be assessed an on-going annualized asset- based fee that will be determine by the reporting period ending value of your account (e.g., the last market day of the quarter). Our fee is based on a straight tier; all accounts are charged a single percentage rate that declines as asset levels increase. For the benefit of discounting your asset-based fee, we will attempt to aggregate accounts for the same household. These fees will be billed quarterly, in advance, per the following table. Assets Under Management $0 - $249,999 $250,000-$499,999 Annualized Asset-Based Flat Fee Rate 1.50% (150 basis points) 1.25% (125 basis points) CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 8 of 21  $500,000-$999,999 $1,000,000-1,499,999 $1,500,000-1,999,999 $2,000,000-$2,999,999 $3,000,000-4,999,999 $5,000,000-$7,499,999 $7,500,000-$9,999,999 $10,000,000-Above 1.00% (100 basis points) 0.90% (90 basis points) 0.80% (80 basis points) 0.70% (70 basis points) 0.60% (60 basis points) 0.50% (50 basis points) 0.45% (45 basis points) Negotiable Accounts will be assessed in accordance with asset values disclosed on the statement the client will receive from the custodian of record for the purpose of verifying the computation of the advisory fee. In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized industry source (e.g., unaffiliated public accounting firm), and the client may choose to separately seek such an opinion at their own expense as to the valuation of “hard-to-price” securities if necessary. Your first billing cycle will begin once your agreement is executed with our firm and assets have settled into your account held by the custodian of record. Advisory fees for partial quarters as well as mid-cycle additions or withdrawals of $50,000 or more will be prorated based on the remaining days in the reporting period in which our firm services the account. Fee payments will generally be assessed within the first 10 calendar days of each billing cycle. By signing our firm’s engagement agreement, as well as the selected custodian account opening documents, you will be authorizing the withdrawal of our advisory fees from your account. The withdrawal will be accomplished by the custodian of record at the request of our firm, and the custodian will remit our fee directly to our firm. All fees deducted will be noted on account statements that you will receive directly from the custodian of record on at least a quarterly basis. Alternatively, you may request to directly pay our advisory firm its portfolio management fee in lieu of having the advisory fee withdrawn from your investment account. Your payment must be received by our firm within the first 10 calendar days of each quarter. Accounts maintained at American Funds Service Company are assessed on an “offset quarter,” with periods ending February, May, August, and November; not on a calendar-quarter basis. An exception to the American Funds billing schedule would be 529 Plan funds. In order to avoid tax issues with advisor fees deducted from 529 plan assets, the bill for 529 plan assets will be calculated and deducted against other client accounts maintained at Stewardship Advisors, LLC or invoiced directly to the client, as per the agreement signed. Portfolio Management Services Fees - Third-Party Investment Managers The annualized asset-based fee ranges from 0.50% to 2.00% (50 to 200 basis points) and our firm will receive a portion of the fee ranging from 0.25% to 1.50% (25 to 150 basis points) for our consultation service, which we will describe to you in your engagement agreement with our firm or in the Third-Party Investment Managers account paperwork. Payment may be made on a monthly or quarterly basis, either in advance or arrears, depending on the selected investment manager. Private Investment Fees For clients Stewardship places in private investments, the client will be billed at the fee schedule agreed to in their portfolio management or wrap fee addendum while giving them the benefit of any fee reductions thresholds crossed by aggregating all investment accounts including any alternative investments. We reserve the right to bill at a lower CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 9 of 21  fee schedule for certain alternative investments. Advisory fees and reported values will be determined by the reporting account value as of the last market day of each quarter. In the absence of a reportable market value (which is frequently the case with alternative or private investments) at our discretion, our firm may rely on the reported value of the underlying portfolio company or private fund, seek a third-party opinion from a recognized source (unaffiliated accounting firm), or utilize the original deposit amount provided by the investment continues to be an ongoing concern. Educational Workshops Fees Workshops sessions are complimentary; no fee is assessed by our firm. Additional Client Fees Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees, qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account holder and per the separate fee schedule of the custodian of record. We will ensure you receive a copy of our custodian’s fee schedule at the beginning of the engagement, and you will be notified of any future changes to these fees by the custodian of record and/or third-party administrator for certain tax-qualified plans. Fees paid to our firm by our clients for our advisory services are separate from any internal fees involving mutual funds as outlined in their prospectus, including, but not limited to 12b-1 fees, expense ratios, etc., exchange-traded funds(ETFs), exchange- traded notes (ETNs), or other similar investments. Per annum interest at the current maximum statutory rate may be assessed on fee balances due more than 30 days; we may refer past due accounts to collections or legal counsel for processing. We reserve the right to suspend some or all services once an account is deemed past due. Stewardship Advisors, LLC and our associates do not charge or receive a commission or mark-up on your securities transactions, nor does the firm receive “trailer” or SEC Rule 12b-1 fees from an investment company. Termination of Services Either party may terminate the agreement at any time by communicating the intent to terminate in writing. If you verbally notify our firm of the termination and, if in two business days following this notification, we have not received your notice in writing, we will make a written notice of the termination in our records and send you our own termination notice as a substitute. Our firm will not be responsible for investment allocation, advice or transactional services (except for limited closing transactions) upon receipt of a termination notice. It will also be necessary that we inform the custodian of record and/or third-party investment manager that the relationship between parties has been terminated. If a client did not receive our Form ADV Part 2 firm brochure at least 48 hours prior to entering into the firm’s agreement, then that client will have the right to terminate the engagement without fee or penalty within five business days after entering into the agreement. If a client terminates a project-based financial planning service after this five-day period, the client will be assessed fees at the firm’s current hourly rate for any time incurred in the preparation of the client’s analysis or plan. When a retainer or portfolio management service client terminates their agreement after the five-day period, the client will be assessed fees on a per-day prorated basis for services incurred from either (i) as a new client, the date of the engagement to the date of the firm’s receipt of the written notice of termination, or (ii) all other accounts, the last billing period to the date of the firm’s physical or constructive receipt of written termination notice. If you were required to provide an initial deposit of $1,200 or more for a financial planning engagement, you provided all requisite information, and your plan has not been delivered to you within six months’ time from the date of the engagement, you may be entitled to a refund. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 10 of 21  The firm will return any prepaid, unearned fees within 30 days of the firm’s receipt of termination notice. Earned fees in excess of any prepaid deposit will be billed at the time of termination. Our return of payment to a client for our financial planning services will only be completed via check from our firm’s US-based financial institution. We will only coordinate remuneration of prepaid asset-based fees to an investment account via the account custodian. Return of prepaid fees will never involve a personal check, cash, or money order from our firm or from an associate of our firm. Item 6 - Performance-Based Fees and Side-By-Side Management We do not charge performance fees or engage in side-by-side management. Item 7 - Types of Clients We are available to serve individuals and high net worth individuals, as well as charitable organizations, businesses of all size, and their retirement plans. Stewardship Advisors, LLC has a minimum investment amount of $25,000 to establish an account, however this does not apply to our financial planning only clients. We will inform you in advance of any minimum criteria should a third-party investment manager be engaged. We reserve the right to waive or reduce certain fees based on unique individual circumstances, special arrangements or preexisting relationships. The firm reserves the right to decline services to any prospective client for any nondiscriminatory reason. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We employ a blend of fundamental and technical analyses. For example, fundamental analysis involves evaluating economic factors including interest rates, the current state of the economy, or the future growth of an industry sector. Technical analysis may involve studying the historical patterns and trends of securities and their markets in an effort to determine potential future behaviors, the estimation of price movement, and an evaluation of a transaction before entry into the market in terms of risk and profit potential. Firm research may be drawn from sources that include financial periodicals and research published by economists and other industry professionals. Investment Strategies Strategic Asset Allocation We utilize a strategic asset allocation approach to investing, with a long-term view of the markets. We recommend investment models to suit various risk tolerances. We typically recommend portfolios that contain ETFs and mutual funds. Environmental, Social and Governance Allocation (“ESG”) We also provide a values-based portfolio for clients that can deliver positive social or environmental impact alongside financial returns. Our ESG portfolio focuses on environmental issues such as climate change, pollution, and energy efficiency. The portfolio also screens out investments that generate revenue from the sale of alcohol, tobacco, gambling, and controversial weapons (“social issues”). Risk of Loss Our firm believes our strategies and investment recommendations are designed to produce the appropriate potential return for the given level of risk; however, there is no guarantee that an investment objective or planning goal will be achieved. Investing in securities involves risk of loss that clients should be prepared to bear. We have offered examples of such risk in the following paragraphs, and we believe it is important that our clients review and consider each of them prior to investing. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 11 of 21  Active Management Risks A portfolio that employs active management strategies may, at times, outperform or underperform various benchmarks or other strategies. In an effort to meet or surpass these benchmarks, active portfolio management may require more frequent trading or “turnover.” This may result in shorter holding periods, higher transactional costs and/or taxable events generally borne by the client, thereby potentially reducing or negating certain benefits of active asset management. Company Risk When investing in securities, such as stocks, there is always a certain level of company or industry-specific risk that is inherent in each company or issuer. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic risk and can be reduced or mitigated through diversification. ETF and Mutual Fund Risks The risk of owning ETFs and mutual funds reflect their underlying securities (e.g., stocks, bonds, etc.). These forms of securities typically carry additional expenses based on their share of operating expenses and certain brokerage fees, which may result in the potential duplication of certain fees. We do not recommend leveraged or inverse ETFs due to their inherent heightened risk. Failure to Implement Each client is free to accept or reject any or all of the recommendations made by our firm. While no advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients who choose not to take the steps recommended in their financial plan may face an increased risk that their stated goals and objectives will not be achieved. Financial Risk Excessive borrowing to finance a business operation increases profitability risk because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Force Majeure Risk This is the risk that there may be an act of God, terrorist act, global health pandemic, failure of utilities or other similar circumstance not within the reasonable control of Stewardship that may have an unknown and potentially catastrophic effect on the global markets. Stewardship has a business continuity plan to mitigate the effects of a force majeure risk, however, these events may still affect Stewardship, our clients, and the financial markets. Fundamental Analysis The challenge involving fundamental analysis is that information obtained may be incorrect; the analysis may not provide an accurate estimate of earnings, which may be the basis for a security’s value. Index Investing Certain ETFs and indexed funds have the potential to be affected by “active risk” or “tracking error risk;” a deviation from a stated benchmark. Inflation Risk CRD # 277099 SEC # 801-108174 When any type of inflation is present, a dollar today will not buy as much as a dollar next year because purchasing Stewardship Advisors, LLC Form ADV Part 2 - Page 12 of 21  power is eroding at the rate of inflation. Market Risk When the stock market as a whole or an industry as a whole fall, it can cause the prices of individual stocks to fall indiscriminately. This is also called systemic or systematic risk. Passive Investing A portfolio that employs a passive, efficient markets approach has the potential risk at times to generate lower- than-expected returns for the broader allocation than might be the case for a more narrowly focused asset class, and the return on each type of asset may be a deviation from the average return for the asset class. Long-Term Investment Investments in alternative investments generally involve a long-term commitment, and there is no assurance of any return on investment prior to or upon liquidation of the investment. Investors should be prepared to hold their securities for the life of the investment. Illiquidity of Limited Investment Ownership Interests. Ownership interests in limited investments are often highly illiquid, may have no public market, or are not transferable except in limited circumstances. Geopolitical Risk Geopolitical and other events (e.g., war or terrorism) may disrupt securities markets and adversely affect global economies and markets, thereby decreasing the value of an account’s investments. Sudden or significant changes in the supply or prices of commodities or other economic inputs such as oil may have material and unexpected effects on both global securities markets and individual countries, regions, sectors, companies, or industries, which could significantly reduce the value of an account’s investments. War, terrorism, and related geopolitical events have led, and in the future may lead, to increased short-term market volatility and may have adverse long- term effects on U.S. and world economies and markets generally. QDI Ratios While many ETFs and index mutual funds are known for their potential tax-efficiency and higher “qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be part of an ETF or mutual fund portfolio), may be considered “non-qualified” under certain tax code provisions. A holding’s QDI will be considered when tax-efficiency is an important aspect of the client’s portfolio. Research Data When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. While our firm makes every effort to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the advice on or investment management of an account. Technical Analysis CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 13 of 21  The risk of investing based on technical analyses is that it may not consistently predict a future price movement; the current price of a security may reflect all known information. This may occur due to analyst bias or misinterpretation, a sector analysis error, late recognition of a trend, etc. ESG Risks Stewardship uses Morningstar’s ESG screening tool. There is a risk that the investments listed as meeting our ESG criteria as a result of our screening, were incorrectly entered in the Morningstar screening tool and thus do not meet our ESG criteria. ESG (Environmental, Social, and Governance) investing seeks to align client’s investment interests with a sustainable set of standards to screen potential investments. Environmental criteria consider how a company performs as a steward of nature. Social criteria examine how companies manage relationships with employees, suppliers, customers, and the communities where it operates. Governance deals with a company’s leadership, executive pay, audits, internal controls, and shareholder rights. One of the largest issues with ESG investing is getting reliable and accurate information to evaluate ESG criteria for companies. Also, while companies that meet ESG criteria are generally believed to be more ethical and have high environmental standards, the trade-off is that these companies may have lower profits anticipated in the short term with the potential for better profits over the life of the company due to the ethical choices, however, there is a risk that even companies believed to have met ESG criteria could be subject to events that would reduce their income and reputation and open the company up to lawsuits and regulatory inquiries. Not all companies considered ESG companies meet ESG criteria in all areas. In addition, there is a risk that a company is accidentally included with ESG companies in ETF and mutual fund investments, but they do not actually meet the ESG criteria. In addition, with the increase in popularity of ESG investing in the past few years, there is also the potential that ETFs or mutual funds that focus on ESG investing may trade at a premium. Epidemics, Pandemics, Outbreaks of Disease and Public Health Issues. Our business activities could be materially adversely affected by pandemics, epidemics and outbreaks of disease in Asia, Europe, North America and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu, severe acute respiratory syndrome (SARS), and/or other epidemics, pandemics, outbreaks of disease, viruses and/or public health issues. Specifically, COVID-19 has spread (and is currently spreading) rapidly around the world since its initial emergence in China in December 2019 and has severely negatively affected (and may continue to materially adversely affect) the global economy and equity markets (including, in particular, equity markets in Asia, Europe and the United States). Although the long- term effects or consequences of COVID-19 and/or other epidemics, pandemics and outbreaks of disease cannot currently be predicted, previous occurrences of other pandemics, epidemics and other outbreaks of disease, such as H5N1 flu, H1N1 flu, SARS and the Spanish flu, had a material adverse effect on the economies and markets of those countries and regions in which they were most prevalent. Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic, communicable disease or virus or major public health issue could cause a slowdown in the levels of economic activity generally (or cause the global economy to enter into a recession or depression), which would adversely affect the business, financial condition and operations of the Adviser. Should these or other major public health issues, including pandemics, arise or spread farther (or continue to spread or materially impact the day to day lives of persons around the globe), the Adviser could be adversely affected by more stringent travel restrictions, additional limitations on the Adviser’s operations or business and/or governmental actions limiting the movement of people between regions and other activities or operations (or to otherwise stop the spread or continued spread of any disease or outbreak). Item 9 - Disciplinary Information Neither the firm nor our management have been involved in a disclosure event. Item 10 - Other Financial Industry Activities and Affiliations CRD # 277099 SEC # 801-108174 Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of interest Stewardship Advisors, LLC Form ADV Part 2 - Page 14 of 21  between the firm and its clients, or that may be contrary to law. Our firm will provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts of interest involving its business relationships that might reasonably compromise its impartiality or independence. Whether serving a client in one or more capacities, each associate will disclose in advance how they are being compensated and if there is a conflict of interest involving any advice or service they may provide. At no time will there be tying between business practices and/or services; a condition where a client or prospective client would be required to accept one product or service which is conditional upon the selection of a second, distinctive tied product or service. The external investment managers that we may recommend for your portfolio are required to be registered as investment advisors. If we recommend that your portfolio be created and maintained by an external investment manager, we will first ensure that their firm is appropriately registered and/or notice-filed within your state of residence. As referenced in Item 5 of this brochure, each firm is compensated for their respective services by the client through a portion of the fee that is assessed. We may have an incentive to recommend one investment manager over another if less favorable compensation or services arrangements are offered by another. In light of this conflict of interest, we will review our recommendations and “mix of business” in light of our client’s needs, goals and objectives with respect to all of our portfolio management offerings. There is also the potential for clients’ fees assessed via these engagements to be higher than had a client obtained them directly from an external investment manager or the client were able to purchase similar underlying investments on their own. Clients are encouraged to review all of our offerings and their stated fees prior to the engagement, and each client has the option to purchase recommended or similar investments through their own selected service provider. It should be noted that certain third-party managers/sub-advisors and/or underlying investments may not be available to self- directed investors or at the same cost. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has a fiduciary duty to our clients, which means the firm and our associates will act in the utmost good faith, performing in a manner believed to be in the best interests of its clients. Code of Ethics We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical and professionally responsible manner in all professional services and activities. Our firm policies include prohibitions against insider trading, the circulation of industry rumors, and certain political contributions, among others. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require firm personnel to annually attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the firm’s Code of Ethics is made available to any client or prospective client upon request. To request a copy of our Code of Ethics, please contact the Firm using the contact information on the Cover Page of this brochure. Firm associates that are CERTIFIED FINANCIAL PLANNERTM Practitioners also adhere to the Certified Financial Planner Board of Standards, Inc.’s Code of Ethics & Professional Responsibility which you may find at www.cfp.net. Firm Recommendations and Conflicts of Interest Our Firm remains focused on ensuring that recommended securities are based upon the individual needs of the clients, not resultant on fees received for such services. You are under no obligation to act on a recommendation from our firm and, if you elect to do so, you are under no obligation to complete them through our Firm or a service provider whom we may recommend. We do not trade for our own account (e.g., proprietary trading). The Firm’s related persons may buy or sell CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 15 of 21  securities that are the same as, similar to, or different from, those recommended to clients for their accounts, and this poses a conflict of interest. We mitigate this conflict by ensuring that we have policies and procedures in place to ensure that the firm or a related person will not receive preferential treatment over a client. Employees wishing to trade in the same securities as clients must receive pre-approval from our CCO, or designee, or engage in a trade aggregated with client trades. Employees and related persons of the firm will report, and the firm will periodically review, personal securities accounts and holdings for any potential trade indicating that the employee is trading ahead of clients or engaging in insider trading. Upon discovering a violation of policy, the firm may impose any sanctions as deemed appropriate, including disgorgement of profits, trade reversals, and up to and including termination. Item 12 - Brokerage Practices Factors Used to Select Broker/Dealers for Client Transactions Stewardship Advisors, LLC does not maintain physical custody of your assets. Your account must be maintained by a qualified custodian (generally a broker/dealer, bank or trust company) that is frequently reviewed for its capabilities to serve in that capacity by their respective industry regulatory authority. When we are engaged to provide an investment consultation via a planning service component, we may recommend the service provider with whom your assets are currently maintained. Should you prefer a new service provider, we may make a recommendation based on your needs, overall cost, and ease of use, and following our review of the recommended provider. Accounts served by a third-party investment manager are to be maintained at one or more custodians that have been selected by the respective third-party investment manager and they will be disclosed in the third-party investment manager’s disclosure documents and account opening forms. We prefer that our portfolio management services clients use Charles Schwab, a division of Charles Schwab & Co., Inc. (“Schwab”), Trade-PMR, Inc. (“Trade-PMR”), MTG, LLC doing business as Betterment Securities. Members FINRA/SIPC, or SEI. While we recommend a custodian of record, you will decide whether to do so and will open your account in your name with them by entering into an agreement directly with them. We do not technically open the account for you, although we will assist you in doing so. If you do not wish to place your assets with a recommended custodian, we may be able to serve as your investment advisor with another custodian of your choice if the other custodian’s policies allow us to do so. Our custodians offer independent investment advisors various services which include custody of client assets, trade execution, clearance and settlement, etc. Our firm may receive certain benefits from a custodian through participation in its independent advisor support program (please refer to Item 14 for further details), however, there is no direct link between our firm’s participation in their program and the investment advice we may provide to our clients. Our firm periodically conducts an assessment of any recommended service provider which generally involves a review of the range and quality of services, reasonableness of fees, among other items, in comparison to industry peers. In certain situations, we may recommend American Funds Service Company or Nebraska Educational Savings Trust (NEST) as custodian of record. Best Execution CRD # 277099 SEC # 801-108174 “Best execution” means the most favorable terms for a transaction based on all relevant factors, including those listed in the earlier paragraph titled Factors Used to Select Broker/Dealers for Client Transactions and in Item 14. We recognize our obligation in seeking best execution for our clients; however, it is our belief that the determinative factor is not always the lowest possible cost but whether the selected custodian’s transactions represent the best “qualitative execution” while taking into consideration the full range of services provided. Stewardship Advisors, LLC Form ADV Part 2 - Page 16 of 21  Our firm will seek services involving competitive rate but it may not necessarily correlate into the lowest possible rate for each transaction. We have determined having our portfolio management clients’ accounts trades completed through our recommended custodian is consistent with our obligation to seek best execution of client trades. A review is regularly conducted with regard to recommending a custodian to our clients in light of our duty to seek best execution. Stewardship Advisors, LLC may, in our discretion, accept the client’s transfer of preexisting retail mutual funds into their account. A transfer-in-kind of retail share class mutual funds may potentially benefit the client since they are able to invest in their portfolio more quickly, mitigate tax and/or short-term trading liabilities, and/or avoid contingent deferred sales charges (CDSC). Our firm regularly reviews accounts that have transferred different share classes of mutual funds and will convert share classes to a lower expense share class when we believe doing so would be beneficial to the client. In addition, if account assets remain in a retail share class and within a CDSC period, we may exclude those assets from our advisory fee until they have been converted to what we believe is a more appropriate share class. Directed Brokerage Our internal policy and operational relationship with our custodian require client accounts custodied with them to have trades executed per their order routing requirements. We do not direct which executing broker should be selected for client account trades; whether that is an affiliate of our preferred custodian or another executing broker of our custodian’s choice. As a result, you may pay higher commissions or other transaction costs, experience greater spreads, or receive less favorable net prices on transactions than might otherwise be the case. In addition, since we routinely recommend a custodian for our advisory clients, and that custodian may choose to use the execution services of its broker affiliate for some or all of our client account transactions, there is an inherent conflict of interest involving our recommendation since our advisory firm receives various products or services described in this section from that custodian. Client accounts maintained at our custodian are unable to direct brokerage. As a result, they may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case if they had the opportunity to direct brokerage. For accounts maintained at a custodian of the client’s choice (e.g., held-away accounts), the client may choose to request that a particular broker is used to execute some or all account transactions. Under these circumstances, the client will be responsible for negotiating, in advance of each trade, the terms and/or arrangements involving their account with that broker, and whether the selected broker is affiliated with their custodian of record or not. We will not be obligated to seek better execution services or prices from these other brokers, and we will be unable to aggregate transactions for execution via our custodian with other orders for accounts managed by our firm. As a result, the client may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case. Aggregating Securities Transactions Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately the same time. This may also be termed “blocked, “bunched” or “batched” orders. Aggregated orders are effected in an attempt to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple client accounts should there be differences in prices, brokerage commissions or other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm may, but is not obligated to, aggregate orders and we do not receive additional compensation or remuneration as a result of aggregated CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 17 of 21  transactions. Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that the firm determines to aggregate client orders for the purchase or sale of securities, including securities in which a related person may invest, the firm will generally do so in accordance with the parameters set forth in SEC No- Action Letter SMC Capital, Inc. Please note that when trade aggregation is not allowed or infeasible and necessitates individual transactions (e.g., withdrawal or liquidation requests, odd-lot trades, nondiscretionary accounts, etc.), an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. We review firm trading processes on a periodic basis to ensure they remain within stated policies and regulation. You will be informed, in advance, should trading practices change at any point in the future. Client Referrals from Custodians We do not receive referrals from our preferred custodian, nor are client referrals a factor in our selection of a custodian. Item 13 - Review of Accounts Scheduled Reviews Financial Planning Services Periodic financial check-ups or reviews are recommended if you are receiving our financial planning services. Depending on the type of engagement with our firm, they may occur on a monthly, quarterly or at least on an annual basis. Reviews will be conducted by your investment advisor representative and typically involve analysis and possible revision of your previous financial plan or investment allocation. A copy of revised plans or asset allocation reports will be provided to the client upon request. Unless provided for in your engagement agreement, reviews are generally conducted under a new or amended agreement and will be assessed at our current fee rate. Third-Party Investment Management Services For accounts served by a recommended third-party investment manager, your investment advisor representative will periodically review reports provided to you by your third-party investment manager. We will contact you at least annually to review your financial situation and objectives. We will communicate information to your third- party investment manager as warranted and assist you in understanding and evaluating the services provided by the third-party manager. In certain instances, you may be able to communicate directly with your selected third- party investment manager but we ask that you coordinate the session through our firm. Portfolio Management Services Investment account allocations are reviewed on a quarterly or more frequent basis by our investment team. Client level reviews are also completed by your investment advisor representative, and we recommend that they occur on at least an annual basis. A copy of a revised investment guideline or asset allocation reports will be provided to the client upon request using the contact information on the cover page of this brochure. Interim Reviews Financial Planning Services You should contact our firm for additional reviews when you anticipate or have experienced changes in your CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 18 of 21  financial situation (i.e., changes in employment, an inheritance, the birth of a new child, etc.), or if you prefer to change requirements involving your investment account. Interim reviews are conducted by your investment advisor representative, and a copy of revised plans or asset allocation reports will be provided to the client upon request. Portfolio Management Services Additional reviews by your portfolio manager and your investment advisor representative may be triggered by news or research related to a specific holding, a change in our view of the investment merits of a holding, or news related to the macroeconomic climate affecting a sector or holding within that sector. A portfolio may be reviewed for an additional holding or when an increase in a current position is under consideration. Account cash levels above or below what we deem appropriate for the investment environment, given the client's stated tolerance for risk and investment objectives, may also trigger a review. Client Reports and Frequency Whether you have opened and maintained an investment account on your own or with our assistance, you will receive quarterly or more frequent account statements sent directly from mutual fund companies, transfer agents, custodians or brokerage companies where your investments are held. We urge you to carefully review these account statements for accuracy and clarity, and to ask questions when something is not clear. Our firm uses a third party to produce written performance reports which are calculated using a time-weighted methodology that are reviewed for accuracy by compliance personnel prior to delivery. The reports are intended to inform clients about their investment performance over the current period, as well as over the longer term since the account’s inception; both on an absolute basis and as compared to a known benchmark. Clients are urged to carefully review and compare account statements that they have received directly from their custodian of record with any report they may receive from our firm or any other source that contains investment performance information. Item 14 - Client Referrals and Other Compensation Economic Benefit from External Sources Per Items 4 and 5 of this brochure, for our initial and continuing consultation we receive a portion of the asset-based fee that is paid by a client to a third-party investment manager. Please refer to Item 10 for additional information with respect to our offerings and the potential conflict of interest this may present. As disclosed in Item 12, Stewardship Advisors, LLC receives economic benefit from our custodians in the form of various products and services they make available to the firm and other independent investment advisors that may not be made available to a “retail investor.” There is no direct link between our firm’s participation in their program and the investment advice we may provide to our clients. These benefits may include the following products and services (provided either without cost or at a discount): • receipt of duplicate client statements and confirmations • research related products and tools • access to trading desks serving our clients • access to block trading services • the ability to have advisory fees deducted directly from a client’s accounts (per written agreement) • resource information related to capital markets and various investments CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 19 of 21  • access to an electronic communications network for client order entry and account information • access to mutual funds with no transaction fees and/or select investment managers • discounts on marketing, research, technology, and practice management products or services provided to our firm by third-party providers Some of the noted products and services made available by a custodian may benefit our advisory firm but may not directly benefit a client account, and certain research and other previously referenced services may qualify as "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934. The availability of these services from a custodian benefits our firm because it does not have to produce or purchase them as long as firm clients maintain assets in accounts at a custodian. There is a conflict of interest since our firm has an incentive to select or recommend a custodian based on our firm’s interest in receiving these benefits rather than your interest in receiving favorable trade execution. It is important to mention that the benefit received by our firm through participation in any custodian’s program does not depend on the amount of brokerage transactions directed to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a whole -- not just those services that benefit only our advisory firm. Further, we will act in the best interest of our clients regardless of the custodian we may select. Client Referrals Upon your request, you may be provided a referral to various professionals, such as an accountant or an attorney. If we receive or offer an introduction to a client involving these other professionals, we do not pay or earn referral fee, nor are there established quid pro quo arrangements. Each client retains the right to accept or deny such referral or their subsequent services. Stewardship employees do receive compensation for referring clients to the Firm. This compensation is in addition to their salaries. In addition, Stewardship may pay referral fees for client referrals. Any compensation paid, either to Stewardship employees or to a third party, does not increase Stewardship fees charged to clients. Item 15 - Custody Your assets will be maintained by an unaffiliated, qualified custodian. Your assets are not held by our firm or any associate or our firm. In keeping with this policy involving our client funds or securities, Stewardship Advisors, LLC: • Restricts the firm or an associate from serving as trustee or having general power of attorney over a client account; • Prohibits any associate from having authority to directly withdraw securities or cash assets from a client account; • Does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm; • Will not collect advance fees of $1,200 or more for services that are to be performed six months or more into the future; • Will not authorize an associate to have knowledge of a client’s account access information (i.e., online401(k), brokerage or bank accounts) if such access would allow physical control over account assets. Your account custodian will provide you with your investment account transaction confirmations and account statements, which will include all debits and credits for that period. Statements are provided on at least a quarterly basis and confirmations are provided as transactions occur within your account, unless otherwise agreed upon. Our advisory firm will not create an account statement for a client nor serve as the sole recipient of a client account statement. Clients are urged to carefully review and compare their account statements that they have received CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 20 of 21  directly from their custodian of record with any performance report they may receive from any source. Item 16 - Investment Discretion Portfolio Management Services We generally provide our portfolio management services on a discretionary basis. Via limited power of attorney, discretionary authority allows our firm to implement investment decisions, such as the purchase or sale of a security on behalf of your account, without requiring your prior authorization for each transaction in order to meet your stated investment objectives. This authority will be granted through your execution of both our engagement agreement and the selected custodian’s account opening documents. Note that your custodian will specifically limit our firm’s authority within your account to the placement of trade orders and the request for the deduction of our advisory fees. Our firm prefers to not manage client accounts on a nondiscretionary basis but we may accommodate such requests on a case-by-case basis. Such account authority requires your ongoing prior approval involving the investment and reinvestment of account assets, portfolio rebalancing, or for our firm to give instructions to the custodian maintaining your account (i.e., wire instructions, etc.). You will be required to execute our firm’s client services agreement that describes our limited account authority, as well as the custodian of record’s account opening document that includes their limited power of attorney form or clause. You may amend our account authority by providing our firm revised written instructions. As noted in Item 4, we will allow for reasonable restrictions involving the management of your account. It remains your responsibility to notify us if there is any change in your situation and/or investment objective so that we may reevaluate previous investment recommendations or portfolio holdings. Financial Planning Services If you ask us to assist you in any trade execution (including account rebalancing) under an investment consultation component of our financial planning engagement, such as assisting you with your held-away assets, it will typically be accomplished on a nondiscretionary basis. Item 17 - Voting Client Securities Our firm does not vote proxies on your behalf, including accounts that we have discretionary authority. We do not offer guidance on how to vote proxies, nor will we offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. We will answer limited questions with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer or their legal representative. Item 18 - Financial Information Nether the firm nor our management have a financial condition likely to impair our ability to meet commitments to clients, nor has the firm and its management been the subject of a bankruptcy petition. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - Page 21 of 21 

Item 1 - Cover Page Stewardship Advisors, LLC 321 W. Main Street Mount Joy, PA 17552 Tel: (717) 492-4787 Fax:(717)283-4049 www.mystewardshipadvisor.com Form ADV Part2A Firm Brochure Retirement Plans March 16, 2026 This brochure provides information about the qualifications and business practices of Stewardship Advisors, LLC. Please contact our Chief Compliance Officer, Mr. Mark Brinser, at (717) 492-4787 if you have any questions about the content of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or any state securities administrator. Additional information about Stewardship Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Click on the “Investment Adviser Search” link and then search for “Investment Adviser Firm” using the firm’s IARD (“CRD”) number, which is 277099. While the firm and its associates may be registered and/or licensed within a particular jurisdiction, that registration and/or licensing in itself does not imply an endorsement by any regulatory authority, nor does it imply a certain level of skill or training on the part of the firm or its associated personnel. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 1 of 19  Item 2 - Material Changes Since our previous amendment on March 17, 2025 there has been no material changes to Stewardship Advisors, LLC (“Stewardship” or “Firm”) ADV brochures As with all firm documents, clients and prospective clients are encouraged to review this brochure in its entirety and as there may be other small changes not included here. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 2 of 19  Item 3 - Table of Contents Contents Item 1 - Cover Page ................................................................................................... 1 Item 2 - Material Changes ......................................................................................... 2 Item 3 - Table of Contents ......................................................................................... 3 Item 4 - Advisory Business ........................................................................................ 4 Item 5 - Fees and Compensation ................................................................................ 6 Item 6 - Performance-Based Fees and Side-By-Side Management ..................................... 8 Item 7 - Types of Clients ........................................................................................... 8 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................... 9 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 ................................................................................................................ 12 Item 12 - Brokerage Practices .................................................................................. 13 Item 13 - Review of Accounts ................................................................................... 16 Item 14 - Client Referrals and Other Compensation ...................................................... 17 Item 15 - Custody .................................................................................................. 18 Item 16 - Investment Discretion ............................................................................... 18 Item 17 - Voting Client Securities ............................................................................. 19 Item 18 - Financial Information ................................................................................ 19 CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 3 of 19  Item 4 - Advisory Business Description of the Firm Stewardship Advisors, LLC is a Pennsylvania domiciled limited liability company formed in November, 2011. Our firm is not a subsidiary of, nor does it control another reportable financial industry entity. The firm’s initial registration as an investment advisor had occurred with the Commonwealth of Pennsylvania in October of 2015, followed by our SEC registration in July of 2016. The firm’s principal owner is W. Lee Shertzer. Description of Services Offered Stewardship Advisors, LLC provides a broad range of solutions to our clients. In addition to our retirement plan services, we are available to serve individual investors and businesses interested in financial planning and portfolio management. We also maintain a wrap fee investment program for investors with an account value of $250,000 or greater of investable assets that are managed by our firm, however, the wrap fee program is not accepting new investors. These individualized services are described in further detail in separate firm brochures that are available upon request. Our retirement plan consulting services assist plan sponsors in understanding the scope of their fiduciary duties and responsibilities, develop prudent practices and procedures to enable them to effectively discharge those duties and responsibilities, and document their actions and decisions. Our firm assists plan fiduciaries in the development of committee charters, fiduciary eligibility documentation, and committee meeting documentation, investment policy and other activities that generally relate to prudent plan governance. Also included is assistance in preparing an annual report to the board of director or trustees as our client deems prudent and appropriate. Our firm is available to provide process assessments on the practices currently in place to manage fiduciary duties and responsibilities, as well as offer recommendation to improve current plan practices. We can assist in benchmarking service providers by evaluating existing providers and their expenses incurred for their services, and we can prepare a vendor request for information and complete an analysis of the vendor responses. We may be engaged pursuant to § 3(21) and/or § 3(38) of the Employee Retirement Income Security Act of 1974 (“ERISA”). Our level of account authority is defined in further detail in Item 16 of this brochure. We do not serve as ERISA § 3(16) plan third-party administrator (“TPA”), but we will assist the plan sponsor in identifying a TPA. if appropriate. An initial interview is conducted with the plan sponsor to discuss their current situation, goals, and the scope of services that may be provided by our firm. If the plan sponsor wishes to engage our firm, parties must enter into a written agreement; thereafter, discussion and analysis will be conducted to determine plan requirements. We will then provide written recommendations and deliverables as specified within our engagement scope. With respect to advisory services provided to a plan sponsor, we are available to conduct: • Due diligence on existing, potential, and selected investment managers and/or service providers • Retirement plan asset-class menu recommendations • Investment Policy Statement (IPS) review or its development and implementation 1 Throughout this brochure, the term “plan sponsor” includes any person with the authority to review and implement plan investment decisions, such as executive management, investment committees, retirement plan committees, general counsel,plan advisor, etc. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 4 of 19  • Trustee education • Plan design recommendations • Plan mid-year and year-end reviews with trustee(s), as appropriate • Investment monitoring reports • Substitution recommendations • Watch list recommendations • Model portfolio generation for participants • Participant educational workshops • Site visits when/where needed, upon request Upon request, we will review an existing or prepare a new IPS or similar written plan guidelines. The purpose of the IPS is to assist plan investment committees in effectively supervising, monitoring and evaluating their company's retirement plan. Topics might include: Investment committee's expectations, objectives and guidelines for the plan, as well as ensuring effective communications between the investment committee and all parties involved with investment management decisions; Establishing formal criteria for provider selection and evaluation; and Complying with all ERISA, fiduciary, prudence and due diligence requirements applicable with laws, rules and regulations from various local, state or federal entities that may impact plan assets. We are available to conduct ongoing assessments of selected providers. We may recommend replacement of some or all of plan investments, a recordkeeper, TPA and/or custodian. Our recommendations will depend on a combination of plan goals and objectives, updated due diligence information, as well as cost or other service considerations. Our advisory firm does not provide legal or accounting services. With your consent, we will work with a professional of your choice to assist with the coordination and implementation of various strategies. You should be aware that these other professionals will charge you separately for their services and these fees will be in addition to our own advisory fee. If the plan does not call for self-directed investing by plan participants, the plan sponsor may choose to engage our firm to assist with implementing investment strategies. For those plans that we serve as portfolio manager we employ strategies and a range of investment vehicles as described in Item 8 of this brochure. We manage plan portfolios on a discretionary basis as defined in Item 16. We will utilize the plan’s IPS, observing reasonable investment constraints as stated in the IPS. For example, the plan may choose to exclude certain securities (e.g., options, stocks, illiquid securities, etc.). Investment guidelines should be designed to be specific enough to provide future guidance while allowing flexibility to work with changing market conditions. It will remain the plan sponsor’s responsibility to promptly notify us if there is any change in the sponsor’s financial situation and/or investment objectives for the purpose of our reviewing, evaluating or revising previous account restrictions or firm investment recommendations. As of December 31, 2025, our firm managed approximately $538,071,393 in assets under management on a discretionary basis and $7,109,067 on a non-discretionary basis for total assets managed of approximately $545,180,460. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 5 of 19  Item 5 - Fees and Compensation Forms of payment are based on the types of services being provided, term of service, etc., and will be stated in the engagement agreement. Depending on the services utilized you will pay a flat fee or an on-going asset management fee based on the assets we manage. All fees are charged in advance. Our fees are negotiable, with the final determination to be made by the firm. Fees may be paid to our firm by check or draft from US-based financial institutions. With the plan sponsor’s prior authorization, payment may also be made by credit card through a qualified, unaffiliated PCI compliant third- party processor, or via withdrawal from the investment account held at the custodian of record by the custodian or TPA. Method of Compensation and Fee Schedule Option 1a: Portfolio Management Services Fees - Internal Portfolio Management For those portfolios that we internally manage, at the beginning of each calendar quarter the plan or plan participant (as determined by the engagement) will pay our firm an asset-based fee based on an annualized rate as indicated in the following fee table. The fee is determined using the value of account assets on the last day of each quarter and multiplying the asset value by the fee percentage applicable from the chart below. Fees are charged in advance; see Termination of Services below for our policy on refunding fees. Formula: ((quarter-end market value) x (applicable number of basis points))/4 Assets Under Management Annualized Asset-Based Fee 1.00% (100 basis points) 0.85% (85 basis points) 0.70% (70 basis points) $0-$499,999 $500,000 - $999,999 $1,000,000 - $2,999,999 $3,000,000-Above Negotiable Our fee schedule is based on a straight tier; all accounts are charged a single percentage rate that declines as asset levels increase. Our firm will aggregate plan accounts for all participants in order to apply a discount to the asset- based fee. We will prorate the first period’s fee based on the number of days remaining in the first billing cycle. In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized industry source (e.g., unaffiliated public accounting firm), and the plan sponsor and/or plan participant may choose to separately seek such an opinion at their own expense as to the valuation of “hard-to-price” securities if they believe it to be necessary. Deducted fees will be noted on account statements that the plan sponsor and/or participant (per the engagement) receives from the custodian of record and/or third-party administrator on a quarterly or more frequent basis. It is important that the plan/plan participants also verify the accuracy of fee calculations; the custodian does not verify the accuracy of advisory fee assessments for each account. By signing our firm’s engagement agreement, as well as the selected custodian account opening documents and/or TPA forms, the plan sponsor/participant will be authorizing the withdrawal of both advisory and transactional fees (described below) from their account. The withdrawal of these fees will be accomplished by the selected custodian or TPA, not by our firm, and our advisory fees will be remitted directly to our firm. Alternatively, the plan sponsor may request to directly pay our advisory firm its portfolio management fee in lieu of having the advisory fee withdrawn from plan accounts. Our valuation assessment will remain the same as described above, and the plan’s direct payment must be received by our firm within 10 days of our invoice. We do not accommodate requests for direct payment from plan participants. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 6 of 19  Option 1b: Portfolio Management Services Fees - Third-Party Investment Managers Each third-party investment manager program has a stated fee range that will be described through the use of that external investment manager’s disclosure documents and prior to the selection of the third-party investment manager. We will inform the plan sponsor in advance whether the selected third-party investment manager allows for account aggregation for the purpose of fee discounts. The annualized asset-based fee ranges from 0.50% to 2.00% (50 to 200 basis points, depending on the third-party investment manager selected) and our firm will receive a portion of the fee, ranging from 0.25% to 1.50% (25 to 150 basis points) for our continued consultation service, which we will describe to in our engagement agreement. Investment management services fees, including debits and credits, will be noted on account statements that the plan sponsor and/or plan participant receives directly from the custodian of record on a quarterly or more frequent basis. Our advisory firm is not directly involved in the billing process of third-party investment management accounts. Written authorization is required in order for the custodian of record to deduct advisory fees from investment accounts. By signing the custodian account documents, the plan will be authorizing the withdrawal of fees from plan accounts. The withdrawal of these fees will be accomplished by the custodian of record or TPA. Our portion of the advisory fee will be remitted directly to our firm via the third-party investment manager or TPA. Option 2: Fixed Fee Engagement We offer both plan consultation and our internal portfolio management services on a fixed fee basis; typically, ranging from $500 up to $10,000 for more extensive engagements. The fee is to be paid on a calendar quarter basis, but we will accommodate requests for monthly payment cycles. The fee is paid to our firm in advance, and is due within the first 10 calendar days of each service period. We will prorate the first period’s fee based on the number of days remaining in the first billing cycle. See Termination of Services below for our policy on refunding fees. We take into consideration factors such as the estimated amount of time dedicated to the engagement, project complexity, as well as the number of associates needed to meet program needs. When our fixed fee services include ongoing portfolio monitoring, the fee will reflect the assets that comprise the plan, number of participants, required review frequency, among other factors that will be described in writing within the agreement. Option 3: Combination Fee Engagement For new plans with no assets but prefer our portfolio management support, we offer a blended fee schedule. Our initial start-up fee ranges from $500 up to $10,000 for extensive engagements, which is combined with our asset-based fee schedule noted in Option 1a. The fee is to be paid on a calendar quarter basis, but we will accommodate requests for our fixed fee to be paid on a monthly cycle, in advance. Additional Client Fees Any transactional or service fees (sometimes termed brokerage fees) assessed by a selected service provider (i.e., a custodian), individual retirement account fees, qualified retirement plan or account termination fees will be borne by the account holder as stated in current, separate fee schedules of any selected service provider. We will ensure a copy of the custodian’s fee schedule is delivered at the beginning of the engagement, and plan sponsors and participants will be notified of any future changes to these fees by the custodian of record and/or TPA. Fees paid by our clients to our firm for our advisory services are separate from any of these fees or other similar charges. CRD # 277099 SEC # 801-108174 In addition, our advisory fees are separate from any internal fees or charges a client may pay involving mutual Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 7 of 19  funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), or other similar investments. Additional information about our fees in relationship to our business practices are noted in Items 12 and 14 of this document. Per annum interest at the current statutory rate may be assessed on fee balances due morethan30 days; we may refer past due accounts to collections or legal counsel for processing. We reserve the right to suspend some or all services once an account is deemed past due. Termination of Services Either party may terminate the plan engagement agreement at any time in writing. We do not accept verbal notifications involving retirement plans. For those plan sponsors who utilize our portfolio management services, our firm will not be responsible for future allocations, investment advice or transactional services (except closing transactions) upon receipt of termination notice. It will also be necessary that we inform the custodian of record, TPA and/or third-party investment manager serving the plan that the relationship between our firm and the plan has been terminated. If our Form ADV Part 2A firm brochure was not delivered to the plan sponsor at least 48 hours prior to entering into the engagement contract, then the plan sponsor has the right to terminate the engagement without fee or penalty within five business days after entering into the agreement. If a plan sponsor terminates an engagement after this period, they may be assessed fees for any time or charges incurred by our firm in the preparation of their plan, and we may assess our asset-based fee on a prorated basis from the date of last payment to the date of termination. We will promptly return any unearned amount upon receipt of a written termination notice. If the plan is required to provide an advance fee of $1,200 or more for our services and had provided all requested information and agreed upon plans or services have not been delivered within six months’ time from the date of the engagement, the plan will be entitled to a refund. Our firm will return any prepaid, unearned fees within 30 days of the firm’s receipt of termination notice. Earned fees in excess of any prepaid deposit will be billed at the time of termination and will be due upon receipt of our invoice. Our return of payment to a client for our planning services will be completed via check from our firm’s US-based financial institution; no credits or “transaction reversals” will be issued. We will coordinate remuneration of prepaid asset-based fees to investment accounts. Return of prepaid fees will never involve a personal check, cash or money order from our firm or from an associate of our firm. Item 6 - Performance-Based Fees and Side-By-Side Management Our firm does not charge performance fees or engage in side-by-side management. Item 7 - Types of Clients We provide retirement plan services to pension and profit-sharing plans for small businesses, self- employed individuals, etc. We also serve individuals, high net worth individuals, and businesses, as discussed in a separate brochure. Our firm does not require minimum asset levels or other similar preconditions for our retirement plan engagements. We reserve the right to decline services to any prospective client for any nondiscriminatory reason. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 8 of 19  Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We employ a blend of fundamental and technical analyses. Fundamental analysis involves evaluating economic factors including interest rates, the current state of the economy, or the future growth of an industry sector. Technical analysis involves studying the historical patterns and trends of securities and their markets in an effort to determine potential future behaviors, the estimation of price movement, and an evaluation of a transaction before entry into the market in terms of risk and profit potential. Firm research is drawn from sources that may include financial periodicals and research published by economists and other industry professionals. Investment Strategies Strategic Asset Allocation We utilize a strategic asset allocation approach to investing, with a long-term view of the markets. We recommend investment models to suit various risk tolerances. We typically recommend portfolios that contain ETFs and mutual funds. Environmental, Social and Governance Allocation (“ESG”) We also provide a values-based portfolio for clients that can deliver positive social or environmental impact alongside financial returns. Our ESG portfolio focuses on environmental issues such as climate change, pollution, and energy efficiency. The portfolio also screens out investments that generate revenue from the sale of alcohol, tobacco, gambling, and controversial weapons (“social issues”). Risk of Loss Our firm believes its strategies and investment recommendations are designed to produce the appropriate potential return for the given level of risk; however, there is no guarantee that a planning goal or investment objective will be achieved. Past performance is not necessarily indicative of future results. Investing in securities involves risk of loss that investors should be prepared to bear. While the following list is not exhaustive, we provide some examples of such risk in the following paragraphs, and we believe it is important to review and consider each prior to investing. Active Management Risks A portfolio that employs active management strategies may, at times, outperform or underperform various benchmarks or other strategies. In an effort to meet or surpass these benchmarks, active portfolio management may require more frequent trading or “turnover.” This may result in shorter holding periods, higher transactional costs and/or taxable events generally borne by the client, thereby potentially reducing or negating certain benefits of active asset management. Company Risk When investing in securities, such as stocks, there is always a certain level of company or industry-specific risk that is inherent in each company or issuer. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic risk and can be reduced or mitigated through diversification. ETF and Mutual Fund Risks The risk of owning ETFs and mutual funds reflect their underlying securities (e.g., stocks, bonds, etc.). These forms of securities typically carry additional expenses based on their share of operating expenses and certain CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 9 of 19  brokerage fees, which may result in the potential duplication of certain fees. We do not recommend leveraged or inverse ETFs due to their inherent heightened risk. Financial Risk Excessive borrowing to finance a business operation increases profitability risk because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligationsmay result in bankruptcy and/or adecliningmarketvalue. Fundamental Analysis The challenge involving fundamental analysis is that information obtained may be incorrect; the analysis may not provide an accurate estimate of earnings, which may be the basis for a security’s value. Index Investing Certain ETFs and indexed funds have the potential to be affected by “active risk” or “tracking error risk;” a deviation from a stated benchmark. Inflation Risk When any type of inflation is present, a dollar today will not buy as much as a dollar next year because purchasing power is eroding at the rate of inflation. Market Risk When the stock market as a whole or an industry as a whole fall, it can cause the prices of individual stocks to fall indiscriminately. This is also called systemic or systematic risk. Passive Investing A portfolio that employs a passive, efficient markets approach has the potential risk at times to generate lower- than-expected returns for the broader allocation than might be the case for a more narrowly focused asset class, and the return on each type of asset may be a deviation from the average return for the asset class. Geopolitical Risk Geopolitical and other events (e.g., war or terrorism) may disrupt securities markets and adversely affect global economies and markets, thereby decreasing the value of an account’s investments. Sudden or significant changes in the supply or prices of commodities or other economic inputs such as oil may have material and unexpected effects on both global securities markets and individual countries, regions, sectors, companies, or industries, which could significantly reduce the value of an account’s investments. War, terrorism and related geopolitical events have led, and in the future may lead, to increased short-term market volatility and may have adverse long-term effects on U.S. and world economies and markets generally. QDI Ratios While many ETFs and index mutual funds are known for their potential tax-efficiency and higher “qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be part of an ETF or mutual fund portfolio), may be considered “non-qualified” under certain tax code provisions. A holding’s QDI will be considered when tax-efficiency is an important aspect of the client’s CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 10 of 19  portfolio. Research Data When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. While our firm makes every effort to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the advice on or investment management of an account. Technical Analysis The risk of investing based on technical analyses is that it may not consistently predict a future price movement; the current price of a security may reflect all known information. This may occur due to analyst bias or misinterpretation, a sector analysis error, late recognition of a trend, etc. Force Majeure Risk: This is the risk that there may be an act of God, terrorist act, global health pandemic, failure of utilities or other similar circumstance not within the reasonable control of SCM that may have an unknown and potentially catastrophic effect on the global markets. SCM has a business continuity plan to mitigate the effects of a force majeure risk, however, these events may still affect SCM, our clients, and the financial markets. ESG Risks Stewardship uses Morningstar’s ESG screening tool. There is a risk that the investments listed as meeting our ESG criteria as a result of our screening, were incorrectly entered in the Morningstar screening tool and thus do not meet our ESG criteria. ESG (Environmental, Social, and Governance) investing seeks to align client’s investment interests with a sustainable set of standards to screen potential investments. Environmental criteria consider how a company performs as a steward of nature. Social criteria examine how companies manage relationships with employees, suppliers, customers, and the communities where it operates. Governance deals with a company’s leadership, executive pay, audits, internal controls, and shareholder rights. One of the largest issues with ESG investing is getting reliable and accurate information to evaluate ESG criteria for companies. Also, while companies that meet ESG criteria are generally believed to be more ethical and have high environmental standards, the trade-off is that these companies may have lower profits anticipated in the short term with the potential for better profits over the life of the company due to the ethical choices, however, there is a risk that even companies believed to have met ESG criteria could be subject to events that would reduce their income and reputation and open the company up to lawsuits and regulatory inquiries. Not all companies considered ESG companies meet ESG criteria in all areas. In addition, there is a risk that a company is accidentally included with ESG companies in ETF and mutual fund investments, but they do not actually meet the ESG criteria. In addition, with the increase in popularity of ESG investing in the past few years, there is also the potential that ETFs or mutual funds that focus on ESG investing may trade at a premium. Epidemics, Pandemics, Outbreaks of Disease and Public Health Issues. Our business activities could be materially adversely affected by pandemics, epidemics and outbreaks of disease in Asia, Europe, North America and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu, Severe Acute Respiratory Syndrome (SARS), and/or other epidemics, pandemics, CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 11 of 19  outbreaks of disease, viruses and/or public health issues. Specifically, COVID-19 has spread (and is currently spreading) rapidly around the world since its initial emergence in China in December 2019 and has severely negatively affected (and may continue to materially adversely affect) the global economy and equity markets (including, in particular, equity markets in Asia, Europe and the United States). Although the long- term effects or consequences of COVID-19 and/or other epidemics, pandemics and outbreaks of disease cannot currently be predicted, previous occurrences of other pandemics, epidemics and other outbreaks of disease, such as H5N1 flu, H1N1 flu, SARS and the Spanish flu, had a material adverse effect on the economies and markets of those countries and regions in which they were most prevalent. Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic, communicable disease or virus or major public health issue could cause a slowdown in the levels of economic activity generally (or cause the global economy to enter into a recession or depression), which would adversely affect the business, financial condition and operations of the Adviser. Should these or other major public health issues, including pandemics, arise or spread farther (or continue to spread or materially impact the day to day lives of persons around the globe), the Adviser could be adversely affected by more stringent travel restrictions, additional limitations on the Adviser’s operations or business and/or governmental actions limiting the movement of people between regions and other activities or operations (or to otherwise stop the spread or continued spread of any disease or outbreak). Item 9 - Disciplinary Information Neither the firm nor its management has been involved in a material criminal or civil action in a domestic, foreign or military jurisdiction, an administrative enforcement action, or self-regulatory organization proceeding that would reflect poorly upon our offering advisory business or its integrity. Item 10 - Other Financial Industry Activities and Affiliations Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of interest between the firm and its clients, or that may be contrary to law. Our firm will provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts of interest involving its business relationships that might reasonably compromise its impartiality or independence. Stewardship Advisors, LLC and its management are not registered nor have an application pending to register as a Financial Industry Regulatory Authority (FINRA) or National Futures Association (NFA) member firm, nor is the firm required to be registered with the noted regulatory bodies. Further information with regard to all of these activities may be found in each associates’ Form ADV Part 2B brochure supplement. Whether they are serving a client in one or more capacities, each associate will disclose in advance how they are being compensated and if there is a conflict of interest involving any advice or service they may provide. At no time will there be tying between business practices and/or services; a condition where a client or prospective client would be required to accept one product or service which is conditional upon the selection of a second, distinctive tied product or service. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has a fiduciary duty to our clients, which means the firm and its associates will act with utmost good faith, performing in a manner believed to be in the best interests of its clients. Code of Ethics CRD # 277099 SEC # 801-108174 We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical and professionally responsible manner in all professional services and activities. Firm policies include prohibitions against insider trading, circulation of industry rumors, and certain political contributions, among Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 12 of 19  others. We periodically review and amend our Code of Ethics to ensure that they remain current, and we require firm personnel to annually attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the firm’s Code of Ethics is made available to any client or prospective client upon request using the contact information on the Cover Page of this brochure. Firm associates that are CERTIFIED FINANCIAL PLANNERTM Practitioners also adhere to the Certified Financial Planner Board of Standards, Inc.’s Code of Ethics & Professional Responsibility which you may find at www.cfp.net. Firm Recommendations and Conflicts of Interest We do not trade for our own account (e.g., proprietary trading). The firm’s related persons may buy or sell securities that are the same as, similar to, or different from, those recommended to clients for their accounts, and this poses a conflict of interest. We mitigate this conflict by ensuring that we have policies and procedures in place to ensure that the firm or a related person will not receive preferential treatment over a client. Employees wishing to trade in the same securities as clients must receive pre-approval from our CCO, or designee, or engage in a trade aggregated with client trades. Employees and related persons of the firm will report, and the firm will periodically review, personal securities accounts and holdings for any potential trade indicating that the employee is trading ahead of clients or engaging in insider trading. Upon discovering a violation of policy, the firm may impose any sanctions as deemed appropriate, including disgorgement of profits, trade reversals, and up to and including termination. . Item 12 - Brokerage Practices Factors Used to Select Broker/Dealers for Client Transactions Plan accounts must be separately maintained by a qualified custodian (typically a broker/dealer, trust company or national bank). We do not receive referrals from a custodian, nor are client referrals a factor in our recommendation of a custodian. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 13 of 19  Accounts served by a third-party investment manager are to be maintained at one or more custodians that have been selected by the respective third-party investment manager and they will be disclosed in the third- party investment manager’s disclosure documents and account opening forms. We typically recommend that SIMPLE Plans (Savings Incentive Match Plan for Employees) be served by Aspire Financial Services, LLC. Aspire Financial Services, LLC maintains a business relationship and suggests the use of MG Trust Company, LLC (a Colorado trust company) and the trust company’s affiliate Matrix Settlement and Clearance Services, LLC (a mutual fund transfer agent that may serve as a custodian) to assist qualified plans in the custody and management of retirement plan assets. When we are engaged to provide our own portfolio management services, we prefer to engage Charles Schwab, a division of Charles Schwab & Co., Inc. (“Schwab”), Member FINRA/SIPC, Trade-PMR, Inc. (“Trade-PMR”), MTG, LLC doing business as Betterment Securities. Members FINRA/SIPC, and SEI. While we recommend a custodian of record, the plan sponsor will decide whether to do so and will directly enter into an agreement with the custodian. If the plan sponsor does not wish to place their assets with a recommended custodian, we may be able to serve as portfolio manager with another custodian of the plan’s choice if the other custodian’s policies allow us to do so. Our custodians offer independent investment advisors various services which include custody of assets, trade execution, clearance and settlement, etc. Our firm receives benefits from the recommended custodians through participation in their independent advisor support programs (please refer to Item 14 for further details). Our firm conducts periodic assessments of any recommended service provider (including Schwab), which generally involves a review of the range and quality of services, reasonableness of fees, among other items, in comparison to industry peers. Best Execution “Best execution” means the most favorable terms for a transaction based on all relevant factors, including those listed in the earlier paragraph titled Factors Used to Select Broker/Dealers for Client Transactions and in Item 14. We recognize our obligation in seeking best execution for our clients; however, it is our belief that the determinative factor is not always the lowest possible cost but whether the selected custodian’s transactions represent the best “qualitative execution” while taking into consideration the full range of services provided. Our firm will seek services involving competitive rates, but it may not necessarily correlate into the lowest possible rate for each transaction. We have determined having our portfolio management clients’ accounts trades completed through our recommended custodian is consistent with our obligation to seek best execution of client trades. A review is regularly conducted with regard to recommending a custodian to our clients in light of our duty to seek best execution. Stewardship Advisors, LLC may, in its discretion, accept the client’s transfer of preexisting retail mutual funds into their account. A transfer-in-kind of retail share class mutual funds may potentially benefit the client since they are able to invest in their portfolio more quickly, mitigate tax and/or short-term trading liabilities, and/or avoid contingent deferred sales charges (CDSC). Our firm regularly reviews accounts that have transferred different share classes of mutual funds and will convert share classes to a lower expense share class when we believe doing so would be beneficial to the client. In addition, if account assets remain in a retail share class and within a CDSC period, we may exclude those assets from our advisory fee until they have been converted to what we believe is a more appropriate share class. Directed Brokerage CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 14 of 19  Our internal policy and operational relationship with our custodian requires client accounts custodied with them to have trades executed per their order routing requirements. We do not direct which executing broker should be selected for client account trades; whether that is an affiliate of our preferred custodian or another executing broker of our custodian’s choice. As a result, a client may pay higher commissions or other transaction costs, experience greater spreads, or receive less favorable net prices on transactions than might otherwise be the case. In addition, since we routinely recommend a custodian to our clients, and that custodian may choose to use the execution services of its broker affiliate for some or all of our account transactions, there is an inherent conflict of interest involving our recommendation since our advisory firm receives various products or services described in Item 14 from that custodian. Accounts maintained at our custodian are unable to direct brokerage. As a result, the account holder may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case if they had the opportunity to direct brokerage. For accounts maintained at a custodian of our client’s choice (e.g., held-away accounts), that client may choose to request that a particular broker is used to execute some or all account transactions. Under these circumstances, the client will be responsible for negotiating, in advance of each trade, the terms and/or arrangements involving their account with that broker, and whether the selected broker is affiliated with their custodian of record or not. We will not be obligated to seek better execution services or prices from these other brokers, and we will be unable to aggregate transactions for execution via our custodian with other orders for accounts managed by our firm. As a result, the client may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case. Aggregating Securities Transactions Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately the same time. This may also be termed “blocked” or “batched” orders. Aggregated orders are effected in an attempt to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple accounts should there be differences in prices, brokerage commissions or other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm may, but is not obligated, to aggregate orders. Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that the firm determines to aggregate orders for the purchase or sale of securities, including securities in which a related person may invest, the firm will generally do so in accordance with the parameters set forth in SEC No- Action Letter SMC Capital, Inc. Please note that when trade aggregation is not allowed or infeasible and necessitates individual transactions (e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 15 of 19  Item 13 - Review of Accounts Scheduled Reviews Plan sponsors should contact our firm for additional reviews when making decisions about changes to their plan. Periodic reviews are recommended on an annual basis whenever practical. Reviews will be conducted by the plan’s assigned investment advisor representative. These reviews normally involve an analysis and possible plan revision recommendations, and a copy of the review, revised plans or reports in printed or digital format will be provided. Unless provided for in the engagement agreement with our firm, reviews are generally conducted under a new or amended agreement. For accounts served by a recommended third-party investment manager, the plan’s assigned investment advisor representative will periodically review reports provided to the plan sponsor by your third-party investment manager. Our firm will contact the plan sponsor at least annually to review its financial situation and objectives. We will communicate information to the third-party investment manager as warranted and will assist the plan sponsor in understanding and evaluating the services provided by the third-party investment manager. Portfolios managed by our firm are reviewed on a semi-annual or more frequent basis by the plan’s assigned investment advisor representative. Plan-level reviews are also completed by the plan’s assigned investment advisor representative, and it is recommended these occur on at least an annual basis. A copy of a revised IPS or asset allocation reports in printed or digital format will be provided to the client upon request. Non-Periodic Reviews Plan sponsors should contact our firm for additional reviews when there are material changes to the plan requirements or the businesses financial situation. The review is conducted by the plan’s assigned investment advisor representative, and typically involves an analysis and possible revision of previous plan recommendations. A copy of revised plans or asset allocation reports will be provided in printed or digital format. Unless provided for in the engagement agreement, the interim review may be conducted under a new or amended agreement. Additional reviews by the plan’s external portfolio manager and the plan’s assigned investment advisor representative may be triggered by news or research related to a specific holding, a change in our view of the investment merits of a holding, or news related to the macroeconomic climate affecting a sector or holding within that sector. A portfolio may be reviewed for an additional holding or when an increase in a current position is under consideration. Account cash levels above or below what we deem appropriate for the investment environment pursuant to the IPS may also trigger a review. Client Reports and Frequency Each plan participant will receive account statements sent directly from the custodian on at least a quarterly basis. We urge each participant to carefully review account statements for accuracy, and to ask questions when something is not clear. Our firm uses a third-party to produce written performance reports which are calculated using a time- weighted methodology that are reviewed for accuracy by compliance personnel prior to delivery. The reports are provided in printed and digital format and are intended to inform clients about their investment performance over the current period, as well as over the longer term since the account’s inception; both on an absolute basis and as compared to a known benchmark. Third-party CRD # 277099 SEC # 801-108174 Stewardship Advisors, LLC Form ADV Part 2 - 2022Ret Plans Page 16 of 19  investment management clients may receive portfolio performance reports directly from their third-party manager; we do not back-test nor certify reports from an external party. Plan sponsors and/or participants are urged to carefully review and compare account statements that they have received directly from the custodian of record with any report they may receive from our firm or any other source that contains account performance information. Item 14 - Client Referrals and Other Compensation Economic Benefit from External Sources Per Items 4 and 5 of this brochure, for our initial and continuing consultation we receive a portion of the asset- based fee that is paid by a client to a third-party investment manager. Please refer to Item 10 for additional information with respect to our offerings and the potential conflict of interest this may present. As disclosed in Item 12, Stewardship Advisors, LLC receives economic benefit from its custodians in the form of various products and services they make available to the firm and other independent investment advisors that may not be made available to a “retail investor.” There is no direct link between our firm’s participation in their program and the investment advice we may provide to our clients. These benefits may include the following products and services (provided either without cost or at a discount): receipt of duplicate client statements and confirmations research related products and tools access to trading desks serving our clients access to block trading services the ability to have advisory fees deducted directly from a client’s accounts (per written agreement) resource information related to capital markets and various investments access to an electronic communications network for client order entry and account information access to mutual funds with no transaction fees and/or select investment managers discounts on marketing, research, technology, and practice management products or services provided to our firm by third-party providers Some of the noted products and services made available by a custodian may benefit our advisory firm but may not directly benefit a client account, and certain research and other previously referenced services may qualify as "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934. The availability of these services from a custodian benefits our firm because it does not have to produce or purchase them as long as firm clients maintain assets in accounts at a custodian. There is a conflict of interest since our firm has an incentive to select or recommend a custodian based on our firm’s interest in receiving these benefits rather than your interest in receiving favorable trade execution. It is important to mention that the benefit received by our firm through participation in any custodian’s program does not depend on the amount of brokerage transactions directed to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a whole -- not just those services that benefit only our advisory firm. Further, we will act in the best interest of our clients regardless of the custodian we may select. Client Referrals CRD # 277099 SEC # 801- Upon client request, we provide referrals to various professionals, such as an accountant or an attorney. If we receive or offer an introduction to a client involving these other professionals, we do not pay or earn referral Stewardship Advisors, LLC Form ADV Part 2 - Ret  fees, nor are there established quid pro quo arrangements. Each client retains the right to accept or deny such referral or their subsequent services. Stewardship employees do receive compensation for referring clients the Firm. This compensation is in addition to their salaries. In addition, Stewardship may pay referral fees for client referrals. Any compensation paid, either to Stewardship employees or to a third party, does not increase Stewardship fees charged to clients. Item 15 - Custody Plan assets are maintained by an unaffiliated, qualified custodian. In keeping with this policy involving our client funds or securities, Stewardship Advisors, LLC: Restricts the firm or an associate from serving as trustee or having general power of attorney over a client account; Prohibits any associate from having authority to directly withdraw securities or cash assets from a client account; Does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm; Will not collect advance fees of $1,200 or more for services that are to be performed six months or more into the future; and Will not authorize an associate to have knowledge of a client’s account access information (i.e., online 401(k),brokerage or bank accounts) if such access would allow physical control over account assets. The plan’s custodian of record and/or third-party administrator will provide investment account transaction confirmations and account statements, which will include debits and credits for that period. Statements are provided on at least a quarterly basis and confirmations are provided as transactions occur within an account. Our advisory firm will not create an account statement for an account nor serve as the sole recipient of an account statement. Any account holder receiving periodic reports that include investment performance information should carefully review and compare their account statement that they have received directly from the custodian of record with that performance report. Item 16 - Investment Discretion Internal Portfolio Management We serve internal portfolio management accounts on a discretionary or non-discretionary basis. Via limited power of attorney, discretionary authority allows our firm to implement investment decisions, such as the purchase or sale of a security on behalf of an account, without requiring continued prior authorization for each transaction in order to meet stated investment objectives. This authority is provided to our firm through the execution of our engagement agreement and the custodian’s account opening documents. Note that the custodian will specifically limit our firm’s authority within an account to the placement of trade orders and our request for the deduction of our advisory fees. We will account for reasonable restrictions as noted in the plan’s IPS. It remains the plan sponsor’s responsibility to notify our firm if there is a change in their investment objective so that we may reevaluate previous investment recommendations or portfolio holdings. CRD # 277099 SEC # 801- Stewardship Advisors, LLC Form ADV Part 2 - Ret  Self-Directed Retirement Plans We do not execute trades for plan participants or maintain trading authority within a plan participant self- directed account. Item 17 - Voting Client Securities Our firm does not vote proxies on your behalf, including accounts that we have discretionary authority. We do not offer guidance on how to vote proxies, nor will we offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. We will answer limited questions with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer or their legal representative. Item 18 - Financial Information The firm and its management do not have a financial condition likely to impair its ability to meet commitments to clients, nor has the firm and its management been the subject of a bankruptcy petition. CRD # 277099 SEC # 801- Stewardship Advisors, LLC Form ADV Part 2 - Ret 

Item 1 - Cover Page Stewardship Advisors, LLC 321 W. Main Street Mount Joy, PA 17552 Tel: (717) 492-4787 Fax: (717) 283-4049 www.mystewardshipadvisor.com Form ADV Part 2A – Appendix 1 Wrap Fee Program Brochure March 16, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Stewardship Advisors, LLC. Please contact our Chief Compliance Officer, Mr. Mark Brinser, at (717) 492-4787 if you have any questions about the content of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or any state securities administrator. Additional information about Stewardship Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Click on the “Investment Adviser Search” link and then search for “Investment Adviser Firm” using the firm’s IARD (“CRD”) number, which is 277099. While the firm and its associates may be registered and/or licensed within a particular jurisdiction, that registration and/or licensing in itself does not imply an endorsement by any regulatory authority, nor does it imply a certain level of skill or training on the part of the firm or its associated personnel. 1  Item 2 - Material Changes Since our previous amendment on March 17, 2025 there has been no material changes to Stewardship Advisors, LLC (“Stewardship” or “Firm”) ADV brochures. As with all firm documents, clients and prospective clients are encouraged to review this brochure in its entirety and as there may be other small changes not included here. 2  Item 3 – Table of Contents Item 1 - Cover Page .................................................................................................................................................. 1 Item 2 - Material Changes ........................................................................................................................................ 2 Item 3 – Table of Contents ....................................................................................................................................... 3 Item 4 - Services, Fees and Compensation ............................................................................................................... 4 Item 5 - Account Requirements and Types of Clients............................................................................................... 9 Item 6 - Selection and Review of Portfolio Managers ............................................................................................ 10 Item 7 - Client Information Provided to Portfolio Managers .................................................................................. 14 Item 8 - Client Contact with Portfolio Managers .................................................................................................... 15 Item 9 - Additional Information ............................................................................................................................. 15 3  Item 4 - Services, Fees and Compensation Description of the Firm Stewardship Advisors, LLC is a Pennsylvania domiciled limited liability company formed in November of 2011. In October 2015, Stewardship registered as a Pennsylvania investment adviser, followed by our SEC registration in July of 2016. Stewardship Advisors, LLC and our associates may notice- file (register) and/or become licensed or meet certain exemptions to registration and/or licensing within other jurisdictions where investment advisory business is conducted. The firm’s principal owner is W. Lee Shertzer. As of December 31, 2025, our firm managed approximately $538,071,393 in assets under management on a discretionary basis and $7,109,067 on a non-discretionary basis for total assets managed of approximately $545,180,460. We also provide financial planning and portfolio management services which do not involve wrapped (unbundled) fees, as well as services for retirement plans. Additional information about these other services are described in greater detail in our separate Form ADV Part 2A firm brochures and interested parties should contact our firm for further information. Description of Services Offered Our wrap fee program incorporates financial planning, portfolio management and brokerage transactional services for a single asset-based fee. Advisory fees for participating in alternative investments, such as limited offerings, are in addition to our wrap fee program fee. Our firm serves as program sponsor and provides financial planning and portfolio management for participants. Charles Schwab, a division of Charles Schwab & Co., Inc. (“Schwab”); Member FINRA/SIPC. Schwab offers independent investment advisors various services which may include custody of securities, trade execution, clearance and settlement of transactions, and in which our firm receives benefits from a custodian through our participation in their program offerings which will be described in further detail in later sections of this brochure. During or prior to this meeting you will be provided with our Form ADV Part 2 firm brochure, our privacy policy, and brochure supplements for the representatives who will be assisting you. We will also ensure that any material conflicts of interest have been disclosed to you that could be reasonably expected to impair the rendering of unbiased and objective advice. If you wish to engage Stewardship Advisors, LLC for our services, you must first execute a written engagement agreement with our firm. Thereafter discussion and analysis will be conducted to determine your financial needs, goals, holdings, etc. It is important that you provide us with an adequate level of information and supporting documentation throughout the term of the engagement, including but not limited to: source of funds, income levels, and an account holder or their legal agent’s authority to act on behalf of the account, among other information that may be necessary. This helps us determine the appropriateness of our planning strategies and/or investment recommendations. The information and/or financial statements you provide needs to be accurate. Our Firm is not obligated to verify the information you provide. It is also essential to keep us informed of significant issues that may call for an update to your plan. Events such as changes in employment or marital status, an unplanned windfall, etc., can have an impact on your circumstances and needs. We need to be aware of such events, so that we may make adjustments as necessary in order to keep you on track toward your goals. 4  Financial Planning Component The incorporation of most or all of the following planning components allows for not only a thorough analysis but also a refined focus of your goals and objectives. Your plan may be as broad-based or narrowly focused as you desire. Note that when our planning focuses only on certain areas of your interest or need, your overall situation or needs may not be fully addressed due to limitations you may have established. We will present you with a summary of our recommendations, guide you in the implementation of some or all of them per your decisions, as well as encourage ongoing reviews thereafter. You retain full discretion over all implementation decisions and are free to accept or reject any recommendation we make. Cash Flow Analysis and Debt Management A review of your income and expenses may be conducted to determine your current surplus or deficit. Based upon the results, we might recommend prioritizing how any surplus should be used, or how to reduce expenses if they exceed your income. In addition, advice on the prioritization of which debts to repay may be provided, based upon such factors as the debt’s interest rate and any income tax ramifications. Recommendations may also be made regarding the appropriate level of cash reserves for emergencies and other financial goals. These recommendations are based upon a review of cash accounts (such as money market funds) for such reserves and may include strategies to save desired reserve amounts. Risk Management A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”). Employee Benefits A review is conducted, and analysis is made as to whether you, as an employee, are taking maximum advantage of your employee benefits. We will also offer guidance on your employer-sponsored retirement plan and/or stock options, along with other benefits that may be available to you. Personal Retirement Planning Retirement planning strategies typically include projections of your likelihood of achieving your financial goals, with financial independence usually the primary objective. For situations where projections show less than the desired results, a recommendation may include showing you the impact on those projections by making changes in certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. College Funding Advice involving college funding may include projecting the amount that will be needed to achieve post- secondary education funding goals, along with savings strategies and the “pros-and-cons” of various college savings vehicles that are available. We are also available to review your financial picture as it relates to eligibility for financial aid or the best way to contribute to family members, such as grandchildren, if appropriate. Tax Strategies 5  Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, recommendations may be offered as to which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. Upon your request, we will assist you in preparing tax forms or data collection for your accountant’s review. Estate Planning Our review typically includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts and other related documents. We may assess ways to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We generally recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your prior approval. Divorce Planning Separation or divorce can have a major impact on your goals and plans. We will work with you to help you gain an understanding of your unique situation and provide you with a realistic financial picture so that you are in a better situation to communicate with your legal counsel, mediator or soon to be ex-spouse. We can assist in the completion of cash flow and net worth projections, budget analysis, as well as help you to understand what the consequences and/or benefits are involving a settlement. Investment Consultation Our investment consultation component often involves providing information on the types of investment vehicles available, employee retirement plans and/or stock options, investment analysis and strategies, asset selection and portfolio design. The strategies and types of investments that may be recommended are further discussed in Item 8 of this brochure. Business Consultation We are available to assist small businesses in a variety of ways to include business strategy, debt management, general financial advice, risk management, as well as assisting you with matters involving coordination with your financial institution, retirement plan advisor, and attorney or accounting firm. Broad-Based v. Modular Planning A broad-based plan is an endeavor that requires detail. Certain variables can affect the development of the plan, such as the quality of your own records, complexity and number of current investments, diversity of insurance products and employee benefits you currently hold, size of the potential estate, and special needs of the client or their dependents, among others. At your request, we may concentrate on reviewing only a specific area (modular or component planning), such as investment allocation at your employer’s retirement plan, funding an education, an estate planning issue, or simply evaluating the sufficiency of your current retirement plan. Note that when these services focus only on certain areas that of your interest or need, your overall situation or needs may not be fully addressed due to limitations you may have established. Whether we have created a broad-based or modular plan, we will present you with a summary of our recommendations, guide you in the implementation of some or all of them per your decision, as well as offer you periodic reviews thereafter. In all instances involving our financial planning engagements, our clients retain full discretion over all implementation decisions and are free to accept or reject any recommendation that we make. Portfolio Management Component 6  The investment strategies and types of investments that may be recommended for your account are found in Item 6 of this brochure. Our wrap fee program services are typically provided on a discretionary basis (defined in Item 7), and the process normally includes: • Determination of risk tolerance • Investment strategy • Investment guideline development • Asset allocation • Asset selection • Regular monitoring • Periodic rebalancing We will prepare written guidelines that reflect your investment objectives, time horizon, tolerance for risk, as well as any reasonable constraints you may have for your account. Please note that any restriction you may place on the management of your account may have an effect on the strategy, investment vehicle selection and, potentially, investment results within your portfolio. These guidelines will be designed to be specific enough to provide future guidance while concurrently allowing flexibility to respond to changing market conditions. You will be responsible for reviewing and providing final approval of the plan. Further, it remains your responsibility to promptly notify us if there is any change in your financial situation or investment objectives for the purpose of our reviewing, evaluating or revising previous recommendations. Wrap Fees Assessed Your account will be assessed an annualized asset-based fee that will be determine by the reporting period ending value of your account (e.g., the last market day of the quarter). Our fee is based on a straight tier; all accounts are charged a single percentage rate that declines as asset levels increase. For the benefit of discounting your asset-based fee, we will attempt to aggregate accounts for the same individual or two or more accounts within the same family, or accounts where a family member has power of attorney over another family member’s account. We require a minimum account size of $250,000 for our wrap fee investment program. These fees will be billed quarterly, in advance, per the following table. Our fees are negotiable, with the final determination to be made by the firm. Assets Under Management $250,000-$499,999 $500,000-$999,999 $1,000,000-1,499,999 $1,500,000-1,999,999 $2,000,000-$2,999,999 $3,000,000-4,999,999 $5,000,000-$7,499,999 $7,500,000-$9,999,999 $10,000,000-Above Annualized Asset-Based Fee 1.25% (125 basis points) 1.00% (100 basis points) 0.90% (90 basis points) 0.80% (80 basis points) 0.70% (70 basis points) 0.60% (60 basis points) 0.50% (50 basis points) 0.45% (45 basis points) Negotiable Accounts will be assessed in accordance with asset values disclosed on the statement the client will receive from the custodian of record for the purpose of verifying the computation of the advisory fee. In the rare 7  absence of a reportable market value, our firm may seek a third-party opinion from a recognized industry source (e.g., unaffiliated public accounting firm), and the client may choose to separately seek such an opinion at their own expense as to the valuation of “hard-to-price” securities if necessary. Advisory fees for partial quarters as well as mid-cycle additions or withdrawals of $50,000 or more will be prorated based on the remaining days in the reporting period in which our firm services the account. Fee payments will generally be assessed within the first 10 calendar days of each billing cycle. By signing our firm’s engagement agreement, as well as the selected custodian account opening documents, you will be authorizing the withdrawal of our advisory fees from your account. The withdrawal will be accomplished by the custodian of record at the request of our firm, and the custodian will remit our fee directly to our firm. All fees deducted will be noted on account statements that you will receive directly from the custodian of record on at least a quarterly basis. Alternatively, you may request to directly pay our advisory firm its portfolio management fee in lieu of having the advisory fee withdrawn from your investment account. Our valuation assessment will remain the same as described above, and the client’s direct payment must be received by our firm within 10 calendar days of our invoice. Fees may be paid by check or draft from US-based financial institutions. With your prior authorization payment may also be made through a qualified, unaffiliated PCI compliant third-party processor or via the investment account. Our firm does not accept cash, money orders or similar forms of payment for its engagements. Please refer to Items 5, 6 and 9 of this brochure for additional information about our fees in relationship to our brokerage and operational practices, and their inherent conflicts of interest. Private Investment Fees For clients Stewardship places in private investments, the client will be billed at the fee schedule agreed to in their portfolio management or wrap fee addendum while giving them the benefit of any fee reductions thresholds crossed by aggregating all investment accounts including any alternative investments. We reserve the right to bill at a lower fee schedule for certain alternative investments. Advisory fees and reported values will be determined by the reporting account value as of the last market day of each quarter. In the absence of a reportable market value (which is frequently the case with alternative or private investments) at our discretion, our firm may rely on the reported value of the underlying portfolio company or private fund, seek a third-party opinion from a recognized source (unaffiliated accounting firm), or utilize the original deposit amount provided by the investment continues to be an ongoing concern. Termination of Services Either party may terminate the agreement at any time, in writing. Our firm will not be responsible for investment allocation, advice or transactional services (except for limited closing transactions) upon receipt of a termination notice. It will also be necessary that we inform the custodian of record that the relationship between our firm and the client has been terminated. Our firm will return any prepaid, unearned fees within 30 days of the Firm’s receipt of termination notice. We will coordinate remuneration of prepaid fees to an investment account via the custodian of record. Services Purchased Separately The total costs associated with the wrap fee investment program account may be more or less than purchasing brokerage and advisory services separately. The factors that bear upon the relative costs include the number of and timing of transactions, portfolio management, custody fees, regulatory compliance and administrative charges, research costs, and promotional materials. These and other factors may affect the 8  cost of obtaining these services separately. Additional Client Fees There are no sales loads, brokerage fees, mark-ups, mark-downs, spreads paid to market makers, or brokerage termination fees associated with our wrap fee program. Accounts may be subject to individual retirement account or qualified retirement plan fees and their respective account termination fees, as well as wire transfer fees, and those will be borne by the account holder per the custodian of record’s separate fee schedule. We will ensure you receive a copy of our recommended custodian’s fee schedule at the beginning of the engagement, and you will be notified of any future changes to these fees by the custodian of record and/or third-party administrator for certain tax-qualified plans. Fees paid to our firm by our clients for our advisory services are separate from any internal fees involving mutual funds as outlined in their prospectus, including, but not limited to expense ratios, etc., exchange-traded funds (ETFs), exchange-traded notes (ETNs), or other similar investments. Portfolio Management Services Fees - Third-Party Investment Managers Each third-party investment manager program has a stated fee range that will be described to you through the use of that investment manager’s disclosure documents and prior to your selection of the manager. We will inform you in advance as to whether the selected third-party investment manager(s) will allow for account aggregation for the purpose of fee discounts. The annualized asset-based fee ranges from 0.50% to 2.00% (50 to 200 basis points) and our firm will receive a portion ranging from 0.25% to 1.50% (25 to 150 basis points) for our consultation service, which we will describe to you in your engagement agreement with our firm. Payment may be made on a monthly or quarterly basis, either in advance or arrears, depending on the selected investment manager. General Information Account Custody Your assets will be maintained by an unaffiliated, qualified custodian. They are not held by our firm or any associate or our firm. In keeping with this policy involving our client funds or securities, Stewardship Advisors, LLC: • Restricts the firm or an associate from serving as trustee or having general power of attorney over a client account; • Prohibits any associate from having authority to directly withdraw securities or cash assets from a client account; • Does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm; • Will not collect advance fees of $1,200 or more for services that are to be performed six months or more into the future; and • Will not authorize an associate to have knowledge of a client’s account access information (i.e., online 401(k), brokerage or bank accounts) if such access would allow physical control over account assets. Your account custodian will provide you with your investment account transaction confirmations and account statements, which will include all debits and credits for that period. Statements are provided on at least a quarterly basis, and confirmations are provided as transactions occur within your account, unless otherwise agree upon. Our advisory firm will not create an account statement for a client nor serve as the sole recipient of 9  a client account statement. Clients are urged to carefully review and compare their account statements that they have received directly from their custodian of record with any performance report they may receive from any source. Item 5 - Account Requirements and Types of Clients Account Requirements Minimum Account Requirements While the wrap fee program is no longer accepting clients, when it was available, the program required a minimum of $250,000 in investable assets. Account Opening Process The wrap fee program is no longer accepting participants. Participation in the program was initiated by submitting the following completed documents to the firm, typically through an investment advisor representative of our firm: • Wrap Fee Investment Program Agreement • Custodian Account Application • Investment Questionnaire, if required investment advisor representative made the Based on these completed documents, the initial determination as to the client’s suitability for the wrap fee investment program. The firm also performed an assessment of whether to establish an account for a particular client that includes ensuring the appropriate documentation, risk tolerance and asset allocation are made. The account custodian executes and clears all purchase and sale orders directed, maintains wrap fee investment program account assets, and provides other functions such as crediting of interest and dividends on accounts, crediting of principal on called or matured securities, as well as other customary custodial functions. They serve as general administrator of accounts, which includes charging and collecting advisory fees and processing, deposits to and withdrawals from program accounts, etc. The account custodian will forward a confirmation of each purchase and sale directly to the client as well as our firm. Additionally, they will forward account statement to clients for each period in which account activity occurs, and at least quarterly regardless of account activity. Types of Clients Served by the Firm We are available to serve individuals and high net worth individuals, as well as charitable organizations, businesses of all size, and their retirement plans. We encourage interested individuals of all economic levels and investment experience to seek our advisory services; we do not require minimum income, minimum asset levels or other similar preconditions for our general advisory services. Types of Clients Served within the Wrap Fee Program We typically serve individual and high net worth individuals via our wrap fee program; however, we included some small businesses if their investment guidelines permitted us to do so. We reserve the right to waive or reduce certain fees based on unique circumstances, special arrangements or pre-existing relationships, and he may also decline services to a prospective client for any nondiscriminatory reason. 10  Item 6 - Selection and Review of Portfolio Managers Selection and Review of Portfolio Managers We will ensure due diligence is completed on any portfolio manager to include determining whether that manager is registered/notice-filed (or required to be) within the jurisdiction the client resides. At least annually thereafter our review will be performed from both a compliance and performance perspective to determine that the selected portfolio manager remains an appropriate fit. We also review each portfolio manager’s performance over an extended period, as well as at least quarterly to discuss any potential concerns or recommended changes to the program’s managers. The firm will also be responsible for determining if a portfolio investment manager should be replaced due to poor performance, regulatory or compliance matters, etc. The benchmarks for account performance are based on each client’s responses to firm suitability information and their stated investment guidelines. Using these responses, we are able to employ the appropriate investment strategy as well as develop a diversified portfolio using this strategy. Our firm maintains current client profiles and will recommend adjustments to portfolios when the firm believes it to be necessary. Our Firm uses a third party to produce written performance reports which are calculated using a time- weighted methodology that are reviewed for accuracy by compliance personnel prior to delivery. The reports are intended to inform clients about their investment performance over the current period, as well as over the longer term since the account’s inception; both on an absolute basis and as compared to a known benchmark. Clients are urged to carefully review and compare account statements that they have received directly from their custodian of record with any report they may receive from our firm or any other source that contains investment performance information. Related Persons Serving as Portfolio Manager The wrap fee program portfolio manager is an associate of Stewardship Advisors, LLC. An inherent conflict of interest exists since the associate and firm both benefit from a greater percentage of the advisory fee by not outsourcing the investment management aspect of the wrap fee program to another portfolio manager. In light of this matter, the Firm will ensure it utilizes the same due diligence and selection and/or termination criteria for its own portfolio manager that it would have an external source been engaged, in addition to further scrutiny to ensure appropriate portfolio selection, fees and other compensation are within the account investment policy statement, firm procedures and regulatory guidelines. Performance-Based Fees and Side-By-Side Management Stewardship does not charge performance fees or engage in side-by-side management. Methods of Analysis, Investment Strategies and Risk of Loss Method of Analysis We employ a blend of fundamental and technical analyses. For example, fundamental analysis involves evaluating economic factors including interest rates, the current state of the economy, or the future growth of an industry sector. Technical analysis may involve studying the historical patterns and trends of securities and their markets in an effort to determine potential future behaviors, the estimation of price movement, and an evaluation of a transaction before entry into the market in terms of risk and profit potential. Firm research may be drawn from sources that include financial periodicals and research published by economists and other industry professionals. 11  Investment Strategy Strategic Asset Allocation We utilize a strategic asset allocation approach to investing, with a long-term view of the markets. We recommend investment models to suit various risk tolerances. We typically recommend portfolios that contain ETFs and mutual funds. Environmental, Social and Governance Allocation (“ESG”) We also provide a values-based portfolio for clients that can deliver positive social or environmental impact alongside financial returns. Our ESG portfolio focuses on environmental issues such as climate change, pollution, and energy efficiency. The portfolio also screens out investments that generate revenue from the sale of alcohol, tobacco, gambling, and controversial weapons (“social issues”). Risk of Loss Our firm believes our strategies and investment recommendations are designed to produce the appropriate potential return for the given level of risk; however, there is no guarantee that an investment objective or planning goal will be achieved. Investing in securities involves risk of loss that clients should be prepared to bear. We have offered examples of such risk in the following paragraphs, and we believe it is important that our clients review and consider each of them prior to investing. Active Management Risks A portfolio that employs active management strategies may, at times, outperform or underperform various benchmarks or other strategies. In an effort to meet or surpass these benchmarks, active portfolio management may require more frequent trading or “turnover.” This may result in shorter holding periods, higher transactional costs and/or taxable events generally borne by the client, thereby potentially reducing or negating certain benefits of active asset management. Company Risk When investing in securities, such as stocks, there is always a certain level of company or industry-specific risk that is inherent in each company or issuer. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic risk and can be reduced or mitigated through diversification. ETF and Mutual Fund Risks The risk of owning ETFs and mutual funds reflect their underlying securities (e.g., stocks, bonds, etc.). These forms of securities typically carry additional expenses based on their share of operating expenses and certain brokerage fees, which may result in the potential duplication of certain fees. Certain ETFs and indexed funds have the potential to be affected by “active risk” or “tracking error risk;” a deviation from a stated benchmark. While many ETFs and index mutual funds are known for their potential tax-efficiency and higher “qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be part of an ETF or mutual fund portfolio), may be considered “non-qualified” under certain tax code provisions. A holding’s QDI will be considered when tax-efficiency is an important aspect of the client’s portfolio. We do not recommend leveraged or inverse ETFs due to their inherent heightened risk. 12  ESG Risks Stewardship uses Morningstar’s ESG screening tool. There is a risk that the investments listed as meeting our ESG criteria as a result of our screening, were incorrectly entered in the Morningstar screening tool and thus do not meet our ESG criteria. ESG (Environmental, Social, and Governance) investing seeks to align client’s investment interests with a sustainable set of standards to screen potential investments. Environmental criteria consider how a company performs as a steward of nature. Social criteria examine how companies manage relationships with employees, suppliers, customers, and the communities where it operates. Governance deals with a company’s leadership, executive pay, audits, internal controls, and shareholder rights. One of the largest issues with ESG investing is getting reliable and accurate information to evaluate ESG criteria for companies. Also, while companies that meet ESG criteria are generally believed to be more ethical and have high environmental standards, the trade-off is that these companies may have lower profits anticipated in the short term with the potential for better profits over the life of the company due to the ethical choices, however, there is a risk that even companies believed to have met ESG criteria could be subject to events that would reduce their income and reputation and open the company up to lawsuits and regulatory inquiries. Not all companies considered ESG companies meet ESG criteria in all areas. In addition, there is a risk that a company is accidentally included with ESG companies in ETF and mutual fund investments, but they do not actually meet the ESG criteria. In addition, with the increase in popularity of ESG investing in the past few years, there is also the potential that ETFs or mutual funds that focus on ESG investing may trade at a premium. Failure to Implement Each client is free to accept or reject any or all of the recommendations made by our firm. While no advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients who choose not to take the steps recommended in their financial plan may face an increased risk that their stated goals and objectives will not be achieved. Financial Risk Excessive borrowing to finance a business operation increases profitability risk because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Fundamental Analysis The challenge involving fundamental analysis is that information obtained may be incorrect; the analysis may not provide an accurate estimate of earnings, which may be the basis for a security’s value. Inflation Risk When any type of inflation is present, a dollar today will not buy as much as a dollar next year because purchasing power is eroding at the rate of inflation. Market Risk When the stock market as a whole or an industry as a whole falls, it can cause the prices of individual stocks to fall indiscriminately. This is also called systemic or systematic risk. Passive Investing A portfolio that employs a passive, efficient markets approach has the potential risk at times to generate lower-than-expected returns for the broader allocation than might be the case for a more narrowly focused 13  asset class, and the return on each type of asset may be a deviation from the average return for the asset class. Long-Term Investment Investments in alternative investments generally involve a long-term commitment, and there is no assurance of any return on investment prior to or upon liquidation of the investment. Investors should be prepared to hold their securities for the life of the investment. Illiquidity of Limited Investment Ownership Interests. Ownership interests in limited investments are often highly illiquid, may have no public market, or are not transferable except in limited circumstances. Geopolitical Risk Geopolitical and other events (e.g., war or terrorism) may disrupt securities markets and adversely affect global economies and markets, thereby decreasing the value of an account’s investments. Sudden or significant changes in the supply or prices of commodities or other economic inputs such as oil may have material and unexpected effects on both global securities markets and individual countries, regions, sectors, companies, or industries, which could significantly reduce the value of an account’s investments. War, terrorism and related geopolitical events have led, and in the future may lead, to increased short-term market volatility and may have adverse long-term effects on U.S. and world economies and markets generally. Research Data When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. While our firm makes every effort to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the advice on or investment management of an account. Technical Analysis The risk of investing based on technical analyses is that it may not consistently predict a future price movement; the current price of a security may reflect all known information. This may occur due to analyst bias or misinterpretation, a sector analysis error, late recognition of a trend, etc. Voting Client Securities You may periodically receive proxies or other similar solicitations sent directly from your selected custodian or transfer agent. Should we receive a duplicate copy, note that we do not forward these or any correspondence relating to the voting of your securities, class action litigation, or other corporate actions. Our firm does not vote proxies on your behalf, including accounts that we have discretionary authority. We do not offer guidance on how to vote proxies, nor will we offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. We will answer limited questions with respect to what a proxy voting request or other 14  corporate matter may be and how to reach the issuer or their legal representative. You will maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of securities that are beneficially owned by you shall be voted, as well as making all other elections relative to mergers, acquisitions, tender offers or other legal matters or events pertaining to your holdings. You should consider contacting the issuer or your legal counsel involving specific questions you may have with respect to a particular proxy solicitation or corporate action. Epidemics, Pandemics, Outbreaks of Disease and Public Health Issues. Our business activities could be materially adversely affected by pandemics, epidemics and outbreaks of disease in Asia, Europe, North America and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu, severe acute respiratory syndrome (SARS), and/or other epidemics, pandemics, outbreaks of disease, viruses and/or public health issues. Specifically, COVID-19 has spread (and is currently spreading) rapidly around the world since its initial emergence in China in December 2019 and has severely negatively affected (and may continue to materially adversely affect) the global economy and equity markets (including, in particular, equity markets in Asia, Europe and the United States). Although the long- term effects or consequences of COVID-19 and/or other epidemics, pandemics and outbreaks of disease cannot currently be predicted, previous occurrences of other pandemics, epidemics and other outbreaks of disease, such as H5N1 flu, H1N1 flu, SARS and the Spanish flu, had a material adverse effect on the economies and markets of those countries and regions in which they were most prevalent. Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic, communicable disease or virus or major public health issue could cause a slowdown in the levels of economic activity generally (or cause the global economy to enter into a recession or depression), which would adversely affect the business, financial condition and operations of the Adviser. Should these or other major public health issues, including pandemics, arise or spread farther (or continue to spread or materially impact the day to day lives of persons around the globe), the Adviser could be adversely affected by more stringent travel restrictions, additional limitations on the Adviser’s operations or business and/or governmental actions limiting the movement of people between regions and other activities or operations (or to otherwise stop the spread or continued spread of any disease or outbreak). Item 7 - Client Information Provided to Portfolio Managers Information Provided to Portfolio Managers Under our wrap fee program engagement, we will gather information about your financial situation, investment objectives, and any reasonable restrictions you may want to impose on the management of the account. We will then provide this data to your portfolio manager who will invest on behalf of the account in accordance with the strategies set forth within stated investment guidelines. Account Investment Authority Our wrap fee program accounts are managed on a discretionary basis. Via limited power of attorney, discretionary authority allows our firm to implement investment decisions, such as the purchase or sale of a security on behalf of your account, without requiring your prior authorization for each transaction in order to meet your stated investment objectives. This authority will be granted through your execution of both our engagement agreement and the selected custodian’s account opening documents. Note that the custodian of record will specifically limit our firm’s authority within your account to the placement of trade orders and the request for the deduction of our advisory fees. 15  Our firm prefers to not manage client accounts on a nondiscretionary basis, but we may accommodate such requests on a case-by-case basis. Such account authority requires your ongoing prior approval involving the investment and reinvestment of account assets, portfolio rebalancing, or for our firm to give instructions to the custodian maintaining your account (i.e., wire instructions, etc.). You will be required to execute our firm’s client services agreement that describes our limited account authority, as well as the custodian of record’s account opening document that includes their limited power of attorney form or clause. Please note that in light of the requirement for your pre-approval you must make yourself available and keep our firm updated on your contact information so that instructions can be efficiently effected on your behalf. You may amend our account authority by providing our firm revised written instructions. As noted in Item 4, we will allow for reasonable restrictions involving the management of your account. It remains your responsibility to notify us if there is any change in your situation and/or investment objective so that we may reevaluate previous investment recommendations or portfolio holdings. Item 8 - Client Contact with Portfolio Managers Clients are invited to attend general communications sessions offered by their portfolio manager. When desiring to communicate with a portfolio manager, we ask that clients schedule these sessions in advance so that we may effectively assist all parties and follow up as necessary. Item 9 - Additional Information Disciplinary Information Neither the firm nor its management has been involved in a material criminal or civil action in a domestic, foreign or military jurisdiction, an administrative enforcement action, or self-regulatory organization proceeding that would reflect poorly upon our offering advisory business or its integrity. Other Financial Industry Activities and Affiliations Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of interest between the firm and its clients, or that may be contrary to law. Our firm will provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts of interest involving its business relationships that might reasonably compromise its impartiality or independence. Further information with regard to all employee outside business activities may be found in each associates’ Form ADV Part 2B brochure supplement. Whether they are serving a client in one or more capacities, each associate will disclose in advance how they are being compensated and if there is a conflict of interest involving any advice or service they may provide. At no time will we require financial planning clients to use us to implement the plan through our investment management service. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has a fiduciary duty to our clients, which means the firm and its associates will act in the utmost good faith, performing in a manner believed to be in the best interests of its clients. Code of Ethics We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical and professionally responsible manner in all professional services and activities. Our firm policies include 16  prohibitions against insider trading, the circulation of industry rumors, and certain political contributions, among others. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require firm personnel to annually attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the firm’s Code of Ethics is made available to any client or prospective client upon request using the contact information on the Cover Page of this brochure. Firm associates that are CERTIFIED FINANCIAL PLANNERTM Practitioners also adhere to the Certified Financial Planner Board of Standards, Inc.’s Code of Ethics & Professional Responsibility which you may find at www.cfp.net. Firm Recommendations and Conflicts of Interest The firm remains focused on ensuring that recommended securities are based upon the individual needs of the clients, not resultant on fees received for such services. You are under no obligation to act on a recommendation from our firm and, if you elect to do so, you are under no obligation to complete them through our firm or a service provider whom we may recommend. We do not trade for our own account (e.g., proprietary trading). The firm’s related persons may buy or sell securities that are the same as, similar to, or different from, those recommended to clients for their accounts, and this poses a conflict of interest. We mitigate this conflict by ensuring that we have policies and procedures in place to ensure that the firm or a related person will not receive preferential treatment over a client. Employees wishing to trade in the same securities as clients must receive pre-approval from our CCO, or designee, or engage in a trade aggregated with client trades. Employees and related persons of the firm will report, and the firm will periodically review, personal securities accounts and holdings for any potential trade indicating that the employee is trading ahead of clients or engaging in insider trading. Upon discovering a violation of policy, the firm may impose any sanctions as deemed appropriate, including disgorgement of profits, trade reversals, and up to and including termination. Review of Accounts Scheduled Reviews We recommend your accounts be reviewed on a least an annual basis with your assigned investment advisor representative. Data and reviews will also be analyzed by firm supervisory personnel. We are available to periodically review reports provided to you and we will contact you at least annually to review your financial situation and objectives. We will submit information to your portfolio manager as warranted and assist you in understanding and evaluating the services provided to you under out wrap fee program. You will be able to communicate with your portfolio manager on a scheduled basis. Interim Reviews You may contact our firm for additional reviews when there are material changes that occur in your financial situation (i.e., loss of a job, early retirement, receipt of a significant bonus, an inheritance, or other circumstances), or should you prefer to change requirements involving your account. We will then communicate this information to your portfolio manager and you may be able to communicate directly with the portfolio manager when it is necessary. Additional reviews by your investment advisor representative and/or supervisory personnel may be triggered by news or research related to a specific holding, a change in our view of the investment merits of a holding, or news related to the macroeconomic climate affecting a sector or holding within that sector. 17  Account cash levels above or below what we deem appropriate for the investment environment, given the client's stated tolerance for risk and investment objectives, may also trigger a review. Client Referrals and Other Compensation Economic Benefit from External Sources Stewardship Advisors, LLC receives economic benefit from our custodians in the form of various products and services they make available to the firm and other independent investment advisors that may not be made available to a “retail investor.” There is no direct link between our firm’s participation in their program and the investment advice we may provide to our clients. These benefits include the following products and services (provided either without cost or at a discount): receipt of duplicate client statements and confirmations research related products and tools access to trading desks serving our clients access to block trading services the ability to have advisory fees deducted directly from a client’s accounts (per written agreement) resource information related to capital markets and various investments access to an electronic communications network for client order entry and account information access to mutual funds with no transaction fees and/or select investment managers discounts onmarketing, research, technology, and practice management products or services provided to our firm by third-party providers Some of the noted products and services made available by a custodian may benefit our advisory firm but do not directly benefit a client account, and certain research and other previously referenced services may qualify as "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934. The availability of these services from a custodian benefits our firm because we do not have to produce or purchase them as long as Firm clients maintain assets in accounts at a custodian. There is a conflict of interest since our firm has an incentive to select or recommend a custodian based on our firm’s interest in receiving these benefits rather than your interest in receiving favorable trade execution. It is important to mention that the benefit received by our firm through participation in any custodian’s program does not depend on the amount of brokerage transactions directed to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a whole -- not just those services that benefit only our advisory firm. Further, we will act in the best interest of our clients regardless of the custodian we may select. Stewardship Advisors, LLC may, in our discretion, accept the client’s transfer of preexisting retail mutual funds into their account. A transfer-in-kind of retail share class mutual funds may potentially benefit the client since they are able to invest in their portfolio more quickly, mitigate tax and/or short-term trading liabilities, and/or avoid contingent deferred sales charges (CDSC). Our firm regularly reviews accounts that have transferred different share classes of mutual funds and will convert share classes to a lower expense share class when we believe doing so would be beneficial to the client. In addition, if account assets remain in a retail share class and within a CDSC period, we may exclude those assets from our advisory fee until they have been converted to what we believe is a more appropriate share class. While our firm has access to a broad range of securities through our custodian, it is a finite number. In addition, not all investment managers, share classes, etc., are represented at each custodian. Due to these normal and customary limitations, not all portfolio holdings will be readily available, least expensive, best performing, etc. It is an unrealistic expectation for an investor to maintain a premise otherwise. 18  Directed Brokerage Our internal policy and operational relationship with our custodian require client accounts custodied with them to have trades executed per their order routing requirements. We do not direct which executing broker should be selected for client account trades; whether that is an affiliate of our preferred custodian or another executing broker of our custodian’s choice. As a result, you may experience greater spreads or receive less favorable net prices on transactions than might otherwise be the case. Since we routinely recommend a custodian for our advisory clients, and that custodian may choose to use the execution services of its broker affiliate for some or all of our client account transactions, there is an inherent conflict of interest involving our recommendation since our advisory firm receives various products or services described in this section from that custodian. We do not accommodate client-directed brokerage requests via our wrap fee investment program. As a result, a client may receive less favorable execution and greater price spreads. Aggregating Securities Transactions Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately the same time. This may also be termed “blocked, “bunched” or “batched” orders. Aggregated orders are effected in an attempt to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple client accounts should there be differences in prices, brokerage commissions or other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm may, but is not obligated to, aggregate orders. Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that the firm determines to aggregate client orders for the purchase or sale of securities, including securities in which a related person may invest, the firm will generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. Please note that when trade aggregation is not allowed or infeasible and necessitates individual transactions (e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. We review firm trading processes on a periodic basis to ensure they remain within stated policies and regulation. You will be informed, in advance, should trading practices change at any point in the future. Client Referrals Upon your request, you may be provided a referral to various professionals, such as an accountant or an attorney. If we receive or offer an introduction to a client involving these other professionals, we do not pay or earn referral fee, nor are there established quid pro quo arrangements. Each client retains the right to accept or deny such referral or their subsequent services. Stewardship employees do receive compensation for referring clients to the Firm. This compensation is in addition to their salaries. In addition, Stewardship may pay referral fees for client referrals. Any compensation paid, either to Stewardship employees or to a third party, does not increase Stewardship fees charged to clients. Financial Information The Firm and our management do not have a financial condition likely to impair its ability to meet commitments to clients, nor has the Firm or our management been the subject of a bankruptcy petition. 19