JOHN HANCOCK PERSONAL FINANCIAL SERVICES, LLC

John Hancock Personal Financial Services, LLC 200 Berkeley Street Boston, MA 02116 (617) 663-3000 March 28, 2025 This Form ADV Part 2A Brochure provides information about the qualifications and business practices of John Hancock Personal Financial Services, LLC, (“JHPFS”). If you have any questions about the contents of this Brochure, please contact us at 855-969-5737. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about JHPFS also is available on the SEC’s website at www.adviserinfo.sec.gov. JHPFS is a registered investment adviser. Registration of an investment adviser does not imply a certain level of skill or training. CONFIDENTIAL  Item 2 – Material Changes No material changes have been made to this brochure since its last update on March 29, 2024. However, certain non-material updates have been made as follows: Item 4: Assets under management were updated. Item 3 – Table of Contents Item 1– Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ......................................................................................................................... 2 Item 3 – Table of Contents ......................................................................................................................... 2 Item 4 – Advisory Business ....................................................................................................................... 3 Item 5 – Fees and Compensation ............................................................................................................ 5 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................... 6 Item 7 – Types of Clients ............................................................................................................................ 6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................. 6 Item 9 – Disciplinary Information .......................................................................................................... 8 Item 10 – Other Financial Industry Activities and Affiliations .................................................. 9 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................................................................... 10 Item 12 – Brokerage Practices .............................................................................................................. 12 Item 13 – Review of Accounts ............................................................................................................... 12 Item 14 – Client Referrals and Other Compensation .................................................................. 12 Item 15 – Custody ....................................................................................................................................... 13 Item 16 – Investment Discretion ......................................................................................................... 13 Item 17 – Voting Client Securities ....................................................................................................... 13 Item 18 – Financial Information .......................................................................................................... 13 2 CONFIDENTIAL  Item 4 – Advisory Business JHPFS is a Delaware limited liability company founded in 2014. JHPFS’ owner is The Manufacturers Investment Corporation, which is an indirect, wholly owned subsidiary of Manulife Financial Corporation (“MFC”), a diversified international management and holding company with interests in companies that are active in, among other things, financial services and insurance. MFC is a publicly traded company listed on the Toronto Stock Exchange, the New York Stock Exchange, the Stock Exchange of Hong Kong and the Philippine Stock Exchange under the ticker symbol MFC. JHPFS provides discretionary investment management services through a service program (the “John Hancock Personalized Retirement Advice” service or “Retirement Advice Service” or “Service”) as described below. JHPFS and its affiliates also provide discretionary services to other programs that are not described in the brochure. This brochure is limited to the Retirement Advice Service. About The Retirement Advice Service The Retirement Advice Service is a discretionary investment management service offered only to persons residing in the United States who are participants in retirement plans for which John Hancock Retirement Plan Services LLC (“JHRPS”) is the recordkeeper. The Retirement Advice Service invests eligible assets in a fund-specific portfolio. The fund- specific portfolio is developed and maintained based on personalized information provided to the Retirement Advice Service and according to asset allocation and diversification principles. Investment strategies are long term. The Retirement Advice Service is designed for the sole objective of managing a participant’s retirement account for which JHRPS is the recordkeeper and does not provide the participant with a comprehensive financial plan. The Retirement Advice Service does not provide advice with respect to other accounts or financial goals the participant may have. There is no guarantee that the advisory services offered through the Retirement Advice Service will result in the participant’s retirement savings objectives being met. In addition to the management of program assets, the Retirement Advice Service can also provide forecasts and recommendations on the following areas: a) forecasted retirement income estimates based on client’s current situation as well as the proposed strategy; b) recommendations on savings strategies to achieve retirement income goals; c) recommendations on retirement age; and d) guidance on when a client may wish to begin receiving social security benefits. For participants over age 50, the Retirement Advice Service also provides a module which can help guide the participant to evaluate different retirement drawdown strategies. The investment options eligible for inclusion in the fund-specific portfolio for the 3 CONFIDENTIAL  Retirement Advice Service are limited to those chosen for a participant’s plan by the plan sponsor or the plan’s fiduciary. These must be investments that can be purchased and sold without restriction by the participant’s employer or the plan’s fiduciary and that the participant has not restricted from the Retirement Advice Service. Employer stock is not eligible for the Retirement Advice Service. Once a participant enrolls, the Retirement Advice Service will manage eligible assets, including future contributions, in the participant’s retirement plan account on a discretionary basis, and the participant will not be able to make any exchanges of eligible assets among investment options within that account or otherwise direct the management of assets. The Retirement Advice Service will determine the eligible assets to be bought or sold, the amount of eligible assets to be bought or sold, and, if applicable, the broker-dealer to be used and the commissions to be paid. If your plan offers Automatic Increase in combination with Retirement Advice, your contribution rate may be increased annually by a percentage determined by your plan's fiduciary, until you reach a rate determined by your plan's fiduciary or the legal limit, whichever is less. A terminated participant who continues to maintain a balance in the retirement plan and remains enrolled in the Retirement Advice Service after terminating from employment will still be enrolled in the service upon rehire. If a participant in this situation and an investment option other than the Service is the retirement plan’s qualified default investment alternative, upon rehire the participant’s future investment election will be changed to the retirement plan’s qualified default investment alternative until the next scheduled quarterly account rebalance. If, however, the Service is the retirement plan’s qualified default investment alternative, upon rehire the Service‘s investment allocation will continue, and the Service will reallocate the participant’s account based on any new information provided by the employer in the next scheduled quarterly account rebalance JHPFS may terminate a participant from the Retirement Advice Service for any reason including not providing JHPFS with current and active contact information or information JHPFS has requested that is deemed necessary or appropriate to manage the participant’s account. A participant may terminate the Retirement Advice Service for his or her account upon three business days’ notice to JHPFS and payment of all outstanding fees to JHPFS. Retirement Advice provides a participant with discretionary investment management services, as described in this Brochure, electronically through the use of a website. A participant should carefully consider whether his or her participation in Retirement Advice is appropriate for his or her confidence and facility in participating in a web-based investment program. Assets Under Management As of December 31, 2024, JHPFS had approximately $1.9 billion under management on a discretionary basis. 4 CONFIDENTIAL  Item 5 – Fees and Compensation The Retirement Advice Service Unless the plan or plan sponsor pays a participant’s fee, in whole or in part, participants who enroll in the Service will be charged an annual advisory fee based on the following schedule: % Account Balance On the first $50,000 On the next $50,000 On the next $150,000 On amounts over $250,000 .50 .40 .30 .20 For example, a participant with an account balance of $130,000 will be charged .50% on the first $50,000, .40% on the next $50,000, and .30% on the remaining $30,000, totaling an annual fee of $540 (approximately $45 per month) calculated as follows (.0050 x $50,000) + (.0040 x $50,000) + (.0030 x $30,000) = $250 + $200 + $90 = $540. The “Account Balance” used in determining the fee is the average daily balance of “eligible assets,” as defined in the Retirement Advice Investment Advisory Service Agreement, in a participant’s accounts. Eligible assets do not include the participant’s company stock and other investments that have been restricted per the rules of the Plan. pro rata The fee is payable monthly in arrears, will be calculated on the basis of JHPFS’s then current fee schedule, and will be deducted directly from each participant’s plan account on the business day following the fee calculation. Participants may choose to terminate their participation in the Service at any time with no additional charge by providing the required notice, and fees for periods of less than a full month will be calculated on a basis. For certain plans, and with the agreement of both JHPFS and the plan sponsor, the Service will be used as the Qualified Default Investment Alternative (“QDIA”) of the plan. In such cases, and as permitted under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), the contributions of plan participants who are enrolled in the plan and do not make an alternative investment election will be invested in John Hancock Personalized Retirement Advice as the QDIA for the plan. Under the terms of such plans, the plan sponsor will automatically enroll such participants in the Service. The date of enrollment in the Service may be later than the date of enrollment in the plan. If a participant is automatically enrolled in the Service, the advisory fee shall be waived for the first ninety (90) days following such enrollment in the Service and the participant may choose to terminate their participation in the Service at any time within the initial ninety (90) day period with no charge by providing the required notice. After the initial 90-day period, fees will be applicable to an automatically enrolled participant account as provided in this section. 5 CONFIDENTIAL  JHPFS will provide each participant with at least thirty (30) days’ notice of any changes in the above-listed fee schedule. To the extent that Retirement Advice Service fees are paid in whole or in part by the plan or plan sponsor, the plan or plan sponsor may choose to reduce or eliminate these subsidies at any time. JHPFS will seek to notify participants as soon as practicable after it becomes aware of such change. In the event a subsidy is eliminated or reduced, the fees described above will apply. JHPFS may from time to time in its sole discretion make exceptions to the fee schedule set forth above. The Retirement Advice Service will include mutual funds and/or other investment options available under a participant’s plan (“Funds”), some or all of which may be managed by affiliates of JHPFS who receive advisory fees from the Funds. The Retirement Advice annual advisory fee is in addition to fees and expenses charged by the Funds. All investments in the Funds are subject to the terms of each of the applicable prospectuses, including associated fees and operating fund expenses, which a participant ultimately bears. Prospectuses are available on the plan’s website or by calling the plan’s Participant Service Center. Participants enrolling in the Retirement Advice Service will receive or have received a description of the investment alternatives, which contain more complete information, including management fees and operating expenses. Mutual funds may assess redemption fees against a participant’s account if purchases and sales of fund shares are effected within a specified period of time. Applicable plan administrative fees such as loan origination fees will continue to be assessed in accordance with the governing retirement plan account documents. Item 6 – Performance-Based Fees and Side-By-Side Management JHPFS does not receive performance-based fees for advisory services provided to clients. Therefore, JHPFS does not engage in side-by-side management of clients with performance- based fees. Item 7 – Types of Clients Retirement Advice Service As discussed in the “Advisory Business” section above, the Retirement Advice Service is offered only to persons residing in the United States who are participants in retirement plans for which JHRPS is the recordkeeper. The plan’s named fiduciary must authorize JHPFS to offer the Retirement Advice Service to participants in the plan. The plan’s named fiduciary may terminate such authorization at any time. 6 CONFIDENTIAL  For certain plans, and with the agreement of both JHPFS and the plan sponsor, the Retirement Advice Service will be used as the Qualified Default Investment Alternative (“QDIA”) of the plan. In such cases, and as permitted under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), the contributions of plan participants who are enrolled in the plan and do not make an alternative investment election will be invested in John Hancock Personalized Retirement Advice as the QDIA for the plan. The Retirement Advice Service does not require a minimum account balance. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss JHPFS selected Morningstar Investment Management LLC (“Morningstar”) (SEC File No. 801-56896) to act as an independent financial expert for the Retirement Advice Service. The plan sponsor or the plan’s fiduciary selects the investment options for the plan. The investment options are tested by Morningstar to determine whether the plan has a sufficient investment option lineup to ensure that appropriate portfolios can be constructed for participants through combinations of the available investment options. Once the asset allocation targets for a portfolio are built, Morningstar then determines which funds to use to meet their asset class targets and standards for quality. The selection process relies on both quantitative and qualitative measures. The selection criteria include: manager experience, performance record, manager history, alpha (excess returns provided by the manager), style consistency and fund type. A participant will be assigned a fund-specific portfolio based on his or her financial situation, time horizon and other information the participant and the plan sponsor have provided. The program will consider the outside account balances, including a partner’s financial information, that the participant reports or will monitor outside account balances where the participant has provided Morningstar or John Hancock with informational account access to update the program advice. In some cases, Morningstar may adjust the participant’s proposed strategy if the participant has excluded certain funds and/or has assets frozen in a fund. The participant is responsible for the accuracy of the information that the participant provides. If the information is inaccurate, the resulting recommendation might not be appropriate for the participant. The Retirement Advice Service will rely on this information in making an initial recommendation and in managing the participant’s account and does not independently verify the information. There may be other factors that the Retirement Advice Service does not take into account that could be relevant in making the initial recommendation and managing the participant’s account. It is the participant’s responsibility to notify the Retirement Advice Service promptly of any change that may affect the manner in which the Retirement Advice Service should allocate or invest the eligible assets in the participant’s account. 7 CONFIDENTIAL  . Morningstar’s advice and account management instructions, including rebalancing instructions, may be generated by computer-based applications (algorithms) and Morningstar may not always assess each participant’s account individually The Retirement Advice Service relies on historical performance and other data, all of which have limitations. Past performance of investments is no guarantee of future results. The Retirement Advice Service depends upon a number of factors, including the information participants provide, various assumptions and estimates, and other considerations. As a result, the forecast developed, and the analysis and actions taken under the Retirement Advice Service are not guarantees that participants will achieve their retirement goals. Investments in retirement plan accounts are subject to the risks associated with investing in mutual funds and other securities, will not always be profitable, and involve risk of loss that participants should be prepared to bear. The Retirement Advice Service does not guarantee the results or timing of any recommendations, or that the investment objectives of the funds or the participants’ accounts will be met. All investments in retirement plans are subject to the terms of the governing document for that investment option. Participants should read all prospectuses and other documents for mutual funds and other investment options. These documents describe the investment objective and policies as well as the risks of the mutual fund or other investment options. Investing in Retirement Advice is also subject to the following risks: Risk of Loss Investing in mutual funds involves risk of loss that clients should be prepared to bear. Past performance is not indicative of future results. As with all investments, there is no assurance that any of the mutual funds in a participant’s account will achieve their investment objective and a client could lose money by investing in them. Model Risks Morningstar may use quantitative analyses and/or models to create or manage a participant’ account. Any imperfections, limitations or inaccuracies in its analyses and/or models could affect its ability to implement investment strategies. By necessity, these tools make simplifying assumptions that may limit their effectiveness. Models that appear to explain prior market data can fail to predict future market events. Further, the data used in models may be inaccurate and/or it may not include the most current information available. In addition, computer-based applications rebalance a participant’s account based on factors other than just market conditions and may rebalance on a more frequent basis than the participant might expect. Computer based applications may also not address prolonged changes in market conditions. Risks Related to the Use of Automated Investment Tools 8 CONFIDENTIAL  There are risks associated with utilizing automated investment tools, such as Retirement Advice Service, including the following risks: • • • • The investment tool uses certain economic assumptions that may not be updated in a timely manner or reflect shifts in the market. The output of the automated investment tool depends upon the accuracy of the information inputted into the investment tool. There may be certain factors or variables which have not been included in the automated investment tool. To the extent some questions are over-generalized, ambiguous or designed to fit a pre-determined option, the output may not reflect a particular participant’s needs or goals. By only using the automated investment service, participants may not receive individually tailored investment advice. Cybersecurity Risk Cybersecurity breaches may allow an unauthorized party to gain access to portfolio assets, participant data, or proprietary information, or cause JHPFS or John Hancock Trust Company, the trustee and/or custodian of all applicable retirement plans, to suffer data corruption or lose operational functionality. Similar incidents affecting mutual funds held by a participant may negatively impact performance. Operational Risk Retirement Advice is subject to operational risk arising from a number of factors, including, but not limited to, human error, processing and communication errors, errors of Retirement Advice’s service providers or other third parties, errors of the plan sponsor or the plan’s third-party administrator, failed or inadequate processes and technology or system failures. Item 9 – Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of or the integrity of JHPFS or its management persons. Item 10 – Other Financial Industry Activities and Affiliations JHPFS is an indirect, wholly owned subsidiary of MFC. As such, JHPFS is affiliated with a number of investment advisers, investment companies, broker-dealers and insurance companies. Except as noted below, JHPFS does not believe that these relationships are material to JHPFS’s advisory business. 9 CONFIDENTIAL  Investment Companies and Investment Advisers John Hancock Investment Management LLC (“JHIM”) serves as investment adviser to the John Hancock Group of Funds. JHIM is a related person of JHPFS. JHPFS may from time to time offer funds advised by JHIM in its Retirement Advice Service program. Insurance Companies MFC is the sole owner of Manufacturers Life Insurance Company, which is indirectly the sole owner of The Manufacturers Investment Corporation and JHIM. The Manufacturers Investment Corporation directly owns JHPFS. John Hancock Life Insurance Company (U.S.A.) and John Hancock Life Insurance Company of New York, both indirect wholly- owned subsidiaries of MFC, may serve as custodian of retirement plan separate account assets covered by the Service. Banking Institutions John Hancock Trust Company LLC, a New Hampshire-chartered trust company and indirect wholly-owned subsidiary of MFC, may serve as custodian of retirement plan assets covered by the Service. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics JHPFS has adopted a Code of Ethics (the “Code”) which establishes standards of conduct for its “Associates” (which includes any partner, officer, director or other person who provides investment advice and is subject to the supervision and control of JHPFS) and “Access Persons” (which include any Associate who, in connection with their regular duties, has access to non-public information regarding the purchase or sale of securities or the portfolio holdings of client or firm accounts). The Code is designed to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between an investment adviser, including its personnel and affiliates, and accounts managed for its clients. The Code requires Associates to adhere to general principles of business conduct which include a duty to (i) place the interests of JHPFS’s clients first; (ii) conduct all personal securities transactions in such a manner as to avoid any actual or potential conflict of interest and any other abuse of trust or responsibility; (iii) treat as confidential any non- public or confidential information concerning the identity of security holdings and financial circumstances of JHPFS’s clients; (iv) comply with all applicable laws including applicable 10 CONFIDENTIAL  securities laws; and (v) promptly report any violation of the Code to the code administrator or Chief Compliance Officer (“CCO”). The Code prohibits Associates from (i) employing any device, scheme or artifice to defraud a client (ii) making any untrue statement of a material fact to the client; or (iii) taking inappropriate advantage of our position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect to the accounts JHPFS manages. When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, Associates owe a fiduciary duty to JHPFS’s clients. The Code is also designed to permit JHPFS to monitor various securities transactions by Access Persons in which they may have a direct or indirect beneficial ownership interest. Under the Code and subject to limited exceptions, Access Persons must obtain the approval of the code administrator before engaging in securities transactions. The Code includes sections on policies in and outside the Code, reporting requirements and other disclosures inside and outside the Code, reporting violations, interpretation and enforcement, exemptions and appeals, education of employees and recordkeeping. This Code will be provided to any client or prospective client upon request by contacting JHPFS at 855-969-5737. JHPFS has also adopted an Amended and Restated Policy Statement and Procedures on Insider Trading in accordance with Section 204A of the Advisers Act which establishes procedures to prevent the misuse of material information by its officers, directors and employees. JHPFS and its related persons may, from time to time, come into possession of material nonpublic and other confidential information which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, JHPFS and its related persons may be prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should such persons come into possession of material nonpublic or other confidential information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Participation or Interest in Client Transactions From time to time, employees and principals of JHPFS or a related person may also invest or otherwise have an interest in securities owned by or recommended to JHPFS’s clients. Similarly, some or all of the financial services businesses under common control with JHPFS may invest in securities that are also owned by JHPFS’s clients. Any of such persons 11 CONFIDENTIAL  . may invest or otherwise have an interest, either directly or indirectly, in certain pooled vehicles, which, in turn, may invest in securities held in other managed accounts. As these situations may involve potential conflicts of interest, JHPFS has implemented policies and procedures relating to personal securities transactions and insider trading, that are designed to identify potential conflicts of interest, to prevent or mitigate actual conflicts of interest and to resolve such conflicts appropriately if they do occur Item 12 – Brokerage Practices The Retirement Advice Service does not utilize the services of broker- dealers. John Hancock Trust Company, as trustee and/or custodian of the applicable retirement plan effects all transactions. Item 13 – Review of Accounts Retirement Advice Service At least annually, JHPFS will ask participants to update the information they provided to the Retirement Advice Service. It is important for participants to do so, as based on the information participants provide, the fund-specific portfolio to which the Retirement Advice Service manages their eligible assets may be changed. On a quarterly basis, if appropriate, the Retirement Advice Service will rebalance accounts to the recommended asset allocation. Over time, the Retirement Advice Service will generally reallocate a participant’s account to a more conservative fund- specific portfolio, absent any other changes to the participant’s personal or financial situation. Distributions, withdrawals, and loans will be satisfied according to plan rules, and may temporarily impact the Retirement Advice Service’s ability to closely track the fund-specific portfolio. Transfers to an alternate payee pursuant to a qualified domestic relations order will be governed by court order and plan rules, but such a transfer will immediately terminate the Retirement Advice Service’s obligation to manage the portion of the account transferred. Participants will receive confirmations of all transactions in their accounts attributable to the Retirement Advice Service as well as an annual progress report. In addition, they will continue to receive all reports with respect to their accounts that they would receive if they were not enrolled in the Retirement Advice Service. In addition, participants are able to electronically access an annual Retirement Advice Service progress report and will receive this brochure and other documents electronically. Item 14 – Client Referrals and Other Compensation JHPFS does not directly or indirectly compensate any person for client referrals. 12 CONFIDENTIAL  Item 15 – Custody JHPFS is deemed to have indirect custody of the retirement plan accounts enrolled in the Retirement Advice Service because its affiliate, either John Hancock Trust Company, John Hancock Life Insurance Company (U.S.A.), or John Hancock Life Insurance Company of New York, is the named custodian for the applicable retirement plan. JHPFS participants will receive account statements from their retirement plan and should carefully review those statements. Item 16 – Investment Discretion Retirement Advice Service The Retirement Advice Service is a discretionary investment management service. As discussed above, JHPFS selected Morningstar to act as an independent financial expert for the Retirement Advice Service. Morningstar has developed the investment models for the Retirement Advice Service. Such models are outside the control of JHPFS. In order to avoid potential conflicts of interest, all investment decisions, including the allocation of a participant’s retirement plan assets among the various investment options, will be based upon recommendations provided by Morningstar. This enables JHPFS to offer objective, on- going investment management of a participant’s retirement plan assets through many of the investment options in the universe of eligible investment options in the participant’s retirement plan. JHPFS assumes fiduciary responsibility for this role. Item 17 – Voting Client Securities Participants are responsible for exercising shareholder and other rights with respect to investment options in their account, to the extent permitted by their plans. Neither JHPFS nor the Retirement Advice Service is authorized to exercise any shareholder rights on their behalf unless required by law. The Retirement Advice Service will not advise participants on the voting of proxies for fund shares held in their accounts. In addition, neither JHPFS nor the Retirement Advice Service will advise participants on tax matters or legal proceedings, including bankruptcies and class actions, involving investment options. Item 18 – Financial Information JHPFS is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy petition at any time during the past ten years. 13 CONFIDENTIAL 

John Hancock Personal Financial Services, LLC 200 Berkeley Street Boston, MA 02116 myplan.johnhancock.com March 28, 2025 This wrap-fee program brochure provides information about the qualifications and business practices of John Hancock Personal Financial Services, LLC, (“JHPFS”). If you have any questions about the contents of this Brochure, please contact us at (888) 232-3695. The website for JHPFS and its program, John Hancock Managed IRA is myplan.johnhancock.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about JHPFS also is available on the SEC’s website at www.adviserinfo.sec.gov. JHPFS is a registered investment adviser. Registration of an investment adviser does not imply a certain level of skill or training. CONFIDENTIAL CONFIDENTIAL  Item 2 – Material Changes No material changes have been made to this brochure since its last update on March 29, 2024. However, certain non-material updates have been made as follows: Item 4: Assets under management were updated. Item 3 – Table of Contents Item 1– Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ......................................................................................................................... 2 Item 3 – Table of Contents ......................................................................................................................... 2 Item 4 – Service, Fees and Compensation ........................................................................................... 3 Item 5 – Account Requirements and Types of Clients ................................................................ 15 Item 6 – Portfolio Manager Selection and Evaluation ................................................................ 17 Item 7 – Client Information Provided to Portfolio Managers .................................................. 24 Item 8 – Client Contact with Portfolio Managers .......................................................................... 24 Item 9 – Additional Information .......................................................................................................... 24 Disciplinary Information .................................................................................................... 24 Other Financial Industry Activities and Affiliations ............................................... 24 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................................................................... 25 Review of Accounts .............................................................................................................. 27 Financial Information ................................................................................................ 27 2 CONFIDENTIAL CONFIDENTIAL  Item 4 – Services, Fees and Compensation JHPFS is a Delaware limited liability company founded in 2014. JHPFS’s principal owner is The Manufacturers Investment Corporation, which is an indirect, majority-owned subsidiary of Manulife Financial Corporation (“MFC”), a diversified international management and holding company with interests in companies that are active in, among other things, financial services and insurance. MFC is a publicly traded company listed on the Toronto Stock Exchange, the New York Stock Exchange, the Stock Exchange of Hong Kong and the Philippine Stock Exchange under the ticker symbol MFC. JHPFS provides discretionary, web-based, advisory services in connection with JHPFS’s managed account program, John Hancock Managed IRA (the “Program) as well as other programs. You can obtain investment solutions that are similar to the investment strategies offered in the Program through other investment advisory programs sponsored by John Hancock, at a higher or lower cost than in this Program. The services that you receive by investing in such solution through a different program or service may or may not be similar to the services you receive through the Program. You should visit www.johnhancock.com to learn more about other John Hancock investment solutions, services and strategies available to determine which may be most appropriate. This brochure is limited to the Program. Overview The Program utilizes an interactive website to collect information about you and provide investment advice regarding your rollover individual retirement account (“IRA”) through computer-based applications. You will interact with us primarily through the Program’s telephone support representatives or the Program’s website. Although telephone support is available for administrative issues, the Program does not offer in-person or telephonic advice consultation with a live investment adviser representative; telephone support representatives do not formulate or provide investment advice. The Program is designed for the sole objective of managing an IRA to help you toward achieving your retirement income goal; it does not provide advice with respect to other accounts or financial goals you may have. The Program utilizes model portfolios (“Model Portfolios”) that are comprised of exchange-traded funds (“ETFs”). The sponsor and portfolio manager of the Program is JHPFS. JHPFS utilizes algorithms to manage client accounts on a discretionary basis. Manulife Investment Management (“MIM”), an affiliate of JHPFS, creates and maintains the Model Portfolios and recommends ETFs for the Model Portfolios in the Program. MIM also provides other services to JHPFS for the Program as set forth below under “Item 6 – Selection of Portfolio Manager”. Pershing Adviser Solutions LLC and its affiliates (“Pershing”) provides custodial services to your IRA and trade execution for Program investment strategies. The Program is a goal-based advisory program designed to help you achieve the goal of sufficient retirement income to meet your anticipated retirement spending needs over your expected lifespan. The Program’s management of your account is based on the probabilities 3 CONFIDENTIAL CONFIDENTIAL  of certain investment and savings strategies achieving your anticipated retirement income needs. Generally, the risk that the Program seeks to minimize is the risk of your account and savings being insufficient to meet your retirement goal, however, you have the option to adjust the goal-based recommended asset allocation model to reflect your personal investment risk tolerance by completing an Optional Risk Preferences Questionnaire. The provision of discretionary investment advisory services to you has been structured to follow the conditions of Rule 3a-4 (the “Rule”) under the Investment Company Act of 1940, as amended. JHPFS is the “sponsor” of the Program within the meaning of the Rule. There is no guarantee that the advisory services offered under the JHPFS program will result in your goals and objectives being met. Nor is there any guarantee of profit or protection from loss. A Digital -Only Advice Program The Program provides you with fully discretionary investment management services, described in this Brochure, electronically through use of the Program website. Although telephone support is available for administrative issues, the Program does not offer in- person or telephonic advice consultation with a live investment adviser representative; telephone support representatives do not formulate or provide investment advice. Telephonic support is limited to help with enrolling into the Program as well as assistance with account servicing needs. You should carefully consider whether your participation in the Program is appropriate for your confidence and facility in participating in a web-based electronic-only investment program and well as your investment needs and goals. You must log in to the Program website to access important documents, ensure information is accurate and up to date and complete periodic reviews. You can communicate with us through the Program Website or by telephone at 1-888-232-3695. We will gather from you and at least annually request that you confirm and update important financial and personal information used as the basis for our investment recommendations. It is your responsibility to ensure that the information you provide to us is complete and accurate. When you provide accurate and complete information, we will be better able to make suitable investment allocations of your IRA assets. It is also your responsibility to notify us if any information we have about you is inaccurate or becomes inaccurate. Through the Program Website, we request certain information and ask questions of you to gather information about you. If you feel any of the questions are unclear or you do not understand why the information is being sought, please contact us at 1-888-232-3695. Be careful when inputting your answers or information. If you enter inaccurate information, the resulting recommendation might not be right for you. The Program incorporates only the financial information you provide, and our investment recommendations are limited to and based only on the information you provide through the Program Website. We will not independently verify the information you provide through the Program Website. If you 4 CONFIDENTIAL CONFIDENTIAL  believe there is additional financial information that should be considered to inform the investment recommendations made through the Program, please contact us at 1-888-232-3695. The Program’s advice and account management instructions will be generated by the Program’s algorithms. JHPFS investment professionals oversee and monitor the operation of the algorithm but, in general, JHPFS personnel will not assess each account individually nor will they override the advice generated by the algorithm with respect to any account except in the event of a known malfunctioning of the algorithm systems or when, in its sole discretion, JHPFS deems that extraordinary market conditions necessitate changes or delays in the best interests of a client. About The Program Investment Strategies JHPFS manages the Program, which offers you actively managed portfolios comprised of ETFs. JHPFS is granted investment discretion and will continuously monitor your portfolio through computer-based applications. MIM provides JHPFS with recommended Model Portfolios based on specific investment strategies and glide paths and may, from time to time, recommend changes to asset class allocations and specific investment selections. Goldman Sachs Asset Management (“GSAM”) provides the user interface and software that implements the JHPFS investment methodology and algorithms, and certain non- discretionary administrative services for the Program (the services provided by GSAM are not advisory or fiduciary services). Pershing provides custodial services to your IRA and trade execution for Program investment strategies. JHPFS is responsible for the evaluation, selection and ongoing monitoring of MIM, GSAM, and Pershing services to JHPFS. The Program recommends, implements, monitors and rebalances your IRA to a personalized asset allocation plan intended to help you meet your retirement income goal. JHPFS accomplishes this by investing your IRA in one or more Model Portfolios. To develop an appropriate strategy, the Program relies on certain assumptions based on JHPFS's understanding of the global macro-economy, financial markets, rules, regulations, and laws governing investments. The program also relies on personal data that you provide in an online questionnaire. By enrolling in the Program, you authorize your account custodian; Pershing, your previous retirement plan recordkeeper; John Hancock US Retirement as well as any other outside provider you may have used to transfer assets into the Program to share necessary information about you with JHPFS. The Program’s personalization algorithm evaluates the personal data provided and certain assumptions, which may include some or all of the following: age, health, gender, marital status, future earnings, savings potential, education & skills, and riskiness of salary, retirement age, spouse information, existing account balances for discretionary and non-discretionary accounts, 401(k) loans, sources of guaranteed income, annuities, pensions, rental income, Social Security, retirement age, and risk preference. The Program’s personalization algorithm uses the collected personal data to optimize your current and future portfolio allocations (“glide path”) relative to the Program’s age-based baseline allocations by running mathematic simulations of potential investment strategies and identifies an 5 CONFIDENTIAL CONFIDENTIAL  investment glide path that maximize your sustainable retirement income amount (at a 70% confidence level) over your lifetime. If all we know about you is your age, you will receive a simple age-based allocation. However, where more information is available about you and your circumstances, either through John Hancock Retirement Plan Services or through information you provide, the advice is incrementally personalized, and the optimization results incrementally more refined. If any of your investor profile data are not known, the methodology makes default assumptions about you being similar to the average of the general working population or the average of a representative cohort. More information about the advice, methodology and algorithm is provided in the following section. There is no guarantee that the personalization methodology will produce better investment results than the baseline age-based glide path. You may choose to supplement the goals-based personalization methodology by completing an Optional Risk Preference Questionnaire when reviewing the investment plan generated by the Program. The Optional Risk Preference Questionnaire is intended to gauge your investment experience and risk tolerance preferences and based on your answers; the Program may adjust the recommended equity allocation in your portfolio up to +/- 15%. If you accept the risk preference adjustment, the changes to your portfolio allocation may also impact your recommended retirement age and projected retirement income. JHPFS actively manages your Account’s investments; the Program’s portfolio management software continuously monitors your account and may rebalance these investments to match the Program’s personalized allocations any time your account deviates in ways that JHPFS, in its sole discretion, deems unacceptable. When JHPFS updates your personalized allocations or Model Portfolio ETFs, these changes may result in all, a portion of, or none of the assets in your Account being traded. JHPFS monitors your Account for drift from your target allocations and may rebalance all or a portion of your Account’s assets to the recommended allocation. JHPFS may apply tolerance parameters or other criteria when rebalancing your Account to focus on the ETFs or assets with greatest deviation from the recommended allocations. The frequency and parameters JHPFS use to rebalance your Account may change at any time and may be different from the parameters used in other types of investment strategies or investment advisory programs sponsored by John Hancock. JHPFS will review your asset allocation glide path on a quarterly basis based upon your birthdate and John Hancock's financial economic assumptions. At any time throughout the year, you can update your information through the Program website, including personal profile, spouse information and information regarding your other retirement accounts. Information that you update will only be reviewed and considered in your next quarterly plan review. Depending on the results of the plan review, the Program may reforecast your retirement income projections and/or make changes to your asset allocation. These changes will be automatically implemented in your IRA and your portfolio will be monitored and rebalanced to follow the prescribed personalized age-based glide path until the plan is updated with a new plan. 6 CONFIDENTIAL CONFIDENTIAL  You may impose reasonable restrictions on the management of your account subject to JHPFS’s determination that the restriction is reasonable. A request to impose restrictions on the management of an account may result in delays in the implementation of the Program. The performance of accounts subject to reasonable restrictions may differ from accounts that are not subject to restrictions, possibly producing lower overall results. While you may impose reasonable restrictions on your account, it is not possible to impose restrictions on how the underlying ETFs are managed. These underlying investments are subject to investment restrictions described in the applicable prospectus, Statement of Additional Information or other offering documents and restrictions under applicable law. What Advice is Provided and How is it Generated • The John Hancock Managed IRA program provides you with four main recommendations: (i) Portfolio Advice, (ii) Retirement Savings Advice, (iii) Retirement Income/Spending Advice and (iv) Retirement Age Advice. • • • Portfolio Advice. We recommend a personalized asset allocation glide path for your John Hancock Managed IRA investments both for the period before you retire and for your life expectancy in retirement. The program also regularly rebalances your investments to maintain that personalized glide path. Retirement Savings Advice. If your retirement account is under-funded, then we will provide advice regarding how much to contribute to your John Hancock Managed IRA. Because the Internal Revenue Service limits how much you can contribute to an IRA, in most cases our advice will be to contribute the maximum amount allowable. Due to the IRS contribution limit, there may be a significant gap between your Projected Retirement Income (described below, the amount we forecast that you are likely to generate from your John Hancock Managed IRA and other reported assets) and your Target Retirement Income (your goal; the amount we calculate you will need to sustain a similar standard of living in retirement). The Program will consider the outside account balances that you report or will monitor outside account balances where you have provided us with informational account access and use those other account balances and contributions to update the Program advice, including your Projected Retirement Income, accordingly. Retirement Income/Spending Advice. Retirement Income refers to your after-tax retirement spending requirements, adjusted for inflation, until the end of your life expectancy in retirement. The planner takes the personalized asset allocation glide path, the investor specific profile data, and our forecast of financial economic scenarios, and simulates a wide range of potential outcomes for you. We display the minimum amount of annual retirement income projected in 70% of our simulations as your Projected Retirement Income. We also simulate alternative withdrawal strategies to find the optimal withdrawal strategy that allows you to sustain the maximum possible real after-tax spending through your life with 70% confidence. This is your Sustainable Retirement Spending. Retirement Age Advice. Some investors are so under-saved that they may not be able to reach their retirement goal. For those investors, we will recommend saving a higher amount up to practical constraints, and beyond that point, we recommend 7 CONFIDENTIAL CONFIDENTIAL  considering delaying the age at which they retire and start to take social security benefits. Our advice methodology, as automated and computerized, receives some basic information about you from your retirement plan (e.g., age, salary and account balance) and relies on you to provide more information about yourself and your other accounts. The program will generate advice and manage your account based only on the information received from your retirement plan but the additional information we ask you to provide helps us to better personalize our projections and recommendations. The more information you provide, the more refined our advice will be. It is important that you update your information at least annually so that our projections and recommendations can change to meet your changing personal circumstances over time. • The program seeks to assess your needs by capturing investor profile data that impact our four factors that drive personalized advice; (i) Human Capital, (ii) Funded Ratio, (iii) Sequence Risk, (iv) Longevity Risk. • • Human Capital is a measure of your potential for asset accumulation over time and is based on information such as future earnings and savings potential, education and skills, riskiness of salary, age, gender, and retirement age. Among US workers there are largely predictable patterns of variation in growth of income and riskiness of income. Accordingly, the program captures these patterns and based on your circumstances, adjusts the retirement income forecast and personalizes portfolio and saving advice. Funded Ratio is a measure of how many assets you have already accumulated for retirement and is based on information such as existing account balances for discretionary and non-discretionary retirement accounts, 401(k) loans, and spouse information. Investors may face a funding gap if their current savings and future contributions are unlikely to generate a given target retirement income amount. The program takes this potential funding gap into account in providing your advice. For investors accumulating wealth for retirement, the program calculates the Funded Ratio based on the ratio of their projected sustainable after-tax retirement income at the 70th percentile (the amount they can generate with 70% estimated confidence) to their take-home income net of taxes and retirement contributions. Our general philosophy is that young investors with a significant funding gap should take more risk to catch up but young investors who project to easily replace their take-home pay in retirement can afford to de-risk their portfolios. On the other hand, investors near retirement, have run out of time to make up a significant funding gap. Rather than “rolling the dice” with a risky portfolio, we would recommend they reset their retirement income expectations to suit the savings they do have. Sequence Risk is the risk of experiencing bad returns at a bad time. All other things being equal, market crashes have a minimal impact on the projected wealth at retirement age of young investors with no financial capital. As investors approach retirement, they have built up financial capital, have fewer working years left and are less able to withstand catastrophic setbacks from large financial losses. The 8 CONFIDENTIAL CONFIDENTIAL  • unfortunate investor who experiences a once in a lifetime market crash on the date they retire experiences the largest possible drop in their sustainable retirement income. This potential impact decreases during retirement as the investor ages and has the least impact in the last year of the investor’s life. The program evaluates Sequence Risk based on information such as sources of guaranteed income, annuities, pensions, rental income, Social Security, and retirement age. Portfolios generated by the program are designed to mitigate the sequence risk of the portfolio as you approach retirement. Longevity Risk is the risk of outliving one’s financial assets. This is the biggest risk facing retirees and, accordingly, one of the most important drivers of financial advice. The program evaluates Longevity Risk using an actuarial analysis based on information such as age, health, gender, marital status. We mitigate this Longevity Risk by selecting a conservative planning horizon and altering your portfolio allocation, spending and saving advice accordingly. These factors are used to personalize our advice to better reflect your individual circumstances in the following ways. Portfolio Advice and Retirement Income Forecasting. We utilize a standard age-based glide path stating the equity allocation level spanning a period from 40 years prior to the target retirement date and extending to 30 years past the target retirement date. John Hancock has constructed 99 model portfolios of ETFs (ranging from 0% to 98% equity in 1% increments) composed of 21 asset classes that may be used to allocate your investments in accordance with the recommended glide path. The program personalizes your glide path allocation, making adjustments, within a constrained range of +/- 15%, based on your profile information. The personalization algorithm uses factors such as longevity risk, sequence risk, human capital, and funding gap. We evaluate the likelihood that your recommended investment plan will achieve a target retirement wealth level by running “Monte Carlo” computer simulations of the plan’s performance in hundreds of possible economic scenarios. The simulations consider the possible business cycles, financial market returns, interest rates, level of inflation and salary risk an investor may experience over the course of his or her lifetime. The simulations are informed by extensive historical and current data and are integrated such that the various components of the model are generated in a realistic, internally consistent manner. For instance, in the Monte Carlo simulations, financial market returns are likely to be poor during a downturn in the business cycle. The Model’s simulations are in terms of today’s dollars. Throughout our materials, we display the scenario that the simulations show as a “likely” outcome, but no outcome is guaranteed, and the simulations produce other outcomes with a greater or lesser likelihood. What we call a “likely” outcome is the highest common projected annual retirement income or retirement wealth amount that was generated in 70% of the simulations (i.e., that amount or greater was achieved in 70% of the simulations). Retirement Savings Advice. The program calculates a personalized savings rate for your John Hancock Managed IRA based on your age, account balance, and salary. The program 9 CONFIDENTIAL CONFIDENTIAL  will not recommend a savings rate that exceeds 15% of your salary or that exceeds the applicable IRS limit. If you wish to contribute more to your retirement accounts, you can override the 15% cap by manually entering a higher savings rate (but not more than the IRS limit) for your John Hancock Managed IRA or other retirement account not managed by John Hancock via the Program website. The Program will recommend a savings rate only for your John Hancock Managed IRA but will consider savings that you have indicated you make towards retirement and reported balances in other accounts not managed by John Hancock. We make no recommendations about how much you should save in other accounts or what types of other accounts or institutions you should use but we will consider the account balances that you report or will monitor account balances where you have provided us with informational account access and use those other account balances and contributions to update the Program advice, including your Projected Retirement Income, accordingly. Retirement Age Advice. The program calculates a recommended retirement age based on your age, account balance and savings rate. The program will not recommend a retirement age higher than 70 years old. The objective of the retirement age and savings rate optimization is to minimize the retirement age and savings rate increases while still allowing you to achieve success. We define success as follows: in at least 70% of simulated lifetime scenarios, you can spend your Target (Desired) Retirement Income in the last simulated retirement year. The program calculates the number of years that you would have to delay retirement to smooth your pre- and post-retirement spending (i.e., to avoid sudden large changes in your available income and lifestyle). Brokerage and Custody of your Managed IRA To participate in the Program, you are required to maintain an IRA held in custody by Pershing. The Program Fees you pay generally cover the custody of your assets and the execution of transactions in the Program (except as otherwise indicated). Other terms and conditions relating to your IRA are governed by your Traditional IRA Custodial Account Agreement with Pershing. In your Client Agreement with JHPFS, you appoint JHPFS (and GSAM, acting as its agent) to act as your agent and attorney-in-fact with such discretionary power and authority to buy, sell or otherwise effect transactions in ETFs and any other securities or other property in your Program IRA. Accordingly, JHPFS may change the investments used to affect the investment strategy set forth in the Plan at any time and without prior notice to you, including changing the investments used in a Model Portfolio or substituting a particular investment for another investment. JHPFS aggregates client trade orders where possible and when advantageous to its clients. JHPFS also directs GSAM, placing Program trades with Pershing as JHPFS’s agent, to aggregate such trade orders with GSAM client orders where possible and when advantageous to JHPFS clients. When your account participates in aggregated transactions, 10 CONFIDENTIAL CONFIDENTIAL  yours and each client account will pay or receive an average share price. GSAM may aggregate all such client transactions into a block trade that is executed through Pershing. GSAM translates orders generated on behalf of JHPFS clients in terms of U.S. Dollars to a corresponding number of shares for purposes of executing orders in the market and thereafter maintaining assets in JHPFS client Accounts. As a consequence of dollar-based transactions, your IRA will hold fractional share interests in securities. Fractional share amounts may be unrecognized, illiquid, unmarketable or unable to transfer to another brokerage account outside of the Program. To facilitate the allocation of fractional shares to client accounts when portfolio ETFs trade only in whole shares, JHPFS has directed GSAM to participate side-by-side in client transactions only to the extent required to zero-out JHPFS’s Average Price Allocation Account at Pershing prior to the end of each trading day and if JHPFS and GSAM receive no aggregate financial benefit from such transactions. JHPFS and Pershing have established procedures to eliminate the opportunity for JHPFS and GSAM to benefit incidentally from this limited participation in client transactions and to avoid any material conflict that may result from residual fractional shares being allocated to the JHPFS fractional share facilitation account. Rebalancing transactions may occur frequently due to market conditions. JHPFS in its sole discretion may decide to delay a scheduled rebalancing due to unfavorable or volatile market conditions. This delay could adversely affect the performance of the account. All customer trades for an account, including those for rebalancing and/or redemptions are blocked into a single allocation file and transmitted to Pershing for execution once per day so that all customer accounts receive an average share price on a pro-rata basis. All subsequent trade instructions, including redemptions, received prior to 10 a.m., Eastern Time will be placed with Pershing for execution on the same day. Trade instructions received after 10 a.m., Eastern Time will be placed with Pershing for execution by the following regular trading business day. Rebalancing may result in gains or losses in a Program account. The tax treatment of these gains or losses will depend on the type of IRA you have. Any dividends paid on the ETFs in the Program account are deposited to the cash portion of the customer’s account. Cash balances that exceed the targeted allocation for the model portfolio are then reinvested back into the model based on the predetermined target allocations for that model. Administrative and Platform Services Provided by GSAM JHPFS has contracted with and pays GSAM to utilize its digital advisory and technology platforms. In addition to the trading services described above, GSAM supports JHPFS by providing a customized website, website administration, and other functions related to the 11 CONFIDENTIAL CONFIDENTIAL  administrative tasks of managing client accounts and implementing the Program. JHPFS pays GSAM out of the advisory fees it receives from clients. GSAM is part of The Goldman Sachs Group, Inc., a public company that is a bank holding company, financial holding company and a world-wide, full-service financial services organization. Fees and Compensation You will pay JHPFS a Program Fee. The Program Fee is deducted from your account at Pershing (the “Program Account”) and paid directly to JHPFS. You authorize JHPFS to transfer assets or funds from your IRA with Pershing solely for the purpose of collecting the Program Fee. The Program Fee will be calculated quarterly based on the average daily account balance and will be debited in arrears from your Program Account at the beginning of each calendar quarter. The Program Fee is 0.50% annually for accounts with a balance of $50,000 or more. The Program Fee is 0.50% annually plus $4 monthly for accounts with a balance less than $50,000. If a Program Account is opened during the billing period, that period’s Program Fee will be prorated for the number of days in the period that the Program Account was opened and funded. If the Program Account closes before the end of a billing period, the Program Account will be billed through the date in which the Program Account was closed. The Program Fee for that period will be prorated for the number of days in the period the Program Account was opened and funded. The $4 monthly Program Fee addition will be charged quarterly in arrears for each month when your Program Account balance is less than $50,000 on the last day of the month (or the day before your Program Account is closed). You should review your account statements from Pershing and verify that the appropriate Program Fee has been deducted. JHPFS may in its sole discretion make exceptions to the fee schedule set forth above and negotiate different fees for certain clients. The Program Fee covers investment advice, the ongoing management of the Program Account’s assets, as well as trade execution, clearance, settlement and custodial services provided by Pershing. The Program Fee does not cover the expenses of the ETFs in which the Program Account invests, including transaction-related charges ETFs incur. The Program Fee also does not cover certain execution costs that may be charged to you, including: (a) broker-dealer spreads and certain markups or markdowns paid to market makers; (b) transfer taxes; (c) fees charged by exchanges on a per transaction basis or other fees required by law; (d) any other fees that Pershing may charge, as may be outlined from time-to-time in 12 CONFIDENTIAL CONFIDENTIAL  Pershing’s separate fee schedule; and (e) any other charges imposed by law or otherwise agreed to regarding your Program Account. The Program Fee may cost you more or less than purchasing such services separately depending on several factors including the fees Pershing charges for custody and trading and the trading activity in your account. MIM, the provider of recommended Model Portfolios, is affiliated with JHPFS and receives a portion of the Program Fee from JHPFS. Pershing bills its fees, directly to JHPFS. JHPFS does not receive any portion of such expenses or fees from you. In addition, you may incur certain charges imposed by third parties, other than JHPFS, in connection with investments made through your Program Account. The Program Fee is in addition to fees and expenses charged by ETFs that are held in your Program Account. All investments in ETFs are subject to the terms of each of the applicable prospectuses, including associated fees and operating fund expenses, which you ultimately bear. JHPFS may change the Program Fee including increasing the Program Fee at any time provided it notifies you in writing thirty (30) days in advance. JHPFS may presume you have consented to the change in the Program Fee if you have not communicated your objection by calling JHPFS at (888) 232-3695 prior to the end of the 30-day period. In the event, you, during the 30-day period, notify JHPFS of your objection to the Program Fee change, the change will not take effect and JHPFS may, at its option, terminate its advisory agreement with you. Investing in ETFs The Program’s Model Portfolios generally consist of shares of, or interests in, ETFs. As an ETF shareholder, you, along with other shareholders of the ETF, will bear a proportionate share of the ETF’s expenses, including, as permitted by applicable law, certain management and other fees, which may be payable to an affiliate of JHPFS or Pershing. An ETF’s Prospectus contains a description of its fees and expenses. When you invest in an ETF, you will indirectly pay a proportionate share of the ETF’s costs for services that may be similar to, or duplicative of, services rendered as part of the Program and paid for directly through the Program Fees. You may be able to purchase shares of the ETFs included in a Model Portfolio in the secondary market or from an ETF through an Authorized Participant (in creation unit aggregations only), without enrolling in the Program. If you do so, you would not pay the Program Fee for such assets. Below is a summary of certain risks relating to investing in ETFs that may apply to all or certain types of ETFs included in a Model Portfolio. Please refer to the particular ETF Prospectus for more information about the risks applicable for a particular ETF. 13 CONFIDENTIAL CONFIDENTIAL  ETFs are subject to risks relating to market trading that include the potential lack of an active market for ETF shares and disruptions in the creation and redemption process. Although ETF shares are listed on a national securities exchange, it is possible that an active trading market in the shares of a particular ETF may not develop or be maintained, particularly during times of severe market disruption. If ETF shares need to be sold when trading markets are not properly functioning, the ETF shares may be sold at a significant discount to their Net Asset Value (“NAV”). In some cases, it may not be possible to sell ETF shares in the secondary market. For example, an unanticipated closing of the national securities exchange on which an ETF’s shares are listed or one or more markets on which either the ETF’s shares trade or the ETF’s portfolio holdings trade or the inability of such markets to open for trading during normal business hours, such as in response to a natural disaster or other event causing severe market disruption, could result in the inability to buy or sell shares of the ETF and the ETF’s inability to buy and sell exchange-traded portfolio securities during that period, or in a disruption of the ETF’s creation and redemption process, and may make it difficult for the ETF to accurately price its investments, thereby potentially affecting the price at which ETF shares trade in the secondary market. These events could adversely affect the performance of the ETF. Trading in ETF shares also may be halted by an exchange or other markets because of market conditions or other reasons. If a trading halt occurs, an investor may temporarily be unable to purchase or sell shares of the ETF. Similarly, an exchange or other markets may issue trading halts on specific securities or derivatives, which will affect the ability of the ETF to buy or sell certain securities or derivatives. In such circumstances, the ETF may be unable to rebalance its portfolio or accurately price its investments and may incur substantial trading losses. ETF shares also may trade on an exchange or on other markets at prices below their NAV. The NAV of ETF shares will fluctuate with changes in the market value of the ETF’s holdings and the exchange-traded prices of the ETF’s shares may not reflect these market values. Only an Authorized Participant may engage in creation or redemption transactions directly with an ETF. To the extent that these institutions exit the business or are unable to proceed with creation and/or redemption orders with respect to an ETF and no other Authorized Participant can step forward to create or redeem, ETF shares may trade at a discount to NAV and possibly face delisting. This risk is exacerbated if an ETF has a limited number of institutions that serve as Authorized Participants. Certain ETFs may affect creations and redemptions for cash, rather than in-kind. Thus, an investment in such an ETF may be less tax-efficient than an investment in a more conventional ETF. ETFs generally can make in-kind redemptions and avoid being taxed on gain on the distributed portfolio securities at the ETF level. An ETF that effects redemptions for cash, rather than in-kind distributions, may be required to sell portfolio securities to obtain the cash needed to distribute redemption proceeds. If the ETF recognizes gain on these sales, this generally will cause the ETF to recognize gain it might not otherwise have recognized, or to recognize such gain sooner than would otherwise be 14 CONFIDENTIAL CONFIDENTIAL  required if it were to distribute portfolio securities in-kind. ETFs generally intend to distribute these gains to shareholders to avoid being taxed on the gain at the ETF level and otherwise comply with the special tax rules that apply to it. This strategy may cause shareholders to be subject to tax on gains they would not otherwise be subject to, or at an earlier date than, if they had made an investment in a different ETF. Moreover, cash transactions may have to be carried out over several days if the securities market is relatively illiquid and may involve considerable brokerage fees and taxes. These brokerage fees and taxes, which will be higher than if the ETF sold and redeemed its shares principally in-kind, will be passed on to purchasers and redeemers of creation units in the form of creation and redemption transaction fees. In addition, cash transactions may result in wider bid-ask spreads in shares trading in the secondary market as compared to ETFs that transact exclusively in-kind. ETFs that seek to track the performance of a specified underlying index (“Index ETFs”) are not actively managed and the investment advisers of such ETFs do not attempt to take defensive positions in declining markets. Therefore, Index ETFs may be subject to greater losses in a declining market than a fund that is actively managed. Several factors may affect an Index ETF’s ability to achieve a high degree of correlation with its underlying index, and there can be no guarantee that an ETF will achieve a high degree of correlation with its underlying index either on a single trading day or for a longer period. Factors such as ETF expenses, imperfect correlation between the ETF’s investments and the components of the underlying index, rounding of share prices, changes to the composition of the underlying index, regulatory policies, a high portfolio turnover rate, and the use of leverage all contribute to tracking error and correlation risk. Failure to achieve a high degree of correlation may prevent an ETF from achieving its investment objective and cause the ETF’s performance to be less than you expect. For additional information on the risks of investing in the Program and in ETFs see “Methods of Analysis, Investment Strategies and Risk of Loss” below. Assets Under Management As of December 31, 2024, JHPFS had approximately $1.9 billion under management on a discretionary basis. Item 5 – Account Requirements and Types of Clients Account Requirements You must meet the minimum investment amount for the Program. Currently, the minimum is $5,000. If the market value of a Program account falls below the minimum investment amount, JHPFS reserves the right to terminate or suspend its services to the Program account. JHPFS may in its sole discretion make exceptions to the minimum investment 15 CONFIDENTIAL CONFIDENTIAL  amount for certain clients. You will execute a written advisory agreement with JHPFS specifying the advisory services to be provided and under the terms of the agreement will agree to receive all account information and account documents (including this Brochure), and any updates to these documents, through your access to JHPFS’s website and JHPFS electronic communications. Pershing, the custodian of accounts in the Program, effects all transactions. You must appoint JHPFS as the investment adviser of record on accounts in the Program at Pershing. Pershing maintains physical custody of all funds and securities in accounts in the Program. You retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the securities in its Program account. Types of Clients The Program is only offered to Traditional and Roth Individual Retirement Accounts (“IRAs”). Business entities, government entities and accounts that are subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) are not eligible for the Program. Redemption Requests and Termination of an Account All trades for a Program account, including those for redemption are transmitted to Pershing for execution once per day. Trades for redemption may be placed with Pershing for execution on the regular trading business day following the day of receipt of the redemption request. Depending on your circumstances, partial redemptions or distributions in connections with the termination of your Program account may be subject to tax penalties. We do not provide tax advice with respect to your redemptions from or termination of your Program account. If the amount of the redemption is less than the available cash or cash equivalents held in the account, the available cash/cash equivalents will be used to process the transaction. If the amount of the redemption is greater than the available cash held in the account, securities in the account will be sold to satisfy the redemption request. The proceeds from the redemption request will be sent to you upon settlement of these trades. JHPFS may terminate a client from the Program for any reason including having an account balance below the minimum investment amount and not providing JHPFS with information it has requested that is deemed necessary, or appropriate, to manage the Program account. JHPFS also may terminate a client from the Program if JHPFS deems the client’s requested investment restrictions to be unreasonable. You may terminate your participation in the Program upon written notice to JHPFS. In 16 CONFIDENTIAL CONFIDENTIAL  connection with the termination of your Program account, you may request a distribution in kind, a cash distribution or a rollover to another IRA. When a distribution in kind is requested, any fractional shares held in the Program account will be sold and the client may realize a gain or loss on the sale. A cash distribution or an in-kind distribution that is not rolled over to another IRA may be taxable event for the client. Any Termination requests received prior to 3:00 p.m. EST will result in a cancellation of any open trade orders on a best-efforts basis. In addition, we will process final billing, close the account and submit a termination request to Pershing. Any termination request that includes a liquidation of account securities will be processed on the following regular trading business day. After trades have been sent, we will process final billing, close the account and submit termination request to Pershing. Upon termination of your Program account, JHPFS will no longer provide you with investment advisory services and the account will become an unmanaged brokerage account. Item 6 – Portfolio Manager Selection and Evaluation Selection of Portfolio Manager JHPFS will act as the portfolio manager in the Program. JHPFS will utilize its affiliate, MIM, to create and maintain Model Portfolios for the Program and to recommend ETFs to be included in the Model Portfolios and the allocation of ETFs in a Model Portfolios, subject to JHPFS’s approval and supervision. JHPFS could be deemed to have a conflict in performing these services because JHPFS and its affiliate will keep a larger share of the Program Fee than if JHPFS had selected a third party to create and maintain Model Portfolios and select ETFs. JHPFS believes that MIM possesses the requisite expertise to serve in this capacity. To the extent this decision represents a conflict, JHPFS addresses this conflict through disclosure in this Brochure. MIM also provides the following other services to JHPFS related to the Program on a nondiscretionary basis subject to the review and approval of JHPFS: • • • • assists with the optimization and rebalancing for the Model Portfolios. assists with the risk, quantitative, qualitative and performance analysis on ETFs and other investments held by the client Program Accounts. assists with the administrations of an algorithm oversight program. assists with the oversight of vendors used in managing the Programs and Model Portfolios. JHPFS reviews the performance of the investment strategies quarterly. Performance-Based Fees and Side-By-Side Management 17 CONFIDENTIAL CONFIDENTIAL  JHPFS does not receive performance-based fees for advisory services provided to clients. Therefore, JHPFS does not engage in side-by-side management of clients with performance- based fees. Methods of Analysis, Investment Strategies and Risk of Loss JHPFS has created several Model Portfolios for the Program that consists of a diversified portfolio of ETFs. Each Model Portfolio is designed to be consistent with a certain combination of investment strategies and risk tolerances. JHPFS has entered an agreement with MIM whereby MIM recommends Model Portfolios for the Program including the investments to be included in the Model Portfolios and the allocations among these investments. MIM will also provide ongoing review of the Model Portfolios. The Model Portfolios will consist primarily of ETFs. Investing in the Model Portfolios is subject to risks including: Risk of Loss Investing in ETFs involves risk of loss that clients should be prepared to bear. Past performance is not indicative of future results. As with all investments, there is no assurance that any of the ETFs in the Program will achieve their investment objective and a client could lose money by investing in them. Selection and Management Risk Actively managed investment portfolios like the Program are subject to management risk. The securities or instruments in a Model Portfolio may decline in value. Security or instrument selection risk may cause a Model Portfolio to underperform other portfolios with similar investment objectives and investment strategies even in a rising market. Despite strategies to achieve positive investment returns regardless of general market conditions, the values of investments will change with market conditions, and so will the value of any investment in a Model Portfolio. Investments in the Program could lose value, or a Model Portfolio could underperform other investments. General Risks Model Portfolio Risks JHPFS and MIM may use quantitative analyses and/or models to create or manage the Model Portfolios. Any imperfections, limitations or inaccuracies in its analyses and/or models could affect its ability to implement investment strategies. By necessity, these tools make simplifying assumptions that may limit their effectiveness. Model Portfolios that appear to explain prior market data can fail to predict future market events. Further, the data used in models may be inaccurate and/or it may not include the most current information available. 18 CONFIDENTIAL CONFIDENTIAL  In addition, computer-based applications rebalance a client’s account based on factors other than just market conditions and may rebalance on a more frequent basis than the client might expect. Computer based applications may also not address prolonged changes in market conditions. Further, JHPFS oversees and monitors the computer-based application and the Model Portfolios but does not necessarily monitor each client’s account. ETFs General Risks For information on the risks of investing in ETFs see “Investing in ETFs” above as well as the disclosure set forth below. Strategy Risk In addition to the risks detailed herein, each ETF included in the Program is subject to investment risks that are unique to the specific investment strategy of the fund’s manager and disclosed in each fund’s prospectus. Market Risk ETFs invest in equity and fixed income securities. Equity and fixed income markets rise and fall daily. The performance of client investments is, to varying degrees, tied to these markets. When markets fall, the value of a client’s investments will fluctuate, which means a client could lose money. Events in the financial sector have resulted, and may continue to result, in an unusually high degree of volatility in the financial markets, both domestic and foreign. Asset Allocation/Strategy/Diversification Risks The asset classes in which an investment strategy in the Program seeks investment exposure can perform differently from each other at any given time (as well as over longer time periods), so the investment strategy will be affected by its allocation among the various asset classes. The asset allocation decisions can result in more portfolio concentration in a certain asset class or classes, which could reduce overall return if the concentrated assets underperform JHPFS’s expectations. The more aggressive the investment strategy selected, the more likely the portfolio will contain larger weights in riskier asset classes, such as equities. Depending on market conditions, there may be times where diversified portfolios perform worse than less diversified portfolios. Risks Related to the Use of Automated Investment Tools There are risks associated with utilizing automated investment tools such as the Program, including the following risks: 19 CONFIDENTIAL CONFIDENTIAL  • • • • The investment tool uses certain economic assumptions that may not be updated in a timely manner or reflect shifts in the market. The output of the automated investment tool depends upon the accuracy of the information inputted into the investment tool. There may be certain factors or variables which have not been included in the automated investment tool. To the extent some questions are over-generalized, ambiguous or designed to fit a pre-determined option, the output may not reflect a particular client’s needs or goals. By only using the automated investment service, clients may not receive individually tailored investment advice. Cybersecurity Risk Cybersecurity breaches may allow an unauthorized party to gain access to portfolio assets, client data, or proprietary information, or cause JHPFS or Pershing to suffer data corruption or lose operational functionality. Similar incidents affecting issuers of securities held by an ETF may negatively impact performance. Operational Risk The Program is subject to operational risk arising from a number of factors, including, but not limited to, human error, processing and communication errors, errors of the Program’s service providers or other third parties, failed or inadequate processes and technology or system failures. Underlying Securities Risk Equity-Related Risks ETFs that invest in equities are subject to the following risks: General Risks. The price of equity securities may decline due to changes in a company’s financial condition or overall market conditions. Growth company securities may fluctuate more in price than other securities because of the greater emphasis on earnings expectations. Securities the manager believes are undervalued may never realize their full potential value, and in certain markets value stocks may underperform the market as a whole. Large Cap Risk. Larger companies may grow more slowly than smaller companies or be slower to respond to business developments. Large-capitalization securities may underperform the market as a whole. Small and Mid-Cap Risk. Small and mid-size companies are generally less established and may be more volatile in price than larger companies. Small and midsize companies tend to 20 CONFIDENTIAL CONFIDENTIAL  have greater stock volatility because, among other things, these companies are more sensitive to changing economic conditions. Small capitalization securities may underperform the market as a whole. Fixed Income-Related Risks ETFs that invest in fixed income securities are subject to the following risks: Counterparty Risk. To the extent an ETF is invested in fixed-income securities, such as bonds, it may be subject to the risk that a bond issuer will fail to pay interest or principal in a timely manner or that negative perceptions of the issuer’s ability to make such payments will cause the price of that bond to decline. An ETF may also be subject to counterparty risk or the risk that a counterparty fails to meet its contractual obligations to the ETF. In such situations, an ETF may be unable to terminate or realize any gain on the investment or transaction, or to recover collateral posted to the counterparty, resulting in a loss to the ETF. If the ETF holds collateral posted by its counterparty, it may be delayed or prevented from realizing on the collateral in the event of a bankruptcy or insolvency proceeding relating to the counterparty. Interest Rate Risk. ETFs invested in fixed-income investments may experience a decline in income when interest rates fall. This decline can occur because the ETF may subsequently invest in lower-yielding bonds as bonds in its portfolio mature, are near maturity or are called, bonds in the underlying index are substituted, or the ETF otherwise needs to purchase additional bonds. During periods of falling interest rates, homeowners will refinance their mortgages before their maturity dates, resulting in prepayment of mortgage-backed securities held by an ETF. The ETF would then lose any price appreciation above the mortgage’s principal and would be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the ETF‘s income. In addition, issuers of callable bonds may call securities with higher coupon rates or interest rates before their maturity dates. An ETF would then lose any price appreciation above the bond’s call price and would be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the ETF’s income. An increase in interest rates may cause the value of securities held by an ETF to decline. During periods of rising interest rates, certain debt securities will be paid off substantially more slowly than originally anticipated, and the value of those securities may fall. For mortgage-backed securities, the risk is that during periods of rising interest rates, homeowners will prepay their mortgages at slower rates. This will lengthen the duration or average life of mortgage-backed securities held by an ETF and delay the ETF’s ability to reinvest proceeds at higher interest rates. Lower Quality Debt Securities. To the extent an ETF invests in lower-quality debt securities (“high-yield” or “junk” bonds), which are considered predominantly speculative, the ETF is subject to the substantially greater risk of default of such securities than higher- quality debt securities. Lower-quality debt securities can be illiquid, and their values can have significant volatility and may decline significantly over short periods of time. Lower- 21 CONFIDENTIAL CONFIDENTIAL  quality debt securities tend to be more sensitive to adverse news about the issuer, or the market or economy in general. Municipal Securities. An ETF invested in municipal securities can be significantly affected by political or economic changes as well as uncertainties in the municipal market related to taxation, legislative changes or the rights of municipal security holders, including in connection with an issuer insolvency. Municipal securities backed by current or anticipated revenues from a specific project or specific assets can be negatively affected by the inability to collect revenues for the project or from the assets. Foreign Investment-Related Risks ETFs that invest in securities of foreign issuers are subject to the following risks: General Risks. Investments in securities of foreign issuers may involve certain risks that are greater than those associated with investments in securities of U.S. issuers. Less information may be publicly available regarding foreign issuers. Foreign securities may be subject to foreign taxes and may be more volatile than U.S. securities. Currency fluctuations and political and economic developments may adversely impact the value of foreign securities. The prices of foreign stocks and the prices of U.S. stocks may move in opposite directions. In addition, if an ETF’s underlying or target index becomes focused in stocks of a particular market sector, the ETF would have proportionately higher exposure to the risks of that sector. Emerging Market Risk. The risks of investing in foreign securities are magnified in emerging markets. Emerging-market countries may experience higher inflation, interest rates, and unemployment and greater social, economic, and political uncertainties than more developed countries. Currency Risk. Fluctuations in exchange rates may adversely affect the U.S. dollar value of a fund’s investments. Foreign currencies may decline in value, which could negatively impact performance. Geopolitical/Disruption-of-Markets Risks. Geopolitical events may adversely affect global economies and markets and thereby decrease the value of and/or the ease of trading the ETFs invested in those affected markets. Those events as well as other changes in foreign and domestic economic and political conditions could adversely affect the value of the strategy’s investments. Country/regional risk and currency risk. Country/regional risk is the chance that world events — such as political upheaval, financial troubles, or natural disasters — will adversely affect the value of securities issued by companies in foreign countries or regions. If an ETF invests a large portion of its assets in securities of companies located in any one country or region, the ETF’s performance may be hurt disproportionately by the poor performance of its investments in that area. Currency risk is the chance that the value of a 22 CONFIDENTIAL CONFIDENTIAL  foreign investment, measured in U.S. dollars, will decrease because of unfavorable changes in currency exchange rates. Risks Related to Other Asset Classes ETFs are subject to the following risks to the extent the ETFs invests in the particular asset class. Commodity Risk. Commodity prices may be volatile due to fluctuating demand, supply disruption, speculation, and other factors. Certain commodity investments may have no active trading market at times. Hard Asset Risk. The production and marketing of hard assets, such as precious metals, oil and gas, real estate and/or agricultural commodities may be affected by geopolitical and environmental factors and are cyclical in nature. During periods of economic or financial instability, hard asset securities and other instruments may be subject to broad price fluctuations, reflecting volatility of energy and basic material prices and possible instability of supply of various hard assets. Hard asset securities, hard asset companies, and other instruments may also experience greater price fluctuation than the relevant hard asset. In periods of rising hard asset prices, such securities or instruments may rise at a faster rate, and conversely, in time of falling hard asset prices, such securities may suffer a greater price decline. Real Estate Risks. Real estate-related investments may be adversely affected by factors affecting the real estate industry, which may include changes in interest rates and social and economic trends. Real estate investment trusts (“REITs”) may also be subject to the risk of fluctuations in income from underlying real estate assets, poor performance by the REITs’ managers, prepayment and defaults by borrowers, adverse changes in tax laws, and, for U.S. REITs, their failure to qualify for the special tax treatment granted to REITs under the Internal Revenue Code of 1986 and/or to maintain exempt status under the Investment Company Act. Limitations of Disclosure The foregoing list of risks does not purport to be a complete enumeration or explanation of the risks involved in JHPFS’s investment strategies. As JHPFS’s investment strategies develop and change over time, clients and investors may be subject to additional and different risk factors. No assurance can be made that profits will be achieved or that substantial losses will not be incurred. Voting Client Securities JHPFS will not vote and will not provide recommendations regarding the voting of proxies and other corporate governance actions. JHPFS does not offer monitoring and processing of class action litigation settlements regarding program account investments and will not 23 CONFIDENTIAL CONFIDENTIAL  otherwise advise clients on legal proceedings, including bankruptcies and class actions pertaining to investments in their accounts. Item 7 - Client Information Provided to Portfolio Manager Prior to enrolling in the Program, the client provides JHPFS with information about the client’s investment time horizon, risk tolerance, age as well as other information and any reasonable restrictions applicable to the client’s account in order that JHPFS may provide portfolio management services to the client. Item 8 - Client Contact with Portfolio Manager Clients who wish to contact JHPFS can do so by calling the phone number listed on the cover page. Item 9 – Additional Information Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of or the integrity of JHPFS or its management persons. Other Financial Industry Activities and Affiliations JHPFS is an indirect, majority-owned subsidiary of MFC and is directly owned by Manufacturers Investment Corporation. As such, JHPFS is affiliated with several investment advisers, investment companies, broker-dealers and insurance companies. Except as noted below, JHPFS does not believe that these relationships are material to JHPFS’s advisory business. MIM MIM, an investment adviser that creates and maintains the Model Portfolios for the Program and selects ETFs, is an affiliate of JHPFS. Broker-Dealers John Hancock Distributors LLC (“JHD”) is the distributor of the John Hancock Variable Insurance Trust (“JHVIT”), a no-load, open-end investment company that serves as the underlying investment medium for variable annuity and variable life contracts issued by John Hancock Life Insurance Company (U.S.A.) and affiliated entities. John Hancock Investment Management Distributors LLC (“JHIMD”) is the distributor of all the funds in the John Hancock Group of Funds advised by John Hancock Investment Management, LLC (“JHIM”), an affiliate of JHPFS. JHD and JHIMD are each related persons of JHPFS. JHIMD and JHD are broker-dealers registered with the SEC. 24 CONFIDENTIAL CONFIDENTIAL  Investment Companies and Investment Advisers As described above, JHIMD serves as investment adviser to the John Hancock Group of Funds, and John Hancock Variable Trust Advisers, LLC (“JHVTA”), an affiliated investment adviser, serves as investment adviser to JHVIT. JHIM and JHVTA are each related persons of JHPFS. Insurance Companies MFC is the sole owner of Manufacturers Life Insurance Company, which is indirectly the sole owner of The Manufacturers Investment Corporation and JHIM. The Manufacturers Investment Corporation directly owns JHPFS. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics JHPFS has adopted a Code of Ethics (the “Code”) which establishes standards of conduct for its “Associates” (which includes any partner, officer, director or other person who provides investment advice and is subject to the supervision and control of JHPFS) and “Access Persons” (which include any Associate who, in connection with their regular duties, has access to non-public information regarding the purchase or sale of securities or the portfolio holdings of client or firm accounts). The Code is designed to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between an investment adviser, including its personnel and affiliates, and accounts managed for its clients. The Code requires Associates to adhere to general principles of business conduct which include a duty to (i) place the interests of JHPFS’s clients first; (ii) conduct all personal securities transactions in such a manner as to avoid any actual or potential conflict of interest and any other abuse of trust or responsibility; (iii) treat as confidential any non- public or confidential information concerning the identity of security holdings and financial circumstances of JHPFS’s clients; (iv) comply with all applicable laws including applicable securities laws; and (v) promptly report any violation of the Code to the code administrator or Chief Compliance Officer (“CCO”). The Code prohibits Associates from (i) employing any device, scheme or artifice to defraud a client (ii) making any untrue statement of a material fact to the client; or (iii) taking inappropriate advantage of our position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect to the accounts JHPFS manages. 25 CONFIDENTIAL CONFIDENTIAL  When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, Associates owe a fiduciary duty to JHPFS’s clients. The Code is also designed to permit JHPFS to monitor various securities transactions by Access Persons in which they may have a direct or indirect beneficial ownership interest. Under the Code and subject to limited exceptions, Access Persons must obtain the approval of the code administrator before engaging in securities transactions. The Code includes sections on policies in and outside the Code, reporting requirements and other disclosures inside and outside the Code, reporting violations, interpretation and enforcement, exemptions and appeals, education of employees and recordkeeping. This Code will be provided to any client or prospective client upon request by contacting JHPFS at (888) 232-3695. JHPFS has also adopted an Amended and Restated Policy Statement and Procedures on Insider Trading in accordance with Section 204A of the Investment Advisers Act of 1940 which establishes procedures to prevent the misuse of material information by its officers, directors and employees. JHPFS and its related persons may, from time to time, come into possession of material nonpublic and other confidential information which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, JHPFS and its related persons may be prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should such persons come into possession of material nonpublic or other confidential information about any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Participation or Interest in Client Transactions From time to time, employees and principals of JHPFS or a related person may also invest or otherwise have an interest in securities owned by or recommended to JHPFS’s clients. . Similarly, some or all the financial services businesses under common control with JHPFS may invest in securities that are also owned by JHPFS’s clients. Any of such persons may invest or otherwise have an interest, either directly or indirectly, in certain pooled vehicles, which, in turn, may invest in securities held in other managed accounts. As these situations, may involve potential conflicts of interest, JHPFS has implemented policies and procedures relating to personal securities transactions and insider trading, that are designed to identify potential conflicts of interest, to prevent or mitigate actual conflicts of interest and to resolve such conflicts appropriately if they do occur 26 CONFIDENTIAL CONFIDENTIAL  Review of Accounts JHPFS will periodically, no less frequently than annually, ask clients via electronic channels to update the information they provided to JHPFS on its interactive website. Based on the updated information provided, JHPFS may change the Model a client has selected. Client is responsible for promptly notifying JHPFS of any change to Client’s investment objectives, reasonable restrictions or other information that may affect the advisory services provided hereunder. Client understands that Client’s failure to provide JHPFS with current, accurate information could adversely affect JHPFS’s ability to effectively manage Client’s account in the Program. JHPFS associates and designees will also be available to discuss the Program during normal business hours. Financial Information JHPFS is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy petition at any time during the past ten years. JHPFS does not require or solicit prepayment of the wrap fee and is therefore not required to include a balance sheet for its most recent fiscal year. 27 CONFIDENTIAL CONFIDENTIAL 

– Cover Page John Hancock Personal Financial Services, LLC 200 Berkeley Street Boston, MA 02116 https://digital.customer.johnhancock.com/emergency-savings/registration March 28, 2025 This brochure provides information about the qualifications and business practices of John Hancock Personal Financial Services, LLC, (“JHPFS”). If you have any questions about the contents of this Brochure related to John Hancock Advice, please contact us at 888-999- 4307. The website for the Emergency Savings portion of the program is https://digital.customer.johnhancock.com/emergency-savings/registration. If you have any questions about the contents of this Brochure related to Emergency Savings, please contact us at 888-999-4307. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about JHPFS also is available on the SEC’s website at www.adviserinfo.sec.gov. JHPFS is a registered investment adviser. Registration of an investment adviser does not imply a certain level of skill or training.  Item 2 – Material Changes No material changes have been made to this brochure since its last update on March 29, 2024. However, certain non-material updates have been made as follows: Item 4: Assets under management were updated. Item 3 – Table of Contents Item 1 – Cover Page 1 Item 2 – Material Changes 2 Item 3 – Table of Contents 2 Item 4 – Advisory Business 3 Item 5 – Fees and Compensation 4 Item 6 – Performance-Based Fees and Side-By-Side Management 5 Item 7 – Types of Clients 5 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss 6 Item 9 – Disciplinary Information 12 Item 10 – Other Financial Industry Activities and Affiliations 12 Item 11 – Code of Ethics 12 Item 13 – Review of Accounts 13 Item 14 – Client Referrals and Other Compensation 15 Item 15 – Custody 15 Item 16 – Investment Discretion 15 Item 17 – Voting of Client Securities 15 Item 18 – Financial Information 15 2  Item 4 – Advisory Business JHPFS is a Delaware limited liability company founded in 2014. JHPFS’s principal owner is The Manufacturers Investment Corporation, which is an indirect, majority-owned subsidiary of Manulife Financial Corporation (“MFC”), a diversified international management and holding company with interests in companies that are active in, among other things, financial services and insurance. MFC is a publicly traded company listed on the Toronto Stock Exchange, the New York Stock Exchange, the Stock Exchange of Hong Kong and the Philippine Stock Exchange under the ticker symbol MFC. Certain advisory services that JHPFS provides to clients are described below. JHPFS also provides discretionary advisory services to programs that are not described in this brochure. This brochure is limited to the services described below. Services Offered JHPFS and its Investment Adviser Representatives (“IARs”) offer the following services: • • • Financial Planning Consultative Services Emergency Savings Please see below for a full description of these investment advisory services through JHPFS and its IARs. Financial Planning IARs offer financial planning on a case-by-case basis for specific client needs. These financial plans may provide recommendations on the client’s overall investment allocation, insurance needs as well as other financial matters. JHPFS defines financial planning in a broad sense as services that typically involve assisting clients in identifying long-term economic goals, analyzing their current financial situation, and recommending a comprehensive financial program designed to achieve those goals. Consultative Services IARs offer clients consultative services and provide general investment advice or guidance to clients in accordance with a written service agreement. The consulting services may include (and are not limited to) one or more of the following financial planning topics: • • • • • • asset allocation estate plan review retirement planning accumulation goal planning insurance planning college planning 3  Emergency Savings JHPFS offers an Emergency Savings program (the “Program”) as described under Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss). JHPFS does not charge a fee for this Program. Apex Clearing Corporation (“Apex”) is the custodian and clearing agent for the Program. Assets Under Management As of December 31, 2024, JHPFS had approximately $1.9 billion under management on a discretionary basis. Item 5 – Fees and Compensation Financial Planning If there is compensation to JHPFS for rendering the financial plan, clients will be charged a fee based on the complexity of the plan and the client’s financial objectives and needs. The exact fees to be charged for the financial plan will be specifically listed, by the IAR, in the advisory agreement, which is presented to the client for his or her signature before the planning process begins. The IAR may charge an hourly fee up to $200 per hour or may elect to charge a flat fee. A maximum deposit of $1200.00 or 50% of the total fee, whichever is less, may be taken no more than six months in advance, with the balance due upon presentation of the plan. JHPFS in its sole discretion may from time to time waive fees (in whole or in part) for certain financial plans, planning services, or for access to financial planning software. John Hancock employees and immediate family members may be eligible for discounts on Financial Planning services. The client may terminate the advisory agreement by written notice within five (5) business days following the date of the contract and receive a full refund of all amounts deposited. However, the client will be responsible for financial planning performed prior to termination, and the balance of the client’s deposit, if any, will be properly refunded to the client. Consultative Services For consultative services, clients will be charged an hourly rate of $200 per hour for the actual hours spent providing services. Payment of the Fee All fees charged for financial planning or consultative services are paid to JHPFS. 4  Referral Fees An IAR may refer an individual to Trust & Will for the preparation of a will, trust or estate planning documents. JHPFS will receive a fee for the referral. Emergency Savings Program Clients pay no fee to JHPFS for participating in the Emergency Savings Program. Custody fees charged by Apex are paid by JHPFS. Clients are responsible for payment of any other fees that Apex may charge relating to client’s account in the Emergency Savings Program including fees for wire transfers, paper delivery of client statements and ACH reversals. Fee Change JHPFS may assess a fee for the Emergency Savings Program at any time provided it notifies client thirty (30) days in advance. JHPFS may presume client has consented to the change in the fee if JHPFS has not received any objection thereto from client at the end of the 30- day period. In the event the client, during the 30-day period, notifies JHPFS of its objection to the fee change, the change will not take effect and JHPFS may, at its option, terminate its advisory agreement with the client. Item 6 – Performance-Based Fees and Side-By-Side Management JHPFS does not receive performance-based fees for advisory services provided to clients. Therefore, JHPFS does not engage in side-by-side management of clients with performance- based fees. Fees related to financial planning and consultative services are based on the complexity of the plan, time needed to complete the plan and the client’s financial objectives and needs. Please refer to Item 5 - Fees and Compensation for more information. Item 7 – Types of Clients JHPFS offers investment advisory services to individuals, trusts, estates, non-profit organizations, corporations, partnerships and other types of business entities. Emergency Savings Program The Program is offered only to U.S. citizens and U.S. resident aliens over the age of 18. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Item 8 provides information on Financial Planning and Consultative Services as well as the Emergency Savings Program. Financial Planning and Consultative Services 5  Pursuant to a written and executed advisory agreement, the IARs of JHPFS will consult with the client to obtain information regarding the client’s financial situation. The client is responsible for the accuracy and completeness of the information. With this information, the IAR will utilize third party software to create an appropriate financial plan or written consultative services recommendation, based upon the facts obtained by the IAR. During the onboarding process, clients agree that records and disclosure for the Services will be delivered, and agreements will be signed, electronically. This is a requirement both now and in the future. This includes this Form ADV brochure, any other disclosure brochures, supplements, Privacy Notice and other documents. Subsequent to the information gathering period, JHPFS, through its IARs, will deliver a written financial plan or consultative services recommendation(s) to the client and shall arrange to meet with the client to discuss. This plan or recommendation(s) may be the product of a computer-generated program that is offered by a third-party financial planning software vendor. The program draws on statistical samples and is designed to provide general guidance towards accomplishing stated goals. The third-party software vendors who supply the programs are unaffiliated with JHPFS. Financial plans or written consultative services recommendations provided by JHPFS will only offer generic recommendations and do not make recommendations for specifically named investment, advisory or insurance products. Any recommendations developed by an IAR are based upon the IAR’s professional judgment and neither JHPFS nor its IAR can guarantee the results of these recommendations. The clients may obtain legal, accounting and other investment services from any professional source to implement any recommendations made by JHPFS IARs. JHPFS does not provide legal or accounting services. Based on the plan or written recommendation presented, the client may implement solutions with non-advisory products leveraging the representative’s capacity as an insurance agent of John Hancock Life Insurance Company (U.S.A.) and/or John Hancock Life Insurance Company of New York. Clients will not be obligated to use John Hancock Life Insurance Company (U.S.A) or John Hancock Life Insurance Company of New York (collectively, the “John Hancock Insurance Companies”) as agency of record to purchase insurance. Clients are made aware, in writing, that the IAR is also an insurance agent of each of the John Hancock Insurance Companies. The client is informed that the insurance agent may give more specific recommendations regarding investments in his or her separate role as an insurance agent. Clients will not be obligated to use JHPFS to purchase specific products. If the client chooses to purchase advisory products, a separate investment advisory agreement with the client will be executed. After the plan or recommendation is delivered, any updates to the plan or written recommendation, or execution of the recommendations made in the plan or written recommendation is at the sole discretion of the client. The client is not obligated to 6  implement any part of the plan or written recommendation. JHPFS and its IAR are not obligated to update the plan. Risk of Loss Investments are subject to various market, political, currency, economic, business and other risks, and may not always be profitable. All investment programs carry the risk of loss and there is no guarantee that any investment strategy will meet its objective. Certain strategies, methods of analysis and underlying securities may carry more risk than others. JHPFS does not develop the investment strategies offered by the third-party asset management firms. The material risks associated with the financial plans are (1) that the generic recommendations are derived from historical data and forward-looking assumptions that may not continue in the future or may not completely or accurately capture all the possible scenarios of future financial markets, and (2) asset allocations may not be optimal as market environments continue to evolve. The projections and simulations are based on a variety of assumptions that may prove, in the future, to be erroneous. The results that clients obtain may vary significantly from the projections. In addition, the results of the simulation may under-compensate or over- compensate for the impact, if any, of certain market factors and may underestimate the impact of market extremes and the related risk of loss. Emergency Savings Program JHPFS offers an Emergency Savings program (the “Program”) as described below. JHPFS does not charge a fee for this Program. Apex is the custodian and clearing agent for the Program. Custody fees charged by Apex are paid by JHPFS. Clients are responsible for payment of any other fees that Apex may charge relating to client’s account in the Program including fees for wire transfers, paper delivery of client statements and ACH reversal. JHPFS recommends that a client save three to six months of the client’s normal living expenses for emergencies such as the unexpected loss of a job. If a client elects to participate in the Program, a cash account is opened for the client at Apex (the “Cash Account”), the client links a bank account to the client’s account in the Program and then authorizes the automated transfer of money from the linked bank account to the client’s account in the Program. A client may change the amount transferred at any time prior to the time the transfer request has been transmitted to Apex. A client may also cancel or postpone any transfer prior to the time the transfer request has been transmitted to Apex. About the Cash Account The Cash Account is not intended to be used for common and frequent transactions since a 7  client may not receive the proceeds from a withdrawal request for up to five business days under normal circumstances after the withdrawal request is received by JHPFS for an open account. Client Cash Accounts The Cash Account currently utilizes an Apex cash sweep vehicle. The cash in a client’s Cash Account may be automatically “swept” into and out of interest-bearing FDIC-insured deposit accounts opened by Apex at participating banks (“Participating Banks”). A list of the current Participating Banks is available on Apex’s website: https://apexfintechsolutions.com/legal/disclosures/. Participating in the Program does not guarantee that any or all of a client’s Cash Account will be swept into a Participating Bank and all such sweeps are in Apex’s sole discretion. A client may specify that cash in his or her Cash Account does not participate in the cash sweep program and may also elect not to have cash swept into one or more Participating Banks by contacting JHPFS. Exclusion of a Participating Bank from the cash sweep program for a client may result in some or all of client’s cash remaining in the Cash Account and not being swept into the accounts of Participating Banks. A client will not be given notice when Participating Banks are added or withdrawn from the cash sweep program. If the cash in a client’s Cash Account is such that a single deposit at a Participating Bank would put that amount beyond FDIC coverage, then Apex will sweep the excess cash into multiple Participating Banks. Interest is paid on the Cash Account only when clients elect to participate in the cash sweep program. Interest will vary over time and can change daily without notice to the client. Interest paid on the Cash Account may be lower or higher than interest paid on the bank account used by a client to fund the Cash Account or the interest paid on deposits at the Participating Banks or at other banks. If a client has accounts at a Participating Bank in addition to the Cash Account (“Additional Accounts”), the value of the Additional Accounts is aggregated with the value of the Cash Account at the Participating Bank for purposes of determining the Client’s FDIC insurance coverage. Apex does not consider the value of the Additional Accounts when sweeping cash into accounts of Participating Banks. FDIC insurance only applies to those assets in the Cash Account that are swept into a Participating Bank. Other assets in the Cash Account are not insured by the FDIC and have no bank or government guarantees but are instead covered up to $250,000 by the Securities Investor Protection Corporation (“SIPC”) of which Apex is a member. Additional Information to the Program During the online application process, clients agree that records and disclosure for the Program will be delivered, and agreements will be signed, electronically. This is a 8  requirement both now and in the future. This includes this Form ADV brochure, any other disclosure brochures, supplements, Privacy Notice and other documents relating to a client’s account. Each client has an obligation to maintain an accurate and up-to-date email address with JHPFS and to ensure that the client has the ability to read, download, and retain documents received from JHPFS. If a client wishes to print documents, client must also have access to a printer. If a client is unable or unwilling to accept electronic delivery, the client’s enrollment in the Program and their account may be terminated. Clients can communicate with JHPFS via email at customer_support@jhancock.com and via telephone at 888-999-4307. JHPFS will send all emails to the email address client provides to JHPFS. In the event that an email containing an account statement is returned to Apex as undeliverable, Apex will deliver the documents to Client’s postal mail address of record and thereafter JHPFS may terminate Client’s Account as described above. A client may incur additional costs if documents are mailed to the client’s postal mail address. Client assets invested in the Program will not be available for brokerage activities, including but not limited to margin trading or trading securities by client or any of client’s designated agents. If a client initiates brokerage activity for the Program directly with Apex, the client may be charged a fee by Apex and JHPFS may exercise its right to terminate its agreement with the client. JHPFS will periodically, but at least annually, ask clients via electronic mail to update the information they provided to JHPFS. Client may at any time throughout the year update the information it has provided to JHPFS. Account Requirements Clients will execute a written advisory agreement with JHPFS specifying the advisory services to be provided and appointing JHPFS to act as the client’s agent and attorney-in-fact with such discretionary power and authority to buy, sell or otherwise effect transactions in the Cash Account. Under the terms of the advisory agreement, the client will also agree to receive all account information and account documents (including this Brochure), and any updates to these documents, through JHPFS electronic communications. Apex, the custodian of accounts in the Program, effects all transactions. The client must appoint JHPFS as its investment adviser of record on accounts in the Program at Apex. Apex maintains physical custody of all funds in the Cash Account. The client retains all rights of ownership in the Cash Account (e.g., right to withdraw cash). 9  Redemption Requests and Termination of an Account Withdrawal requests received by 3 p.m. Eastern Standard Time will generally be completed within three to five business days. Requests received after 3 p.m. will be processed on a best effort’s basis within three to five business days. JHPFS may terminate a client from the Program for any reason including not providing JHPFS with information it has requested that is deemed necessary, or appropriate, to manage the client’s Cash Account. A client may terminate its account in the Program upon notice to JHPFS, including electronic notice, and payment of all outstanding fees to JHPFS. A client’s termination of its brokerage account with Apex will terminate the client’s advisory agreement upon receipt of notice by JHPFS of such termination and payment of all outstanding fees to JHPFS. Upon termination of the client’s account in the Program, JHPFS will no longer provide the client with investment advisory services and the account will be closed and Client must transfer the assets in his or her account to another financial institution. Risks of Investing in the Program Investing in the Program is subject to risks including those noted below. Cybersecurity Risk Cybersecurity breaches may allow an unauthorized party to gain access to the Program, client accounts and assets, client data, or proprietary information, or cause JHPFS or Apex to suffer data corruption or lose operational functionality. Similar incidents affecting Participating Banks in the cash sweep program may negatively impact performance. Intentional cybersecurity breaches include unauthorized access to systems, networks, or devices (such as through “hacking” activity); infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. In addition, unintentional incidents can occur, such as the inadvertent release of confidential information (possibly resulting in the violation of applicable privacy laws). Cyber incidents affecting JHPFS, Apex or any service providers to the Program have the ability to cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. 10  Operational Risk The Program is subject to operational risk arising from a number of factors, including, but not limited to, human error, processing and communication errors, errors of the Program’s service providers or other third parties, failed or inadequate processes and technology or system failures. The Cash Account The Cash Account is administered by Apex. Investing in the Cash Account is subject to risks including: Risks Related to Cash Sweep Program Interest paid on the Cash Account will vary over time and can change daily without notice to you. Interest paid on the Cash Account may be lower or higher than interest paid on the bank account used by a client to fund the Cash Account or the interest paid on deposits at the Participating Banks or at other banks. Interest paid on the Cash Account may be lower than the rate of inflation. The Program is not intended for Clients that needs immediate access to assets in the Cash Account since a Client may not receive the proceeds from a withdrawal request for up to five business days after the withdrawal request is received by JHPFS. In addition, ACH contributions are subject to a 5-day holding period before withdrawals can be made. Client’s assets in the Cash Account may be swept into one or more Participating Banks unless the client elects otherwise. If a client has accounts at a Participating Bank in addition to the Cash Account (“Additional Accounts”), the value of the Additional Accounts is aggregated with the value of the Cash Account at the Participating Bank for purposes of determining the client’s FDIC insurance coverage. Neither JHPFS nor Apex monitor the amount of client’s assets in Additional Accounts. Therefore, the amount of a client’s assets held at a Participating Bank could exceed FDIC insurance coverage limits. A client will not be given notice when Participating Banks are added or withdrawn from the cash sweep program. A client may specify that cash in his or her Cash Account is not swept into one or more Participating Banks. If a client excludes a Participating Bank from the cash sweep program, this action may result in some of client’s cash remaining in the Cash Account and not being swept into the accounts of Participating Banks. Participating in the Program does not guarantee that any or all of your Cash Account will be swept into a Participating Bank and all such sweeps are in Apex’s sole discretion. FDIC insurance only applies to those assets in the Cash Account that are swept into a 11  Participating Bank. Other assets in the Cash Account are not insured by the FDIC and have no bank or government guarantees but are instead covered up to $250,000 by the Securities Investor Protection Corporation (“SIPC”) of which Apex is a member. Item 9 – Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of or the integrity of JHPFS or its management persons. Item 10 Other Financial Industry Activities and Affiliations – JHPFS is an indirect, majority-owned subsidiary of MFC and is directly owned by Manufacturers Investment Corporation. As such, JHPFS is affiliated with a number of investment advisers, investment companies, broker-dealers and insurance companies including each of the John Hancock Insurance Companies, John Hancock Distributors LLC, and John Hancock Investment Management Distributors LLC. Except as noted below, JHPFS does not believe that these relationships are material to JHPFS’s advisory business. JHPFS IARs are also insurance agents of John Hancock Life Insurance Company (U.S.A.) and if requested by the client may give more specific recommendations regarding investments and insurance in these roles. As a result, a conflict arises between the client’s interests and JHPFS’s and the IAR’s interests if the client chooses to effect transactions with JHPFS and a John Hancock Insurance Company separate from the financial planning or consultative services described in this brochure. Specifically, JHPFS and the IAR may collect transaction fees, commissions or other forms of compensation separate from the financial planning/consulting fees charged in connection with the financial planning or consultative services described in this brochure. Code of Ethics Item 11 – Participation or Interest in Client Transactions and Personal Trading Code of Ethics JHPFS has adopted a Code of Ethics (the “Code”) which establishes standards of conduct for its “Associates” (which includes any partner, officer, director or other person who provides investment advice and is subject to the supervision and control of JHPFS) and “Access Persons” (which include any Associate who, in connection with their regular duties, has access to non-public information regarding the purchase or sale of securities or the portfolio holdings of client or firm accounts). 12  The Code is designed to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between an investment adviser, including its personnel and affiliates, and accounts managed for its clients. The Code requires Associates to adhere to general principles of business conduct which include a duty to (i) place the interests of JHPFS’s clients first; (ii) conduct all personal securities transactions in such a manner as to avoid any actual or potential conflict of interest and any other abuse of trust or responsibility; (iii) treat as confidential any non- public or confidential information concerning the identity of security holdings and financial circumstances of JHPFS’s clients; (iv) comply with all applicable laws including applicable securities laws; and (v) promptly report any violation of the Code to the code administrator or Chief Compliance Officer (“CCO”). The Code prohibits Associates from (i) employing any device, scheme or artifice to defraud a client (ii) making any untrue statement of a material fact to the client; or (iii) taking inappropriate advantage of our position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect to the accounts JHPFS manages. When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, Associates owe a fiduciary duty to JHPFS’s clients. The Code is also designed to permit JHPFS to monitor various securities transactions by Access Persons in which they may have a direct or indirect beneficial ownership interest. Under the Code and subject to limited exceptions, Access Persons must obtain the approval of the code administrator before engaging in securities transactions. The Code includes sections on policies in and outside the Code, reporting requirements and other disclosures inside and outside the Code, reporting violations, interpretation and enforcement, exemptions and appeals, education of employees and recordkeeping. This Code will be provided to any client or prospective client upon request by contacting John Hancock Advice at 888-999-4307. JHPFS has also adopted an Amended and Restated Policy Statement and Procedures on Insider Trading in accordance with Section 204A of the Investment Advisers Act of 1940 which establishes procedures to prevent the misuse of material information by its officers, directors and employees. JHPFS and its related persons may, from time to time, come into possession of material nonpublic and other confidential information which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, JHPFS and its related persons may be prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should such persons come into possession of material nonpublic or other confidential information about any company, they may be prohibited from communicating such information to, or using such 13  information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Participation or Interest in Client Transactions From time to time, employees and principals of JHPFS or a related person may also invest or otherwise have an interest in securities owned by or recommended to JHPFS’s clients. . Similarly, some or all of the financial services businesses under common control with JHPFS may invest in securities that are also owned by JHPFS’s clients. Any of such persons may invest or otherwise have an interest, either directly or indirectly, in certain pooled vehicles, which, in turn, may invest in securities held in other managed accounts. As these situations may involve potential conflicts of interest, JHPFS has implemented policies and procedures relating to personal securities transactions and insider trading, that are designed to identify potential conflicts of interest, to prevent or mitigate actual conflicts of interest and to resolve such conflicts appropriately if they do occur Item 12 – Brokerage Practices Not Applicable. Item 13 Review of Accounts – Review of Financial Plans and Consultative Services Financial plans and consultative services written recommendations generated by JHPFS Investment Adviser Representatives (“IARs”) are reviewed prior to the presentation of the financial plan and consultative services written recommendation to the client. The financial plans and consultative services written recommendations are reviewed to verify that: • • • • they do not include specific product recommendation they meet the client’s stated needs and objectives the plans and recommendations are delivered in a timely manner the IAR used JHPFS-approved financial planning software Review of Accounts in the Program JHPFS will periodically, no less frequently than annually, ask clients via electronic mail to update the information they provided to JHPFS. Client may at any time throughout the year update the information he or she has provided to JHPFS. Telephone support is available for administrative issues during normal business hours (EST). 14  Item 14 Client Referrals and Other Compensation JHPFS does not directly or indirectly compensate any person for client referrals. – Item 15 Custody – Apex, the custodian of the client accounts in the Program, effects all transactions. The client must appoint JHPFS as its investment adviser of record on its accounts in the Program at Apex. Apex maintains physical custody of all funds in the client’s account in the Program. The client retains all rights of ownership in its account in the Program (e.g., right to withdraw cash). Clients receive account statements from Apex at least quarterly. JHPFS does not create or provide clients with account statements; however, clients can access their Apex account statements as well as view their account balance through the Program website. Information regarding a Client’s account provided on the Program website are provided for informational purposes only. Clients are urged to carefully compare the account statements provided by Apex to information provided on the Program website. If any discrepancies are detected, please contact JHPFS promptly. Item 16 Investment Discretion – Not Applicable Item 17 Voting of Client Securities – Not Applicable Item 18 – Financial Information JHPFS is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy petition at any time during the past ten years. JHPFS does not require or solicit prepayment of any fee more than six months in advance and is therefore not required to include a balance sheet for its most recent fiscal year. 15 

John Hancock Personal Financial Services, LLC 200 Berkeley Street Boston, MA 02116 www.jhmyportfolio.com March 28, 2025 This wrap-fee program brochure provides information about the qualifications and business practices of John Hancock Personal Financial Services, LLC, (“JHPFS”). If you have any questions about the contents of this Brochure, please contact us at 1-844-328-2122. The website for this program, MyPortfolio, is www.jhmyportfolio.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about JHPFS also is available on the SEC’s website at www.adviserinfo.sec.gov. JHPFS is a registered investment adviser. Registration of an investment adviser does not imply a certain level of skill or training.  Item 2 – Material Changes No material changes have been made to this brochure since its last update on June 27, 2024. However, certain non-material updates have been made as follows: Item 4: Assets under management were updated. Item 3 – Table of Contents Item 1 – Cover Page 1 Item 2 – Material Changes 2 Item 3 – Table of Contents 2 Item 4 – Services, Fees and Compensation 3 Item 5 – Account Requirements and Types of Clients 8 Item 6 – Portfolio Manager Selection and Evaluation 10 Item 7 - Client Information Provided to Portfolio Manager 19 Item 8 - Client Contact with Portfolio Manager 20 Item 9 – Additional Information 20 Disciplinary Information 20 Other Financial Industry Activities and Affiliations 20 Code of Ethics, Participation or Interest in Client Transactions and PersonalTrading 20 Review of Accounts 22 Financial Information 22 2  Item 4 – Services, Fees and Compensation JHPFS is a Delaware limited liability company founded in 2014. JHPFS’s principal owner is The Manufacturers Investment Corporation, which is an indirect, majority-owned subsidiary of Manulife Financial Corporation (“MFC”), a diversified international management and holding company with interests in companies that are active in, among other things, financial services and insurance. MFC is a publicly traded company listed on the Toronto Stock Exchange, the New York Stock Exchange, the Stock Exchange of Hong Kong and the Philippine Stock Exchange under the ticker symbol MFC. JHPFS provides discretionary advisory services in connection with JHPFS’s managed account program, MyPortfolio (the “Program”) as well as other programs. This brochure is limited to the Program. Overview The Program relies on telephone communications to collect information about clients and provide investment advice using computer-based applications (also known as “algorithms”). The Program utilizes portfolios (“Models”) that are comprised of exchange- traded funds (“ETFs”). The sponsor and portfolio manager of the Program is JHPFS. JHPFS manages client accounts on a discretionary basis. Manulife Investment Management (“MIM”), an affiliate of JHPFS, creates and maintains the Models and recommends ETFs for the Models in the Program. The provision of discretionary investment advisory services to clients has been structured to follow the conditions of Rule 3a-4 (the “Rule”) under the Investment Company Act of 1940, as amended. JHPFS is the “sponsor” of the Program within the meaning of the Rule. The Program Fee also covers access to educational resources. The Program does not offer tax advice or comprehensive financial planning as part of the Program. There is no guarantee that the advisory services offered under the Program will result in the clients’ goals and objectives being met. Nor is there any guarantee of profit or protection from loss. JHPFS also provides discretionary advisory services to other programs that are not described in this brochure. A client may be able to obtain investment solutions through other investment advisory programs or services sponsored by JHPFS or affiliate channels, at a higher or lower cost than this Program. The services that a client receives by investing in such strategies through a different program or service may or may not be similar to the services the client receives through the Program. A client should contact JHPFS if he or she has questions about the Program or to discuss the investment solutions, services and strategies available to determine which may be most appropriate. This brochure is limited to the Program. 3  Information about the Program JHPFS manages the Program, which offers individual clients actively managed portfolios comprised of ETFs. JHPFS is granted investment discretion and will continuously monitor each client’s portfolio through computer-based applications. MIM provides JHPFS with recommended Models based on specific investment strategies and risk tolerances and may, from time to time, recommend changes to asset class allocations and specific investment selections. MIM also provides other services to JHPFS for the Program as set forth below under “Item 6 – Selection of Portfolio Manager”. JHPFS is responsible for the evaluation, selection and ongoing monitoring of MIM’s services to JHPFS. The Program’s advice and account management instructions will be generated by the Program’s algorithms. JHPFS investment professionals oversee and monitor the operation of the algorithm however, in general, JHPFS personnel may not assess each account individually nor will they generally override the advice generated by the algorithm, although JHPFS may make exceptions to this policy from time to time such as to manage client investment and redemption activity or to halt trading or take other temporary defensive measures in stressed market conditions. In addition to the Program’s algorithms, clients have access to educational resources. The Program does not offer tax advice or comprehensive financial planning. To determine a client’s investment objectives, the Program relies on telephone communications to collect information. JHPFS assigns a model portfolio based on the client’s investment time horizon and risk tolerance. When managing a client’s account, JHPFS is relying on the information obtained from the client. The client is responsible for providing JHPFS with any changes to this information. The client gives investment discretion to JHPFS to manage their account and make trades in their account. Clients will not be allowed to make trades in their account. The client may impose reasonable restrictions on the management of their account subject to JHPFS’s determination that the restriction is reasonable. A request to impose restrictions on the management of an account may result in delays in the implementation of the Program. The performance of accounts subject to reasonable restrictions may differ from accounts that are not subject to restrictions, possibly producing lower overall results. While a client may impose reasonable restrictions on their account, it is not possible to impose restrictions on how the underlying ETFs are managed. These underlying investments are subject to investment restrictions described in the applicable prospectus, Statement of Additional Information or other offering documents and restrictions under applicable law. JHPFS has entered into an agreement with Envestnet to provide rebalancing services for accounts in the Program. In connection with these services, Envestnet receives data from the custodian to monitor customers’ accounts against their assigned portfolio models. Accounts in the Program are rebalanced periodically through the use of computer-based applications to maintain target asset allocations and risk levels. Rebalancing will generally 4  occur quarterly based on the anniversary date of the creation of the account and then once the investments in the account are reset to follow any changes in the Model portfolio, rebalancing will generally occur quarterly based on the anniversary date of the reset. Rebalancing may occur more frequently due to market conditions. JHPFS in its sole discretion may decide to delay a scheduled rebalancing due to unfavorable or volatile market conditions. This delay could adversely affect the performance of the account. A rebalancing is triggered when the amount invested in a particular ETF has drifted by more than a predetermined percentage from the target allocation. Rebalancing frequency and drift tolerance levels may be changed in the future. Rebalancing may result in taxable gains or losses in a Program account. ETFs are only traded in whole shares for a Program account. Any dividends paid on the ETFs in the Program account are held in cash. If the amount of cash exceeds the target allocation to cash by more than a certain amount determined from time to time by JHPFS, JHPFS will invest the cash in ETF shares. The cash portion of the client account will be held in cash or cash equivalents such as money market. Clients can communicate with JHPFS via electronic mail and via telephone. The Program relies on telephone communications to collect information about a client and determine an investment strategy. In the event the client completes a new assessment, the investment strategy may change. Clients should carefully consider whether participation in the Program is appropriate for his or her investment needs and goals, along with his or her confidence and facility in using an automated investment program with a web-based portal for ongoing account monitoring. The Program will not be appropriate for all clients. The Program is designed for investors who are comfortable with online access.. The Program is generally not suitable for clients with highly complex financial needs or a preference for frequent, in-person interactions. During the application process, clients agree that records and disclosure for the Program will be delivered, and agreements will be signed, electronically. This is a requirement both now and in the future. This includes this Form ADV brochure, any other disclosure brochures, supplements, Privacy Notice and other documents relating to a client’s account. Each client has an obligation to maintain an accurate and up-to-date email address with JHPFS and to ensure that the client has the ability to read, download, print, and retain documents the client receives from JHPFS. If a client is unable or unwilling to accept electronic delivery, JHPFS may, in its discretion, terminate the client’s enrollment in the Program and the client’s account. JHPFS will send all emails to the email address client provides to JHPFS. If an email notification is undeliverable, JHPFS will deliver the documents to client’s postal mail address 5  of record and thereafter may, in its discretion, terminate client’s account. A client may incur additional costs if documents are mailed to the client’s postal mail address. Charles Schwab & Co, Inc (“Charles Schwab), the custodian of accounts in the Program, effects all transactions. Client assets invested in the Program will not be available for brokerage activities that are not directed by JHPFS, including but not limited to margin trading or trading securities by client or any of client’s designated agents. If a client initiates brokerage activity for the Program directly with Charles Schwab, the client may be charged a fee by Charles Schwab and JHPFS may exercise its right to terminate its agreement with the client. Investing in ETFs The Program’s Model Portfolio generally consist of shares of, or interests in, ETFs. As an ETF shareholder, the client, along with other shareholders of the ETF, will bear a proportionate share of the ETF’s expenses. An ETF’s prospectus contains a description of its fees and expenses. When a client invests in an ETF, the client will indirectly pay a proportionate share of the ETF’s costs for services that may be similar to, or duplicative of, services rendered as part of the Program and paid for directly through the Program Fees. A client may be able to purchase shares of the ETFs included in a Model Portfolio in the secondary market or from an ETF through an Authorized Participant (in creation units only), without enrolling in the Program. If a client does so, the client would not pay the Program Fee for such assets. Under “Methods of Analysis, Investment Strategies and Risk of Loss” below is summary of certain risks relating to investing in ETFs that may apply to all or certain types of ETFs included in a Model Portfolio. Please refer to the particular ETF Prospectus for more information about the risks applicable for a particular ETF. Additional Information about the Program Clients can communicate with JHPFS via electronic mail and via telephone at 1-844-328- 2122. JHPFS will periodically, but at least annually, ask clients via electronic mail to update the information they provided to JHPFS. Client may at any time throughout the year update the information it has provided to JHPFS. The update, in turn, will trigger a review of the client’s account and depending on the results of the review, JHPFS may recommend changes to the client’s account. Client is responsible for promptly notifying JHPFS of any change to client’s saving or investment objectives or other information that may impact the advisory services provided through the Program. Client understands that client’s failure to provide JHPFS with current, accurate information could adversely impact JHPFS’s ability to effectively manage client’s account in the Program. 6  The Program Fee also covers access to educational resources. Fees and Compensation Clients will pay JHPFS a Program Fee. The Program Fee is deducted from the client’s account at Charles Schwab (the “Program Account”) and paid directly to JHPFS. The Program Fee will be charged monthly in arrears and will be debited from the client’s Program Account the following month. The Program Fee is calculated as follows: a. . b. The balance in the Program Account at the end of each day in the prior calendar month is added together and averaged out. If the Program Account does not have balances for part of the month, the balance for those days would be $0 for average balance calculation. The average daily balance is then multiplied by the Annual Program Fee set forth below and then divided by 12. The Program Fee for the month is charged to the client at the beginning of the next month JHPFS’s Program Fee schedule is as follows: Annual Program Fee Asset Range 0.50% All Asset levels For accounts of Signator Investors Inc, LLC that were assigned to JHPFS effective July 6, 2018, the Program Fee is: Asset Range Annual Program Fee $0 to $100,000 Next $150,000 Over $250,000 0.50% 0.45% 0.35% For example, a client with an account balance of $130,000 will be charged .50% on the first $100,000, and .45% on the remaining $30,000, totaling an annual program fee of $635, calculated as follows (.0050 x $100,000) + (.0045 x $30,000) = $500 + $135 = $635. This would result in a monthly fee of approximately $53. Clients should review their account statements from Charles Schwab and verify that the appropriate Program Fee has been deducted. JHPFS may in its sole discretion make exceptions to the fee schedule set forth above and negotiate different fees for certain clients. The Program Fee covers investment advice, the ongoing management of the Program 7  Accounts assets, as well as trade execution, clearance, settlement and custodial services provided by Charles Schwab. The Program Fee does not cover the expenses of the ETFs in which the Program Account invests, including commission and other transaction-related charges ETFs incur. The Program Fee does not cover certain execution costs that may be charged to clients, including: a) b) c) d) e) broker-dealer spreads and certain markups or markdowns paid to market makers; transfer taxes; fees charged by exchanges on a per transaction basis or other fees required by law; any other fees that Charles Schwab may charge, as may be outlined from time-to- time in Charles Schwab’s separate fee schedule; and any other charges imposed by law or otherwise agreed to with regard to a Client’s Program Account. The Program Fee may cost a client more or less than purchasing such services separately depending on several factors including the fees Charles Schwab charges for custody and trading and the trading activity in a client’s account. MIM, the provider of recommended model portfolios, is affiliated with JHPFS and receives a portion of the Program Fee from JHPFS. Charles Schwab bills its fees, other than trade execution and custody fees, directly to the client’s account. JHPFS does not receive any portion of such expenses or fees from the client or Charles Schwab. In addition, clients may incur certain charges imposed by third parties, other than JHPFS, in connection with investments made through the client’s Program Account including, but not limited to, 12b-1 fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed by Charles Schwab. The Program Fee is in addition to fees and expenses charged by ETFs that are held in a client’s Program Account. All investments in ETFs are subject to the terms of each of the applicable prospectuses, including associated fees and operating fund expenses, which the client ultimately bears. Fee Change JHPFS may change the Program Fee for the Program Account including increasing the Program Fee at any time provided it notifies client (which may include electronic notice) thirty (30) days in advance. JHPFS may presume client has consented to the change in the fee if JHPFS has not received any written objection thereto from client at the end of the 30- day period. In the event the client, during the 30-day period, notifies JHPFS of its objection to the fee change, the change will not take effect and JHPFS may, at its option, terminate its advisory agreement with the client. Assets Under Management 8  As of December 31, 2024, JHPFS had approximately $1.9 billion under management on a discretionary basis. Item 5 – Account Requirements and Types of Clients Account Requirements Clients must meet the minimum investment amount for the Program. Currently, the minimum investment is $10,000 although JHPFS may, from time to time, make exceptions to this minimum amount. If the market value of a Program account falls below the minimum investment amount, JHPFS reserves the right to terminate or suspend its services to the Program account. JHPFS may, in its sole discretion, make exceptions to the minimum investment amount for certain clients. Clients will execute a written advisory agreement with JHPFS specifying the advisory services to be provided, and under the terms of the agreement will agree to receive all account information and account documents (including this Brochure), and any updates to these documents, through their access to MyPortfolio’s website and JHPFS electronic mail. Charles Schwab, the custodian of accounts in the Program, effects all transactions as clearing broker-dealer. The client must appoint JHPFS as its investment adviser of record on accounts in the Program at Charles Schwab. Charles Schwab maintains physical custody of all funds and securities in accounts in the Program. The client retains all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the securities in its Program account. The client cannot delegate proxy voting to JHPFS, as JHPFS does not vote client proxies. Types of Clients The Program is offered to the following types of clients: Individual and joint brokerage accounts, Trust accounts, and Individual Retirement Accounts (“IRAs”). Business entities, government entities and accounts that are subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) are not eligible for the Program. Transfer of Money into an Account in the Investment Program Account After JHPFS submits a purchase or other transaction in a client’s account to Charles Schwab or another broker for processing, the transaction will be completed within the standard 9  settlement cycle for the ETF followed by that broker. JHPFS will not be liable for any delays in completing a transaction on the client’s behalf if caused by the broker to whom JHPFS submits the client’s transaction or as otherwise limited by the limitation on liability set forth in JHPFS’ agreement with the client. Redemption Requests and Termination of an Account Redemption requests must be received by 1 p.m. on a business day in order to be processed that day. Generally, requests received after 1 p.m. will be traded on the next business day. If the amount of the redemption is less than the available cash in the account, the available cash will be used to process the redemption. If the amount of the redemption is greater than the available cash in the account, securities in the account will be sold to satisfy the redemption request. The proceeds from the redemption request will be sent to the client upon settlement of these trades which is typically one business day after trade date. or another broker for After JHPFS submits a trade in a client’s account to Charles Schwab processing, the trade will be completed within the standard settlement cycle for the ETF followed by that broker. JHPFS will not be liable for any delays in completing a transaction on the client’s behalf if caused by the broker to whom JHPFS submits the client’s transaction or as otherwise limited by the limitation on liability set forth in JHPFS’ agreement with the client. Proceeds from a requested withdrawal will be made available after trades settle and as soon as administratively possible. If a client has deposited funds in its account within the five business days preceding the withdrawal request, these funds may not be available for withdrawal for five business days after the date of the deposit. JHPFS may terminate a client from the Program for any reason including not providing JHPFS with information it has requested that is deemed necessary, or appropriate, to manage the client’s Program account. JHPFS may also terminate a client from the Program if JHPFS deems the client’s requested investment restrictions to be unreasonable. A client may terminate the Program account upon notice to JHPFS and payment of all outstanding fees to JHPFS. A client’s termination of its brokerage account with Charles Schwab will terminate the client’s advisory agreement upon receipt of notice by JHPFS of such termination and payment of all outstanding fees to JHPFS. Upon termination of the client’s account(s) in the Program, JHPFS will no longer provide the client with investment advisory services on the account(s). 10  Item 6 – Portfolio Manager Selection and Evaluation Selection of Portfolio Manager JHPFS has selected itself as the portfolio manager in the Program. JHPFS utilizes its affiliate, MIM, to create and maintain Model Portfolios for the Investment Program and to recommend ETFs to be included in the Model Portfolios and the allocation of ETFs in a Model Portfolio, subject to JHPFS’s approval and supervision. JHPFS could be deemed to have a conflict in performing these services because JHPFS and MIM will keep a larger share of the Program Fee than if JHPFS had selected a nonaffiliated firm to create and maintain Model Portfolios and select ETFs. JHPFS believes that MIM possesses the requisite expertise to serve in this capacity. To the extent this decision represents a conflict, JHPFS addresses this conflict through disclosure in this Brochure. MIM also provides the following other services to JHPFS related to the Program on a nondiscretionary basis subject to the review and approval of JHPFS: • • • • assists with the optimization and rebalancing for the Model Portfolios. assists with the risk, quantitative, qualitative and performance analysis on ETFs and other investments held by the client Program Accounts. assists with the administrations of an algorithm oversight program. assists with the oversight of vendors used in managing the Programs and Model Portfolios. JHPFS utilizes an unaffiliated firm to develop, manage and own the algorithm(s) used for rebalancing in the MyPortfolio program. Performance-Based Fees and Side-By-Side Management JHPFS does not receive performance-based fees for advisory services provided to clients. Therefore, JHPFS does not engage in side-by-side management of clients with performance- based fees. Methods of Analysis, Investment Strategies and Risk of Loss The Program Investing in the Program is subject to risks including those noted below. Risks Related to the Use of Computer Based Applications (also known as algorithms) There are risks associated with utilizing computer-based applications, including the following risks: 11  • • • • The output of the computer-based applications depends upon the accuracy and availability of the information inputted into the application. There may be certain factors or variables which have not been included in the computer-based application. To the extent some questions are over-generalized, ambiguous or designed to fit a pre-determined option, the output may not reflect a particular client’s needs or goals. Computer based applications may have errors, omissions, imperfections and malfunctions. Errors in the application are often extremely difficult to detect and may go undetected for long periods of time and some errors may never be detected. While this risk may be mitigated by testing, there is no assurance that the algorithm will always work as intended. By only using the computer-based application, clients may not receive individually tailored investment advice. Cybersecurity Risk Cybersecurity breaches may allow an unauthorized party to gain access to the Program, client accounts and assets, client data, or proprietary information, or cause JHPFS or Charles Schwab to suffer data corruption or lose operational functionality. Cybersecurity breaches include unauthorized access to systems, networks, or devices (such as through “hacking” activity); infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. In addition, unintentional incidents can occur, such as the inadvertent release of confidential information (possibly resulting in the violation of applicable privacy laws). Cyber incidents affecting JHPFS, Charles Schwab or any service providers to the Program have the ability to cause disruptions and affect business operations, potentially resulting in financial losses, interference with the ability to calculate net asset value (“NAV”), impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of ETFs and other securities in which a client’s account invests, counterparties with which an ETF engages in transactions, exchanges and other financial market operators, banks, brokers, dealers and financial intermediaries and service providers. Operational Risk The Program is subject to operational risk arising from a number of factors, including, but not limited to, human error, processing and communication errors, errors of the Program’s service providers or other third parties, failed or inadequate processes and technology or system failures. 12  Model Portfolios JHPFS uses Model Portfolios for the Program each of which consist of a diversified portfolio of ETFs. JHPFS has entered into an agreement with MIM whereby MIM recommends Model Portfolios for the Program including the investments to be included in the Model Portfolios and the allocations among these investments. MIM will also provide ongoing review of the Model Portfolios. Investing in the Models is subject to risks including: Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Past performance is not indicative of future results. As with all investments, there is no assurance that any of the ETFs in the Program will achieve their investment objective and a client could lose money by investing in them. Selection and Management Risk Actively managed investment portfolios like the Program are subject to management risk. The ETFs in a Model Portfolio may decline in value. Security or instrument selection risk may cause a Model Portfolio to underperform other portfolios with similar investment objectives and investment strategies even in a rising market. Despite strategies to achieve positive investment returns regardless of general market conditions, the values of investments will change with market conditions, and so will the value of any investment in a Model Portfolio. Investments in the Program could be lost, or a Model Portfolio could underperform other investments. General Risks Model Portfolio Risks JHPFS and MIM may use quantitative analyses and/or models to create or manage the Model Portfolios. Any imperfections, limitations, inaccuracies or incorrect assumptions, including assumptions regarding the global economy and financial markets, in its analyses and/or models could affect its ability to implement investment strategies. By necessity, these tools make simplifying assumptions that may limit their effectiveness. Models that appear to explain prior market data can fail to predict future market events. Further, the data used in models may be inaccurate and/or it may not include the most current information available. In addition, models may also not address prolonged changes in market conditions. Further, JHPFS oversees and monitors the computer-based applications and the Model Portfolios but does not necessarily monitor each client’s account. 13  ETFs General Risks ETFs in which the strategy may invest involve certain inherent risks generally associated with investments in a portfolio of securities, including the risk that the general level of security prices may decline, thereby adversely affecting the value of each unit of the ETF. Moreover, an ETF may not fully replicate the performance of its benchmark index because of the temporary unavailability of certain index securities in the secondary market or discrepancies between the ETF and the index as to the weighting of securities or the number of securities held. ETFs in which the strategies invest have their own fees and expenses as set forth in the ETF prospectuses. ETFs may have exposure to derivative instruments, such as futures contracts, forward contracts, options, and swaps. There is a risk that a derivative may not perform as expected. The main risk with derivatives is that some types can amplify a gain or loss, potentially earning or losing substantially more money than the actual cost of the derivative, or that the counterparty may fail to honor its contract terms, causing a loss for the ETF. Use of these instruments may also involve certain costs and risks such as liquidity risk, interest rate risk, market risk, credit risk, management risk, and the risk that an ETF could not close out a position when it would be most advantageous to do so. A particular ETF may be difficult to purchase or sell or may become difficult to sell after being purchased for a client account. JHPFS may be unable to sell ETFs on behalf of a client at an advantageous time and/or price due to then-existing trading market conditions. ETFs are subject to risks relating to market trading that include the potential lack of an active market for ETF shares and disruptions in the creation and redemption process. Although ETF shares are listed on a national securities exchange, it is possible that an active trading market in the shares of a particular ETF may not develop or be maintained, particularly during times of severe market disruption. If ETF shares need to be sold when trading markets are not properly functioning, the ETF shares may be sold at a significant discount to their Net Asset Value (“NAV”). In some cases, it may not be possible to sell ETF shares in the secondary market. For example, an unanticipated closing of the national securities exchange on which an ETF’s shares are listed or one or more markets on which either the ETF’s shares trade or the ETF’s portfolio holdings trade or the inability of such markets to open for trading during normal business hours, such as in response to a natural disaster or other event causing severe market disruption, could result in the inability to buy or sell shares of the ETF and the ETF’s inability to buy and sell exchange-traded portfolio securities during that period, or in a disruption of the ETF’s creation and redemption process, and may make it difficult for the ETF to accurately price its investments, thereby potentially affecting the price at which ETF shares trade in the secondary market. These events could adversely affect the performance of the ETF. Trading in ETF shares also may be halted by an exchange or other markets because of market conditions or other reasons. If a trading halt occurs, JHPFS may temporarily be 14  unable to purchase or sell shares of the ETF. Similarly, an exchange or other markets may issue trading halts on specific securities or derivatives, which will affect the ability of the ETF to buy or sell certain securities or derivatives. In such circumstances, the ETF may be unable to rebalance its portfolio or accurately price its investments and may incur substantial trading losses. ETF shares also may trade on an exchange or on other markets at prices below their NAV. The NAV of ETF shares will fluctuate with changes in the market value of the ETF’s holdings and the exchange-traded prices of the ETF’s shares may not reflect these market values. Only an Authorized Participant may engage in creation or redemption transactions directly with an ETF. To the extent that these institutions exit the business or are unable to proceed with creation and/or redemption orders with respect to an ETF and no other Authorized Participant can step forward to create or redeem, ETF shares may trade at a discount to NAV and possibly face delisting. This risk is exacerbated if an ETF has a limited number of institutions that serve as Authorized Participants. Certain ETFs may affect creations and redemptions for cash, rather than in-kind. Thus, an investment in such an ETF may be less tax-efficient than an investment in a more conventional ETF. ETFs generally can make in-kind redemptions and avoid being taxed on gain on the distributed portfolio securities at the ETF level. An ETF that effects redemptions for cash, rather than in-kind distributions, may be required to sell portfolio securities to obtain the cash needed to distribute redemption proceeds. If the ETF recognizes gain on these sales, this generally will cause the ETF to recognize gain it might not otherwise have recognized, or to recognize such gain sooner than would otherwise be required if it were to distribute portfolio securities in-kind. ETFs generally intend to distribute these gains to shareholders to avoid being taxed on the gain at the ETF level and otherwise comply with the special tax rules that apply to it. In taxable accounts, this strategy may cause shareholders to be subject to tax on gains they would not otherwise be subject to, or at an earlier date than, if they had made an investment in a different ETF. Moreover, cash transactions may have to be carried out over several days if the securities market is relatively illiquid and may involve considerable brokerage fees and taxes. These brokerage fees and taxes, which will be higher than if the ETF sold and redeemed its shares principally in-kind, will be passed on to purchasers and redeemers of creation units in the form of creation and redemption transaction fees. In addition, cash transactions may result in wider bid-ask spreads in shares trading in the secondary market as compared to ETFs that transact exclusively in-kind. ETFs that seek to track the performance of a specified underlying index (“Index ETFs”) are not actively managed and the investment advisers of such ETFs do not attempt to take defensive positions in declining markets. Therefore, Index ETFs may be subject to greater losses in a declining market than a fund that is actively managed. Several factors may affect an Index ETF’s ability to achieve a high degree of correlation with its underlying index, and there can be no guarantee that an ETF will achieve a high 15  degree of correlation with its underlying index either on a single trading day or for a longer period. Factors such as ETF expenses, imperfect correlation between the ETF’s investments and the components of the underlying index, rounding of share prices, changes to the composition of the underlying index, regulatory policies, a high portfolio turnover rate, and the use of leverage all contribute to tracking error and correlation risk. Failure to achieve a high degree of correlation may prevent an ETF from achieving its investment objective and cause the ETF’s performance to be less than you expect. Strategy Risk In addition to the risks detailed herein, each ETF included in the Program is subject to investment risks that are unique to the specific investment strategy of the fund’s manager and disclosed in each fund’s prospectus. Market Risk Equity and fixed income markets rise and fall daily. The performance of client investments is, to varying degrees, tied to these markets. When markets fall, the value of a client’s investments will fluctuate, which means a client could lose money. Events in the financial sector have resulted, and may continue to result, in an unusually high degree of volatility in the financial markets, both domestic and foreign. Asset Allocation/Strategy/Diversification Risks The asset classes in which an investment strategy in the Program seeks investment exposure can perform differently from each other at any given time (as well as over longer time periods), so the investment strategy will be affected by its allocation among the various asset classes. The asset allocation decisions can result in more portfolio concentration in a certain asset class or classes, which could reduce overall return if the concentrated assets underperform JHPFS’s expectations. The more aggressive the investment strategy selected, the more likely the portfolio will contain larger weights in riskier asset classes, such as equities. Depending on market conditions, there may be times where diversified portfolios perform worse than less diversified portfolios. Risks Related to the Use of Computer Based Applications (also known as algorithms) to Create Model Portfolios There are risks associated with utilizing computer-based applications to create Model Portfolios for the Program, including the following risks: • • The computer-based application uses certain economic assumptions that may not be updated in a timely manner or reflect shifts in the market. The output of the computer-based application depends upon the accuracy of the information inputted into the investment tool. 16  • • • There may be certain factors or variables which have not been included in the computer-based application. To the extent some questions are over-generalized, ambiguous or designed to fit a pre-determined option, the output may not reflect a particular client’s needs or goals. Computer based applications may have errors, omissions, imperfections and malfunctions. Errors in the application are often extremely difficult to detect and may go undetected for long periods of time and some errors may never be detected. While this risk may be mitigated by testing, there is no assurance that the algorithm will always work as intended. By only using the computer-based application, clients may not receive individually tailored investment advice. In addition, computer-based applications may rebalance a client’s account based on factors other than just market conditions and may rebalance on a more frequent basis than the client might expect. Underlying Securities Risk ETFs invest in securities. The risks of investing in various types of securities are set forth below. Equity-Related Risks: General Risks. The price of equity securities may decline due to changes in a company’s financial condition or overall market conditions. Growth company securities may fluctuate more in price than other securities because of the greater emphasis on earnings expectations. Securities the manager believes are undervalued may never realize their full potential value, and in certain markets value stocks may underperform the market as a whole. Large Cap Risk. Larger companies may grow more slowly than smaller companies or be slower to respond to business developments. Large-capitalization securities may underperform the market as a whole. Small and Mid-Cap Risk. Small and mid-size companies are generally less established and may be more volatile than larger companies. Small capitalization securities may underperform the market as a whole. Fixed Income-Related Risks: General Risks. A rise in interest rates typically causes bond prices to fall. The longer the average maturity or duration of the bonds held by an ETF, the more sensitive it will likely be to interest-rate fluctuations. An issuer may not make all interest payments or repay all 17  or any of the principal borrowed. Changes in a security’s credit quality may adversely affect fund performance. High-Yield Risks. High-yield securities and unrated securities of similar credit quality (sometimes called junk bonds) are subject to greater levels of credit and liquidity risks. High-yield securities and the ETFs that invest in them may be considered speculative. Government Securities Risk. Many U.S. government securities are not backed by the full faith and credit of the United States government, which means they are neither issued nor guaranteed by the U.S. Treasury. Certain issuers of securities, such as the Federal Home Loan Banks, maintain limited lines of credit with the U.S. Treasury. Securities issued by other issuers, such as the Federal Farm Credit Bank Funding Corporation, are supported solely by the credit of the issuer. There can be no assurance that the U.S. government will provide financial support to securities of its agencies and instrumentalities if it is not obligated to do so under law. Foreign Investment-Related Risks: General Risks. Investments in securities of foreign issuers may involve certain risks that are greater than those associated with investments in securities of U.S. issuers. Less information may be publicly available regarding foreign issuers. Foreign securities may be subject to foreign taxes and may be more volatile than U.S. securities. Currency fluctuations and political and economic developments may adversely impact the value of foreign securities. Emerging Market Risk. The risks of investing in foreign securities are magnified in emerging markets. Emerging-market countries may experience higher inflation, interest rates, and unemployment and greater social, economic, and political uncertainties than more developed countries. Currency Risk. Fluctuations in exchange rates may adversely affect the U.S. dollar value of a fund’s investments. Foreign currencies may decline in value, which could negatively impact performance. Geopolitical/Disruption-of-Markets Risks. Geopolitical events may adversely affect global economies and markets and thereby decrease the value of and/or the ease of trading the ETFs invested in those affected markets. Those events as well as other changes in foreign and domestic economic and political conditions could adversely affect the value of the strategy’s investments. Health Crisis Risk. A widespread health crisis such as a global pandemic could cause substantial market volatility, exchange trading suspensions and closures, and affect Program performance. For example, the novel coronavirus disease (COVID-19) resulted in significant disruptions to global business activity. The impact of a health crisis and other epidemics and pandemics that may arise in the future, could affect the global economy in 18  ways that cannot necessarily be foreseen at the present time. A health crisis may exacerbate other pre-existing political, social and economic risks. Any such impact could adversely affect the Program’s performance, resulting in losses to your investment. Risks Related to Other Asset Classes: Commodity Risk. Commodity prices may be volatile due to fluctuating demand, supply disruption, speculation, and other factors. Certain commodity investments may have no active trading market at times. Hard Asset Risk. The production and marketing of hard assets, such as precious metals, oil and gas, real estate and/or agricultural commodities may be affected by geopolitical and environmental factors and are cyclical in nature. During periods of economic or financial instability, hard asset securities and other instruments may be subject to broad price fluctuations, reflecting volatility of energy and basic material prices and possible instability of supply of various hard assets. Hard asset securities, hard asset companies, and other instruments may also experience greater price fluctuation than the relevant hard asset. In periods of rising hard asset prices, such securities or instruments may rise at a faster rate, and conversely, in time of falling hard asset prices, such securities may suffer a greater price decline. Real Estate Risks. Real estate-related investments may be adversely affected by factors affecting the real estate industry, which may include changes in interest rates and social and economic trends. Real estate investment trusts (“REITs”) may also be subject to the risk of fluctuations in income from underlying real estate assets, poor performance by the REITs’ managers, prepayment and defaults by borrowers, adverse changes in tax laws, and, for U.S. REITs, their failure to qualify for the special tax treatment granted to REITs under the Internal Revenue Code of 1986 and/or to maintain exempt status under the Investment Company Act. Limitations of Disclosure The foregoing list of risks does not purport to be a complete enumeration or explanation of the risks involved in JHPFS’s investment strategies. As JHPFS’s investment strategies develop and change over time, clients and investors may be subject to additional and different risk factors. No assurance can be made that profits will be achieved, or that substantial losses will not be incurred. Voting Client Securities JHPFS does not vote client proxies for investments in a client’s account. Clients are responsible for exercising shareholder and other rights as owners of ETFs. JHPFS will not advise clients on the voting of proxies for investments held in their accounts. In addition, JHPFS will not advise clients on legal proceedings, including bankruptcies and class actions pertaining to investments in their accounts. 19  Item 7 - Client Information Provided to JHPFS Prior to enrolling in the Program, the client provides JHPFS with nonpublic personal and financial information about the client’s investment time horizon, risk tolerance, age as well as other information in order that JHPFS may provide portfolio management services to the client. The client is responsible for providing JHPFS with any changes to this information. A client should be careful when providing answers or information. If the information is inaccurate, the resulting recommendation might not be appropriate for the client. JHPFS does not independently verify the information a client provides. Item 8 - Client Contact with JHPFS Clients who wish to contact JHPFS can do so by calling the phone number listed on the cover page or using the email option on the Program website. Item 9 – Additional Information Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of or the integrity of JHPFS or its management persons. Other Financial Industry Activities and Affiliations JHPFS is an indirect, majority-owned subsidiary of MFC and is directly owned by Manufacturers Investment Corporation. As such, JHPFS is affiliated with a number of investment advisers, investment companies, broker-dealers and insurance companies. Except as noted below, JHPFS does not believe that these relationships are material to JHPFS’s advisory business. MFC is the sole owner of The Manufacturers Life Insurance Company which in turn wholly owns, directly or indirectly, a number of subsidiaries, including The Manufacturers Investment Corporation. MIM, an investment adviser that creates and maintains the Model Portfolios for the Program and selects the ETFs, is an affiliate of JHPFS. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 20  Code of Ethics JHPFS has adopted a Code of Ethics (the “Code”) which establishes standards of conduct for its “Associates” (which includes any partner, officer, director or other person who provides investment advice and is subject to the supervision and control of JHPFS) and “Access Persons” (which include any Associate who, in connection with their regular duties, has access to non-public information regarding the purchase or sale of securities or the portfolio holdings of client or firm accounts). The Code is designed to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between an investment adviser, including its personnel and affiliates, and accounts managed for its clients. The Code requires Associates to adhere to general principles of business conduct which include a duty to (i) place the interests of JHPFS’s clients first; (ii) conduct all personal securities transactions in such a manner as to avoid any actual or potential conflict of interest and any other abuse of trust or responsibility; (iii) treat as confidential any non- public or confidential information concerning the identity of security holdings and financial circumstances of JHPFS’s clients; (iv) comply with all applicable laws including applicable securities laws; and (v) promptly report any violation of the Code to the code administrator or Chief Compliance Officer (“CCO”). The Code prohibits Associates from (i) employing any device, scheme or artifice to defraud a client (ii) making any untrue statement of a material fact to the client; or (iii) taking inappropriate advantage of our position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect to the accounts JHPFS manages. When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, Associates owe a fiduciary duty to JHPFS’s clients. The Code is also designed to permit JHPFS to monitor various securities transactions by Access Persons in which they may have a direct or indirect beneficial ownership interest. Under the Code and subject to limited exceptions, Access Persons must obtain the approval of the code administrator before engaging in securities transactions. The Code includes sections on policies in and outside the Code, reporting requirements and other disclosures inside and outside the Code, reporting violations, interpretation and enforcement, exemptions and appeals, education of employees and recordkeeping. This Code will be provided to any client or prospective client upon request by contacting JHPFS at 1-844-328-2122. JHPFS has also adopted an Amended and Restated Policy Statement and Procedures on Insider Trading in accordance with Section 204A of the Investment Advisers Act of 1940 21  which establishes procedures to prevent the misuse of material information by its officers, directors and employees. JHPFS and its related persons may, from time to time, come into possession of material nonpublic and other confidential information which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, JHPFS and its related persons may be prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should such persons come into possession of material nonpublic or other confidential information about any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Participation or Interest in Client Transactions From time to time, employees and principals of JHPFS or a related person may also invest or otherwise have an interest in securities owned by or recommended to JHPFS’s clients. . Similarly, some or all of the financial services businesses under common control with JHPFS may invest in securities that are also owned by JHPFS’s clients. Any of such persons may invest or otherwise have an interest, either directly or indirectly, in certain pooled vehicles, which, in turn, may invest in securities held in other managed accounts. As these situations may involve potential conflicts of interest, JHPFS has implemented policies and procedures relating to personal securities transactions and insider trading, that are designed to identify potential conflicts of interest, to prevent or mitigate actual conflicts of interest and to resolve such conflicts appropriately if they do occur Review of Accounts JHPFS will periodically, no less frequently than annually, ask clients via electronic mail to update the information they provided to JHPFS. Based on the updated information provided, JHPFS may change the Model a client has selected. Client is responsible for promptly notifying JHPFS of any change to client’s investment objectives, reasonable restrictions or other information that may affect the advisory services provided hereunder. Client understands that client’s failure to provide JHPFS with current, accurate information could adversely affect JHPFS’s ability to effectively manage client’s account in the Program. JHPFS associates and designees will also be available to discuss the Program during normal business hours. Clients receive account statements from Charles Schwab at least quarterly. JHPFS does not create or provide clients with account statements. Information regarding a client’s account provided on the Program website are not account statements and are provided for 22  informational purposes only. Clients are urged to compare the account statements provided by Charles Schwab to information provided on the Program website. If any discrepancies are detected, please contact JHPFS promptly. Financial Information JHPFS is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy petition at any time during the past ten years. JHPFS does not require or solicit prepayment of any fee and is therefore not required to include a balance sheet for its most recent fiscal year. 23 

Form ADV Part 2A – Appendix 1 Wrap Fee Brochure for Manulife John Hancock Private Wealth Program John Hancock Personal Financial Services, LLC 200 Berkeley Street Boston, MA 02116 1-888-785-6958 March 28, 2025 This wrap-fee program brochure provides information about the qualifications and business practices of John Hancock Personal Financial Services, LLC (“JHPFS”) and the JHPFS wrap fee program, Manulife John Hancock Private Wealth. If you have any questions about the contents of this brochure, please contact us at 1-888-785-6958. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about JHPFS also is available on the SEC’s website at www.adviserinfo.sec.gov. JHPFS is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training.  Item 2 – Material Changes No material changes have been made to this brochure since its last update on September 25, 2024. However, certain non-material updates have been made as follows: Item 4: Assets under management were updated. 2  Item 3 – Table of Contents Item 1 – Cover Page .............................................................................................................1 Item 2 – Material Changes Item 3 – Table of Contents ......................................................................................................................... 2 Item 4 – Service, Fees and Compensation ........................................................................................................................ 3 Item 5 – Account Requirements and Types of Clients ........................................................................................... 4 Item 6 – Portfolio Manager Selection and Evaluation .................................................................. 11 Item 7 – Client Information Provided to Portfolio Managers .................................................................. 12 Item 8 – Client Contact with Portfolio Managers ..................................................... 20 Item 9 – Additional Information ........................................................................... 20 Disciplinary Information ........................................................................................................... 21 Other Financial Industry Activities and Affiliations ...................................................................................................... 21 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................... 21 Review of Accounts ........ 22 Client Referrals and Other Compensation ........................................................... 24 .................................................................................................................................... 23 Financial Information .................................................................................................................................. 24 3  Item 4 – Services, Fees and Compensation JHPFS is a Delaware limited liability company founded in 2014. JHPFS’s principal owner is The Manufacturers Investment Corporation, which is an indirect, majority-owned subsidiary of Manulife Financial Corporation (“MFC”), a diversified international management and holding company with interests in companies that are active in, among other things, financial services and insurance. MFC is a publicly traded company listed on the Toronto Stock Exchange, the New York Stock Exchange, the Stock Exchange of Hong Kong and the Philippine Stock Exchange under the ticker symbol MFC. This Brochure provides information relating to the JHPFS Manulife John Hancock Private Wealth Program (the “Program”), an advisory offering through which JHPFS and its investment advisor representatives, referred to herein and elsewhere as the Manulife John Hancock Private Wealth financial advisors (each, an “Advisor”), provide fee-based discretionary advisory services to clients primarily located in the United States. Overview of Program Services Through the Program, JHPFS offers discretionary wealth management advisory services to clients. Advisors act as portfolio manager for each client account in the Program (each, an “Account”). Advisors provide clients with customized wealth management services. The scope of the investment advisory relationship between JHPFS and a client is defined in the client’s advisory agreement with JHPFS and applies to the client’s Accounts enrolled in the Program. JHPFS provides advice based on the investment objectives, risk tolerance and long-term goals of each client by collecting information from clients to manage Accounts in accordance with individual client’s objectives, as described in this Brochure. Capital Preservation (Low Risk Tolerance) This investment objective is characterized by a very low tolerance to risk, with a primary focus on capital preservation. Investors in this category prioritize the protection of their assets accepting lower growth potential in exchange for reduced volatility. These portfolios consist primarily of low-risk assets, such as cash and cash equivalents, high quality bonds and have minimal exposure to equities as well as volatile investments. Conservative (Low Risk Tolerance) This investment objective is characterized by a low tolerance for risk and prioritizes capital preservation over growth. These portfolios typically allocate a larger proportion of assets to fixed income securities, such as bonds, which offer stability and income generation. While there may still be some exposure to equities, it is typically limited. Moderate Diversified (Moderate Risk Tolerance) This investment objective is characterized by a moderate tolerance for risk. It is characterized by a balanced approach to risk management and return expectations. Investors in this category 4  prioritize both capital growth and preservation, aiming to achieve a stable yet reasonable rate of return over time. These portfolios are diversified across various asset classes, including cash and cash equivalents, fixed income securities, and equities, as well as potential exposure to alternative assets, with the objective of mitigating risk while maintaining growth potential. Growth (High Risk Tolerance) This investment objective is characterized by a high tolerance for risk. Investors in this category prioritize capital growth and can withstand volatility of returns over time. These portfolios typically hold a diversified mix of assets, including cash & cash equivalents, fixed income securities, equities, bonds, and potentially alternative investments, however tend to be characterized by higher allocations to higher risk assets. Aggressive Growth (High Risk Tolerance) This investment objective is characterized by a very high tolerance for risk and volatility in pursuit of potentially significant returns. Investors embracing this profile typically allocate a substantial portion of their portfolio to assets with high growth potential, such as equities and alternative investments. The emphasis is on maximizing long term growth, albeit with a heightened exposure to market fluctuations and the possibility of substantial losses. As portfolio managers, Advisors work to develop an allocation for each Account and determine how to implement the allocations in accordance with the client’s profile and selected strategy within an Account (each strategy, a “Portfolio”). Portfolios within an Account may include a combination of separately managed accounts (“SMAs”), model portfolios, exchange-traded funds, stocks, bonds, mutual funds, private placements and/or municipal securities. The allocations will be managed as an investment model through one of the following investment programs sponsored by FIWA: 1. The Rep as PM program whereby you’re invested in a custom model prepared by your Advisor 2. The Fund Strategist Portfolio (FSP) whereby you’re invested in a model prepared by a third party that is comprised entirely of exchange-traded funds (ETFs) and mutual funds as the underlying investments 3. The Unified Managed Account (UMA) whereby you’re invested in one or more models in a single account. The models available include SMAs, FSPs and custom models from the Rep as PM program. For discretionary investment advisory services, the client appoints a JHPFS Advisor to act as the client’s agent and attorney-in-fact with such discretionary power and authority to buy, sell or otherwise effect transactions in investments and any other securities or other property in the Account. Accordingly, the JHPFS Advisor may change the investments used to effect the investment strategy set forth in the Statement of Investment Selection (as defined below) at any time and without prior notice to the client, including changing the investments used in a Portfolio or substituting a particular investment for another investment. Fidelity Brokerage Services LLC (“FBS”) serves as the introducing broker-dealer for the Accounts in the Program, and National Financial Services (“NFS”) provides custodial, clearing 5  and certain trade execution services for each Account. JHPFS serves as the investment adviser to the Programs and will be responsible for the selection of the third-party managers, Portfolios and other investment products available within the Program. Both FBS and NFS are unaffiliated with JHPFS. Generally, the Program is designed for clients who: • Want to implement an investment plan or strategy with the advice and guidance of a dedicated Advisor. • Want access to an individual investment professional for the management of their investment assets. • Want discretionary investment management services. • Anticipate trading activity in the Account, including rebalancing transactions. • Prefer asset-based fee pricing for their transactions. While this Program is designed to help clients meet a variety of investment needs, it may not be appropriate for clients who: • Do not want customized professional investment advice. • Want non-discretionary investment management services • Have an interest in maintaining consistently high levels of cash or money market funds in their Account for an extended period of time. • Want to engage in excessive trading and “day trading” activity or want to engage in a significant level of unsolicited trade activity. • Are not interested in target asset allocation and other monitoring or complying with Program guidelines. • Want to pay for advisory and brokerage services separately. There is no guarantee that the advisory services offered in the Program will result in a client’s goals and objectives being met, nor is there any guarantee of profit or protection from loss. Rebalancing may result in gains or losses in an Account. The tax treatment of these gains or losses will depend on the type of account a client has. Account Opening Clients will sign an investment advisory agreement governing the management of their Account by JHPFS and their Advisor. This agreement will shape the nature and extent of the investment advisory relationship between a given client, JHPFS and the Advisor, and will include important information about the services to be provided. Clients will also be provided Form ADV Part 2B, as applicable, no later than account opening. A client and an Advisor must also complete a Statement of Investment Selection (“SIS”). A SIS is a document created by the Advisor that outlines the parameters governing the management of a client’s Account, including the risk tolerance, client fees and outlines the investment selection the Advisor will employ to seek to achieve the client’s financial goals. 6  Advisors will meet at least annually with clients to review the contents of the SIS. Account Restrictions Clients may impose reasonable restrictions on the management of their Account(s) subject to JHPFS’s determination that the restriction is reasonable. JHPFS in its sole discretion will determine whether a restriction request is reasonable in light of the Program and Portfolio(s) selected for the client’s Account. Requests for restrictions within a client’s Account must be provided to JHPFS in writing, and the restrictions deemed reasonable by JHPFS will be memorialized in the client’s SIS. A request to impose restrictions on the management of an Account may result in delays in the implementation or rejection of the Account by the Advisor. The performance of Accounts subject to reasonable restrictions may differ from Accounts that are not subject to restrictions, possibly producing lower overall results than Accounts managed in accordance with similar or the same strategies. It is not possible for clients to impose restrictions on investments underlying pooled investment vehicles, such as mutual funds or exchange traded funds, nor can clients restrict how the underlying investment products are managed. These underlying investments are subject to investment restrictions described in the applicable prospectus, Statement of Additional Information, or other offering documents, as well as restrictions required under applicable law. Account Termination Termination of an Account’s enrollment in the Program, or an advisory agreement associated with the Account, will end JHPFS’s investment advisory relationship with respect to that Account and cause the Account to be converted to, and designated as, a self-directed brokerage account held with the unaffiliated broker and custodian NFS. Clients should refer to their advisory agreement for more information about Account termination. Brokerage and Custody To participate in the Program, a client is required to maintain a brokerage account held in custody by NFS. The terms and conditions relating to the brokerage/custody account are governed by the agreement clients enter into with NFS. There are no soft dollar agreements in place between NFS and JHPFS. JHPFS does not make decisions on a trade away (a practice further described below) from the selected broker. This is at the discretion of FMAX (described below in the “Administration and Platform Services” section). Other firms may not require clients to direct brokerage, and this Program may cost more or less than similar competing services. Clients should be aware that discretionary third-party managers, when placing trades for certain Strategies, particularly those involving fixed income, illiquid, or thinly traded securities, may place all or substantially all trades with broker-dealers other than NFS. This practice is often referred to as “trading away,” and these types of trades are frequently called “step-out” trades. Step-out trades are executed at another broker-dealer and cleared and settled at NFS. If the discretionary Investment Manager or Implementation Manager effects step-out trades, Investors will, in most cases, incur commissions, markups, markdowns, or spreads paid to market makers 7  in addition to the Program Fee. Investors should be aware that some discretionary Investment Managers may place all or substantially all trades as step-out trades. As a result, the trading costs of these discretionary Investment Managers and their Strategies will be more costly to Investors than those Strategies where the Implementation Manager places trades with FIWA and its affiliates for execution. JHPFS is deemed to have custody of client assets pursuant to Rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) because it can deduct fees from client Accounts. To comply with the requirements of the Custody Rule, JHPFS has arranged for clients to receive at least quarterly account statements from their custodians. If a client does not receive account statements directly from the custodian, then the client should contact his or her Advisor or custodian immediately. Clients are urged to carefully review their custodian statements to ensure they are accurate. Clients should also compare the available quarterly performance reports from JHPFS to the account statements they receive from their custodian to ensure they are consistent. Administrative and Platform Services JHPFS has contracted with and pays an unaffiliated third party, Fidelity Institutional Wealth Adviser LLC (“FIWA”) (a Fidelity company), to utilize its digital portfolio management and technology platform, Fidelity Managed Account Xchange® managed account program (“FMAX”), for the Program. In addition to the trading services described above, JHPFS also uses other functions through the FMAX platform related to the administrative tasks of managing client Accounts and implementing the Program. Investor Fees The Intermediary Fee, Firm Fee and Program Fee make up the bundled Investor Fee (the “Investor Fee”) on the Statement of Investment Selection that each client will sign off on. Each client in the Program will pay an asset-based fee for certain services provided by JHPFS and the client’s Advisor (the “Intermediary Fee”). The Intermediary Fee is a fee that includes costs associated with providing investment advice, the ongoing management of an Account’s assets, and is paid to the Advisor. The Intermediary Fee is negotiable at the Advisor’s discretion depending upon the market value of the assets under management. Tiers First $250k Next $250k Next $500k Next $1M Next $3M Intermediary Fees Min 0.75% 0.75% 0.75% 0.70% 0.65% Max 1.50% 1.50% 1.50% 1.25% 1.20% 8  Next $5M >$10M 0.40% 0.30% 0.95% 0.65% Each client will also pay a Firm Fee. The Firm Fee is an asset-based fee that is paid by the client to our firm, JHPFS, for JHPFS’ costs associated with the administrative operations, management and oversight of this Program and your Account. Firm Fees First $250k Next $250k Next $500k Next $1M Next $3M Next $5M >$10M 0.30% 0.30% 0.30% 0.275% 0.25% 0.185% 0.075% Each client will also pay an asset-based fee for certain services provided by NFS, FBS and FIWA (the “Program Fee”), which includes the FMAX platform fees (the “Platform Fee”) and third-party money manager fees (the “Third-Party Money Manager Fee”). The Platform fee includes trade execution, clearance, settlement, custodial, administrative and platform services. It also generally includes investment management services composed of client profiling assistance, asset allocation assistance, style allocation assistance, research and evaluation of investment Strategies and Funds, account performance calculations, account rebalancing, account reporting, billing administration, and other operational and administrative services. The Program Fee also does not include the fees charged by investments as part of the investment’s expense ratio. Program Fees Tiers Rep as PM First $250k Next $250k Next $500k Next $1M Next $3M >$5M 0.10% 0.09% 0.075% 0.06% 0.05% 0.04% Fund Strategist Portfolio (FSP) 0.13% 0.12% 0.09% 0.07% 0.05% 0.04% Unified Managed Account (UMA) 0.13% 0.12% 0.09% 0.07% 0.05% 0.04% Third-Party Money Manager Fees may be added to your Platform Fee when your Advisor puts you in an FSP, or UMA account. Through their advisory agreements, clients in the Program authorize FIWA to deduct the Investor Fee from their Account(s) held at NFS, and such Investor Fee is paid directly to FIWA. FIWA retains the Platform Fee for itself, FBS, and NFS, as well as any portion of the fee payable 9  to a third-party manager. FIWA then pays JHPFS the Intermediary Fee. JHPFS is responsible for paying the Advisor their portion of the Intermediary Fee. The Investor Fee for an Account will generally be billed quarterly in advance utilizing the end of quarter balances and debited from the Account on or about the tenth day of each quarter. If an Account is opened during the billing period, that period’s Investor Fee will be prorated for the number of days in the period that the Account was opened and funded. If the Account closes before the end of a billing period, the Account will be billed through the date on which the Account was closed, and refunded for the remaining days in the quarter. The Investor Fee for that period will be prorated for the number of days in the period the Account was opened and funded. For mid-quarter deposits or withdrawals exceeding $10,000, FIWA will calculate an adjustment to the Investor Fee for those assets for the remainder of the quarter (“Intra-Quarter Billable Assets”). Withdrawal or deposits for those Intra-Quarter Billable Assets will be calculated in accordance with the allocation of the assets in the Strategies or Funds at the time of the intra- quarter billing. Clients should review their account statements from NFS and verify that the appropriate Investor Fee has been deducted. Other Fees Aside from the Investor Fee, additional costs may be charged for certain ancillary services. The Program Fee does not include underlying costs that FBS may charge, which would fall under the definition of Direct Client Charges. This includes but is not limited to the following: • Foreign Currency Exchange transaction • International dividend/reorganization • Wire fee (including foreign currency) • Wire fee (if the online cashiering feature is not used) • Check reorder • Overnight check request • Retirement Account closeout fee • Non-retirement account closeout fee • ADR wind/unwind fees • 990T Service Fee • Transfer taxes • Fees charged by exchanges on a per transaction basis or other fees required by law The Program Fee does not include underlying costs or expenses embedded in the investments in which the Account invests, including transaction-related charges incurred. These include the management fees within the investment products, and any additional custody fees, taxes, and 10  other costs incurred by the investment product subject to the terms of their applicable prospectuses. Fee Grouping for Billing Purposes Clients may also combine households to form a fee group. In other words, a household of family members may combine assets with another household of their family members to achieve the lower fee rate. A household is a related group of family members who are generally defined as those who are directly related by birth, adoption or marriage. This is understood to also include grandparents, adult children, and grandchildren who all reside in the same house, and does not include aunts, uncles and cousins. The Advisor may set minimum annual fees for the fee group and each household within a fee group. Account grouping is for the purpose of reducing overall fees to a fee group, and does not affect any suitability analysis performed by the Advisor on behalf of the individual clients. Assets Under Management As of December 31, 2024, JHPFS had approximately $1.9 billion under management on a discretionary basis. Item 5 – Account Requirements and Types of Clients Account Requirements The minimum household size to open or retain an Account in the Program is $100,000. The Advisor retains the right to reduce the account minimum at any time in his or her sole discretion. Clients will sign a brokerage application with NFS and then the SIS agreement with FIWA. The client will also enter into a client advisory agreement specifying the advisory services to be provided and appointing JHPFS as the investment adviser of record on Accounts in the Program held at NFS. Under the terms of the agreement, clients will agree to receive all account information and account documents (including this Brochure), and any updates to these documents, from their Advisor through the FMAX platform electronically, unless the client properly revokes their consent to electronic delivery. As discussed in Item 4 under “Account Opening” above, clients must also complete the SIS with their Advisor. All account holdings must be US traded with US tickers represented in the account. Accounts are restricted from holding foreign currency, and all cash must be in US dollars. Types of Clients The Program is offered to and designed for natural person clients in addition to entities, trusts, pension plans and other types of clients. 11  Item 6 – Portfolio Manager Selection and Evaluation The Advisor serves as the client’s portfolio manager for the Account. As such, the portfolio manager may choose to utilize a third-party manager for some or all of the recommended portfolio(s). Should additional costs be incurred with this recommendation, they will be disclosed at the time of the recommendation. The Advisor’s management of the client’s account is subject to regular oversight to ensure that it aligns with the Program guidelines and regulatory requirements. Third-party managers offered on the platform are evaluated and reviewed by the investment research teams at JHPFS or its affiliates and Fidelity. The teams review the investment products’ philosophy, qualitative and quantitative aspects of the investment process, historical performance, risk statistics, and investment firm personnel and experience. The Advisor will use their discretion in selection of the third-party manager used in accordance with their clients’ investment objectives and risk tolerance. In addition to third-party managers, JHPFS’s related persons, including the Advisors and third- party managers that are affiliated with JHPFS, act as portfolio managers for Accounts in the Program. There is a conflict of interest associated with this practice as JHPFS has an incentive to select JHPFS-affiliated managers as portfolio managers for client Accounts. This is because JHPFS or JHPFS affiliates may be compensated more as a result. However, the portfolio manager maintains a fiduciary responsibility and mandate to act in the client’s best interest. As described in detail in Item 4 above, JHPFS offers discretionary advisory services to clients in this Program. Advisors (which are affiliated persons of JHPFS) provide customized investment advisory services based on a given strategy selected for a client’s Account. Advisors may also engage other managers (which may be affiliated or unaffiliated with JHPFS) to manage part or all of a Portfolio within an Account. Advisors tailor their advice to individual clients by meeting with clients and collecting information to ultimately build a customized plan for management of a client’s Account. For more information on the Program and how Advisors manage Accounts in the Program, clients should refer to “Overview of Program Services” in Item 4 above, “Investment Strategies” in this Item below or speak to their Advisor. This Program Brochure describes a wrap fee program, in which JHPFS charges a single Program Fee which covers account management and certain brokerage and custodial services (with certain exceptions, some of which are described in Item 4 above, “Other Fees”). As explained above, JHPFS is paid a portion of the Intermediary Fee for the provision of advisory services provided by JHPFS and its Advisors. Clients in the Program may pay more or less than those not using a wrap fee program, and choosing to purchase advisory and brokerage services separately. JHPFS also offers non-wrap fee investment advisory services, which differ from the services offered in the Program which are non-discretionary financial planning. 12  For more information on these offerings, please see JHPFS’s other Form ADV Part 2A Brochures available at adviserinfo.sec.gov. Methods of Analysis JHPFS’s evaluation of investments places primary emphasis on the analysis of investment products as detailed below. In addition, political and economic factors that may have an impact on the value of an investment are reviewed. JHPFS relies on unaffiliated third-party research and recommendations. JHPFS also uses various databases available to investment firms and other sources of information, such as online and financial database services. In addition, JHPFS relies on third-party rating services that perform independent credit and investment analysis. JHPFS may recommend investment strategies and vehicles that are not managed by it or its affiliates, including mutual funds, exchange-traded funds (“ETFs”), and exchange-traded notes. Investment Strategies JHPFS provides customized investment strategies designed to meet each client’s individual investment profile. The investment strategy designed for the client will be tailored to his or her unique situation and described in the Statement of Investment Selection. However, when designing an investment strategy, JHPFS will generally consider investments in one or more of the following asset classes: equities; municipal bonds; liquid alternatives; real property or real assets; and funds (including registered and private funds). JHPFS also offers investment strategies managed by affiliated or third-party managers that include, but are not limited to, private equity, hedge funds, fund of funds and traditional asset classes. While JHPFS often seeks to retain sufficient portfolio flexibility to react to abrupt changes in securities markets, unless otherwise agreed in writing between a client and JHPFS, investment decisions and recommendations are generally made with a long-term outlook consistent with the client’s long-term objectives. In managing investment portfolios, JHPFS seeks to provide proper portfolio balance and diversification. JHPFS does not generally engage in short-term trading for Accounts, although the length of time a security has been held in a client’s Account will not be a limiting factor if JHPFS determines that the holding should no longer be retained in the Account. Conflicts of Interest JHPFS earns revenue in the form of a Firm Fee from the client’s Account. JHPFS, its affiliates, its Advisors, and other of its employees benefit from the fees and charges paid by clients for the services described in this Brochure. 13  The compensation structure for Advisors results in conflicts of interest between clients and Advisors as described in this Brochure. JHPFS may also receive revenue depending on the investment products in which clients invest, which is not part of the Advisor’s compensation. The compensation structure for Advisors results in conflicts of interest between clients and Advisors as described in this Brochure. Advisors earn compensation and benefits based on the revenue that JHPFS earns from the fees paid in the Program, as well as revenue derived from certain, but not all, of the other fees and costs clients incur that are not covered by the Investor Fee. In the case of asset-based fees, the more assets there are in your account, the more you will pay in fees, and JHPFS therefore has an incentive to encourage you to increase the assets in your account. The amount of revenue JHPFS receives from a client’s enrollment in the Program may also be more or less than the revenue that would be received if the client had instead participated in other of JHPFS’s investment advisory programs. Between the different investment strategies and models available in the Program, JHPFS and the Advisor have a financial incentive to recommend investment strategies and custom models for which they could potentially receive higher compensation and to recommend this Program over other programs or other services offered by JHPFS or its affiliates if the compensation to JHPFS or the Advisor is greater than the compensation for the other programs or services. Certain investments are sponsored or managed by, or receive other services from, John Hancock Investments (affiliated “Funds”, through its distributor “JHIMD" or investment adviser “JHIM”) and its affiliates. JHIMD and JHIM are affiliates of JHPFS. The Funds or an affiliated sponsor (or other affiliated service providers) receive additional investment management fees and other fees when JHPFS directs client assets to the affiliated Funds. Therefore, JHPFS has a conflict when recommending affiliated Funds. To mitigate this conflict, Advisors do not receive any additional compensation when recommending affiliated Funds. JHPFS conducts appropriate due diligence prior to recommending such affiliated Funds to ensure any such recommendation aligns with the client’s investment needs and objectives and is in the client’s best interest. Further, upon the initial recommendation of an affiliated Fund, and as part of the JHPFS’s ongoing supervision of the client’s assets, JHPFS provides this Brochure and Form CRS which include relevant details regarding material financial interests and compensation surrounding such investment products. There is no requirement for JHPFS to recommend these products to clients, nor are clients obligated to invest in these products. To the extent that affiliated Funds are offered to and purchased by Retirement Accounts, including but not limited to Individual Retirement Accounts, JHPFS’s Firm Fee on any such Retirement Account will be waived for all amounts invested in an affiliated Fund within such retirement account. Our Firm Fee will be charged on all other non-affiliated assets in a retirement account. For all funds in non-retirement accounts, you pay the fees and expenses of all funds in which your account is invested. Fund fees and expenses are charged directly to the pool of assets the fund invests in and are reflected in each fund’s net asset value. These fees and expenses are an 14  additional cost to you that is embedded in the price of the fund, and therefore, are not included in the fee amount in your account statements. You will be charged these internal fund fees and expenses in addition to our Firm Fee. Retirement Accounts For Program Accounts established for retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA) and for Individual Retirement Accounts (IRAs) (collectively, retirement accounts), when providing services under the Program, JHPFS is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the Internal Revenue Code of 1986, as amended (IRC) with respect to the assets of the retirement accounts invested in the Program. Additionally, for retirement accounts that invest in Programs where JHPFS acts as a Portfolio Manager, JHPFS is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the IRC with respect to the assets that it manages in those Programs. Summary of Material Risks Any investment activity, including investment in securities, involves risk of loss that clients should be prepared to bear. There is no guarantee that any investment strategy will meet its investment or risk management objectives or avoid losses. Any past success of a particular investment strategy or methodology does not imply future success. Below are some examples of the material risks that could be faced by clients. These do not include every material or potential risk associated with investing in the Program. Clients are urged to ask questions about risks applicable to a particular investment or investment strategy and consult with their legal, tax and other professional advisors before investing. The Role of Cash. Portfolio rebalances and bulk buys, sells, and switches create order quantities based on the most recent price for the security in the system. In almost all cases this is the closing price from the previous business day. Because orders will be executed at current market prices in the case of exchange-traded securities and bonds, and the current day’s closing NAV in the case of mutual funds, the resulting cash balance may be higher or lower than anticipated. Block Trading. Orders for the same security on the same side of the market with the same terms from a portfolio rebalance or bulk buy/sell, will be blocked together and sent for execution as a single order with terms identical to that of the individual orders that make up the block. All securities that trade on an exchange, as well as most over the counter (“OTC”) traded fixed income securities, are eligible to be blocked. Besides being required by SEC rules, block trading attempts to ensure a fair allocation of trades to all Accounts included in the block. When a block trade is filled at multiple prices, individual fill prices will be averaged according to their relative size so that all Accounts pay or receive the same price. If a block is not entirely filled at the end of a trading day, the partial allocation will be pro-rated (and fill prices averaged, if necessary) and distributed to the Accounts according to each Account’s relative share of the entire order. 15  Market Risk. Economic and other events (whether real or perceived) such as pandemics, global health crises, war, terrorism, or other geopolitical events can increase volatility and may reduce market prices and cause the value of a client Account to fall. Government, Political, and Regulatory. US and foreign legislative, regulatory, and other government actions, which may include changes to regulations, the tax code, trade policy, or the overall regulatory environment, may negatively affect the value of securities within a client’s Account. Business Continuity. We have developed a Business Continuity Program (BCP) that is designed to minimize the impact of adverse events that affect our ability to carry on normal business operations. Such adverse events include, but are not limited to, natural disasters, outbreaks of pandemic and epidemic diseases (such as the COVID-19 pandemic), terrorism, acts of governments, any act of declared or undeclared war, power shortages or failures, utility or communication failure or delays, shortages, and system failures or malfunctions. While we believe the BCP should allow the resumption of normal business operations in a timely manner following an adverse event, there are inherent limitations in such programs, including the possibility that the BCP does not anticipate all contingencies or procedures do not work as intended. Vendors and service providers to JHPFS and our affiliates may also be affected by adverse events and are subject to the same risks that their respective business continuity plans do not cover all contingencies. In the event our BCP or similar programs at vendors and service providers do not adequately address all contingencies, client Portfolios may be negatively affected as there may be an inability to process transactions, calculate net asset values, value client investments, or disruptions to trading in client accounts. A client’s ability to recover any losses or expenses it incurs as a result of a disruption of business operations may be limited by the liability, standard of care, and related provisions in its contractual agreements with us and other service providers. Cybersecurity. With the increased use of the Internet and other technologies to conduct business, we are susceptible to operational, information security and related risks. We rely on communications technology, systems, and networks to engage with clients, employees, accounts, shareholders, and service providers, and a cyber incident may inhibit our ability to use these technologies. In general, cyber incidents can result from deliberate attacks or unintentional events by insiders or third parties, including cybercriminals, competitors, nation states and “hacktivists,” among others. Cyber-attacks include, but are not limited to, phishing, gaining unauthorized access to digital systems (e.g., through “hacking” or infection from or spread of malware, ransomware, computer viruses or other malicious software coding) for purposes of misappropriating assets or sensitive information, structured query language attacks, corrupting data, or causing operational disruption. Cyber-attacks may also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites. A denial-of-service attack is an effort to make network services unavailable to intended users, which could cause us and our clients to lose access to their electronic accounts, potentially indefinitely. Our employees and service providers may not be able to access electronic systems to perform critical duties, such as trading and account oversight, during a denial-of-service attack. There is also the possibility for systems failures due to malfunctions, user error, 16  misconduct by employees and agents, natural disasters, or other foreseeable and unforeseeable events. Because technology is consistently changing, new ways to carry out cyber-attacks are always developing. Therefore, there is a chance that some risks have not been identified or prepared for, or that an attack may not be detected, which limits our ability to plan for or respond to a cyber- attack. Like other business enterprises, we and our service providers have experienced, and will continue to experience, cyber incidents consistently. In addition to deliberate cyber-attacks, unintentional cyber incidents can occur, such as the inadvertent release of confidential information by us or our service providers. To date, cyber incidents have not had a material adverse effect on our business operations or performance. We use third-party service providers who are also heavily dependent on computers and technology for their operations. Cybersecurity failures or breaches by us, our affiliates, other service providers and the issuers of securities in which a client invests, may disrupt and otherwise adversely affect their business operations. This may result in financial losses to us or our clients or cause violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, litigation costs, or additional compliance costs. In addition, substantial costs may be incurred to prevent any cyber incidents in the future. While we and many of our service providers have established business continuity plans and risk management systems intended to identify and mitigate cyber-attacks, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. We cannot control the cybersecurity plans and systems put in place by service providers and issuers in which we invest on behalf of our clients. We and our clients could be negatively impacted as a result. Data Sources: We subscribe to a variety of third-party data sources that are used to evaluate, analyze and formulate investment decisions. If a third party provides inaccurate data, client accounts may be negatively affected. While we believe the third-party data sources are reliable, there are no guarantees the data is accurate. Selection and Management Risk. Actively managed investment portfolios are subject to management risk. The securities or instruments in a Portfolio or Account may decline in value. Security selection risk may cause a Portfolio to underperform other Portfolios with similar investment objectives and investment strategies even in a rising market, negatively impacting overall Account performance. Equity Securities. Investments in equity securities generally involve a high degree of risk. Stock prices are volatile and change daily, and market movements are difficult to predict. A client could lose money due to a sudden or gradual decline in a stock’s price or due to an overall decline in the stock markets generally. Fixed Income Securities. Investments in fixed income instruments present numerous risks, including credit, interest rate, duration, reinvestment and prepayment risk, all of which affect the price (i.e., value) of the investments. 17  Alternative Investments. Many alternative investments, including private investments, use derivatives, short sales and/or leverage regularly, and the risks associated with those instruments and investment practices are much greater. Many alternative investments, such as private funds, are exempt from SEC registration, and therefore may be subject to less regulatory oversight than other investment products. Limited withdrawal rights and restrictions on transfer create lower liquidity. Fund fees and expenses may be a higher percentage of net assets than traditional investment strategies, and investors typically are subject to performance or incentive fees or allocations in addition to management fees. Alternative investments may be more sensitive to interest rates and include the possibility of more volatility than other investments. Commodities. The value of commodities investments will generally be affected by overall market movements and factors specific to a particular industry or commodity, such as weather or climate, embargoes, tariffs, health, political, international and regulatory developments. Economic and other events (whether real or perceived) can reduce the demand for commodities, which may reduce market prices and cause the value of a given Portfolio or client Account to fall. Exposure to commodities and commodities markets may subject a client’s Account to greater volatility than investments in traditional securities. Derivatives. The use of derivatives can lead to losses because of adverse movements in the price or value of the asset, index, rate or instrument (collectively, the reference instrument) underlying a derivative. ETFs. Investing in an ETF exposes a client Account to all of the risks of that ETF’s investments. As a result, the cost of investing in ETF shares may exceed the cost of investing directly in its underlying investments. ETNs. An exchange-traded note (ETN) is a debt obligation, and its payments of interest or principal are linked to the performance of a referenced investment (typically an index). ETNs are subject to the performance of their issuer and may lose all or a portion of their entire value if the issuer fails or its credit rating changes. Convertible and Other Hybrid Securities. Convertible and other hybrid securities (including preferred and convertible instruments) generally possess certain characteristics of both equity and fixed income securities. In addition to risks associated with investing in income securities, such as interest rate and credit risks, hybrid securities may be subject to issuer-specific and market risks generally applicable to equity securities. Currency. The value of foreign currencies as measured in US dollars may be unpredictably affected by changes in foreign currency rates and exchange control regulations, application of foreign tax laws (including withholding tax), governmental administration of economic or monetary policies (in the US or abroad), intervention (or the failure to intervene) by US or foreign governments or central banks, and relations between nations. Small- and Mid-Capitalization Companies. Small- and mid-capitalization companies are typically more volatile and involve greater risk than companies with a larger market capitalization. As a result, the prices of the securities may fluctuate to a greater degree than the 18  prices of the securities of other issuers. In addition, these companies are often more likely to fail than larger companies, which could result in substantial losses. Emerging Markets. Investment markets in emerging market countries are typically smaller, less liquid and more volatile than developed markets, and emerging market securities often involve greater risks than developed market securities. Real Estate. Real estate investments are subject to risks associated with owning real estate, including declines in real estate values, increases in property taxes, fluctuations in interest rates, limited availability of mortgage financing, decreases in revenues from underlying real estate assets, declines in occupancy rates, changes in government regulations affecting zoning, land use, and rents, environmental liabilities, and risks related to the management skill and creditworthiness of the issuer. Restricted Securities. Unless registered for sale to the public under applicable federal securities law, restricted securities can be sold only in private transactions to qualified investors pursuant to an exemption from registration. The sale price realized from a private transaction could be less than the investor’s purchase price for the restricted security. It may be difficult to identify a qualified investor for a restricted security held by an investor and such security could be deemed illiquid. Responsible Investing and ESG. Clients utilizing responsible investing strategies and environmental, social responsibility, and corporate governance (ESG) factors may underperform strategies which do not impose such restrictions. Concentration. A strategy that concentrates its investments in a particular sector of the market (such as the utilities or financial services sectors) or a specific geographic area (such as a country or state) may be impacted by events that adversely affect that sector or area, and the value of a Portfolio using such a strategy may fluctuate more than a less concentrated Portfolio. Hedging. Failure of the hedge instruments to track a client Account’s investments could result in the client Account having substantial residual exposure to market risk. Tax Management Strategies. The tax treatment of investments held in a client’s Account may be adversely affected by future tax legislation, Treasury Regulations and/or guidance issued by the Internal Revenue Service that could affect the character, timing, and/or amount of taxable income or gains attributable to a Portfolio. Leverage. Certain types of investment transactions may give rise to a form of leverage. A client’s Account may be required to segregate liquid assets or otherwise cover the Portfolio’s obligation created by a transaction that may give rise to leverage. Losses on leveraged transactions can substantially exceed the initial investment. Liquidity. A client’s Account is exposed to liquidity risk when trading volume, product liquidity restrictions, lack of a market maker or trading partner, large position size, market conditions, or 19  legal restrictions impair its ability to sell particular investments or to sell them at advantageous market prices. These effects may be exacerbated during times of financial or political stress. Portfolio Turnover. In general, there is no limit on how frequently trades occur in a client’s Account. A higher turnover rate of instruments in a given Portfolio, or increased trading in a Portfolio, will result in higher transaction costs and higher taxes in taxable Portfolios and may materially affect Account performance. Tracking Error. Tracking error risk refers to the risk that the performance of a client’s Account may not match or correlate to that of the index it attempts to track. Tracking error risk may cause the performance of a client’s Account to be less or more than expected. This list is meant to give examples of the types of risks that could negatively impact the value of a client’s investment and prevent him or her from reaching their investment objectives. It is by no means an exhaustive list of potential risks. Limitations of Disclosure The foregoing list of risks does not purport to be a complete enumeration or explanation of the risks involved in JHPFS’s investment strategies. As JHPFS’s investment strategies develop and change over time, clients and investors may be subject to additional and different risk factors. No assurance can be made that profits will be achieved, or that substantial losses will not be incurred. Voting Client Securities JHPFS will not vote and will not provide recommendations regarding the voting of proxies and other corporate governance actions. Clients are responsible for voting their own proxies. JHPFS does not offer monitoring and processing of class action litigation settlements regarding Program Account investments and will not otherwise advise clients on legal proceedings, including bankruptcies and class actions pertaining to investments in their Accounts. Item 7 - Client Information Provided to Portfolio Managers Prior to Account opening, clients must provide JHPFS with information about their investment time horizon, risk tolerance, age, as well as other information and any reasonable restrictions applicable to the client’s Account so that the Advisor may provide investment advisory services to the client. It is each client’s responsibility to ensure that the information provided to his or her Advisor is complete and accurate. It is also the client’s responsibility to notify his or her Advisor if any information JHPFS has about the client is inaccurate or becomes inaccurate. As described in Item 9 below under “Review of Accounts,” JHPFS will contact each client on a periodic basis to request updates on the client’s information. Item 8 - Client Contact with Portfolio Manager 20  Clients who wish to contact JHPFS can do so by calling the telephone number listed on the cover page or they may contact their Advisor directly. JHPFS does not place restrictions on client contact with their Advisor. Upon learning updated information about a client, JHPFS shall promptly forward such information to the Advisor of record. Item 9 – Additional Information Disciplinary Information There are no legal or disciplinary events reportable under this item that are material to a client’s or prospective client’s evaluation of or the integrity of JHPFS or its management persons. Other Financial Industry Activities and Affiliations JHPFS is an indirect, majority-owned subsidiary of MFC and is directly owned by Manufacturers Investment Corporation. As such, JHPFS is affiliated with several investment advisers, investment companies, broker-dealers and insurance companies. Except as noted below, JHPFS does not believe that these relationships are material to JHPFS’s advisory business. Broker-Dealers John Hancock Investment Management Distributors LLC (“JHIMD”) is the distributor of all the funds in the John Hancock Group of Funds advised by John Hancock Investment Management, LLC (“JHIM”), an affiliate of JHPFS. JHIMD is a related person of JHPFS. Manulife John Hancock Brokerage Services LLC (“MJHBS”) is a retail broker dealer and an affiliate of JHPFS. JHIMD and MJHBS are broker-dealers registered with the SEC and FINRA. Manulife Wealth Inc. (“MWI”) is registered as a mutual fund dealer and investment dealer across Canada, and as a derivatives dealer in Québec. Its principal securities regulator is the Ontario Securities Commission, except for its Québec derivatives dealer registration, which is overseen by the Autorité des marchés financiers. MWI is additionally subject to the supervision of the Canadian Investment Regulatory Organization, a national self-regulatory organization. Advisors in the Program may also separately act for Canadian residents via MWI. MWI will also provide supervisory services with respect to the Program, including but not limited to services performed by compliance and other middle and back-office personnel. MWI will receive fees from JHPFS in connection with these supervisory services. Investment Companies and Investment Advisers 21  As described above, JHIM LLC serves as investment adviser to the John Hancock Group of Funds, and John Hancock Variable Trust Advisers, LLC (“JHVTA”), an affiliated investment adviser, serves as investment adviser to JHVIT. JHIM and JHVTA are each related persons of JHPFS. JHPFS has a conflict of interest when including a John Hancock fund or ETF in a client Account because JHPFS will receive an advisory fee and its affiliate, John Hancock Investments, will receive internal management fees from the fund or ETF. Manulife Private Counsel (“MPC”), is a division of Manulife Investment Management Limited (“MIML”). MIML’s registrations include but are not limited to as a portfolio manager across Canada, as a commodity trading manager in Ontario, and as a derivatives portfolio manager in Québec. Its principal securities regulator is the Ontario Securities Commission, except for its Québec derivatives dealer registration, which is overseen by the Autorité des marchés financiers. Advisors in the Program may also separately act for Canadian residents via MPC. MPC may also provide supervisory services with respect to the Program, including but not limited to services performed by compliance and other middle and back-office personnel. MPC will receive fees from JHPFS in connection with any supervisory services. Insurance Companies MFC is the sole owner of The Manufacturers Life Insurance Company, which is indirectly the sole owner of The Manufacturers Investment Corporation and JHIM. The Manufacturers Investment Corporation directly owns JHPFS. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics JHPFS has adopted a Code of Ethics (the “Code”) which establishes standards of conduct for its “Associates” (which include any partner, officer, director or other person who provides investment advice and is subject to the supervision and control of JHPFS) and “Access Persons” (which include any Associate who, in connection with their regular duties, has access to non- public information regarding the purchase or sale of securities or the portfolio holdings of client or firm accounts). The Code is designed to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between an investment adviser, including its personnel and affiliates, and Accounts managed for its clients. The Code requires Associates to adhere to general principles of business conduct which include a duty to (i) place the interests of JHPFS’s clients first; (ii) conduct all personal securities transactions in such a manner as to avoid any actual or potential conflict of interest and any other abuse of trust or responsibility; (iii) treat as confidential any non-public or confidential information concerning the identity of security holdings and financial circumstances of JHPFS’s clients; (iv) comply with all applicable laws including applicable securities laws; and (v) 22  promptly report any violation of the Code to the code administrator or Chief Compliance Officer(“CCO”). The Code prohibits Associates from (i) employing any device, scheme or artifice to defraud a client; (ii) making any untrue statement of a material fact to a client; or (iii) taking inappropriate advantage of JHPFS’s position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect to the accounts JHPFS manages. When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, Associates owe a fiduciary duty to JHPFS’s clients. The Code is also designed to permit JHPFS to monitor various securities transactions by Access Persons in which they may have a direct or indirect beneficial ownership interest. The Code includes sections on policies in and outside the Code, reporting requirements and other disclosures inside and outside the Code, reporting violations, interpretation and enforcement, exemptions and appeals, education of employees and recordkeeping. This Code will be provided to any client or prospective client upon request by contacting JHPFS at 1-888-785-6958. JHPFS has also adopted an Amended and Restated Policy Statement and Procedures on Insider Trading in accordance with Section 204A of the Advisers Act which establishes procedures to prevent the misuse of material information by its officers, directors and employees. JHPFS and its related persons may, from time to time, come into possession of material non-public and other confidential information which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, JHPFS and its related persons may be prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should such persons come into possession of material nonpublic or other confidential information about any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Participation or Interest in Client Transactions From time to time, employees and principals of JHPFS or a related person (including a client’s Advisor) may also invest or otherwise have an interest in securities owned by or recommended to JHPFS’s clients. Similarly, some or all the financial services businesses under common control with JHPFS may invest in securities that are also owned by JHPFS’s clients. Any such persons may invest or otherwise have an interest, either directly or indirectly, in certain pooled vehicles, which, in turn, may invest in securities held in other managed accounts. As these situations involve conflicts of interest, JHPFS has implemented policies and procedures relating to personal securities 23  transactions and insider trading that are designed to identify potential conflicts of interest, to prevent or mitigate actual conflicts of interest and to resolve such conflicts appropriately if they do occur. JHPFS also mitigates these conflicts by disclosing them to clients. Review of Accounts JHPFS will no less frequently than annually ask the client to update the information the client provided to JHPFS. Based on any new information provided, JHPFS may update the client’s SIS and change the investments in their Account or Portfolio(s) within an Account. The client is responsible for promptly notifying JHPFS of any changes to their investment objectives, reasonable restrictions, or other changes to their information. The client understands that their failure to provide JHPFS with current, accurate information could adversely affect JHPFS’s ability to effectively manage the client’s Account in the Program. No less than quarterly, clients will receive generated statements from the custodian (NFS) and from our portfolio accounting system (FMAX). Statements from NFS will include current holdings, cost basis and all transactions within the reporting period. Statements from FMAX will include performance for the reporting period. Statements will be made available on at least a quarterly basis in the client portal, unless requested in writing for a hard copy delivery. Client Referrals and Other Compensation Other than the Investor Fee described above, JHPFS and its Advisors do not receive an economic benefit or other compensation for providing investment advice to clients via the Program. Financial Information JHPFS is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy petition at any time during the past ten years. JHPFS does not require prepayment of $1,200 or more in fees per client, six months or more in advance, and therefore is not required to include a balance sheet for its most recent fiscal year. 24